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Environmental & Social Review Summary
This Environmental and Social Review Summary (ESRS) is prepared by IFC to disclose its findings and recommendations related to environmental and social considerations regarding potential investments. Its purpose is to enhance the transparency of IFC’s activities. For any project documentation or data included or attached herein that has been prepared by the project sponsor, authorization has been given for public release by the project sponsor. IFC considers that this ESRS is of adequate quality for release to the public, but has not necessarily independently verified all of the project information therein. It is distributed in advance of IFC Board of Directors’ consideration and may be periodically updated thereafter. Board dates are estimates only and this document should not be construed as presuming the outcome of the Board Directors’ decision.
V-BI - Waste to Energy - Renewable Energy Generation
Reg Ind, Infra & Nat Res, ASIA
B - Limited
Date ESRS disclosed
April 28, 2012
Signed: June 15, 2012
Approved: July 31, 2012
View Summary of Investment Information (SII),
E & S ProjectCategorizationand ApplicableStandards
E&S Risks /Impacts andMitigation
E & S ActionPlans
Overview of IFC's Scope of Review
The scope of review of RenewGen’s compliance with IFC’s Performance Standards included assessment of RenewGen's management capacity of its environmental, social, health and safety performance in relation to IFC Performance Standards, national (Sri Lanka) regulatory requirements and relevant Environmental Health and Safety guidelines. The review relied on documents and reports made available by RenewGen, and interviews conducted by IFC staff. Meetings and interviews with staff focused on business development, operations, human resources, environmental, social, health and safety aspects of the business. Since this is RenewGen's first venture, the need for the Company to develop relevant procedures to augment the Company’s existing management capacity to provide adequate oversight of its environmental, social, health and safety performance in conducting its business were discussed. The IFC team also had meetings with the Waste Management Authority (WMA), visited local government offices, various Municipal Solid Waste (MSW) handling and sorting facilities, and the site for the proposed MSW Waste to Energy (WTE) facility at Kaduwela, Western Province in Sri Lanka.
Discussions with government officials on the environment and social impact assessments focused on scope and processes for establishing community acceptance of WTE projects; baseline health monitoring and communication of potential risks to human health from WTE projects (in addition to compliance with regulatory standards for air quality) as part of the community consultation process was also discussed. MSW incineration and WTE has been used interchangeably in the review, but refer to the same basic process of mass burning of municipal solid waste with an added energy recovery component. Hitachi Zosen Inova (HZI), which is the technology provider for the project has provided confirmation that the proposed WTE project at Kaduwela can achieve emission performance standards established by the European Union (Directive 2000/76/EC and relevant Annexes/Amendments), applicable IFC/WB guidelines for incineration of MSW, and relevant national emission standards established by the Central Environment Authority, Sri Lanka (Nov 2011), as well as ESIA approval requirements for the operation of the project facility at Kaduwela.
The scope of this review includes IFC’s proposed equity investment (IFC Project #31944) and debt (IFC Project #32295) in RenewGen Enviro Ventures India Pvt. Ltd. and the Kaduwela project company Renewgen Environment Protection Kotte Pvt Ltd.
RenewGen Enviro Ventures India Pvt. Ltd. is a developer focused on the waste disposal market in and around South Asia. In order to facilitate the development and operation of such projects in the region, the decision has been taken to establish a holding company, as the Sponsor, in Singapore. The Sponsor would hold a portfolio of waste disposal and waste to energy projects in South Asia.
The developer has secured the first competitively awarded Waste to Energy concession in Sri Lanka from the Waste Management Authority of the Western Province in Sri Lanka (WMA). The project is a 25 year concession to build own and operate a 10MW waste to energy project in the Western Province of Sri Lanka. The project will process up to 580MT/day of municipal solid waste (MSW) and will generate up to 10MW of electricity which will be sold to the grid. The concession will be undertaken by Renewgen Environment Protection Kotte Pvt Ltd (“Renewgen Kotte” or “Company”), a company incorporated in Sri Lanka. The Ceylon Electricity Board will off-take the power generated from the plant. The project will use a highly proven (deployed in over 400 plants worldwide) grate based mass incineration technology that is suitable for unsorted MSW in conjunction with advanced emission control systems. The Company will use grate based mass incineration technology (suitable for unsorted MSW) and has tied up with Hitachi Zosen to be the technology partner. The technology is the most widely deployed and commercially proven globally (60% global market share) and Hitachi Zosen is a global leader in the WTE segment with a strong presence in both Europe and Asia having executed more than 450 WTE plants worldwide. The project consultant is Ramboll AG, a leading European engineering firm with experience in over 50 WTE plants, and will be responsible for advisory (concept to commissioning) and project management during execution. The EPC turnkey contractor is Hyquip Technologies Ltd., an Indian EPC company based in Hyderabad, India, which has extensive experience in working on power plants using biomass as feedstock.
The total project cost is estimated at US$ 29 million. IFC is considering providing a financing package of up to US$ 9 million consisting of equity (IFC Project #31944) and debt (IFC Project #32295) at both the Sponsor and Company level.
Identified Applicable Performance Standards**
PS 1 – Assessment and Management of Environmental and Social Risks and Impacts
PS 2 - Labor and working conditions
PS 3 - Resource Efficiency and Pollution Prevention
PS 4 – Community Health, Safety and Security
While all Performance Standards are applicable to this investment, IFC’s environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with the above Performance Standards:
There are no impacts of concern associated with the following Performance Standards: PS5: There is no relocation or physical/economic displacement required for the proposed Kaduwela WTE site. Land for the project is on government land which is owned by and in possession of the WMA. The land will be handed over to RenewGen through a long term lease after the receipt of the Environmental Clearance and will be demonstrated to be free of any dispute / litigation; PS6: Biodiversity Conservation and Sustainable Natural Resource Management – All aspects of concessions including those related to biodiversity and conservation are reviewed through government led impact assessments, and for the Kaduwela concession under consideration for IFC financing, no negative impacts on conservation or biodiversity within the project’s area of influence have been identified; PS7: No Indigenous People are known to have been in the area or affected by the projects; PS8: Cultural Heritage – The proposed Kaduwela WTE project is not located in an area of known historical or cultural significance.
Because the proposed investment will be used to support future, but as yet, undefined projects in addition to existing projects, the principal Performance Standards to be applied to this investment are those listed above. A condition of IFC’s investment going forward will be that the Company shall consider all relevant social and environmental risks and impacts, including the issues identified in PS1 through PS8 while assessing any new business opportunities or service models.
Environmental and Social Categorization and Rationale
This is a Category B project according to IFC’s Procedure for Environmental and Social Review of Projects because the projects currently undertaken by the Company will create a limited number of specific environmental and social impacts that can be minimized, avoided or mitigated by adhering to generally recognized performance standards, guidelines, or design criteria. Waste treatment services provided by the Company help in the management of municipal solid waste using contemporary technology that meets performance standards established by the European Union (Directive 2000/76/EC and relevant Annexes/Amendments), and applicable IFC/WB guidelines for incineration of MSW. Additionally, the Company will work with the local government on a best effort basis to help establish a relevant baseline, and develop a community heath monitoring program for long term exposure to byproducts of MSW incineration.
**Information on IFC's Policy and Performance Standards on Environmental and Social Sustainability can be found at www.ifc.org/sustainability
Main Environmental & Social Risks-Impacts of the Project and Key Mitigation Measures
Key environmental and social issues associated with the Company’s development of the proposed project at Kaduwela and other WTE projects include: environmental and social management system; quality and sustainability of water resources; emissions to the environment – air, water and subsurface; solid, and hazardous waste and materials management, including transportation; life and fire safety; community and occupational health and safety; energy use and efficiency; community engagement; cultural heritage and land acquisition. Environmental, social and health and safety issues that require ameliorative measures will be addressed by the Company as agreed in IFC’s investment documents and any associated agreements.
PS 1: Assessment and Management of Environmental and Social Risks and Impacts
RenewGen will either hire qualified professional staff or engage a third party to commence development of a corporate Environmental and Social, Management System (ESMS), which will be finalized within a timeframe agreed with IFC, to ensure that its individual projects are constructed and operated in a manner consistent with host country requirements, IFC’s Performance Standards and good international industry practice as detailed in IFC’s Environmental, Health and Safety Guidelines. Each project company implements procedures to meet national regulatory requirements and any additional requirement that they may have committed to (such as under the terms of the concession agreement, mitigation requirements identified through impact assessments, etc.).
RenewGen will appoint an appropriately qualified individual, supported by adequate financial and professional staff resources, who will have overall corporate responsibility for the development and implementation of ESMS. Further, RenewGen will, within a timeframe agreed with IFC, ensure that each of the subsidiary project companies implementing Waste to Energy (WTE) project deploys qualified and dedicated staff for safety professional, environmental and social management, and trained health and safety coordinators to manage project site construction and operations. In addition to staff deployed by each of RenewGen’s subsidiary companies, RenewGen will require each major contractor engaged on WTE projects, to deploy qualified site supervisory staff with appropriate health and safety training.
The ESMS will include policies and procedures that will require an environmental impact assessment or environmental audit consistent with IFC Performance Standards of all prospective projects, as appropriate, that results in the development of an Environmental and Social Management Plan (ESMP) setting forth: (a) measures to mitigate adverse impacts, (b) monitoring requirements for ensuring the mitigation measures are implemented effectively and in a timely manner; (c) organizational and financial resources for carrying out the measures; (d) an implementation schedule for these activities; and (e) an appropriate incentive structure (including provisions for reward and penalties) to ensure plans are implemented. If RenewGen proceeds with acquisition of existing or greenfield development of projects, this ESMP would then form the basis for the project company’s ESMS and health and safety management system. In the case of the WTE project at Kaduwela, the Company has completed an environmental impact assessment (EIA) in 2012 as part of the regulatory approval process.
For future projects, RenewGen will engage qualified consultants, in development of the ESMS to: (a) screen projects for environmental, social and health and safety risk; (b) review assessments for completeness and consistency with IFC’s Performance Standards and EHS Guidelines; (c) identify the need for supplemental studies; (d) undertake/carry out the supplemental studies, appropriate update of existing EIAs and/or undertake ESIAs in accordance with IFC Performance Standards; (e) undertake periodic audits during construction to assess status of implementation of the project specific ESMP and implementation of corrective actions identified in the previous quarterly audit; (f) undertake annual audits to assess effectiveness of the corporate ESMS and status of implementation of corrective actions identified in the previous annual ESMS audit; and (g) build the capacity within the Company for corporate-wide management of environmental, social and health and safety issues.
RenewGen’s corporate E&S staff assigned to each project Company will be responsible for ensuring that the ESMP and Corrective Action Plans are implemented by each respective project company throughout the construction and operations of the project. Under the corporate wide applicable ESMS, RenewGen will implement procedures for: (a) ensuring that contractors deployed by each project Company meet relevant provisions of RenewGen’s ESMS and ensure implementation of the ESMP as applicable to their respective activities; (b) E&S and health and safety training of employees and contract labor; (c) procedures for recording, investigation, reporting and corrective action in relation to E&S and health and safety incidents including those involving contractors’ labor; (d) periodic monitoring of E&S and health and safety performance; (e) management review of ESMS effectiveness and implementation of measures for system upgrade; and (f) annual reporting of E&S and health and safety performance to RenewGen’s Board of Directors, regulators and investors.
Site specific pollution prevention and mitigation measures associated with each project are, and will be, identified during the project environmental assessment. At the Kaduwela WTE facility, emissions to air and treated wastewater will meet regulatory standards to meet the national requirements including those for management of hazardous materials, hazardous and other waste, water and sewage; and applicable IFC WBG EHS guidelines. The Company will, as part of its ESMS, develop procedures to ensure that the environmental impacts associated with the construction and operation of its projects are managed in accordance with IFC’s Performance Standard 3 and applicable EHS Guideline provisions. RenewGen will also ensure that in accordance with the respective ESMP, each project company will implement engineering and management measures to effectively manage: general housekeeping; storage, handling and disposal of hazardous materials, hazardous waste and other solid waste at all construction sites to satisfactory standard; collection, segregation and sale of recyclable solid waste; construction spoils and debris; storage, handling and disposal of domestic/sanitary waste/garbage from labor camps and employee colony; treatment and disposal of domestic/sanitary wastewater from labor camp, construction sites and employee colonies; fugitive dust emissions and emissions from vehicles/equipment; and noise impacts. The project company will, in accordance with the ESMP, monitor ambient conditions including air quality, noise levels, and water quality of water bodies at risk of impact from project construction and operation.
RenewGen ensures that all equipment, plants and infrastructure meet good industry practices. All project structures will be designed in accordance with internationally accepted engineering standards for structural integrity. The project company will obtain independent engineer certification for all structural designs prior to commencement of construction and will implement procedures to inspect all project works against design specifications periodically. Respective project companies will, as part of the ESMS, are required to monitor and mitigate on an ongoing basis, unforeseen and other relevant community health, safety and security risks and impacts. Under the ESMS and as part of the project specific ESMP, measures to mitigate community health and safety risks during project construction and operation will be implemented including: movement of vehicles to and from construction site; operation of construction equipment; containment of dust, noise and other nuisance factors; control of public access to construction sites; appropriate material movement planning; provision of signage, traffic control, site barricading, reflectors, and other measures to mitigate the risk of accidents for general public during construction.
Each project Company will as part of the ESMP prepare and implement a labor influx management plan, including procedures to minimize the risk of incremental/accidental community exposure to disease and other potential host community impacts due to influx of labor. RenewGen will require project companies to ensure that appropriate medical facilities are available for employees and contract labor during construction and operation phases. Further, RenewGen will require project companies to ensure that all its employees and laborers undergo periodic health examinations (including for HIV/AIDS), and require contractors to implement a periodic health checkup program for contract labor as well. To ensure security of local communities faced with influx of labor, RenewGen will require the project companies to deploy unarmed security guards/staffed check posts at major civil works sites, along access roads and at labor camps throughout the project area to ensure both the security of the work sites as well as that of the surrounding communities. The Company will require each project company to maintain a community engagement plan and put in place an appropriate disaster and emergency response plan.
The Company including each project company will develop and implement procedures for ensuring that: past records of security personnel employed are screened; security personnel have clear objectives and permissible actions laid out; security personnel are trained in avoidance of human rights violations; security incidents are recorded, investigated and corrective action implemented; bona fide complaints against security personnel are investigated and appropriate disciplinary actions are implemented; and there is a grievance mechanism for aggrieved members of community or employees, in the event of a violation of the code for security personnel.
RenewGen will as part of the ESMS put in place develop formal procedures to ensure compliance of its project companies with the applicable host country requirements as well as IFC requirements for the management of land acquisition, resettlement and rehabilitation of project-affected people as defined in IFC PS 5. At Kaduwela, the WTE facility will be developed on government owned land, and no physical or economic displacement took place because of the project. For future projects, as part of the ESMS, the Company will assess applicability of IFC PS 5 on relocation and involuntary resettlement, and if applicable, implement ameliorative actions as needed. Where projects are likely to materially transform, degrade or impact lands and resources on which indigenous peoples (IP) are dependant, the Company will, as part of the ESMS, implement procedures to identify and mitigate all identified impacts on IPs. The Company will ensure that the social and environmental assessment is undertaken in accordance with the provisions of IFC’s Performance Standard 7 and mitigation plans achieve outcomes consistent with PS 7 provisions.
Biodiversity protection measures specific to each project location will be identified during the project environmental assessment and implemented by the project’s E&S and health and safety management team. In the Kaduwela WTE facility, material adverse impact on biodiversity, particularly threatened species of avifauna is not expected. The Company will require project companies to put in place procedures to : assess, avoid and where avoidance is not possible mitigate material impact, if any, on threatened species of flora and fauna;
RenewGen will require its project companies to develop and implement a chance find procedure including for finds of archaeological, paleontological, historical, cultural, artistic, and religious values, as well as unique natural environmental features that embody cultural values, such as sacred groves. Further, the project companies will be required to put in place procedures to protect and enhance sacred sites in consultation with community members and through support for local religious institutions, festivals, ceremonies and local cultural heritage consistent with IFC’s Performance Standard 8.
Kaduwela Waste to Energy Project
RenewGen was awarded a Waste to Energy (WTE) concession by the WMA of the Western Province in Sri Lanka. WMA in coordination with the local government selected the Kaduwela site for the proposed RenewGen facility, and obtained documented approval from neighboring communities for location of the facility. Consistent with the Sri Lankan laws and requirements, an ESIA was prepared for the Kaduwela project and has been publicly disclosed in January 2012. The impact assessment process included detailed assessment of potential environmental and social impacts, as well as extensive consultation on various aspects of the project – from site selection, land acquisition through conditions for project operation, monitoring and reporting. The process also included extensive consultations with the local community, NGOs and other stakeholders. Through the impact assessment process the government ensures that potential impacts of the project are identified and addressed during the project planning stage, and are used to prepare specific environmental control plans containing identified mitigation measures. The Company's obligation in the concessions is to comply with the requirements set forth in concession documents, as well as with any environmental and social requirements identified during assessment of the project. The Company’s environmental management team has overall responsibility for obtaining appropriate permits and approvals from various government agencies, and ensuring all operations are consistent with the terms of the concession agreement. The ESIA process undertaken by the Company for the Kaduwela project is consistent with IFC PS1 requirements.
During the initial phase of project development, management oversight of the project company will be provided by the Company, and subsequently the Company’s existing management system will be extended to the Project Company at Kaduwela. The Company has procedures, work instructions, and reference documents which, when combined with the findings of the project-specific assessment for the Kaduwela project, comprise a program that effectively manage the E&S risks and impacts of the proposed project. Construction activities at the site will be managed by the EPC Company (Hyquip) with oversight provided by a project management company retained by RenewGen. During the construction phase, the Company will ensure that staff and subcontractors are adequately trained, and project and site managers implement a monitoring and reporting program that periodically reports on environmental, health and safety performance of the project, and has the capacity and resources to ensure compliance with applicable regulatory requirements and consistency with requirements established by IFC Performance Standards 1 and 2.
The WTE facility at Kaduwela will receive approximately 580 tons of municipal solid waste from collection activities of local authorities and in part from the waste currently sent to the Karadiyana controlled dump owned and operated by the WMA. The WMA will ensure the quality of the waste delivered to the Kaduwela WTE facility meets acceptable specifications for energy content and composition, and does not contain any hazardous waste material. A technical review by Hitachi Zosen Inova (HZI) has also confirmed that that the incineration system is well-coordinated with the flue gas treatment systems and it can comply with relevant Sri Lankan emission standards established by the Central Environment Authority, Sri Lanka (Nov 2011), as well as ESIA approval requirements for the operation of the project facility at Kaduwela. The terms of the concession for the Kaduwela WTE facility require RenewGen to comply with local regulatory requirements which are less stringent than those specified for IFC/WB guidelines. Notwithstanding, the Company will operate the plant to achieve consistent compliance, and monitor emissions on an ongoing basis to ensure compliance with the IFC/WBG Guideline; should monitoring show significant deviation from the metrics established by the guideline, the Company will make necessary changes to remedy any non-compliance. RenewGen will install continuous inline monitoring equipment that can reliably and accurately measure relevant parameters, prior to commissioning of the facility.
Moving forward, RenewGen will implement an effective Environmental and Social Management System (per ESMS requirements described earlier in the section) to provide consistent oversight of environmental, social and health and safety for all its activities from construction management to operation of facilities, as well as screening of new opportunities in expanding its business. As the Company continues to grow rapidly, it will augment its management capacity by assigning additional staff and resources to provide oversight of its environmental and social performance. Responsibility for the management of environment, health, safety and social performance will be assigned to a senior level staff as a newly established position within the Company reporting to its CEO. The newly created position will have overall responsibility for strategies, policies, standards, compliance, and management initiatives related to environmental and social matters, and for ensuring adequate resources are made available.
PS 2: Labor and Working Conditions
RenewGen plans to employ about 50 employees at the project Company at Kaduwela. The number of sub-contracted employees can vary significantly depending on construction activities at any given time. RenewGen and its project Company is developing a Human Resources policy that complies with local and Sri Lankan regulatory requirements, and will be applied consistently to all employees, and where applicable to subcontractors. As required by law, the policy will be included in employment contracts, and addresses working conditions, terms of employment, and wages and benefits. This information will be provided in the form of an employee handbook at the time of induction. Although there is no union at RenewGen, employees have the right to freedom of association and have the opportunity to collectively represent to the management any issues or grievances that they may have. Employment relationships recognize the principals of non-discrimination and equal opportunity.
The minimum employment age at RenewGen is 18 years. RenewGen has procedures that ensure child labor or forced labor is not employed directly or by subcontractors through verification of relevant documents. Working hours on site can vary by nature of activity and phase of project, with most labor intensive phases being at the construction phase during which there are continuous operations. Construction activity will largely be subcontracted for which semi-skilled and unskilled labor will be procured locally. Wages will be paid by subcontractors to labor on a monthly basis and calculated on the basis of hours worked, inclusive of overtime. Terms of employment for sub-contractors are as per local laws and the Company relies on regulatory agencies for ensuring that sub contractors comply with applicable labor laws.
Municipal Solid Waste for the RenewGen facility at Kaduwela will be obtained from collection activities of local authorities and in part from the waste currently sent to the Karadiyana controlled dump currently owned and operated by the WMA. There is no informal scavenging at the Karadiyana facility. WMA employs about 30 people at the facility for sorting and handpicking waste at the site through a program run in collaboration with the ILO. The program provides training and employment to a number of people, and promotes safe work practices and social acceptance of sanitary workers in the country. One of the key objectives of the program is to ensure that dignity of laborers is accepted and respected by all stakeholders, key to which is that the laborers themselves have a sense of dignity and pride in the jobs they are performing. The program also helps in preparing them to further their careers, enhance their earning capacity, and improve quality of life.
The Company is in the process of developing policies and procedures that will provide programmatic oversight of occupational health and safety (OHS) issues at the Company. Occupational health and safety of employees at RenewGen will be managed by the Human Resources Department. The OHS program will include a plan for accident prevention and worker safety consistent with local regulatory requirements. All employees in the Company have to undergo a training program at induction and subsequently regarding worker health and safety relevant to their job activity. A similar program will be implemented to ensure subcontractor compliance on OHS standards. The Company will develop training programs, and implement standard operating procedures that specifically seek to mitigate OHS risks during construction and operation of MSW incineration plants.
RenewGen will retain a company with experience and international recognition in the operations and maintenance (O&M) of WTE facilities for O&M at the Kaduwela WTE facility. A key requirement for procurement by RenewGen of O&M services will be compliance with good international industry practice on OHS management for the sector. The O&M service provider will have a worker training program, monitoring and reporting of KPI on a periodic basis to the management team at RenewGen.
PS 3: Resource Efficiency and Pollution Prevention
Recovering energy from the incineration of municipal waste is being widely adopted in Sri Lanka as a technology of choice for the management of MSW. Incineration with adequate engineering/emission controls can provide an environmentally acceptable solution for significant reduction in disposal volumes, and generate energy that can potentially offset many of the small and inefficient thermal power generation schemes prevalent in Sri Lanka.
As with any other WTE plant, the principal source of emissions to the atmosphere is in the form of flue gases produced from the incinerator of MSW. Flue gases from incineration can contain a range of pollutants, which can exhibit rapid variation in composition and concentration due to the heterogeneous nature of MSW. Reduction of these pollutants is achieved through sophisticated engineering controls during the combustion process as well as through post-combustion flue gas treatment (FGT). Data made available by the Company for the proposed WTE facility in Kaduwela confirms that the equipment to be installed can achieve emission performance standards established by the European Union (Directive 2000/76/EC and relevant Annexes/Amendments), and applicable IFC/WB guidelines for incineration of MSW. Emission will be monitored in real time with a continuous emission monitoring system.
Generation of nuisance odors is a common problem in MSW transportation, handling and disposal facilities. Appropriate engineering controls such as negative pressure in MSW storage bunkers, use of chemical agents and other good management practices will be used at RenewGen facility at Kaduwela. Solid waste generated on site primarily includes bottom ash that is left from the waste incineration process which will be sold to certified third party vendors for use as additives in the road and construction industry. Another significant source of solid waste requiring disposal is flyash collected from bag filters. Flyash from the Kaduwela WTE facility will be stabilized in compliance with local regulatory requirements. RenewGen will transport the stabilized flyash to a sanitary landfill designated by the Waste Management Authority.
Process effluents include leachate from MSW silos, wash water from MSW trucks & reception hall, feeder lines, leachate from bottom ash, etc. and sanitary wastewater. Storm water will be collected by and discharged to the onsite wastewater treatment system. Wastewater will be treated on site in a secondary wastewater treatment facility, with some treated effluent being reused as process water and the remaining used for dust suppression and green zone maintenance. The wastewater treatment plant will discharge 24 cubic meters per day of treated effluent. The wastewater treatment facility will be designed to comply with local regulatory requirements and applicable IFC/WBG guidelines for the direct discharge of treated effluents to surface water.
Process water is obtained from the National Water Supply and Drainage Board (NWS&DB). Raw water is delivered to site and treated on site for process use. Water requirement is anticipated to be 350 cubic meters per day. Potable water (about 1.2 cubic meters per day) will either be supplied via government supply network or from underground well near the plant. No significant impact to the environment or availability for economic or public use is expected from this level of water use. The Company will review water usage at the facility with the objective of reducing water usage through improvements in process efficiency and recycle/reuse where feasible.
The incineration of MSW involves the generation of climate-relevant emissions. These are mainly emissions of CO2 (carbon dioxide) as well as N2O (nitrous oxide), NOx (oxides of nitrogen) NH3 (ammonia) and organic carbon, measured as total carbon. CH4 (methane) is not generated in waste incineration during normal operation. It can be assumed that under the oxidative combustion prevailing in waste incineration in MSW incinerators, methane is not present in the waste gas and consequently is not emitted. Although methane emissions may form in the waste bunker, the negative pressure in the waste bunker causes them to be transported with the bunker air to the combustion chamber as primary air, to be converted there. It only arises in particular, exceptional, cases and to a small extent (from waste remaining in the waste bunker), so that in quantitative terms CH4 is not to be regarded as climate-relevant. Based on IPCC guidance on estimation of emissions from waste incineration, it is estimated that operations at Kaduwela will result in GHG emissions in excess of 25,000 tons of CO2 equivalents. Consistent with IFC PS3 requirements on GHG emissions, the Company will monitor and quantify GHG emissions as well as those avoided, in accordance with internationally recognized methodologies. In addition, the Company will evaluate technically and financially feasible and cost-effective options to reduce or offset project-related GHG emissions during the design and operation of the project.
PS 4: Community Health, Safety and Security
Engineering controls and staff training are provided to mitigate risks and issues associated with the Company's operation of its WTE concession at Kaduwela. The use and storage of hazardous chemicals are subject to stringent safety standards as required under Sri Lanka laws. Risks to the community include those from the operation of the WTE facility as well as those from the transportation and handling of MSW and hazardous gases/chemicals. The Company is required to have emergency prevention, control and response plans which specifies responsibilities, ensures appropriate response equipment and materials are in place, and detail a set of procedures to be followed to minimize the harm of any potential accident. Moving forward, the Company will review its scope of emergency response and update procedures as needed, including drills to test the effectiveness. RenewGen will also add a community involvement component that addresses appropriate behavior and safety measures to be implemented in the event of an unplanned release beyond the plant boundaries due to either irregular plant operations or an accident at the facility, or during transportation of material destined for the facility.
Impact to community health from incineration of MSW was considered as part of the EIA review, and setbacks (buffer zone) have been proposed for the site at Kaduwela. The plant site boundary provides adequate setback between the facility and residential areas. Moving forward, the Company will work with the local government on a best effort basis to help establish a relevant baseline, and develop a community heath monitoring program for long term exposure to byproducts of MSW incineration.
Client's Stakeholder Engagement
The Company has had extensive consultations with the local community, NGOs and other stakeholders on the findings of the impact assessment, scope of the project, community concerns, project plans and schedules etc. The project site is close (about 500 meters) to an ancient Buddhist temple that is actively used by the community. There is strong stakeholder support for the project and the relationship with the surrounding community and the neighboring Buddhist temple are amicable. The Company has an active community engagement program in collaboration with the WMA which has initiated a number of schemes and programs that enhance quality of life and create employment opportunities for the surrounding communities. Dialogue and communication with affected communities including public consultation and disclosure of environmental and social impact assessment usually occurs by local government authorities through procedures established by local regulations. As part of continual improvement, RenewGen will establish methods for communicating environmental and social aspects to external interested parties and maintain procedures for receiving, documenting and responding to concerns from any external interested parties relating to the projects. Specific procedures will be developed to incorporate community engagement, including clear procedure on disclosure and consultation with potentially affected stakeholders.
For more information see the company’s website at
Mr. Senthil Kumar / Mr. Vishnu Vasanth
#44/1, 2nd Floor, VCL Building, K.H.Road Bangalore India
Phone: +918041466383/ +919845208479 / +919741957300
Local Access of Project Documentation
A local-language copy of the Environmental and Social Impact Assessment (ESIA) will be posted on the Company's web site (
) and made available at the main entrance of the Kaduwela WTE facility listed below. An announcement informing the public of availability of the ESIA and ESRS/ESAP for review and comment will also be placed in a local newspaper.
RenewGEN Environment Protection Kotte Pvt Ltd, 1438, Rajagiriya, Sri Lanka
IFC supports its clients in addressing environmental and social issues arising from their business activities by requiring them to set up and administer appropriate grievance mechanisms and/or procedures to address complaints from Affected Communities.
In addition, Affected Communities have unrestricted access to the Compliance Advisor/Ombudsman (CAO), the independent accountability mechanism for IFC. The CAO is mandated to address complaints from people affected by IFC-supported business activities in a manner that is fair, objective, and constructive, with the goal of improving environmental and social project outcomes and fostering greater public accountability of IFC.
Independent of IFC management and reporting directly to the World Bank Group President, the CAO works to resolve complaints using a flexible, problem-solving approach through its dispute resolution arm and oversees project-level audits of IFC’s environmental and social performance through its compliance arm.
Complaints may relate to any aspect of IFC-supported business activities that is within the mandate of the CAO. They can be made by any individual, group, community, entity, or other party affected or likely to be affected by the environmental or social impacts of an IFC-financed business activity. Complaints can be submitted to the CAO in writing to the address below:
International Finance Corporation
2121 Pennsylvania Avenue NW
Washington, DC 20433 USA
Tel: 1 202 458 1973
Fax: 1 202 522 7400
The CAO receives and addresses complaints in accordance with the criteria set out in its Operational Guidelines which are available at: www.cao-ombudsman.org
Broad Community Support is not applicable for this project
Environmental & Social Action Plan - Appraisal
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