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.