IFC’s appraisal considered the environmental and social management planning process and documentation for the Project and gaps, if any, between these and IFC’s requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and (if applicable) in an agreed Environmental and Social Action Plan (ESAP). Through implementation of these measures, the Project is expected to be designed and operated in accordance with Performance Standards objectives.
PS 1: Assessment and Management of Environmental and Social Impacts
GVMC has not yet formally established an Environment and Social Policy nor an Environmental and Social Management Systems (ESMS) either at the Municipal Corporation level nor at any Project level. The general practice in projects is to contractually require EPC/O&M contractors to manage EHS & social related issues in each project and follow their own systems/plans/standard operating procedures (SOPs). However, the E&S clauses in the contract are limited. Accordingly, GVMC will, as mentioned at ESAP # 1, will include appropriate clauses of the agreed ESAP and the IFC PS in EPC and O&M contracts requiring them to comply with IFC PSs during construction and O&M stages respectively.
Continuing ESAP#1 GVMC will require its EPC and O&M Contractors to develop a project level Environment and Social Management System (ESMS) to manage EHS and social risks during construction and operations respectively that is aligned with the IFC Performance Standards and the Environmental and Social Impact Assessment (ESIA). The ESMS will be appropriate to the nature and scale of its operations and should include i) EHS and Social Policies; ii) an organizational structure for the project appropriate for ESMS implementation; iii) risk and impact assessment; iv) environmental and social management plans and procedures; v) occupational health and safety management plans; vi) labor management plan including labour accommodation guidelines; vii) emergency response; viii) monitoring, reporting and record keeping; ix) capacity building and training; x) stakeholder engagement and xi) grievance mechanisms.
Identification of Risks and Impacts: GVMC has conducted an ESIA that is compliant with the regulatory requirements and aligned to IFC Performance Standards. Further, since the STP site is located on 30 acre legacy waste site, a Phase II ESA for the STP site was undertaken by GVMC to assess the risk of potential soil and groundwater contamination. Additionally, a third-party Environmental and Social Due Diligence (ESDD) was conducted, and an environmental and social action plan was created. Some of the action plan requirements have been addressed as part of the ESIA and ESMP.
For ESAP#1 GVMC will also require implementation of the ESMP, and all management plans included in the ESIA and the action plans from the ESDD (other than those already covered by the ESIA through its PMC, EPC and O&M contractors. The PMC will prepare a detailed responsibility matrix for different implementing agencies before the start of project activities.
GVMC has agreed to put in place a project specific environmental and social team who can oversee the EPC and the O&M contractor’s E&S performance. For this project: a) GVMC will provide overall project administration including tracking progress, third party approvals and site visits for monitoring; and b) PMC will oversee E&S performance of the EPC contractor during construction and operations. As a part of the ESAP#2 GVMC will recruit an appropriately qualified E&S Officer in the Project Implementation Unit (PIU) to oversee the project implementation and provide the necessary project administration, approvals, compliance management and monitoring. Further, the EPC and O&M contractors will be contractually required to have a dedicated E&S department for the projects staffed with appropriately qualified and experienced environmental, social and Occupational Health and Safety (OHS) personnel. Also, the PMC will have an E&S Cell with at least 1 Senior EHS/OHS Officer and 1 Senior Social Officer to oversee the implementation of the ESAP, ESMS and ESMP as well as the Livelihood Restoration Plan as discussed under PS 5.
GVMC has worked on projects funded by some multilateral agencies but has limited exposure to IFC Performance Standards. Along with PMC and EPC, GVMC will need to be trained on the standards and its implementation on the project. In ESAP#3 The GVMC, with support of IFC will hire a qualified agency experienced in delivering training on IFC PS and infrastructure projects to train the GVMC E&S Officer and the PMC, EPC and O&M E &S teams (when on board) on the IFC Performance Standards, the ESMS, the ESMP and various E & S related construction and operations related procedures, including comprehensive OHS training at all levels of staff prior to commencement of and periodically during the course of construction and operations.
The EPC and O&M contractors will have most of the responsibilities of the project implementation. In ESAP#4 during construction GVMC E&S officer will undertake frequent monitoring site visits and ensure the PMC and the EPC are implementing their E & S and OHS responsibilities, including of their contractors. The PMC will be responsible for monitoring overall E&S performance of the project during construction and submit to GVMC monthly E&S reports. The EPC E&S team will implement their ESMS, the ESMP and the relevant ESAP requirements at the project level, monitor their contractors, provide status and monitoring reports to PMC as required by their contracts and the ESAP and flag high risk issues and incidents as needed. The PMC will continue to monitor the project during operations and oversee the E&S performance of the O&M contractor. Further on ESAP #4, GVMC will conduct bi-annual independent Environmental Health and Safety and Social (EHSS) audit for the project through a third party to ensure all project obligations during construction, the ESAP and ESMP are being met, and the PMC and EPC are implementing their responsibilities. During operation the third party EHSS audit will be done annually for 10 years till the project operation stabilize.
EPC and O&M contractors are required to, as part of the ESMS and as recommended by the ESIA, develop and implement project specific emergency preparedness and response plan for the project considering the findings of the quantitative risk assessment (QRA) undertaken as part of the ESIA. As a part of ESAP #1, the PMC will ensure that an Emergency Preparedness and Response Plan (EPRP), including onsite and offsite emergencies is developed specific to the project for construction (by EPC contractor) and operation (by O&M contractor) phases. The EPRP shall include training requirements associated with emergency response for various emergencies identified during the risk assessment.
PS 2: Labour and Working Conditions:
All the rules and regulations issued by the Government of Andhra Pradesh in terms of managing human resources at government departments in the state are applicable to GVMC’s employees. The applicable rules and regulations broadly cover recruitment and appointment, classification of services, rules on probation and transfers, criteria for promotion, rules around leave, salary structures, scales and allowances, grievance mechanisms, disciplinary actions, retirements benefits, rosters and reservations and record keeping.
As ESAP#5, GVMC will contractually require its EPC and O & M Contractor to have appropriate HR policies and procedures to meet regulatory requirements and those of IFC PS2. In addition to laying down the terms of employment and working conditions, the HR policies and procedures will include commitment to non-discrimination, commitments against using child and forced labour, for freedom of association and collective bargaining to its employees and contractors, employee grievance mechanism, as well as sexual harassment and GBV related policies. The HR procedures should include a demobilization plan upon completion of construction when most of the labour intensive activities will conclude.
Further, as per ESAP#5 GVMC will contractually require the EPC and O&M contractor to set-up and implement project specific internal grievance mechanism recommended by the ESIA to cover both on-roll and contractual workers of the Project. The PMC will monitor the functioning and effectiveness of this mechanism and report back to GVMC as a part of its monthly reporting process. Grievances that are not effectively addressed at EPC and PMC levels will be escalated to GVMC to resolve.
It is anticipated that the construction phase will have total workforce of upto 100 at any given point of time. Over 50% of these workers are expected to be migrant workers from other states. Labour camps, including mobile camps will need to be set up to accommodate workers throughout different phases of construction. Under ESAP#5 the EPC contractor will prepare a labour management plan including labour accommodation that will cover provisions of the law as well relevant requirements of the IFC-EBRD guidance on Worker Accommodation Processes and Standards.
Occupational Health and Safety (OHS) and Operational Safety: In ESAP#1 GVMC will contractually require the EPC contractor and O&M contractor to prepare detailed Occupational Health and Safety Plans. This will include establishment of the process of Hazard Identification and Risk Assessment (HIRA) and a Hazard and Operability (HAZOP) study, and a risk register to be updated on a regular basis as well as awareness raising, training and regular HES/OHS meetings within the contractor teams. For construction and operation stage, an incident/accident reporting and investigation procedure will be established. For operation stage, relevant SOPs should be developed and implemented. The OHS plans and their implementation will be reviewed and approved by PMC and regularly monitored as a part of the PMC monitoring plan.
A consequence analysis has been conducted for the release of toxic chlorine gas as part of the ESIA. The chlorine release analysis indicates that the impact zones are within the site, and while there are no communities residing in the impact zones, employees on premises are exposed to OHS risks. GVMC will, as mentioned at ESAP # 6, complete a quantitative risk assessment (QRA) by updating the consequence analysis under the credible worst-case scenario. The QRA should develop Location Specific Individual Risk (LSIR) contours overlaid on the plant layout; and updating the proposed mitigations and emergency measures to include measures commensurate to the risks within different zones of the LSIR contours, respectively. Further, the O&M stage ESMS and the emergency response plan will include appropriate procedures based on QRA findings (ESAP#6)
PS 3: Resource Efficiency and Pollution Prevention:
The operation stage ESMS (ESAP # 1] to be put in place by the O&M contractor will include procedures for: treated wastewater recycling and reuse where possible; monitoring energy consumption; and implementation of programs to reduce specific energy consumption. Water consumption will be on an average 10 kilolitre per day (KLD) during construction, with a peak consumption of 30 KLD and 2 KLD during operation. Water will be sourced from tankers provided by authorized vendors, primarily to meet the needs of the operational workforce. The project is expected to consume electricity from grid power resulting in 32,802.55tCO2e of indirect greenhouse gas emissions per year for 20MLD capacity plant.
During construction stage, typical impacts would include emissions to air (fugitive, from equipment and transport), noise, vibration, illumination, soil erosion, stormwater runoff, water sourcing and consumption, wastewater, sewage generation, solid waste generation, construction debris, domestic waste, hazardous waste generation and hazardous material use. The EPC contractor will be required to put in place a construction stage E&S management plan (ESMP) that meets the requirements specified in the ESIA and good international industry practice (ESAP # 1).
There are no noise sensitive receptors or residential communities near the proposed STP site. High noise generating equipment will have acoustic enclosures and appropriate PPE will be provided to workers exposed to high noise levels.
Dispersion modelling of fugitive odour impact from the project indicates levels that are within acceptable threshold at sensitive receptors.
The STP is being designed to meet national treated sewage wastewater standards and WBG EHS Guideline limits. Treated sewage will be discharged into a nearby existing open channel which carries stormwater and untreated sewage from a large catchment area. The project will result in at source diversion of some of the sewage flowing in this channel to the sewage treatment plant. Consequently, the quality of the water in the channel is expected to improve.
Sludge will be sent to an existing operational biogas plant nearby for which GVMC will have a contractual agreement with the biogas plant operator. The sludge will be digested there in the anaerobic digester for production of biogas. Other solid waste generated in the process (grit, screened waste from pumping and lifting stations) will be disposed in designated landfill.
The project will have facilities and procedures in the O&M stage ESMS for handling, storage use/disposal of hazardous materials and hazardous wastes that meet national standards and WBG EHS Guideline requirements including duty of care procedures for disposal of hazardous wastes.
Since the STP project is located on a biomined landfill site, a phase II ESA was undertaken to assess presence of historical pollution at site. The phase II ESA indicates that groundwater and soil have elevated levels of some pollutants, but the pollution is not at levels requiring remediation. Groundwater cannot be used for drinking or agriculture and must be treated prior to any other use during construction. Accordingly, as part of the construction stage ESMP and O&M stage ESMS, procedures will be put in place to prevent exposure of employees and workers to groundwater and soil during construction and operation. Further, GVMC will require the EPC contractor to undertake additional soil testing/contamination survey in the area to be developed in phase 1, to understand the potential mosaic of soil contamination and based on the findings, develop a contaminated soil management plan (ESAP#7)
PS 4: Community Health Safety and Security
In addition to constructing the STP and the sewage pumping and lifting station, the project involves laying sewer pipelines within the right of way of existing city roads and/or beneath the carriageway of roads and lanes. This may cause nuisances to communities, including traffic disruptions, noise and dust generation, lane and road closures, excavation near residential and commercial structures, drainage disruptions, community safety concerns, structural safety considerations and potential impacts on buried or overhead utilities.
The EPC contractor will implement a construction-stage ESMP with mitigation measures outlined in the ESIA, IFC PSs, and relevant WBG EHS Guidelines. To minimize disruption and congestion for roadside vendors and pedestrians as well as traffic movement, the ESIA has provided a Site Access Framework that will be implemented prior to construction activities at any location.
The access to the STP site is through an existing 12m right of way (ROW) presently unpaved two-way road. The two-way road is planned to be paved for 7m. This access road to the site is not through any community and is used for transportation of material and machinery for the biomining plant on the adjacent land. The EPC contractor, as a part of the ESMP will implement a traffic management plan to address potential disruptions caused by construction-related activities.
The EPC and O & M contractors will deploy contracted security personnel at the STP and the pumping and lifting station sites. The security personnel will not be armed. As part of the ESMS of the EPC contractor and its HR policies (ESAP#5), EPC will implement procedures, including screening the past records of employed security personnel, defining permissible and impermissible actions, and providing training on preventing violations, covering aspects such as sexual harassment, gender-based violence, and interactions with the community and employees. Bona fide complaints against security personnel will be investigated, disciplinary actions enforced when necessary, and a grievance mechanism will be in place for affected community members or employees in case of violation of the code for security personnel.
PS5: Land Acquisition and Involuntary Resettlement
The sewage treatment project requires 30 acres of government land for the STP, 0.41 acres for three pumping stations, and 0.07 acres for two lifting stations. No private land acquisition is anticipated for the project, as all identified land parcels are government owned. The proposed sewerage trunk line, covering an estimated 84.03 acres, with an approximate length of 410 kilometres will be laid in public roads and will not require any land/ROW procurement. Wherever there is available width, the sewerage network is proposed to be installed in the centre of the road. In more congested areas with narrow roads, the network will be installed on roadsides within the ROW creating temporary access disruptions and impacts on pavements and structures and localised inconveniences.
Preliminary estimates made by the ESIA suggest that the project could marginally/partially impact residential structures extension into the ROW including boundary walls and sheds in some locations; some shops where there could be partial impacts on structures as well as temporary loss of livelihoods; a few mobile vendors who may need to be shifted for construction activities for a few days and may have their daily earnings impacted; and groups of sanitary worker who operate within a 50km radius of Mathurwada and provide septic tank and pipe cleaning services. The livelihoods of these people may be impacted because of the project providing household connection for wastewater. No physical displacement is anticipated.
As a part of the ESMP, the ESIA includes a Livelihood Restoration Framework aligned with IFC PS that provides an assessment of the potential impacts, mostly temporary along the sewage network and livelihood support measures including provisions for reconstruction of damaged structures or compensation, transitional allowance for any temporary loss of income and alternate livelihoods for any permanent loss of livelihoods. As ESAP#8, GVMC will require the EPC contractor to develop site specific Livelihood Restoration Plan/s that will be based on the LRF. The EPC contractor will hire an NGO/agency to implement the LRP and their responsibilities will include a) informing the community of the construction activities; b) conducting a survey of the affected household and the structures; c) preparing an LRP to minimize livelihood and access disruption, and where not avoidable, household level livelihood support measures commensurate with the nature and duration of impacts and d) establishing a grievance mechanism to respond to community grievances. This assessment as well as provisions of mitigation measures should be in place prior to any construction activity at a location. The PMC will monitor the day-to-day activities of LRP including preparation and implementation of the LRP and provide periodic monitoring reports with updated data on impacted households and LRP implementation as well as grievance redressal. In ESAP#8 A third party LRP audit will be conducted which will independently monitor the LRP implementation on a quarterly basis till the conclusion of the construction activities and completion of all LRP related commitments.
PS 6: Biodiversity Conservation and Sustainable Management of Living Natural Resources
The Project is within the Eastern Highlands moist deciduous forests within Andra Pradesh. This ecoregion's coastal areas have been predominately cleared with remnant patches of forest interspersed with agriculture and human settlements. There are several endemic species located within this region, one of which was identified to occur within the vicinity of the Project. Russell's Legless Skink (Barkudia melanosticta) IUCN Data Deficient has potentially triggered critical habitat for the Project. Further analysis of the distribution of the species will be required and survey methods defined so that avoidance and mitigations for the species can be applied prior to and during construction. The result of this analysis is to be included in a Biodiversity Action Plan (BAP), noting that net gains are to be implemented if critical habitat is confirmed (ESAP#9).
The sewerage pipeline network is in close proximity to the eco-sensitive zone of the Kambalakonda Wildlife Sanctuary, although within modified habitats. Coastal habitats associated with the sewerage treatment plant (STP) discharge play host to priority biodiversity values, including Olive Ridley Turtle (Lepidochelys olivacea) IUCN Vulnerable. To reduce risks, the BAP will include measures to manage impacts such as managing construction impacts in sensitive locations and rehabilitating disturbed areas. As outlined in the requirements for PS3, discharges from the STP will be required to meet WB EHS Guidelines which will improve water quality in nearshore marine habitats.
