ENVIRONMENTAL IMPACT ASSESSMENT For the Installation of an Incinerator at Kulhudhuffushi, Haa Dhaalu Atoll
By Water Solutions (January 2020)
Proposed by: Ministry of Environment Prepared by: Ahmed Jameel (EIA P07/2007), Abdul Aleem (EIA P03/2019)
For Water Solutions Pvt. Ltd., Maldives
February 2020 EIA for the Installation of an Incinerator at Kulhudhuffushi, Haa Dhaalu Atoll, Maldives
1 Table of contents 1 Table of contents ...... 2 2 List of Figures and Tables ...... 6 3 Declaration of the consultants ...... 8 4 Proponents Commitment and Declaration ...... 9 5 Non-Technical Summary ...... 13 6 Introduction ...... 15 6.1 Structure of the EIA ...... 15 6.2 Aims and Objectives of the EIA ...... 15 6.3 EIA Implementation ...... 15 6.4 Rational for the formulation of alternatives ...... 15 6.5 Coordination with other stakeholders ...... 15 6.6 Terms of Reference ...... 16 7 Policy, Legal and Administrative Framework ...... 17 7.1 Environmental Protection and Preservation Act ...... 17 7.2 Protected Areas and Sensitive Areas ...... 17 7.3 Environmental Impact Assessment Regulation 2012 ...... 18 7.4 First Addendum to Environmental Impact Assessment Regulation 2012 ..... 18 7.5 Second Addendum to Environmental Impact Assessment Regulation 2012 18 7.6 Thrid Addendum to Environmental Impact Assessment Regulation 2012 ... 18 7.7 Fourth Addendum to Environmental Impact Assessment Regulation 2012 . 19 7.8 Fifth Addendum to Environmental Impact Assessment Regulation 2012 .... 19 7.9 Post EIA Monitoring, Auditing and Evaluation ...... 19 7.10 Waste management policy ...... 20 7.11 Waste Management Regulation (No. 2013/R-58) ...... 20 7.12 Environmental Damage Liabilities Regulation, 2011 ...... 21 7.13 Other Relevant Legislation ...... 21 7.14 Environmental Damage Liabilities Regulation, 2011 ...... 21 7.15 National Biodiversity Strategy and Action Plan ...... 22 7.16 National Framework for Development 2009-2013 ...... 22 7.17 Decentralization Act ...... 22 7.18 Responsible Institutions ...... 22 7.18.1 Ministry of Environment ...... 22 7.18.2 Environmental Protection Agency ...... 22 8 Project Description ...... 23 8.1 Project proponent ...... 23 8.2 Project Location and Study Area ...... 23
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8.3 Need and Justification for the project ...... 23 8.4 Scope of works ...... 24 8.5 Proposed Incinerator Location ...... 24 8.6 Proposed Incinerator...... 24 8.6.1 Process of Incineration ...... 25 8.6.2 Waste feed system ...... 26 8.6.3 Bottom ash discharger ...... 26 8.6.4 Flue Gas ...... 26 8.6.5 Flue gas cleaning and treatment ...... 27 8.6.6 Stack ...... 27 8.7 Construction works ...... 28 8.8 Project management ...... 29 8.8.1 Project duration ...... 29 8.9 Project Inputs and Outputs ...... 29 8.9.1 Project Inputs – Construction phase ...... 29 8.9.2 Project Outputs- construction phase ...... 30 8.9.3 Project Inputs – Operational Phase ...... 31 8.9.4 Project Outputs – Operational Phase ...... 31 9 Methodology ...... 32 10 Existing Environment of Maldives ...... 33 10.1 Existing general environment of Maldives...... 33 10.2 Climate Settings ...... 33 10.2.1 Wind Speed and Direction ...... 33 10.3 Existing Terrestrial Environment ...... 34 10.4 Physical Parameters (Noise) ...... 35 10.5 Ground Water Quality ...... 37 10.6 Air Quality Survey ...... 37 10.7 Existing Dump site ...... 38 10.8 Boundaries of the area affected ...... 39 10.9 Features of the waste stream ...... 40 10.9.1 Amount of waste generated...... 40 10.9.2 Waste Composition ...... 41 10.9.3 Future trends that may affect solid waste generation include: ...... 41 10.10 Existing Socio-Economic Environment ...... 41 10.10.1 Overview of Haa Dhaalu Atoll ...... 41 10.10.2 Kulhudhuffushi City ...... 42 11 Environmental Impacts ...... 43 11.1 Assessing and identification of Impact ...... 43
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11.2 Uncertainty and Limitations in Impact Prediction ...... 43 11.3 Environmental impacts during Construction Stage ...... 44 11.3.1 Removal of Incinerator at Thilafushi ...... 44 11.3.1.1 Mitigation Measures ...... 44 11.3.1.2 Cost of Mitigation ...... 44 11.3.2 Transportation of Incinerator to Kulhudhuffushi ...... 44 11.3.2.1 Mitigation Measures ...... 44 11.3.2.2 Cost of mitigation ...... 44 11.3.3 Site Preparation ...... 44 11.3.4 Mobilization, Transport and Storage of Construction Materials...... 44 11.3.5 Construction of the ...... 45 11.3.5.1 Mitigation Measures ...... 45 11.3.5.1.1 Cost of Mitigation...... 45 11.3.6 Installation of the Incinerator ...... 45 11.3.6.1.1 Mitigation Measures ...... 45 11.3.6.1.2 Cost of Mitigation...... 45 11.3.7 Impacts Due to the Location of the Project ...... 45 11.3.7.1.1 Mitigation Measures ...... 45 11.3.7.1.2 Cost of Mitigation...... 45 11.3.8 Impact on Vegetation ...... 45 11.3.9 Impacts on Avifauna ...... 45 11.3.9.1.1 Mitigation Measures ...... 46 11.3.10 Air Pollution and Noise...... 46 11.3.11 Labor and Working Conditions ...... 46 11.3.11.1 Mitigation measures ...... 46 11.3.11.2 Cost of Mitigation ...... 46 11.3.12 Economic impacts ...... 46 11.4 Environmental impacts during Operation Stage ...... 47 11.4.1 Impacts Due to the Design of Project ...... 47 11.4.1.1 Mitigation Measures ...... 47 11.4.1.2 Cost of Mitigation ...... 47 11.4.2 Waste Management ...... 47 11.4.2.1 Mitigation Measures ...... 47 11.4.2.2 Cost of Mitigation ...... 47 11.4.3 Groundwater, Soil, Seawater and Noise ...... 47 11.4.3.1 Mitigation Measures ...... 48 11.4.3.2 Cost of Mitigation ...... 48 11.4.4 Air Quality, Public Health and Nuisance to Community ...... 48
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11.4.5 Mitigation Measures ...... 48 11.4.6 Cost of Mitigation ...... 48 11.4.7 Hazardous Waste Management ...... 48 11.4.8 Socio-Economic ...... 49 11.4.9 Cumulative and Unavoidable impacts ...... 49 12 Stakeholder Consultations ...... 49 12.1 Consultation with Kulhudhuffushi City Council ...... 49 12.2 Consultation with FENAKA (Kulhudhuffushi Branch) ...... 50 12.3 Consultation with Kulhudhuffushi Regional Hospital ...... 50 12.4 Consultation with National Disaster Management Authority ...... 51 12.5 Consultation with Waste Management Corporation Limited (WAMCO) .... 51 12.6 Consultation with Ministry of Environment (Energy Department) ...... 52 12.7 Consultation with Maldives Land Survey Authority ...... 52 12.8 Consultation with Health Protection Agency ...... 52 12.9 List of personnel consulted ...... 52 13 Alternatives ...... 53 13.1 No Project Option ...... 53 13.2 Alternative analysis matrix ...... 54 13.3 Preferred Alternative ...... 57 13.3.1 Mitigation Measures for the Preferred Alternative ...... 57 14 Environmental Management and Monitoring Plan ...... 58 14.1 Introduction ...... 58 14.2 Environmental monitoring plan ...... 58 14.3 Cost of Monitoring ...... 58 14.4 Duration of Monitoring ...... 58 14.5 Methods of Monitoring ...... 58 14.6 Monitoring Responsibility ...... 58 14.7 Monitoring Report ...... 58 14.8 Environmental Monitoring plan ...... 59 15 Conclusion ...... 61 15.1 Recommendations ...... 62 16 People who have assisted in the preperation of this report ...... 63 17 Acknowledgements ...... 64 18 Reference Books and Sources ...... 65 19 Annex: Terms of reference ...... 67 20 Annex: Proposed Incinerator ...... 69 21 Annex: Proposed location of the Incinerator ...... 71 22 Annex: Proposed Incinerator Shed ...... 73
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23 Methodologies used ...... 75 24 Annex: EIA submission letter from Atoll Council ...... 77 25 Annex: Stakeholder Meeting Attendees ...... 79 26 Annex: Work Schedule ...... 81 27 Annex: MWSC letter for unavailability of water testing ...... 83 28 Comments from NDMA ...... 85 29 Letter Sent To Maldives Land Survey Authority ...... 87 30 Letter sent to Health Protection Agency ...... 89 31 Site Plan ...... 91
2 List of Figures and Tables
Figure 1: Location of HDh. Kulhudhuffushi 23 Figure 2: The proposed location of the incinerator in HDh. Kulhudhuffushi 24 Figure 3: Key parts of i8-700G. 25 Figure 4: Technical specification of the incinerator 25 Figure 5: Process of Incineration 26 Figure 6: Ash door of the incinerator 26 Figure 7: How does a Venturi Scrubber work 27 Figure 8: Incinerator shed with the stack 28 Figure 9 Aerial view of the proposed incinerator location 34 Figure 10 Existing terrestrial environment of the proposed incinerator location 35 Figure 11: Noise levels near the incinerator location on 19-01-2020 36 Figure 12: Ground water samples at Kulhudhuffushi city 37 Figure 13: Air quality location January 2020 38 Figure 14: Existing dump site for HDh. Kulhudhuffushi city 39 Figure 15: Boundaries of the affected areas. (30 meter radius and 100 meter radius from the proposed incinerator location) 40
Table 1: Matrix of major inputs during construction period ...... 29 Table 2: Matrix of major outputs of construction period ...... 30 Table 3: Matrix of major inputs during operational period ...... 31 Table 4 Matrix of major outputs during operational period ...... 31 Table 5 Maximum, continuous exposure time for a given noise level ...... 35 Table 6: Ground water quality results near the proposed incinerator and a control site...... 37 Table 7: Air quality results ...... 38 Table 8: composition of waste at Fuvhamulah ...... 41 Table 9: Population statistics for Haa Dhaalu Atoll (Census 2014) ...... 42
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Table 10: Evaluation criteria and scoring system for impact analysis ...... 43 Table 11: Advantages and disadvantages of the no project option ...... 53 Table 12: Alternative analysis matrix for the project ...... 55 Table 13: Schedule for environmental monitoring during the construction period as well as per annum during operation period...... 59
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3 Declaration of the consultants This EIA report has been prepared according to the EIA Regulations 2012, issued by the Ministry of Housing and Environment and all the amendments brought to the regulation including the amendment number 2016/R-66 gazetted 11 August 2016. The EIA was carried out by a multidisciplinary consulting team representing Water Solutions Private Ltd. In preparing this report, no data has been manipulated. All data has been collected by field visits. I as the lead consultant certify that the statements in this Environmental Impact Assessment study are true, complete and correct. Name: Ahmed Jameel (EIA P07/2007)
Signature:
Water Solutions Project Reference: WS/QUT/2019/88 Email; [email protected] Tel: +960 3341643
Report reviewed by: Abdul Aleem Reviewed date: 10 Feb 2020
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4 Proponents Commitment and Declaration
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ާސާލުޙ ާދާސ ްށަކަމުތަގިއަޑަވިދެއ ެގްޓްނަމްނަރަޔަވްނެއ ްފޮއ ީރްޓްސިނިމ ީކަޓޯޕިރ ިމ ެގުމުޓްއެހެބ ްއެރަޓޭރިނިސްނިއ ާދްނައ ިނުކ ިއަގީށުފްއުދުޅުކ .ދހ ީކަޓޯޕިރ ިމ .ެވެކެޓޯޕިރ ާވިއަފިވެރުކުރާޔްއަތ ާވިއަފިވެރުކުރާޔްއަތ ްނިއްސްނަޝުއިލޮސ ރަޓޯވ ްނުތޮގ ެގުމުލެބ ޯތެނާރުކްއެރަސައ ާހިކ ްށަޓްއެވާމިތ ްނުބަބަސ ުނޫނާޤ( ުނޫނާޤ ެގުމުރުކްތަޔާމިހ ްށޮކިރެތާކްއަރ ިށެވާމިތ ެގޭޖްއާރިހެވިދ ީނާވިއަފިވެރުކާޔްއަތ ްޓޯޕިރިމ .ެވެކެޓޯޕިރ ްށަޓްއެވާމިތ ާވިއަފިއަލާވަލުކެއ ްނުޓްނަމަރަޔަވްނެއ ްޑްނެއ ެގްނިސުއަހ ްފޮއ ީރްޓްސިނިމ ްނުށަދ )39/4 ުރަބްނަނ ިއަގީލައ ެގުކަތުލޫސުއ ާވިއަފިވެރުކްނާޔަބ ިއަގ 2102 ުދިއާވަގ ޭހެބިއާމުދެހ ްޓޯޕިރ ާރުކްނާޔަބ ުރަވްނިމ ާރޯފުރަސައ ިއާއ ްސްނެރަފިރ ްފޮއ ްސްމރާޓ ާވިއަފިވެރުކޫދ ްށަތަކްއަސަމިމ ްނީސްނެޖޭއ ްނަޝްކެޓޮރްޕ ްޓްނަމްނަރަޔަވްނެއ .ެވެށަތޮގްއެއ
ްށަރަވަލަސްއަމ ެގީނުކ ްނިއަދަފްއެއ ްސެވ ޭކެށަރްށަރ ްނެހެއ ެގޭޖްއާރ ީކަޓްއުފްއުދުޅުކ .ދހ ެމްނޮކ .ެވެއެދްނެގ ްށަޔިރުކ ްނިއަކަނެފ ްތަކްއަސަމ ެގުމުރުކްޖޭނެމ ިނުކ ޭދެފުއ ިއަގުށަރ .ެވެކެށަރ ާވިއަފެވުޑޮބ ްއަތިނުކ ާވާމަޖ ިއަގުނަތިމ .ެވެއެވެލާކުއ ްށަޑނޮކިނުކ ާވިއަފިދެހ ިއަގުތާރަފ ުނުކެދ ެގުށަރ ިނުކ ޭދެފުއ ުކަހަވުދ ްށޮކޯރ ިނުކ ްނިއާކަނެފ ިއަގުޑޮގިނުކ ިމ .ެވެންނުތާރަފ ެގާކަނެފ ީނަދްނެގ ްށަޔިރުކ ްތަކްއަސަމ ެގުމުރުކ ްޖޭނެމ ީނަވ ްނަކާދްނައ ްށޮކޯރ ިނުކ ިއަގުކަތުބާސިހިކެއ ެގުށަރ ްނުކަތްތާރަފ ަލްއިމައ ްސެވަމަނ .ެވެއަދަހަނ ާދްނައ .ެވެއަފިވެރުކަގަހާފ
ާވިއަފާޅަހަށުހ ްނަލާވަލުކެއ ިއަގީށުފްއުދުޅުކ.ދހ ްނުތާރަފ ެގްޓްނަމްނަރަޔަވްނެއ ްފޮއ ީރްޓްސިނިމ މިޕްރޮޖެކްޓްގައި ހިމެނެނީ މާލެ އަތޮޅު ތިލަފުށީގައި ބެހެއްޓިފައިހުރި 4 ޓަނުގެ ކުނިއެންދޭ އިންސިނިރޭޓަރެއް ރޫޅާ، އެ އެއިންސިނިރޭޓަރު ކުޅުދުއްފުއްޓަށް ގެންދިއުމާއި، އިންސިނޭޓަރު ބެހެއްޓުމަށް 41 ފޫޓް 41 ފޫޓްގެ އިންސިނިރޭޓަރ ބަހައްޓާނެ ހިޔާކުރެވިފައިވާ ކުޑަ ގެ ގަނޑެއް ގާއިމުކޮށް މި އިންސިނިރޭޓަރ އެތަނުގަ ބަހައްޓައިގެން ރާވާ، ަގަހާފ ްނުލިސްނުއަކ ްށަމަކިމ ީނޭޓްއެހެބ ުރަޓޭނިސްނިއިމ .ެވެމުށެފ ްނަރުކ ްނުނޭބ ިދައ ްށޮކްޓްސެޓ ުރަޓޭނިސްނިއ .ެވެއެވެރުކާފަލ ްށަމަކެނޭމިނ ިއަގޭރެތްސަވުދްސަމ 6 ްތަކްއަސަމިމ .ެވެއަގްއެމިބ ާވިއަފާވްއަރުކ
ހުށަހެޅިފައިވާ ޕްރޮޖެކްޓަށް ރިއާޔަތްކޮށް ބެލި ކަންތައްތަކުން އަދި ހެދުނު ދިރާސާތަކުން، މި މަޝްރޫއުގެ ްނުބަބަސ ެގުޢޫރްޝަމިމ .ެވެއަފިވެނަގެނެދ ްށަކަރަވ ްސެވެމްނޮކ ީނަވުރަސައ ެނާރުކ ަށަޓްއެވާމިތ ްނުބަބަސ ްއެކަތާދިއަފ ެގްއެރަވ ްސެވެމްނޮކ ްށައާރިއާދ ީހްއިސ ިއާށަޓްއެވާމިތ ިއާށަދާސިތްގިއ ެގުށަރ ިއަގްއެތޮގަލްމުޖ .ެވެއަފިވެރުކ ަގަހާފ ީނަވ ްސެވްއެކަތަލަސްއަމ ަނުގ ަނިގ ެނާންނުކިނ ްނުބަބަސ ެގީމ ްސެވަމަނ ުނުވެލެބ ްށަމަކެނޭބިލ ްސެވަމަނ .ެވެއެވެލެބުނ ްށަމަކެނޭބިލ ްނުބަބަސ ެގުއޫރްޝަމ ްއެމުލްއެގ ެގުރަވްނެފ ޭވެރުކުނަދާއިއ ްނުތޮގ ެގީށެވާމިތ ާހެއ ީކަމުރުކުލްއަހ ްއަތޫގަދނުއ ާވާމިދ ްނުބަބަސ ެގީމ ަމަނިފްސޮގްނެގްށައިރުކ ުއޫރްޝަމ ްށަތޮގަވިއަފިވޭރ ުރާހިމ ުމްނިހުމ ުނުވެރުކ ަގަހާފ ިއަގުއޫރްޝަމިމ ްނުތޮގިމ .ެވެއަފިވެރުކަގަހާފ ީނާވ ިއަގްޓރޯޕިރ ްނަކެނާވުނ ްށަކަމަކަހޭސަފ ާންނުތަޔްއަރ ްއެއްލީސްފަތ ްސެވްއެއ ްނިއ ްޓްނެމރަޔަވްނެއ ްފޮއ ީރްޓްސިނިމ ްނުތޮގޭހެބ ާއޫރްޝަމ ިމ ީކަމަކްއެއ .ެވެމުތެނ ިއަފާވްއަރުކ ާސްއިޚ ާލިސްނުއަކ ިދައ
ްއެލްއަހ ާވްނެގީށަކެއ ްށަކަތިތަދ ާވިއަފެވާމިދ ުރާހިމ ްނަރުކްޖޭނެމ ިނުކ ްށަޓްއުފްއުދުޅުކ ްނުބަބަސ ެގުޢޫރްޝަމިމ .ެވެއީނަވިއަފިވެރުކްނާޔަބ ިއަގީރިތ ްއަތުބަބަސ ްއެއަބ ްނޭރެތެގީމ .ެވެއެވެރުކުނ ްއެއަފަލ ްށަކަމަކެނާދްނެގިބިލ
ްސެވްއެއ ްށަމުލެބ ޯތާބޮކ ީކަކަތްތަވާބ ާދަދައ ެގ ީނުކ ޭދެފުއ ްނުށަރ ްނިރުކ ެގުމުޓްއެހެބ ުރަޓޭރަނިސްނިއ -0 .ްނުތެނ ިއަފިދެހ ްއެއ ްޓިޑޯއ ްޓްސޭވ ެގްއެރަވ ްނުމަކ ްއެޒިއަސ ާވްނެގީށކެއ ްށަނަތްނަތ ަދަފ ްލަޓިޕްސޮހ ިދުކ ްށޮކުމްނާއ ީކަރަޓޭރަނިސްނިއ ެގުނަޓ 4 -2 .ްނަކްނޫނ ްއެޒިއަސ ާވްނެގީށަކެއ ާހެއ ީމ ްށަމުދްނެއ ިނުކ ްނުތޮގެގުމުރުކްޖޭނެމ ިނުކ ިއަގ ީށުފްއުދުޅުކ
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ާލިސްނުއަކ ުށަރ ްއެއާރަވްޝަމ ްސެވްއެއ ްލަކިންކެޓ ިދައ ްއެތާމޫލުއަމ ްސެވްއެއ ޭހެބ ާއ ުއޫރްޝަމިމ -9 .ްނަކާވުނ ިއަފިވެރުކ ުދެމ ާއ ީރްޓްސިނިމ 4- ކައުންސިލުން ފާހަގަ ކުރައްވާގޮތުގައި މިކަމަށް ހިނގާނެ ރިކަރަންޓް ޚަރަދާ، މީހުން ތަމްރީނު ކުރުމާ، ްނެގީމ ްނުމަކްއެމަކެނޭހެޖ ްނެވެރުކ ްނެގިވޭރ ާލާރުދ ީކަކަތްއަތްނަކ ްނެހިނެހެއ ާވްނުނެބ ްށަމުގްނިހ ްނަކިމ .ްނުވުނ ުފާސ ްއެތޮގ ްތޮއ ިއަފިހެޖަމަހ ަތަވުނ ްނުތެނ ިއަފިހެޖަމަހ ްއެމަކ ްސެވްއެއ ިއަފިބިލުތާމޫލުއަމ ޭހެބ ާތޮގ ެނޭވެލާތްއަނ ިއަގްއެތޮގާވ ްނެގީށަކެއ ިޅައ ަންނުކިނ ުހަފްށަމުދްނެއ ިނުކ -5 .ްނުތެނ
ުހަފްށަމުލެބ ްށަކަތްއަތްނަކ ްނެހިނެހެއ ިދައ ާށަކަތްއަތްނަކ ާވިއަފިވެރުކ ްނާޔަބ ިއަގީތަމ ިއަގްޓރޯޕިރ ިމ ެގީމ .ެވެއަފިވެރުކަގަހާފ ީނާވ ްއަތްއަތްނަކ ާވްނުނޭބ ްށަރުތިއ ާނަތްނަތ ޭހެޖްނަރުކ ުޅަގނަރ ިއަގުއޫރްޝަމ ީނާވ ްއަތުލަދަބ ޭހެޖ ްނަންނެގ ްށަރުތިއ ާށަމުރުކ ްއަތްއަތްނަކ ަދަފ ްނުރުކ ރަޓިނޮމ ްޓްކެޖޮރްޕ ްނުރުތިއ .ެވެއަފިވެރުކ ަގަހާފ
ީއާމިތްޖިއ ިއާންނުތޮގ ެގީށެވާމިތ ްށަންނުތިޔްއަރ ެގީށުފްއުދުޅުކ ްނުބަބަސ ެގުއޫރްޝަމިމ ިއަގްއެތޮގަލްމުޖ ާދިއަފ ެމްނެއ ްއަތުއޫރްޝަމ ަދަފިމ .ެވެއެވެލެބ ުނ ްށަކަމަކެނާދްނެގިބިލ ްއެކަތާދިއަފ ުޑޮބ ްނުތޮގީދާސިތްގިއ ިދައ ބޮޑުގޮތެއްގައި ކުރިއަށް ގެންދެވޭނީ ކައުންސިލް ތަކާ، ވެމްކޯ / ފެނަކަ ގެ އިތުރުން، ރައްޔަތުންނާ އަދި އެހެނިހެން ކަމާ ބެހޭ މުއައްސަސާ ތަކާ އެއްކޮށް މަޝްވަރާކުރެވިގެން މިފަދަ މަޝްރޫއުތައް އެކުލަވާލެވިގެންނެވެ. ނަމަވެސް، ކުޅުދުއްފުށީ ރީޖަނަލް ހޮސްޕިޓަލަށް މި އިންސިނަރޭޓަރު ބެހެއްޓުމުން، ހޮސްޕިޓަލުގައި އުފެދޭ "ހެޒާޑަސް ވޭސްޓް" .ެވެއެވެލެބ ްށަމަކެނާދްނެގިބިލ ްނުރެއިރުކ ްށަލަޓިޕްސޮހ ެވަހޭސަފ ްށަމުލާތްއަނ ިއަގުތޮގ ުޅަގނަރ
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5 Non-Technical Summary This report discusses the findings of an environmental impact study undertaken by Water Solutions Pvt. Ltd in order to fulfil obligatory requirements of the National Environment Protection and Preservation Act, Law No. 4/93 for the installation of an incinerator in Kulhudhuffushi, Haa Dhaalu Atoll. This project therefore involves setting up of an incinerator in Kulhudhuffushi city. The purpose of this EIA is to identify and minimize potential adverse environmental impacts related to this project and enhance the overall quality of the project. By examining the project location, the legal framework and the existing environmental components such as marine ecology and the socio-economic aspects, this EIA provides useful information regarding the extent, nature and the magnitude of impacts that are likely to occur. The EIA will also help to identify the short and long term socio-economic benefits to the community after implementing this project. It also provides a framework for future monitoring of the environment, so that changes can be monitored and corrective measures can be undertaken. The proposed incinerator installation project, hereafter referred as “the project” aims to install 4 tons/day incinerator in Kulhudhuffushi city to help manage the solid waste generated in the city. The project constitutes the following components: Dismantling one of the incinerators installed at K. Thilafushi, Male’ Atoll. Transport the incinerator from Thilafushi to Kulhudhuffushi city. Construction of a 40 feet by 40 feet shed in the waste management centre. Installation of the incinerator in the waste management centre in Kulhudhuffushi city. Commissioning and testing of the incinerator. Once the incinerator is setup, the commissioning will be done as per standard commissioning procedures. Environmental & social impacts and the mitigation measures Several environmental and social impacts of this proposed project have been examined through a number of processes. These include consultations with the project development team, field surveys, observations and assessment, consultations with relevant stakeholders, and field experience gained from waste management projects implemented throughout the country. Potential positive and negative impacts on the environment have been considered. The assessment indicates environmental and social impacts, both during the construction and operation stage. One of the most important findings of the EIA study is that the proposed incinerator is not adequately sized to the city. Although it can handle 4 tons per day, this volume is not enough to bring any meaningful solution to the ongoing waste management issues faced in the city. Secondly, the report has identified that no waste audit was undertaken before deciding this project. Only a waste audit can determine the required capacity of the incinerator for a given city. Third, there has not been any community consultations or inputs obtained during the planning process. The city Council is not aware of the project and there are several unanswered questions that need to be answered. These issues are highly relevant as they will determine the sustainability of the project. There is also no clear plans on how the introduction of an incinerator will affect the ongoing waste management mechanism in terms of operational cost, human capital and maintenance. The council has indicated that an incinerator will add additional burden to the current capacity gaps in the city. While having these difficulties, if the incinerator cannot bring about a meaningful solution to the waste management issue, then the acceptability of the project will be difficult from the community. It is not expected that during the construction stage, significant environmental impact would be felt on the natural environment of Kulhudhuffushi. During the operational stage, there will be impacts that can potentially affect the natural environment of the city as well as on human health, if these are not properly managed. These include the management of the bottom ash, fly ash and air quality around the project site. In addition, the additional financial burden on
Prepared by Water Solutions Pvt. Ltd, February 2020 Page 13 EIA for the Installation of an Incinerator at Kulhudhuffushi, Haa Dhaalu Atoll, Maldives operation and maintenance will be an added responsibility to whoever will be managing the operation and maintenance of the incinerator. Most of these impacts are highlighted in the report and towards the end, a monitoring programme has been outlined. Parameters selected for monitoring has been done in a way to allow the most significant changes arising from the project activities to be monitored. This includes the groundwater and air quality. The overall conclusion of this study is that although incinerators can bring about significant improvements to the waste management capacity, they need to be appropriately sized to suit a given situation. Their sustainability depends on many factors such as good operation and maintenance including the provision of an annual budget for regular maintenance and repairs, training of operators and ensuring that the incinerator can handle the waste load adequately. To determine the right size, a waste audit needs to be undertaken. The proposed 4 ton per day incinerator is too small for Kulhudhuffushi city and will not bring any significant improvements to the present waste management efforts. A 4 ton per day incinerator is mostly suitable to manage small quantities of waste such as biohazardous waste from the hospital / clinics and other similar institutions. The incinerator can be utilized as a temporary solution to assist the waste management efforts but should not be used in the long term as a means to manage solid waste. The project has several unanswered questions regarding operation and maintenance, management of bottom ash, training and operational staff. The city Council is not willing to accept this project unless the general public is well informed about the project, its potential opportunities and short comings by the client.
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6 Introduction This Environmental Impact Assessment (EIA) report has been prepared to fulfil the requirements of the Environmental Protection and Preservation Act, law no. 4/93 in order to assess the impacts of the proposed installation of the incinerator at Kulhudhuffushi, Haa Dhaalu Atoll. The aim of this project is to ensure that the project is sustainably undertaken to address and manage the solid waste management issue facing the city as the critical environmental issues.
6.1 Structure of the EIA The report has been structured to meet the requirements of the EIA regulations 2012 issued by the Ministry of Housing and Environment and subsequent revisions. Hence, the report will provide an executive summary at the beginning. The report will then have a project description in detail, existing environmental conditions, justifications given by the proponent for undertaking the proposed project components and alternatives. Alternatives to proposed components or activities in terms of location, design and environmental considerations would be suggested. A mitigation plan and monitoring programme before, during and after the works will be outlined at the end. The major findings of this report are based on qualitative and quantitative assessments undertaken during site visit in January 2020 and with the use of available secondary data. The impact assessment methodology has been restricted to field data collected, consultations, experience and professional judgment. In addition, satellite and aerial photos have also been used to study the geography and environment where necessary.
6.2 Aims and Objectives of the EIA The objective of the report is to: Promote informed and environmentally sound decision making. Report the existing situation of waste management and its shortcomings in the city. To fulfill the obligations of the proponent to undertake an EIA under Clause 5 of the Environmental Protection and Preservation Act of the Maldives. Undertake the proposed project work with minimum damage to the environment. Ensure that all the environmental and social aspects of the project are addressed. Propose recommendation measures to the proponent
6.3 EIA Implementation This EIA has been prepared by a local environmental consulting firm, Water Solutions. Water Solutions have been chosen by the proponent as the environmental consultants for this project. The team members were: Ahmed Jameel, MSc – Disaster Management, B. Eng (Environmental), (EIA- P07/2007) Mohamed Umar, BSc - Environmental Management (EIA P02/2019) Yumin Naseem, BSc (Hons) - Environmental Science
6.4 Rational for the formulation of alternatives Alternatives analysis provides other ways of implementing the project or various components of the project. Hence, in formulating the alternatives, various critical components of the project were considered such a, environmental acceptability, cost and benefits to the community. These factors were used to assess the various alternatives for the project as outlined in detail in the relevant sections.
6.5 Coordination with other stakeholders The EIA can be considered as a blanket permit through which, the permit will be given to undertake the works. However, before an EIA is undertaken, various government and other
Prepared by Water Solutions Pvt. Ltd, February 2020 Page 15 EIA for the Installation of an Incinerator at Kulhudhuffushi, Haa Dhaalu Atoll, Maldives stakeholders provide their input to the formulation of the project. Following are key points in this regard. The client develops the project in consultation with the needs and requirements from the community. Independent consultants prepare feasibility studies and outlines the project The community provides assurance to the project by giving their consent for any issues. In parallel, an EIA consultant is hired and awarded the project to prepare the EIA. The EIA Consultant, during the preparation of the report revisits the project concept where by the various components are studied and alternative methods or technologies are identified. The EIA is then reviewed by independent consultants through the EIA review process before approval is granted. Once the EIA is approved, then the contractor can implement the project.
6.6 Terms of Reference This EIA is prepared according to the Terms of Reference issued by Environment Protection Agency on 23rd December 2019. Terms of Reference has been included in the Appendix of this report.
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7 Policy, Legal and Administrative Framework This section outlines the relevant environmental legislation pertaining to this project. The following table outlines a matrix of major environmental laws, guidelines, codes and standards, both local and international indicating the relevance to this project.
7.1 Environmental Protection and Preservation Act The project conforms to the requirements of the Environmental Protection and Preservation Act of the Maldives, Law no. 4/93. The EIA has been undertaken in accordance with the EIA Regulation 2012 of the Maldives by registered consultants. Furthermore, it adheres to the principles underlined in the regulations, action plans, programmes and policies of Ministry of Environment and Energy, Ministry of Housing and Infra Structure and relevant local councils. These are discussed in detail in the following sections and relevant amendments brought to the regulations from time are also considered in this chapter. The Articles of the Environmental Protection and Preservation Act (Law No. 4/93) addresses the following aspects of environmental management: Guidelines and advice on environmental protection shall be provided by the concerned government authorities. Formulating policies, rules and regulations for protection and conservation of the environment in areas that do not already have a designated government authority already carrying out such functions shall be carried out by MEEW. Identifying and registering protected areas and natural reserves and drawing up of rules and regulations for their protection and preservation. An EIA shall be submitted to MEEW before implementing any developing project that may have a potential impact on the environment. Projects that have any undesirable impact on the environment can be terminated without compensation. Disposal of waste, oil, poisonous substances and other harmful substances within the territory of the Republic of Maldives is prohibited. Waste shall be disposed only in the areas designated for the purpose by the government. Hazardous / Toxic or Nuclear Wastes shall not be disposed anywhere within the territory of the country. Permission should be obtained for any trans-boundary movement of such wastes through the territory of Maldives. The Penalty for Breaking the Law and Damaging the Environment are specified. The government of the Maldives reserves the right to claim compensation for all damages that are caused by activities that are detrimental to the environment. The proposed project will fully abide to the Environmental Preservation and Protection Act. Disposal of oil, chemicals and other hazardous materials will be strictly controlled and managed. Such materials will not be disposed in to the local or the regional environment but will be transported to designated waste disposal site (Thilafushi Island). All mitigation measures will be implemented in the interest of the environment.
7.2 Protected Areas and Sensitive Areas Under Article 4 of the Environment Protection and Preservation Act, the Ministry of Environment is vested with the responsibility of identifying and registering protected areas and natural reserves and drawing up of rules and regulations for their protection and preservation. As part of the Environmental Regulation, EPA has established list of ‘sensitive sites’ in the Maldives. Although not formalized as a regulation, the sensitive list is mentioned in the recent Regulation on Dredging and Reclamation (Regulation number 2014/R-13, see Section 5.7, page34). The sensitive sites, according to EPA are sites in the Maldives (islands, reefs, mangroves, inter-tidal areas) where developments ought to be restricted, regulated or controlled.
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7.3 Environmental Impact Assessment Regulation 2012 The Ministry of Environment has issued EIA regulation on May 2012, which guides the process of undertaking the Environmental Impact Assessment in the Maldives – This guideline also provides a comprehensive outline of the EIA process, including the roles and responsibilities of the consultants and the proponents. This regulation outlines every step of the IEE/EIA process beginning from application to undertake an EIA, details on the contents, minimum requirements for consultants undertaking the EIA, format of the EIA/IEE report and many more. The guidance provided in this Regulation was followed in the preparation of this EIA report. and the EIA has also been prepared by registered consultants
7.4 First Addendum to Environmental Impact Assessment Regulation 2012 This amendment was gazetted on 9th April 2013. As per this amendment, the responsible authority has to check the submitted EIA report for everything mentioned in the Regulation’s article (Kaafu) was in order and inform the proponent whether the EIA Report has been accepted or rejected within 2 working days. The penalty for repetitive offenses has been also amended in this amendment of the Regulation.
7.5 Second Addendum to Environmental Impact Assessment Regulation 2012 This amendment was gazetted on 30th August 2015. With this Addendum to the Environmental Impact Assessment Regulation 2012, the following important points were noted. Procedural changes have been made to the EIA process. One of the most important changes was shifting the tourism related developmental project EIA’s to the Ministry of Tourism. Slight changes to the process like finalization of the Terms of Reference during the scoping meeting and changes in the fees structure for review process has been made to three different categories.
Article 8 (a) of the amendment of the decision for screening form is as follows
o Environmental Management Plan o Initial Environmental Examination o Environmental Impact Assessment o Approval to go forward with the screened project o Approval to go forward with the project with as per the mitigation measures proposed by EPA. The amendment’s article 9(b) says the decision for IEE will be as follows
o Environmental Impact Assessment Report if the project anticipated to have major environmental impacts o Environmental Management Plan o Approval to go forward with the project if the project is not anticipated to occur major environmental impacts Article 10 of this amendment says that two (2) reviewers are required to review the environmental management plan and the selection of the reviewers are to be carried out as per the article 13(b).
7.6 Thrid Addendum to Environmental Impact Assessment Regulation 2012 Amendment 3 (issued on 11th August 2016) covers the point systems for consultants, categories of the consultants and amendment of the penalties to consultants and proponents who fail to follow the regulation. This EIA report was prepared by a Category A registered EIA consultant.
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7.7 Fourth Addendum to Environmental Impact Assessment Regulation 2012 There was a 4th amendment done on the EIA regulation 2012 and gazetted on 19th January 2017. This amendment explains about the projects that can be preceded without an Environmental Impact Assessment when the proponent requests to the Ministry of Environment and Energy in writing along with commitments or guarantee that the Proponent will carry out the mitigation measures that may impact on the Environment due to such projects. A list of such projects given in the amendment is as follows. 1. Deepening of Existing harbors and channels as same as the foot print 2. Uprooting trees that fall into the existing plots given to citizens for residential purpose 3. Uprooting trees that fall into the roads/path ways to the above plots. (Only councils or who takes such responsibilities can apply). 4. Drilling boreholes to take water. 5. Reclamation carried out as land extension means to the natural existing land. Such lands that are less than 3 years after the reclamation is completed with exception of the projects mentioned article 1 ( c ) of this amendment. 6. Reclamation carried out in a lagoon with an island shape or characteristics. Such lands that are less than 5 years after the reclamation is completed with exception of the projects mentioned article 1 ( c ) of this amendment. Environmental Impact Assessment shall be carried out and permission shall be obtained in Lands that are mentioned in 5 and 6 as above, when such lands become inhabited. Environmental Impact Assessment shall be carried out in the following projects even in the lands that are reclaimed as per the number 5 and 6 explained above. 1. Projects that involve Dangerous Chemicals 2. Projects that involve in any Oil Storage 3. Projects that involve Incinerators 4. Projects that involves release of any poisonous elements to the atmosphere 5. Projects that involve fiber glass work. The amendment also says that this amendment will come into force from the date it is gazetted.
7.8 Fifth Addendum to Environmental Impact Assessment Regulation 2012 This amendment was gazetted on 27th December 2018. With this Addendum to the Environmental Impact Assessment Regulation 2012, the following important points were noted: It states the termination of article 4(b) of the Environmental Impact Assessment Regulation.
Changes to the Article 13 (G):
o Clause (F): decision after reviewing EIA report means, environmental decision statement or requesting for additional information, Addition of the following points to Annex (d)
o Development of tourist resorts o Development of tourist hotels This regulation does not have any significance to this project.
7.9 Post EIA Monitoring, Auditing and Evaluation The environmental monitoring programme given in EIA reports is an important aspect of the EIA process. The monitoring programme outlines the objectives of the monitoring; the specific
Prepared by Water Solutions Pvt. Ltd, February 2020 Page 19 EIA for the Installation of an Incinerator at Kulhudhuffushi, Haa Dhaalu Atoll, Maldives information to be collected; the data collection program, and managing the monitoring programme. Managing the monitoring programme requires assigning institutional responsibility, reporting requirements, enforcement capability, and ensuring that adequate resources are provided in terms of funds, skilled staff, etc. The monitoring programme outlined in this report will comply with the EIA Regulations 2012 and ToR approved by the EPA for this project.
7.10 Waste management policy The National Solid Waste Management Policy was developed in 2008, by the Ministry of Environment, through consultations with the community and evaluation of existing waste management practices and scope for improved efficiency. The policy was then revised and adapted, and a new policy formulated and adopted in 2015. The policy is in line with government commitment to provide the resources required for waste management in all inhabited islands of the Maldives and is founded on the following 10 principles: (i) Each person should be responsible for waste generated at the individual level and should comply with rules and regulations established locally; (ii) All household waste should be managed in accordance with the requirements of the local council; (iii) Each inhabited island should prepare and submit an island waste management plan for the island; (iv) Waste collection should be undertaken on a fee based system for all waste producers, including households and industries; (v) Agreements with government agencies in different inhabited islands to ensure management of waste in the islands; (vi) Establishment of a waste management system in each inhabited island that is appropriate for the needs of the population and quantity and type of waste generated; (vii) Establishment of regional waste management facilities (RWMF) in each waste management zone; (viii) Establishment of arrangements to transport all residual waste to a RWMF (ix) Promote adoption of waste management practices that generate revenue and to apply revenue to waste management at the island level; and (x) Undertake waste management training and awareness campaigns at the national level Kulhudhuffushi has a designated area for waste management in the city. Incinerator will be installed at location that would be identified by the Council.
7.11 Waste Management Regulation (No. 2013/R-58) The Waste Management Regulation of the Maldives was enacted under Article 3 of the EPPA in 2013 and is implemented by the Environmental Protection Agency. The regulation focuses on the following five areas: (i) Waste management standards: Defines standards for waste collection, transfer, treatment, storage, waste site management, landfills and managing hazardous waste; (ii) Waste management Permits: Defines approval procedures for waste management sites; (iii) Waster transfer: Defines standards and permits required for waste transport on land and sea, including trans-boundary movements; (iv) Reporting: Defines reporting and monitoring requirements and procedures; and (v) Enforcement: Defines procedures to implement the regulations and penalties for non-compliance.
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7.12 Environmental Damage Liabilities Regulation, 2011 Under the Environmental Protection and Preservation Act (No. 4/93), the Ministry of Environment formulated the Environmental Damage Liabilities Regulation in February 2011, which encompasses the basis to avoid environmental deterioration, extinction of biological resources, environmental degradation and avoid wastage of natural resources. The main purpose of this regulation is to stop unlawful activities on environment and adequately implement a fining procedure for violations as well as implement a compensation mechanism on environmental damages. Its Schedules form the basis for levying fines on various environmental components and activities. Under the Article 14 of the regulation, any party, from whom the implementing agency requires information relating to an investigation or for other purposes of this regulation, should provide such information. This regulation describes the factors to consider when determining the fine to be charged on a party causing damage to the environment and formulas to measure the magnitude of the damages caused to the environment.
7.13 Other Relevant Legislation Heritage Act (Law number; 12/2019). Items of cultural heritage significance are protected under of Maldives Cultural and Historical Properties act of 2019 and its implementation is currently under the Ministry of Arts, Culture and Heritage. The new Heritage law that mandates the documentation, preservation and protection of Maldivian cultural heritage. The purpose of the law is to safeguard the perpetuation of items and sites of historical significance to future generations. The Heritage Act specifies procedures and jurisdictions and criminalises acts resulting in the loss of items or sites of historical significance. No site has yet been inscribed under the UNESCO World Heritage List Health and Safety. Legislation covering occupational health and safety is currently included in the Employment Act (2008), Chapter 8 “Work Place Safety and Employer Health”. This requires employers to implement measures for the safety and protection of employees at the work place, including safe work place, procedures, safe equipment and materials, provision of protective equipment, safety training to employees, conducting health checks where work involves chemical or biological materials that may cause a hazard, providing medical care as well as first aid for employees injured while at work. The law also sets out employee’s obligations with regard to safety at work. Land use and acquisition. The Land Act (2002) covers matters relating to land including land use, land ownership, and permissible uses of land belonging to island councils, which includes environmental protection.
7.14 Environmental Damage Liabilities Regulation, 2011 Under the Environmental Protection and Preservation Act (No. 4/93), the Ministry of Environment formulated the Environmental Damage Liabilities Regulation in February 2011, which encompasses the basis to avoid environmental deterioration, extinction of biological resources, environmental degradation and avoid wastage of natural resources. The main purpose of this regulation is to stop unlawful activities on environment and adequately implement a fining procedure for violations as well as implement a compensation mechanism on environmental damages. Its Schedules form the basis for levying fines on various environmental components and activities. Under the Article 14 of the regulation, any party, from whom the implementing agency requires information relating to an investigation or for other purposes of this regulation, should provide such information. This regulation describes the factors to consider when determining the fine to be charged on a party causing damage to the environment and formulas to measure the magnitude of the damages caused to the environment.
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7.15 National Biodiversity Strategy and Action Plan The National Biodiversity Strategy and Action Plan 2016-2025 (NBSAP 2016-2025) seeks to ensure that threats to biodiversity are addressed, biodiversity is conserved, sustainably used and benefits arising from them are shared equitably. It also encompasses ways of addressing gaps, challenges and constraints highlighted in earlier sections. It is a living document that will have the capacity to adapt to changes in national conditions, capacities and to the changes in the international arena. In implementing the proposed project activities due care would be given to ensure that the national biodiversity strategies are adhered to. The proponent has committed on conservation and protection of the environment while undertaking this proposed project.
7.16 National Framework for Development 2009-2013 This framework consists of 10 policies and it is the very important environmental policy guidance given in the Strategic Action Plan. This policy encourages strengthening EIA process and EIA monitoring including conservation and sustainability of biological diversity. Based on this plan, relevant laws, regulations and amendments to such regulations has been done to improve the processes and the relevant laws and regulation are covered under Policy, Legal and Administrative Framework of this report
7.17 Decentralization Act The Decentralization Act establishes the local councils as highest authority in the locality and who shall have executive powers to be exercised in accordance with this Act. The Act establishes Atoll Councils, Island Councils and City Councils. This project will be monitored and overlooked by the Island / City Council.
7.18 Responsible Institutions The main government institutions that have roles and responsibilities relevant to this project are summarised below.
7 . 1 8 . 1 Ministry of Environment The Ministry of Environment is mandated for the effective implementation of the Environmental Protection Act of the country and has the statutory power over issues related to the environment. It has the central control over the environment protection, management, conservation and environmental emergencies. The Ministry operates mainly at a policy level and the more regulatory and technical assessment activities are mandated to the Environmental Protection Agency (EPA). In this respect EPA has now been mandated to manage all issues relating to Environmental Impact Assessment of individual projects.
7 . 1 8 . 2 Environmental Protection Agency The Environment Protection Agency (EPA) of the Ministry of Environment has responsibility for efficient operation of the EIA process. This encompasses a number of tasks, including screening of projects and provision of general procedural advice to the project proponents throughout the EIA process. The EPA manages the review of the EIA report and is responsible for any approvals or recommendations associated with the EIA. It is also responsible for verifying that environmental protection measures are properly implemented by undertaking environmental audits in collaboration with other government as well as non‐government agencies with a role for environmental protection and preservation.
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8 Project Description
8.1 Project proponent The project is proposed by Ministry of Environment, on behalf of the Government of Maldives.
8.2 Project Location and Study Area This city is situated at the geographical coordinates 6°37'20.51"N, 73°4'10.66"E in Haa Dhaalu Atoll. It is the administrative capital of the atoll and is one of the fastest growing urban centres in the north. Kulhudhuffushi contains vital infrastructure such as the regional port and regional hospital. The city has a land area of approximately 232.9 Ha. The registered population of the city is 8224. The length of the city at its longest point is 2.61 km and width of the city at its widest point is 1.38 km. The city lies at the eastern rim of the Atoll about 3.8 km north of Kumundhoo and 2.6 km south of Nolhivaran. The following figure illustrates the location of Kulhudhuffushi.
Figure 1: Location of HDh. Kulhudhuffushi
8.3 Need and Justification for the project The Ministry of Environment (ME) is currently assisting the island communities in their efforts in establishment of solid waste management centres. In order to help these island communities to manage their waste, the Ministry is proposing to setup multiple waste management options in these islands including installation of an incinerator. At present, the existing 4 ton/day incinerators in Thilafushi island is planned to be decommissioned as a mega waste management project in Thilafushi is currently underway that includes setting up of a waste to energy facility. Due to this mega project, the existing incinerators in Thilafushi will become redundant. Hence, these small incinerators have been designated to be established in outer islands to help manage the waste in these target islands. Hence, ME has decided to remove, transfer and install one of these incinerators from Thilafushi and to be setup in Kulhudhufushi city.
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8.4 Scope of works The ME has procured and installed an incineration facility that includes 5 individual incinerators of i8-700 model with a capacity of 4 tons/day each at K. Thilafushi. Since a larger waste management facility is currently underway in Thilafushi, these smaller incinerators mentioned is expected to be redundant. Therefore, in order to utilize these resources in the best manner, they have been allocated to be setup in multiple islands throughout the Maldives.
8.5 Proposed Incinerator Location The incinerator is proposed to be located at the dumpsite situated at the southern end (6°36'47.52"N, 73° 4'18.75"E) of the city (Figure 2).
Figure 2: The proposed location of the incinerator in HDh. Kulhudhuffushi
8.6 Proposed Incinerator It has been proposed to setup a 4 ton / day incinerator, technically referred as i8-700G. The brand, Inciner8 is an incinerator at the fore-front of combustion technology and offers impressive burn rates and large batch sizes achieving some of the lowest emissions in its class. The following figures outlines the key parts of the incinerator and the technical specifications. Further details are attached as an annex.
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Figure 3: Key parts of i8-700G.
Figure 4: Technical specification of the incinerator
8 . 6 . 1 Process of Incineration Incineration is a waste treatment process that involves the combustion of organic substances contained in waste materials. Incineration and other high-temperature waste treatment systems are described as “thermal treatment”. Incineration of waste materials converts the waste into
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ash, flue gas and heat. The ash is mostly formed by the inorganic constituents of the waste and may take the form of solid lumps or powder.
Figure 5: Process of Incineration There are two (2) main by-products to incineration. The first is inert bottom ash which is mostly formed by the in-organic elements of the waste stream, and the second is flue gases. Flue gases need to be provide with appropriate gas cleaning systems in order to be safe to disperse in the atmosphere. The above figure illustrates the process of incineration.
8 . 6 . 2 Waste feed system In this model, waste will be fed to the incinerator manually.
8 . 6 . 3 Bottom ash discharger The bottom ash discharger is used for cooling and removal of solid residue that accumulates on the grate. The bottom ash from the incinerator would be removed from the incinerator manually and taken out to the area where it is stored. The following figure shows the ash door of the incinerator.
Figure 6: Ash door of the incinerator
8 . 6 . 4 F l u e G a s The flue gas emission from the incinerator is expected to have the following characterization. Parameter Limits Measured Total dust 30 mg/m3 12 mg/m3 Sulphur dioxide 200 mg/m3 2.4 mg/m3
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Nitrogen dioxide 400 mg/m3 60 mg/m3 Carbon monooxide 100 mg/m3 78.3 mg/m3 Actual emissions will depend on a number of factors including waste type, volume of waste, moisture content, fuel used and local environmental conditions. The incinerator’s chambers are lined with high grade refractory concrete rated to 1600°C. Secondary chamber technology prevents dioxins from cracking into smaller but more reactive molecules. This is known as de novo formation. This can be especially apparent in the presence of heavy metals, which can act as a catalyst. The prevention method can be explained as follows: system design forces the micro particulates to pass through a flame curtain, this burns harmful emissions, gas remnants are then retained in the secondary chamber through thermal decomposition and complex controlled air distribution to ensure a clean odourless emission.
8 . 6 . 5 Flue gas cleaning and treatment A Venturi Scrubber will do flue gas cleaning and treatment for the flue gas generated from the incineration. It uses a combination of vortex technology and high pressure water misting to remove harmful elements from the exhaust gases. The incinerator is designed to ensure Dioxins, furans and similar gaseous components are destroyed using homogeneous high temperature (> 850°C), ensuring there is an excess of oxygen (>6 %) and sufficient residence time at high temperatures to make sure all 3 conditions are met.
Figure 7: How does a Venturi Scrubber work
The gas stream is introduced into a scrubber box, it is forced to pass through a converging section, where (in accordance with Bernoulli equation) gas stream velocity is rapidly increased. The throat section between pipes is where particle and gas removal occur as the inlet gas stream mixes with the fog of tiny liquid droplets.
8 . 6 . 6 S t a c k Flue gas will be discharged into a stack. The gases will be discharged by means of induced draft fan. The stack of the incinerator will be 7m. The following diagramme outlines the schematic of the incinerator shed with the stack.
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Figure 8: Incinerator shed with the stack
8.7 Construction works The incinerator installation and operation at Kulhudhuffushi is divided into the following phases: I. Preliminary works
a. Mobilization b. Site setup at Kulhudhuffushi
II. Dismantling of the incinerator at Thilafushi
a. One incinerator from 5 of existing incinerator will be dismantled and transported and re installed at Kulhudhuffushi and re-commissioning as per the standard commissioning procedures. b. Dismantling of burners, sensors, and instruments has to be done only by a professional engineer who has experience in thermal engineering. c. The dismantling and handling will be done using a crane above 25 ton capacity . d. Handling of incinerator and chimney by using and wheel loaders and excavators are not allowed. e. Inland transportation has to be done only by trailer at Thilafushi and Kulhudhuffushi
II. Construction of the Incinerator Shed and Installation of the Incinerator
a. Construction of 40 feet by 40 feet incinerator shed - the civil works required for the incinerator building will be done as shown in the drawing. The building needs a special high span truss with steel beams and there should not be any column between the span of the building to allow for wheel loader access to inside the building (shed) for loading waste into the incinerator. The construction of the shed includes: concrete plinth works, floor concrete, steel shed with roof, side cladding for 3 sides, louvers or mechanical exhausts for ventilation, brick boundary wall, required down pipes and gutters, roofing, lights and power outlet sockets b. Installation of the incinerator
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Installation main incinerator, secondary combustion chamber, chimney and the venturi by using a crane. Installation of burners, sensors, instruments as per the electrical diagram. Laying of new cabling as per the electrical diagram. Re commissioning the machine with the PLC as per the commissioning procedures given by the supplier. Re commission the remote monitoring system and connecting to the main server of the INCINER8 and update the software. Once the PLC is programmed and update with new software, new operation password has to be made for different working levels, which should be only done by an authorized electrical engineer with a programmer. Complete new diesel and water piping circuit has to be done at the new site based on the new layout. c. Commissioning of the incinerator
III. Operation of the Incinerator
8.8 Project management The engineer who is handling the installation of the incinerator work has to be qualified in the field of thermal engineering with the knowledge of incinerators, electronics, automation and PLC programming, The engineer should be sound with the knowledge of diesel burner tuning and programming for better emission standards.
8 . 8 . 1 Project duration The project construction stage is expected to be completed within 3 to 6 months. The actual details may be dependent on the final contractor.
8.9 Project Inputs and Outputs The project has inputs in terms of human resources, and natural resources and machinery.
8 . 9 . 1 Project Inputs – Construction phase Table 1: Matrix of major inputs during construction period Input resource(s) Source/ Type How to obtain resources 10 to 15 Construction workers Maldivians +foreign labours Contractor’s responsibility Management and maintenance Locals Proponent and Operator’s staff responsibility Construction materials Reinforcement steel bars, Import and purchase where locally sand, cement, aggregates, available at competitive prices – etc. Contractor’s responsibility. Telecommunication Dhiraagu/Ooredoo Maldives Fuel Available from city Heavy machinery Contractor’s responsibility Electricity/Energy Electricity for operation FENAKA
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8 . 9 . 2 Project Outputs - construction phase The type of outputs (products and waste streams) and what is expected to happen to them are given in the following table. Table 2: Matrix of major outputs of construction period
Products and Anticipated quantities Method of disposal / management waste materials
Constructional 4 to 5 cbm Construction waste will be managed at project waste site
Incinerator Shed 1,600 ft2 -
Noise Localized to the project site Unavoidable during the construction stage but including the surrounding areas. need to be minimized. Loud noise equipment This is unavoidable. not be used at night time.
Air pollution Limited quantities of dust, oxides Mainly arising as a result of emission from the of nitrogen and sulphur from use construction work such as from machinery. of machinery in the construction Only localized but unavoidable. zone.
Waste Oil 15 L per day Stored in a drum and incinerated when incinerator becomes operational.
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8 . 9 . 3 Project Inputs – O p e r ational Phase Table 3: Matrix of major inputs during operational period Input resource (s) Source/ Type How to obtain resources 3 operational staff. city Council Maldivians (city Council Chosen by city Council based on the staff) applicant’s experience and skills Maintenance materials for 5-year Replacement pipes, Import and local purchase. spares made available cleaning gear etc.
Fuel for the incinerator 50 L of diesel Procured locally
Electricity/Energy (during Electricity from the city’s city’s main power grid construction) main power grid.
8 . 9 . 4 Project Outputs – Operational Phase Table 4 Matrix of major outputs during operational period Products and waste Anticipated quantities Method of disposal / management materials Municipal Solid Waste Small quantity Treated at the waste management centre
Noise Not significant -
Air emission Not significant Cleaned through the flue gas cooling and cleaning system Bottom ash 3% of the incoming waste Stored at the site for the time being.
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9 Methodology This section outlines the methodologies used in this environmental assessment. The following table outlines a matrix of methodologies used in this project. Details of these methodologies and their descriptions are attached as an annex. Methodology type Area / environmental aspect Used in this project (yes/no)
General methodologies of data Generally covering the broader Yes collection Environment
Mapping and location identification Coastal, terrestrial and marine Yes environment. Marine Environmental survey Marine environment No
20 m Line Intercept transect (LIT), Reef Marine environment No Check 20 m photo quadrate analysis Marine environment No
Qualitative assessment of the reef Marine environment No Permanent photo quadrate Marine environment No Reef fish visual census Marine environment No
Marine Water Quality Marine environment No Coastal Environment Coastal Environment No Shoreline and vegetation line mapping Coastal Environment No
Coastal structures mapping Coastal Environment No
Erosion and accretion areas mapping Coastal Environment No
Beach profiles Coastal Environment No
Drogues and current Coastal Environment No
Terrestrial Environment Terrestrial environment Yes Terrestrial floral survey Terrestrial environment Yes Terrestrial faunal survey Terrestrial environment No Groundwater assessment Terrestrial environment Yes Bathymetry Marine / Coastal Environment No Aerial Photos Generally covering the broader Yes Environment Air quality Monitoring Project location Yes Long term weather data Generally covering the broader Yes Environment
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10 Existing Environment of Maldives
10.1 Existing general environment of Maldives The general environmental conditions of Maldives is well documented in many EIA reports and reference is made on the following EIA reports. EIA Proposed Land Reclamation and shore Protection project at Maafushi (CDE, 2019) EIA Harbour Development at Maafushi (La Mer, 2008)
10.2 Climate Settings
1 0 . 2 . 1 W i n d S peed and Direction The average monthly wind speed in 2018 has been presented in the figure below. The maximum average wind speed has been observed in the month of May in Male’.
Figure 21: Yearly wind direction and speed by month, 2018 (source: Statistical Yearbook of Maldives 2019) The table below presents the seasonal distribution of wind statistics, sourced from Globocean database. The following periods have been defined in the database: December to March: NE Monsoon April: Transitional season – 1 May to October: SW monsoon November: Transitional season – 2
Table 4: Wind Occurrence Frequency per Directional Sectors
NE Transitional SW Transitional Season > Monsoon Season 1 Monsoon Season 2
Wind Directional Sectors Dec. to March April May to Oct. November
S1 N15°-N105° 71.35 15.28 1.43 23.96 S2 N105°-N225° 6.13 16.55 17.65 17.62
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S3 N225°-N315° 8.42 56.74 77.61 41.11 S4 N315°-N15° 14.10 11.44 3.32 17.31 Source: Globocean database from 1993 to 2004
These results clearly indicate the prevailing directional sectors during the monsoon seasons: N15° to N105° during the NE monsoon, with about 71% of the observations, N225° to N315° during the SW monsoon, with about 78% of the observations.
10.3 Existing Terrestrial Environment Terrestrial vegetation of Kulhudhuffushi was studied by ground truthing of the proposed incinerator area and the surroundings by undertaking a visual inspection and aerial photography. The objective of the terrestrial assessment was to identify whether any vegetation clearance would be required to install incinerator. The area was sparsely vegetated with shrubs and no mature trees (Figure 15 and Figure 16). As there are no mature trees in the surrounding area, no removal of trees will be undertaken in this project.
Figure 9 Aerial view of the proposed incinerator location
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Figure 10 Existing terrestrial environment of the proposed incinerator location
10.4 Physical Parameters (Noise) Noise levels are recorded in different locations with a portable noise meter. The noise meter is turned on for approximately 10 seconds and the maximum reading during the time frame was recorded. The method enables the comparison of noise levels throughout the city. Table below outlines maximum continuous exposure time for given noise levels to prevent hearing impairment. Table 5 Maximum, continuous exposure time for a given noise level Duration, T Duration Exposure Exposure level, L level, L (dBA) Hours Minutes Seconds (dBA) Hours Minutes Seconds 80 25 24 – 106 – 3 45 81 20 10 – 107 – 2 59 82 16 – – 108 – 2 22 83 12 42 – 109 – 1 53 84 10 5 – 110 – 1 29 85 8 – – 111 – 1 11 86 6 21 – 112 – – 56 87 5 2 – 113 – – 45 88 4 – – 114 – – 35 89 3 10 – 115 – – 28 90 2 31 – 116 – – 22 91 2 – – 117 – – 18
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Duration, T Duration Exposure Exposure level, L level, L (dBA) Hours Minutes Seconds (dBA) Hours Minutes Seconds 92 1 35 – 118 – – 14 93 1 16 – 119 – – 11 94 1 – – 120 – – 9 95 – 47 37 121 – – 7 96 – 37 48 122 – – 6 97 – 30 – 123 – – 4 98 – 23 49 124 – – 3 99 – 18 59 125 – – 3 100 – 15 – 126 – – 2 101 – 11 54 127 – – 1 102 – 9 27 128 – – 1 103 – 7 30 129 – – 1 104 – 5 57 130–140 – – < l 105 – 4 43 – – – – Source: U.S Department of Health and National Services, Occupational Noise Exposure Revised Criteria, 1998 The following figure outlines the noise levels near the incinerator.
Figure 11: Noise levels near the incinerator location on 19-01-2020
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10.5 Ground Water Quality The primary objective of the Ground water quality sampling was to determine the baseline conditions in the project site. Qualitative and quantitative assessments were made of ground water from two locations as in Error! Reference source not found. shows the ground water sample locations near the proposed incinerator location (GW1: 6°36'47.79"N 73° 4'16.48"E) and a control site (GW2: 6°37'18.49"N 73° 4'15.22"E). The result of the Ground water quality tests is provided in Table 6.
Figure 12: Ground water samples at Kulhudhuffushi city
Table 6: Ground water quality results near the proposed incinerator and a control site. Parameters GW1 (Near proposed GW2 (Control site) incinerator) Physical appearance Clear Clear pH 7.47 7.59 Conductivity (μS/cm) 1360 595 Salinity (‰) 0.68 0.29 Nitrate (mg/L) 0.6 7.1 Nitrite (mg/L) 0.006 0.261 Nitrogen Ammonia (mg/L) 0.02 0.04 Phosphate 0.18 0.95 Total Petroleum Hydrocarbon Unavailable Unavailable (TPH) Total Coliforms (MPN/100ml) 108 >2420 Faecal Coliforms (MPN/100ml) 11 >2420
10.6 Air Quality Survey Air quality monitoring of the proposed incinerator location (6°36'47.52"N 73° 4'18.75"E) was taken for 24 hours (Figure 14). The parameters that were monitored were carbon dioxide,
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Figure 13: Air quality location January 2020
Table 7: Air quality results Location 68 Parameters Minimum Maximum Average
Carbon dioxide (CO2)/ppm 344 406 374.49 Particulate matter (PM2.5)/ppm 0.001 0.061 0.027 Particulate matter (PM10)/ppm 0.001 0.515 0.046 Nitrogen dioxide (NO2)/ppm 0.029 0.065 0.052 Sulphur dioxide (SO2)/ppm 0.000 0.000 0.000
10.7 Existing Dump site Currently, there is no open burning or burrowing of the waste in the site by the Council or FENAKA. However, open burning is done by some of the locals in this area. The height of the existing pile is approximately 10-15 feet high. The following pictures illustrates the condition of the existing dumpsite.
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Figure 14: Existing dump site for HDh. Kulhudhuffushi city
10.8 Boundaries of the area affected According to Environmental Protection Agency’s guideline for site selection of Waste Management Centers any surface bodies, establishments, or Protected Areas should not be within 30 meter radius from the proposed waste management center. As shown in Figure 18, there are no establishments, surface bodies or protected areas within 30 meters of the proposed location.
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Figure 15: Boundaries of the affected areas. (30 meter radius and 100 meter radius from the proposed incinerator location)
10.9 Features of the waste stream The features of the solid waste stream in Kulhudhuffushi include: A very high proportion of kitchen and green waste; A very high proportion of plastic waste Small proportion of paper and glass is disposed by households; Household gardening waste; Waste oils and batteries from motorized vehicles in the city Apart from the normal household hazardous wastes (such as dry cell batteries), Kulhudhuffushi has few special wastes requiring disposal.
1 0 . 9 . 1 Amount of waste generated The major waste streams contributing to the waste generation in Kulhudhuffushi are household waste, with small amounts of hotel waste, construction and demolition waste, and medical waste. According to FENAKA (Kulhudhuffushi Branch) and Kulhudhuffushi City Council, it is estimated that approximately 45-75 tonnes of waste is generated at Kulhudhuffushi on a daily basis. However, WAMCO (Male’ Branch) estimated that approximately 6 tonnes of waste will be generated on a daily basis in Kulhudhuffushi City. These estimates cannot be verified as there is no official waste audit of Kulhuhuffushi City done.
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1 0 . 9 . 2 Waste Composition Since there are no waste audits of Kulhudhuffushi to refer to, a waste audit of Fuvahmulah (Zone VIII) was reffered to. This audit was done in 2016 as part of the Establishing a Regional Waste Management System in the South Region undertaken by Ministry of Environment and Energy under the Climate Change Adaptation Program CCAP. The following waste composition of Fuvahmulah is based on the Feasibility Study for Establishing a Regional Waste Management System in the South Region (MEE, 2016). Table 8: composition of waste at Fuvhamulah Waste composition % Trend Garden waste 50% Decrease Kitchen waste 15% Increase Other organics 5% constant Paper & Cardboard 7% constant Glass 3% Decrease Plastics 5% Decrease Metals 4% Constant Hazardous waste 2% Constant Other 9% Decrease Total 100%
1 0 . 9 . 3 Future trends that may affect solid waste generation include: Continued population growth on the city leading to even smaller plots, and multiple story buildings. This will result in higher population densities; Increasing building and renovation on the city, producing increased specials wastes (i.e. paints, solvents etc.), continued shift from a typical island to an urban center; Frequent and occasional disposal of large outdated or broken consumer items (i.e. refrigerators, televisions) Increase in motorized vehicles in the city, generating increased special wastes Local tourism will likely to increase in the city
10.10 Existing Socio-Economic Environment
1 0 . 1 0 . 1 Overview of H a a D h a a l u A t o l l Thiladhunmathee Dhekunuburi, also known as Haa Dhaalu Atoll (HDh) is an administrative division of Maldives and stretches approximately 32 km (20 miles) from north to south, and 36 km (22.4 miles) east to west. Some of the facts about the Atoll includes the following: The atoll has an international airport based on the island of Hanimaadhoo Innafinolhu, located in Haa Dhaalu Atoll is the westernmost island in the Maldives Nolhivaranfaru Island was the atoll capital until 1992 The following table shows the population of the inhabited islands in Haa Dhaalu atoll according to the 2014 census.
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Table 9: Population statistics for Haa Dhaalu Atoll (Census 2014) Locality Population 2014 (Including resident foreigners) Total Male Female Finey 409 188 221 Hanimaadhoo 1,951 1,110 841 Hirimandhoo 335 165 170 Kulhudhuffushi 8,440 3,965 4,475 Kumundhoo 886 395 491 Kurin’bee 463 225 238 Makunudhoo 1,282 621 661 Naivaadhoo 417 189 228 Nellaidhoo 859 382 477 Neykurendhoo 743 328 415 Nolhivaramu 1,892 856 1,036 Nolhivaranfaru 1,081 504 577 Vaikaradhoo 783 382 401
1 0 . 1 0 . 2 Kulhudhuffushi C i t y This city is situated at the geographical coordinates 6°37'20.51"N, 73°4'10.66"E in Haa Dhaalu Atoll. It is the administrative capital of the atoll and is one of the fastest growing urban centres in the north. Kulhudhuffushi contains vital infrastructure such as the regional port and regional hospital. The city has a land area of approximately 232.9 Ha. The registered population of the city is 8224. The length of the city at its longest point is 2.61 km and width of the city at its widest point is 1.38 km. The city lies at the eastern rim of the Atoll about 3.8 km north of Kumundhoo and 2.6 km south of Nolhivaran. The following figure illustrates the location of Kulhudhuffushi.
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11 Environmental Impacts Environmental Impact identification was undertaken for the proposed activities necessary for the construction phase and the activities that will continue during the operational phase. The impact analyses for construction phase and operational phase were made separately to better understand the impacts as the duration, magnitude and probability of impacts greatly differ.
11.1 Assessing and identification of Impact Environmental Impact identification was made by a combination of matrices along with expert opinions and experiences from similar projects in the past. The environmental impacts were examined using an adaptation of the Leopold matrix method. The Leopold matrix (Leopold et al, 1971) implements a two-dimensional checklist, where the columns of the matrix contains the project’s activities while the rows list the environmental receptors under the three main categories – Physical components, Biological components, and Socio-economic and Cultural components. This interaction matrix helps to identify impacts on individual factors of the three main categories of the impact. Furthermore, the sum of the magnitude from each impact activity and/or a certain environmental factor could be identified. This method analyses three aspects of each action which may have an impact on the environment – Magnitude, Duration, and Probability. Probability – Likelihood of an impact to be produced from a said activity. Duration – Defines the duration of which the environmental impacts would persist. Magnitude – Defines the severity of the impact, for both positive and negative. A score is given from a scale of +10 to -10. +10 being major positive and -10 being major negative. Table 10: Evaluation criteria and scoring system for impact analysis Magnitude Category Evaluation criteria Score Probability (I) O Impact is possible (Probability < 50%) M Impact is likely (Probability >50%) X Impact is certain (Probability = 100%) Duration (II) T The effects of the activity would not be identifiable within a few months of its completion. S The effects of the activity would not be identifiable within months to a year of its completion. L The effects of the activity would not be identifiable within multiple of its completion. P The effects of the activity will persists endlessly causing irreversible impacts. Magnitude (III) 9 & 10 Major Positive 7 & 8 Moderate Positive 5 & 6 Minor Positive -4 to 4 Negligible -5 & -6 Minor Negative -7 & -8 Moderate Negative -9 & -10 Major negative
11.2 Uncertainty and Limitations in Impact Prediction Environmental impact prediction involves a certain degree of uncertainty as the natural and anthropogenic impacts can vary from place to place due to even slight differences in ecological, geomorphological or social conditions in a particular place. There is also a lack of long term data, for instance, shoreline, local currents, economic actives and such, which are crucial to analyse impact predictions.
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There is also uncertainty with the continuation of this project. Minor or even major changes to the project’s concept plan could alter the series of impacts. Major changes would require an EIA addendum to be prepared.
11.3 Environmental impacts during Construction Stage The impacts expected to occur during construction phase are loss of vegetation and loss of habitat during site clearance, production of construction waste, noise and risks associated with labour and working conditions.
1 1 . 3 . 1 Removal of Incinerator at Thilafushi The incinerator installed at Thilafushi would be dismantled. It will be transported to a landing craft and then to Kulhudhuffushi. The shed where the incinerator is placed will also be dismantled and then transported to a landing craft. This process is not expected to create any significant impact on the environment of Thilafushi. 11.3.1.1 Mitigation Measures The workers who work to dismantle the incinerator and the shed would be given appropriate safety gears including safety shoes, helmets and ear muffles. 11.3.1.2 Cost of Mitigation Cost is included in the transportation component of the project and will be borne by the contractor.
1 1 . 3 . 2 Transportation of Incinerator to Kulhudhuffushi The incinerator and the incinerator shed would be transported from Thilafushi to Kulhudhuffushi on a landing craft. This process is not expected to create any significant impact on the environment of Kulhudhuffushi. 11.3.2.1 Mitigation Measures A large landing craft with the capacity to handle the dismantled incinerator and shed will be hired to transport. The materials, while during transportation will need be properly packed to ensure that all parts reach the destination. 11.3.2.2 Cost of mitigation Mitigation measure is to transport the materials on a landing craft and hence, is included.
1 1 . 3 . 3 Site Preparation The site proposed for the upgrading of the waste management center does not contain any vegetation. Therefore, no direct negative impacts to the biodiversity is perceived to occur as a result of the project since uprooting or cutting down of palms and trees or clearance of shrubs are not required at any scale.
1 1 . 3 . 4 Mobilization, Transport and Storage of Construction Materials No direct negative impacts are envisaged to occur to the flora and fauna from the construction phase, the transport and supply of construction materials and machineries to the site may impose indirect negative impacts to the terrestrial and aquatic biodiversity and slight negative impacts to the soil and groundwater. The impacts may arise from accidental spillage of construction materials (cement bags, timber, iron bars etc.), accidental oil spills (used oil) and damage to vegetation as a result of improper handling and careless driving during transportation of materials. Spillage of oil to the ground has a high potency to contaminate soil and groundwater. Likewise, an oil spill to marine waters may lead to death of marine organism, as it would significantly diminish the dissolved oxygen content of seawater supplemented by an increase in carbon
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1 1 . 3 . 5 Construction of the The shed for the incinerator will be constructed using steel. The steel structure will be supported on concrete foundations. 11.3.5.1 Mitigation Measures The following mitigation measures are proposed. The floor of the shed would be raised as such the area will not be flooded during rainfall. The water from the gutters of the shed would be directed to an infiltration well to avoid flooding the area. 11.3.5.1.1 Cost of Mitigation The cost of constructing a simple infiltration well is MVR 18000.
1 1 . 3 . 6 Installation of the Incinerator The incinerator will be installed on concrete pads inside the incinerator shed. 11.3.6.1.1 Mitigation Measures The following mitigation measures are proposed. The incinerator will be installed on raised concrete pads as to prevent flood water damage during a rainfall event. Machineries to be used to lift heavy parts in order to avoid them being damaged. 11.3.6.1.2 Cost of Mitigation Included in the project.
1 1 . 3 . 7 Impacts Due to the Location of the Project The location of the project at Kulhudhuffushi is in within the dumpsite area. Kulhudhuffushi dumpsite is located on eastern side of the proposed location of the incinerator. 11.3.7.1.1 Mitigation Measures Installing an incinerator at Kulhudhuffushi has been considered as a mitigation measure to manage the waste that is generated at the city. 11.3.7.1.2 Cost of Mitigation Cost has been included as part of the project.
1 1 . 3 . 8 Impact on Vegetation The area proposed does not have any mature coconut and other large trees. The area is covered with sparsely vegetated low bushes and weeds. The removal of these greenery will not impact the terrestrial foot print of the city.
1 1 . 3 . 9 Impacts on Avifauna The birds attracted to the city are mostly sea birds that frequent surrounding waters. They will be benefited from both the improved handling and treatment to remove hazardous fractions onto the landfill or into surrounding waters. The beneficial effect will be minor and long-term.
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11.3.9.1.1 Mitigation Measures The presently proposed 4 ton per day incinerator will not significantly help to remove the organic component of the waste that is generated at the city as the capacity is inadequate. This will therefore not bring about any significant reduction to the food supply of birds and other avifauna.
1 1 . 3 . 1 0 Air Pollution and Noise Air pollution sources during the construction phase will consist of vehicular pollution, and pollution from machineries used in construction work, which will release exhaust and cause dust to be produced. The ambient levels of air pollution at the site is low. The released pollutants are not expected to remain stagnant to any particular area as the site is close to the coast on both sides and therefore the pollutants would be dispersed. Similar to the sources of air pollution, noise and vibrations generated in the construction site caused by the operation of machinery, equipment and vehicles. As there are few residents living close to the project site and they do not live in close proximity to the project site, the impacts on human life in minimal. The impacts of air pollution, noise and vibrations although negative, will be temporary and not significant during construction.
1 1 . 3 . 1 1 Labor and Working Conditions The project relies heavily on workers for the construction of the project. It will be the responsibility of ME to ensure the provision of safe working conditions, responsible recruitment, and training of workers during construction of the project.
Potential impacts to workers include undocumented labour, discrimination and unequal opportunity and Occupational Health & Safety. Undocumented labour and health and safety risks arising from construction work are high. 11.3.11.1 Mitigation measures It is important to take measures to prevent and mitigate risks arises from undocumented labour, discrimination and unequal opportunity and occupational health & safety as some of these can have devastating impacts on lives of individual workers. Responsible recruitment undocumented labour restrictions, safe working conditions and training of workers must be put into mitigation measures and in the management and monitoring plan to minimize and reduce the significant impact. 11.3.11.2 Cost of Mitigation No cost, but the contractor will be required to follow proper protocols.
1 1 . 3 . 1 2 Economic impacts A slight positive impact to the local economy is envisaged from the construction phase as the contractor may obtain certain materials required for construction locally depending on availability. Similarly, the contractor may hire local employees for construction works creating temporary job opportunities within the city. Even if expatriate workers are hired, demand for resources such as food and accommodation for construction workers, equipment, machinery, vehicles and vessels hire will likely benefit the local suppliers and businesses. However, this prospect is only temporary as the opportunity will cease after the completion of construction works.
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11.4 Environmental impacts during Operation Stage Operation and maintenance impacts include impacts arising from the operation and maintenance activities of the Incinerator facility. These include routine management of operational waste streams, and occupational health and safety issues.
1 1 . 4 . 1 Impacts Due to the Design of Project Many aspects of the waste incinerator operations will negatively impact the environment if no proper measures are included or integrated in the design of the incinerator. Following mitigation measures need to be included in the design to ensure no adverse impact occur to the environment 11.4.1.1 Mitigation Measures Performance Guarantees. The design and the installation of the incinerator shall ensure that performance requirements during the operation will comply with applicable environmental standards. 11.4.1.2 Cost of Mitigation Cost is part of the project
1 1 . 4 . 2 Waste Management Incineration will help to reduce the overall volume of waste and removes different kind of risk associated with the waste. 11.4.2.1 Mitigation Measures Control incoming waste stream is necessary to ensure safe and effective processing, treatment, and disposal of the waste and the quality of end products Ensure that waste collection services are provided at least daily. Adequate bins with closures must be provided at the drop off locations at the city Bottom ash and residual waste collected at the facility need to be routinely removed from the city and transferred to a regional facility. Maintain log records of all outgoing waste either in terms of weight or volume of bags and/or containers. The log sheets must be provided to the regional collection supervise or vessel caption.
11.4.2.2 Cost of Mitigation Cost is part of the project
1 1 . 4 . 3 Groundwater, Soil, Seawater and Noise The incinerator area of the site will have a concrete screed and roofing, while a leachate collection well and stormwater drains will be installed, which would ensure proper management of leachate and stormwater runoff during operations of the center. At present, the waste is kept in open ground without any barrier or cover on top, making leachate and subsequent contamination of groundwater and soil a high probability. Therefore, the project is expected to moderately improve the soil and groundwater condition of the city. Moreover, the operator of the incinerator should be able to sort and temporarily store waste at the site before it is fed into the incinerator. As expected, some amount of noise will be generated during waste processing activities undertaken at the incinerator. However, the noise generated during the operational phase is expected to be very small as heavy machineries that emit significant noise are not expected to be used.
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11.4.3.1 Mitigation Measures The incinerator has been proposed to be installed on a concrete platform and hence reduce the risk of groundwater pollution from the project site. 11.4.3.2 Cost of Mitigation Cost is part of the project
1 1 . 4 . 4 Air Quality, Public Health and Nuisance to C o m m u n i t y Incinerator facility with added security features (elevated perimeter walls, installation of surveillance cameras, fire fighting equipment etc.) will assist in mitigating the regularly occurring fires on accumulated waste put up by unknown sources. Such kind of fires are also causing nuisance to the nearby residents and is becoming a major public health concern. Open burning of waste is known to cause numerous health implications to people having respiratory diseases such as asthma, bronchitis, emphysema, and pneumonia. Hence, the project is expected to bring about major positive impacts towards the health and wellbeing of the society by reducing the probability of unauthorized fires and associated respiratory diseases. The health benefits perceived would also indirectly contribute to reduce the amount of money spent by individuals on healthcare. In addition to this, bad smell from used nappies are also currently felt by nearby households. With the use of the incinerator, it will be possible to deal with nappies and other kinds of bio hazards.
1 1 . 4 . 5 Mitigation Measures The incinerator has been proposed with a stack and removal of the pollutants from the fly ash and hence reduce the risk of air pollution from the project site.
1 1 . 4 . 6 Cost of Mitigation Cost is part of the project
1 1 . 4 . 7 Hazardous Waste Management Types of hazardous waste managed at the hospital mainly include needles, syringes, expired medicine and contaminated materials (cloth/gauze/disposable gloves). Other types of hazardous wastes generated within the households including small batteries, solvents, paints, used oils, pharmaceuticals and old lights which use mercury shall be managed at the facility. Incoming hazardous waste to the facility should be stored in the hazardous waste storage containers and regularly treated at the incinerator. Mitigation Measures Use containers appropriate for the wastes they are intended to carry; If drums or other containers are used to transport waste, containers should be in good condition and compatible with the waste and are adequately secured in the transport vehicle; Adequately label containers to identify the contents, hazards, and actions required in various emergency situations. Tampons and nappies, while indicated as hazardous wastes in the center, are biodegradable and can be incinerated. The high temperature of the process has been documented to eradicate any harmful pathogens containing potential biohazards.
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1 1 . 4 . 8 S o c i o - E c o n o m i c Workforce demand is expected to be high during the operational stage as well, with a number of low skilled jobs and skilled jobs made available to provide waste collection and waste processing services. In contrast to the construction phase, the jobs created during operational phase will be permanent or for long term. Similar to construction phase, a moderate negative impact maybe possible in terms of sociocultural conflict if expatriate workers are employed to provide waste management services. However, in contrast, the impact at operational phase is considered moderately negative, since incinerator operating staffs are expected to be employed for longer duration given that the operations of the incinerator will be continuous.
1 1 . 4 . 9 Cumulative and Unavoidable impacts The proposed project at Kulhudhuffushi would result in unavoidable impacts on the environment. Some of the impacts on the environment would be cumulative in nature. An incinerator has been proposed to reduce the waste volume in the city. Incineration of waste would results in generation of flue gases including greenhouse gases, bottom ash and heat which will be vented into the environment. These are unavoidable impacts on the natural environment of the city. Flue gas generated from the incineration would be discharged through the smoke stack at the incinerator. Greenhouse gas would be released to the environment from the incinerator stack. Bottom ash generated from the incineration would be removed from the incinerator and kept in bags before it could be transported to R. Vandhoo for final disposal. If bottom ash is kept at the city for a longer time before it is transported to R. Vandhoo, it has the potential to have cumulative impacts on the city environment. This includes spilling ash on the ground, generation of leachates and impacting on the groundwater of the city.
12 Stakeholder Consultations For the purpose of this project, stakeholder consultations were limited to the organizations who were identified by EPA and outlined in the TOR. Methodology for undertaking these discussions was through meetings and discussions. The following section summarises the stakeholder consultations. 12.1 Consultation with Kulhudhuffushi City Council As part of the EIA consultation process, Kulhudhuffushi City council was consulted on 18th January 2020 during the data collection process to obtain their views and feedback on the proposed incinerator. Following are the summary of major outcomes from the discussions. The council noted that the waste collection and transport from the households and commercial development is carried out by FENAKA. The council raised concerns regarding the smell and smoke from the waste management center, especially during the north-east monsoon. The nearby school suffers from the smell and smoke during this period. According to the city council, approximately 20 trucks filled with waste is generated in the city during weekdays. On weekdays 30 trucks full of waste is taken to the waste management center. (The carrying capacity of the trucks are approximately 2.5-3 tons) The city council raised concerns regarding the capacity of incinerator (4 tons) being too small and not enough for a city such as Kulhudhufushi . Their opinion is that the capacity of the incinerator should be adequate to accommodate the volume of waste that is already being generated in the city.
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The Council raised concerns that the community and the Council has not been adequately informed about the details of the project such as operational and maintenance costs, manpower, budgeting etc. The Council indicated that the project will not be accepted by the community unless proper information about the project is shared. The Council raised the issue of not having undertaken a proper waste audit in the city. The Council indicated that waste management is one of the most significant environmental problems faced by the islanders and although incineration is an essential component in the management of waste, such a small incinerator would not bring any meaningful solution to the current issues.
12.2 Consultation with FENAKA (Kulhudhuffushi Branch) As part of the EIA consultation process, FENAKA (Kulhudhuffushi Branch) was consulted on 19th January 2020 during the data collection process to obtain their views and feedback on the proposed incinerator project. Following are the summary of major outcomes from the discussions. FENAKA noted that they manage waste in Kulhudhuffushi city. By management, FENAKA highlighted that they are merely keeping the site clean by removing all dumped garbage to one area. Hence, there is no proper management of waste. FENAKA collects the waste from bins and transports to the waste dump site located on southern side of the city. FENAKA informed that they do not open burn or burrow of waste in the center. However, it was mentioned that some locals do open burning of wastes in the center.
According to FENAKA, 45-75 tons of waste is generated in the city.
FENAKA’s opinion is that the waste incinerator will improve the waste management on the city but they raised concerns regarding the size of the incinerator being too small and not enough for a city such as Kulhufhufushi.
They informed that there are no engineers to maintain the incinerator, not enough vehicles to transport waste, and not enough space to segregate waste.
Furthermore, they raised concerns about the nearby school suffering from the smell and smoke due to the dumpsite, especially during the north-east monsoon.
FENAKA requested to change the location of the waste management center as the existing site is too small.
FENAKA mentioned that they were not informed about the incinerator and thus are not aware whether they will play a role in managing it or not.
12.3 Consultation with Kulhudhuffushi Regional Hospital As part of the EIA consultation process, Kulhudhuffushi Regional Hospital was consulted on 19th January 2020 during the data collection process to obtain their views and feedback on the proposed project. Following are the summary of major outcomes from the discussions. The Hospital’s opinion is that the waste incinerator will improve the waste management on the city and will reduce the smoke and particles flying over the city as the old incinerator placed in the hospital had ash particles flying around to the nearby Police Station.
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However, they raised their concerns regarding the capacity of the incinerator (4 tons) being too small for the city.
The Hospital informed that hazardous wastes are autoclaved and taken to the waste management center by FENAKA. However, waste generated in the wards are not autoclaved.
According to the Hospital, 2-3 tons of waste is generated weekly in the Hospital.
The incinerator would be a good option to manage the hazardhous waste from the hospital as the capacity of waste is within manageable limits for the incinerator.
12.4 Consultation with National Disaster Management Authority As part of the EIA consultation process, National Disaster Management Authority was consulted on the 27th January 2020, to obtain their views and feedback on the proposed on the proposed incinerator project. NDMA had no specific comments about the project, but had given general comments for EIAs. Following is the summary of the comments provided: The National Disaster Management Authority advices and encourages proponents and consultants working on development projects to carry out a study to identify, predict and evaluate hazard impacts associated with a new development or the extension of an existing facility.
NDMA believes that Hazard impact assessment is an integral component of and extension to the environmental review process and environmental impact assessment in that it encourages explicit consideration and mitigation of hazard risk.
General comment from NDMA for Environmental Impact Assessment scoping/stakeholder meetings which provides information on the different types of hazards and their causes, is attached in the annex.
12.5 Consultation with Waste Management Corporation Limited (WAMCO) As part of the EIA consultation process, WAMCO was consulted on 04th February 2020 during the data collection process to obtain their views and feedback on the proposed incinerator project. Following are the summary of major outcomes from the discussions. WAMCO estimates that Kulhudhuffushi will generate approximately 6 tons of waste daily, in which 2 tons will be the amount that can be incinerated. This estimate is much less compared to the Council and FENAKA’s estimates.
WAMCO’s estimates were done by using data from Villingili, where 200 kg of is generated per head. This totals to 2 tons daily for the whole island.
Furthermore, WAMCO stated that according to their waste audit of Noonu, Baa, Raa, and Lhaviyani atolls, 45 resorts generated approximately a total of 164 tons daily and the estimate for 45 islands were a total of 30 tons daily.
WAMCO’s opinion is that this incinerator is not suitable for the long term use but can be supplemented for an immediate solution for the city.
WAMCO was concerned with how the bottom ash will be disposed and this needs to be made clear.
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12.6 Consultation with Ministry of Environment (Energy Department) As part of the EIA consultation process, Ministry of Environment (Energy Department) was consulted on 05th February 2020 during the data collection process to obtain their views and feedback on the proposed incinerator project. Following are the summary of major outcomes from the discussions. The Energy Department mentioned that there are no guidelines and requirements regarding incinerators from Ministry of Environment’s Energy Department. They informed to check Health Protection Agency’s guidelines.
The Energy Department noted that Waste Management and Pollution Control Department of Ministry of Environment should have been consulted.
There are no specific data such as energy consumption, cost and emission control for incinerators as currently there are no incinerators installed at islands/cities.
12.7 Consultation with Maldives Land Survey Authority To conduct a stakeholder meeting with Maldives Land Survey Authority a letter was sent on 27th January 2020, requesting to inform the EIA consultant of the various concerns related to this project. However, there was no response from Maldives Land Survey Authority regarding the project. The letter is attached in the annex.
12.8 Consultation with Health Protection Agency To conduct a stakeholder meeting with Health Protection Agency a letter was sent on 27th January 2020, requesting to inform the EIA consultant of the various concerns related to this project. However, there was no response from Health Protection Agency regarding the project. The letter is attached in the annex.
12.9 List of personnel consulted The list of personnel consulted is attached in the annex.
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13 Alternatives This section looks at alternative ways of undertaking the proposed project. There are two basic options: (1) leave the problem as it is (no project option), or
(2) Take measures to resolve the problem (undertake the project option).
If the project is to continue, it would be necessary to take economic, ecological and environmental aspects of the project into consideration and ensure that these concerns exist within a delicate balance. Neither the economic benefits nor the environmental and ecological concerns can be avoided. Therefore, it is important to consider all options and ensure that the best available option(s) is chosen to solve the issues/problems. A single activity can bear effects on a considerable number of key components determining a range of closely interconnected impacts. The relative importance of each of these beneficial and detrimental impacts must be evaluated in the context of a set of alternative options. The effectiveness of an EIA process depends on the successful identification of these alternatives. We can then aim at minimising negative impacts and maximising positive ones acting on specific activities through selection of best alternative options and / or mitigation measures.
13.1 No Project Option It should be noted that the “no project” option cannot be excluded without proper evaluation. It is important to evaluate whether without this project, the community will face difficulties or more benefits. In this report, this alternative were considered as the baseline against which to evaluate the other various options. Hence, the no project option takes the following into account. The existing dumpsite will be used for the management of waste. Burning of waste will be done at the waste dumpsite. No installation of an incinerator. The main advantages and disadvantages of these are given in the following table. Table 11: Advantages and disadvantages of the no project option Strategy Advantages Disadvantages Allow the Environmental problems related The community will not be made islanders to to installation of the incinerator aware of the importance of the right dump waste at can be avoided. size of the incinerator. the waste dumpsite with No capital and recurrent cost for Hospital waste (bio hazardous) will open burning. flue gas monitoring. need to be presently managed without the option of proper Will not require closed drums to incineration. stockpile the bottom ash. Misses the opportunity for There will not be any costs to the managing special wastes whose proponent and hence there is a quantity may be adequate to be short term benefit. handled by the incinerator capacity.
Pave way to undertake a proper The size of the existing pile of waste audit which will determine waste will increase. an appropriate size for the incinerator.
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No operation and maintenance costs.
No community dissatisfaction with the lack of meaningful solution to waste management (due to the small size of the incinerator).
13.2 Alternative analysis matrix For this project, an alternative analysis was carried out on the basis of various biophysical and socioeconomic parameters including the following using an analysis matrix: Technical feasibility, Economic viability, Environmental acceptability of the project and Social benefits The following table outlines the various alternatives proposed for this project, their economic, technical, environmental as well as social factors taken into consideration.
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Table 12: Alternative analysis matrix for the project SN Alternatives proposed Technical Economic viability Environmentally Social benefits feasibility acceptable Alternative Locations A1 Within the Waste Dumpsite using a large Technically not Expensive but feasible. The dumpsite Multiple benefits to incinerator. feasible to treat rehabilitation process will the society. all the waste be accelerated Kulhudhufushi has been selected one of the generated with islands where an incinerator would be the proposed established to treat and manage the solid incinerator. waste at the city. The city council is urgently required to establish the incineration facility as the current waste management practice on the city is having negative impact on the city. The allocated location is appropriate and requires only clearing of underbrush. Bottom ash will be stored in enclosed barrels until they can be properly disposed at a landfill.
Alternative methods for treating the waste A2 Composting of organic waste at the city level Technically Economically viable Environmentally This would not be difficult due to unacceptable socially acceptable as In this method, organic waste needs to be proximity to it requires large separated and brought to a site where it is populated areas. manpower to operate composted. The residual waste can then be the system and incinerated using simple incineration method. generates foul odour
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SN Alternatives proposed Technical Economic viability Environmentally Social benefits feasibility acceptable A3 Removal of the waste collected from Technically Very Expensive. Favourable as long as the Very high cost to Kulhudhufushi and transported to Vandhoo feasible transportation is done in transport the waste to Island. closed containers to Vandhoo. prevent marine pollution.
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13.3 Preferred Alternative The preferred alternative includes the following: Rehabilitating the waste management center by cleaning and transporting of existing waste pile to Vandhoo waste management centre (Raa Atoll).
A landing craft collects all the waste that is piled up at the city and transport the waste to Vandhoo for final disposal.
Doing a proper waste audit of Kulhudhufushi city and installing an incinerator with a capacity that is more suitable to manage the waste load.
Consider installation of a large (appropriate size) incinerator and allocate budget for its operation and maintenance.
1 3 . 3 . 1 Mitigation Measures for the Preferred Alternative The following mitigation measures are proposed for the preferred alternative. 1. Only utilize experienced contractors to transport the waste from Kulhudhufushi to Vandhoo.
2. Council ensures that the waste that is loaded onto the landing craft reaches and unloads to Vandhoo city.
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14 Environmental Management and Monitoring Plan
14.1 Introduction Environmental management and monitoring is essential to ensure that potential impacts are minimized and to mitigate unanticipated impacts. Monitoring will be carried out as part of the environmental impact assessment and monitoring requirements addressed in this EIA report. The following table summarizes the aspects of monitoring.
14.2 Environmental monitoring plan An environmental monitoring plan is outlined in this section. This plan outlines the measures that needs to be undertaken during construction and operational period.
14.3 Cost of Monitoring The proponent has committed fully for the monitoring programme outlined in this report. The total cost of undertaking the regular monitoring is estimated in the following table. Cost of monitoring includes all data collection and reporting to the client as well as the relevant government agencies.
14.4 Duration of Monitoring Monitoring will include all the relevant aspects of the project. The proposed scheduled for monitoring has been prepared during the construction and operational stage. Hence, this schedule will be applicable for monitoring during the construction period and during the operational stage after the project. Monitoring will be undertaken by subcontracting the work to an independent consultant or a consulting firm.
14.5 Methods of Monitoring Environmental monitoring will be undertaken using standard methods described in the Methodology section.
14.6 Monitoring Responsibility Monitoring responsibility will be with the client and financial provisions will be made in the project to undertake the monitoring.
14.7 Monitoring Report A detailed monitoring report should be compiled after the completion of the installation of the incinerator. During the construction period, monitoring report must be provided at the end of the construction stage and should adhere to EIA Regulations, 2012. During the operational stage, regular monitoring reports should be provided twice a year. This report will be submitted to the relevant government agencies for compliance. The report will include details of the site, data collection and analysis, quality control measures, sampling frequency and monitoring analysis and details of methodologies and protocols followed.
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14.8 Environmental Monitoring plan
Table 13: Schedule for environmental monitoring during the construction period as well as per annum during operation period. Cost during Cost Per annum Monitoring Attribute Indicator Methodology Monitoring Frequency (construction phase) (operational phase) Construction Operational stage stage Implementation of mitigation Records of Qualitative & Monthly during MVR 10,000 measures during construction successful Quantitative construction implementation period of mitigation measures Groundwater quality pH, turbidity, Qualitative & After Bi-Annually MVR 10,000 MVR 20,000 TDS, Quantitative completion of
conductivity, DO the project Air quality NO, NO2, SO2, Qualitative & After Bi-Annually MVR 20,000 MVR 30,000 PM2.5 & PM10 Quantitative completion of
the project Implementation of mitigation Records of Qualitative & Not required Bi-Annually Not required MVR 10,000 measures during operations of successful Quantitative the incinerator implementation of mitigation measures
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15 Conclusion The EIA for the installation of an incinerator at Kulhudhufushi city has been prepared based on a thorough review of technical information, available design documents and using primary and secondary data and information about the project. Waste management is one of the biggest issues faced by Kulhudhufushi city. Until now, no meaningful solution has been obtained for managing waste in the city. The Ministry of Environment has planned this project in the hope of bringing some solution to the ongoing waste management issues in the city. However, there are several draw backs in this project. One of the most important findings of this EIA study is that the proposed incinerator is not adequately sized to the city. Although it can manage 4 tons per day, this volume is not sufficient to bring any meaningful solution to the ongoing waste management issues faced in the city. Secondly, the report has identified that no waste audit was undertaken before planning this project. Only a waste audit can determine the suitable capacity of the incinerator for a given island/city. Third, there has not been any community consultations or inputs obtained during the planning process. The city Council is not aware of any details of the project and there are several questions that need to be answered. Such a project cannot be successfully implemented without the input of the community as it cannot be sustainable. There is no clear plans on how the introduction of an incinerator will affect the ongoing waste management mechanism in terms of operational cost, human capital and maintenance. The council has indicated that an incinerator will add additional burden to the current capacity difficulties if it cannot bring about a meaningful solution to the waste management issue. Therefore, the acceptability of the project will be difficult from the community. On the positive side, having an incinerator of this capacity can be beneficial for managing hazardous waste from hospital. During the consultations, it was made clear that there are shortages in managing bio hazards in the hospital. Nevertheless, this incinerator will be suitable for the hospital to dispose bio hazards. During the operation of the incinerator, air quality monitoring is a crucial part as it is directly associated with human health. Therefore, a good monitoring mechanism needs to be in place. Based on the discussions, it appears that there is no such capacity in the city nor in the Ministry. The overall conclusion of this study is that although incinerators can bring about significant improvements to the waste management capacity, they need to be appropriately sized to suit a given situation. Their sustainability depends on many factors such as the right size, good operation and maintenance, adequate financial budget for regular maintenance and repairs, and training of operators and ensuring that the incinerator can handle the waste load adequately. To determine the right size, a waste audit needs to be undertaken. The proposed 4 ton per day incinerator is too small for Kulhudhufushi city and will not bring any significant improvements to the present solid waste management efforts. However, it can be a suitable solution for managing hospital waste. The incinerator will also help to reduce the overall solid waste loads temporarily but should never be considered as a permanent solution to manage waste in the city. The successful operation of any incinerator will depend on providing the operators with the right training and an operational budget needs to be allocated. In addition, the emissions should be monitored properly to ensure that flue gasses emitted are within safe limits.
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15.1 Recommendations Following are the major findings and key recommendations based on this EIA assessment. These recommendations cover both environmental and the social aspects. The proposed incinerators capacity is not suitable to manage the waste load in the city. However, this incinerator is useful for the hospital to dispose their bio hazardous waste. The staff handling the hazardous waste and the vehicles transporting the waste need to be in accordance with Health Protection Agency’s requirements and guidelines.
The incinerator can be utilized as a temporary solution to assist the waste management efforts but should not be used in the long term as a means to manage solid waste.
The proposed project work needs to be closely monitored by the Ministry of Environment in consultation with the city council. It is thus recommended that the city Council be involved in day to day monitoring of the works during construction and installation period.
An operational budget needs to be implemented for engineering and repairing works of the incinerator.
Environmental monitoring to be carried as a requirement addressed in this EIA report. The monitoring programme outlined in the report should be used as a basis from the construction period as well as after construction.
Monthly flu gas monitoring of the surrounding area to be carried as a requirement.
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16 People who have assisted in the preperation of this report Chapter Page People who EIA Signature number assisted in data registration collection and number (only report writing for those registered consultants)
Introduction 15 Ahmed Jameel EIA P07/2007
Abdul Aleem EIA P03/2019
Project Description 23 Mohamed Umar EIA P02/2019
Ahmed Jameel EIA P07/2007
Project Setting 17 Ahmed Jameel EIA P07/2007 (Legislative section)
Mohamed Umar EIA P02/2019
Existing 33 Ahmed Jameel EIA P07/2007 Environment
Abdul Aleem EIA P03/2019
Mohamed Umar EIA P02/2019 Impact and 43 Mitigation Ahmed Jameel EIA P07/2007
Mohamed Umar EIA P02/2019 Stakeholder 49 Consultations Abdul Aleem EIA P03/2019
Monitoring 59 Abdul Aleem EIA P03/2019
Alternatives 53 Ahmed Jameel EIA P07/2007
Abdul Aleem EIA P03/2019 Conclusion and 62 Recommendation Ahmed Jameel EIA P07/2007
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17 Acknowledgements Various people have assisted the consulting team in preparing this report, name and their designations are listed below. CV’s of the field assistants are attached as an annex. Water Solutions would like to thank their support and assistance provided in completion of this report.
1. Ahmed Jameel, B. Eng (Environmental), MSc – Environmental (EIA-P07/2007) 2. Mohamed Umar, BSc - Environmental Management (EIA P02/2019) 3. Abdul Aleel, MSC, 4. Yumin Naseem, B.Sc (Hons) - Environmental Science 5. Water Solutions staff 6. Kulhudhuffushi city Council 7. Ministry of Environment
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18 Reference Books and Sources AECOM (2011) Engineering Investigation and Environmental Studies for Integrated Waste Management Facilities or managing municipal solid waste (MSW) Hong Kong Council Directive 1999/31/EC of 26 April 1999 on the Landfill of Waste Directive 2010/75/EU of the European Parliament and the Council (Technical Provisions Relating to emission standards for waste incineration plants and waste co-incineration plants any time). EU Industrial Emission Directives (IED). Kylefors, K. (2002) Predictions of Leaching from Municipal Solid Waste (MSW) and Measures to Improve Leachate Management at Landfills, Doctoral Thesis, Department of Environmental Engineering, Lulea University of Technology, Sweden. Hay, J. E. (2006). Climate Risk Profile for the Maldives. Malé, Maldives: Ministry of Environment and Energy and Water. ME (2017), Feasibility Study for an Integrated Solid Waste Management System for Zone III (including Greater Male') and Preparation of Engineering Design of the Regional Waste Management Facility at Thilafushi MEE (2018). Feasibility Study for an Integrated Solid Waste Management System for Zone 3 (including Greater Malé) and Design of the Regional Waste Management Facility at Thilafushi, Ministry of Environment and Energy. MEE (2017) EMP for the establishment of Island Waste Management Center in L. Hithadhoo, Ministry of Environment and Energy and Energy, Malé. MEE (2017) State of the Environment 2016, Ministry of Environment and Energy and Energy MEE (2016) Second National Communication of the Maldives to the United Nations Framework Convention on Climate Change, Ministry of Environment and Energy and Energy, Malé MEE (2014) Environment & Social Assessment & Management Framework Climate Change Adaptation Project, Ministry of Environment and Energy and Energy, Malé. MEE (2012) Environmental and Social Impact Assessment for North Regional Waste Management Facility Construction and Operation (MEE, 2012), Ministry of Environment and Energy and Energy, Malé. MEE (2012) ESIA for Construction and Operation North Regional Waste Management Facility at R. Vandhoo (MEE, 2012) Ministry of Environment and Energy and Energy, Malé. MEE (2011), EIA for the proposed solid waste management facility at Thilafushi, Kaafu Atoll Maldives, Ministry of Environment and Energy and Energy, Malé. MEEW (2005) State of the Environment of the Maldives 2004, Ministry of Environment and Energy, Energy and Water, Malé Woodroffe, C. D. (1989) Maldives and Sea Level Rise: An Environmental Perspective, University of Wollongong, Wollongong UNDP (2006) Developing a Disaster Risk Profile of the Maldives, UNDP, Malé, Maldives UNEP (2002) State of the Environment (SOE) report, Maldives, United Nations Environment Program. Water Solutions Pvt. Ltd, (2008). Maps of Maldives, the complete guide to the Atolls and Islands of Maldives. Malé: Water Solutions Pvt. Ltd, Maldives
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19 Annex: Terms of reference
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20 Annex: Proposed Incinerator
Prepared by Water Solutions Pvt. Ltd, February 2020 Page 69 i8-700G General Incinerator i8-700G many unique to the i8 range. Developed over the last 3 years the i8-700G is rates and large batch sizes while still acheiving some of the lowest emmisions in its class.
Industry Leading Insulation Coretex© insulation is a specially formulated substrate containing various levels of material that ensure almost all of the heat generated within our incinerators stays inside them - increasing performance and CORETEX INSULATION Rigid, Long Lasting Construction 6mm All our incinerators are constructed from British made high quality 5mm mild steel plate. They are fully welded for maximum strength by our time-served coded welders. Meaning you get years of trouble-free operation. GAUGESTEEL AS STANDARD Fully Compliant Range 850°C Each of our incinerators has been tested to exacting standards ensuring they meet all required guidelines. They are CE declared to BS E7N4 6-2:1997 (industrial thermo processing equipment – part 2). This machine can reach in excess of 850oC in the secondary chamber and also retains the fumes for the 2 seconds required. 2 SECONDTEMP RETENTION
Remote Monitoring & Pro-active Analysis We have developed this control panel to allow trouble-fee operation. Data can be fed back to our HQ where our team of engineers monitor and provide advice when required on optimum operation of your incinerator. It SMARTPANEL REMOTE MONITORING also allows us to advise when your service is due to ensure longevity of the unit.
Technical Specifications
Combustion Chamber Volume (m3) 6.75m3 Gas Retention 2 secs
Maximum Batch Size 8000 litres Average ash residue (%) 3%
Burn Rate 900kg per hour ** Thermostatic Device Yes
Average Fuel Consumption 65 litres per hour Shipping Weight 16000kg
Operational Temperature 850°C* Dimensions (l, w, h) 6.23m x 1.9m x 6.23m Plug and Play CE-7 Control Panel Why is this 3 layer lining so good? All our incinerators’ chambers are lined with high grade refractory concrete rated to 1600C. Completely re-designed and built in-house 25mm insulation block backup layer Our sinceseconda 2017.ry chamber Our control technology panels pr enowvents feature: dioxins from cracking into smaller but more reactive molecules, this is known as de novo formation. This can be especially apparent in the presence of heavy metals, whichAn intermediatecan act as a ca talinsulatingyst. The p rlayerevention in a method 1260 can be grade insulation brick (most insulative block Full PLC and touch screen control gas remnants are then retained in the secondary chamber, through thermal deavailablecomposition, on andthe cmarket).yclonic air distribution to ensure a clean odourlessSelf-fault emission in diagnosticsthe form of vapou r. Final layer of 100mm low cement castable High integrity SIL 3 Safety rated Fast firing characteristics pre-engineered Automatic air modulation Robust, efficient and long lasting SpeakAutomatic to lidthe locking Ex perts One button to start system Our technical sales team are always on hand to answer any questions you may have.
Call +44 1704 884020 or email [email protected] Key Parts of our Incinerator Chimney Stack Stainless steel stack for longevity. 3 Zone Thermocouple Minimum 5.5m stack height required. Fitted with dispersion cap as standard. Allow independent control of primary and secondary temperatures via the control panel. Primary chamber Chamber designed for maximum air flow and circulation which in turn improves efficiency and total burn time.
Secondary Chamber Retains and re-burns the exhaust fumes for minimum of 2 seconds at 850°C to meet EU guidelines.
7 x Low NOx Burners These are some of the cleanest, most efficient burners available today. These Safety Features Ash door can be supplied as gas or oil fired. Kill switches, automatic shutdown, This model now features ‘floating’ ash automatic lock clamps all ensure user doors - Design for better rigidity and safety is at the forefront of operation. can be opened safely.
How incineration works:
Incineration is a waste treatment process that involves the combustion of organic substances contained in waste materials. Incineration and other high-temperature waste treatment systems are described as “thermal treatment”. Incineration of waste materials converts the waste into ash, flue gas and heat. The ash is mostly formed by the inorganic constituents of the waste and may take the form of solid lumps or powder. In some cases, the heat generated by incineration can be used to generate electric power.
Applications
Our versatile range of general incinerators are designed for a wide range of waste types. This model has the largest load door and also benefits from a top loading design and features the latest in operator safety and performance. This model can also use our latest control panel technology for remote monitoring. • Industrial waste applications (including RDF) • Household waste • Wood waste • Oily filters & rags • Mining/exploration/refugee camp waste • Plastics • Oil and gas industry waste applications • Some medical waste streams 50 50
15 7046
12
10
1 SECTION THROUGH LID 17 CENTRE LINE 60 7 3090
16 4 ITEM No PART NUMBER DESCRIPTION LENGTH QTY A 700PC PRIMARY CHAMBER 1405 1 700PC1 LID 2 700PC2 BASE FRAME 3 700PC3 SIDE & BASE PANELS 4 700PC4 SIDE CHANNELS 5 700PC5 WELD ASSEMBLY 2 5 6 TYP A 7 700PC 7 HYDRAULIC ARM ASSEMBLY
10 700SC SECONDARY CHAMBER 11 700SC1 SIDE & TOP PANELS 12 700SC2 CHANNEL FRAME Technical Specification 13 700SC3 WELD ASSEMBLY 14 1000SC7 BASE FOR CHIMNEY STACK 3 3 15 1000CS CHIMNEY STACK Combustion Chamber Volume (m ) 6.75m Average Ash Residue (%) 3% 16 25MB100A 5 17 25MB100S 2
Title Metal Thickness 6mm Thermostatic14 Device yes i800-700 ASSEMBLY Assembly No i800-700 Burn Rate* 300 - 800kg per hour** Shipping Weight (kg) 15000kg Part No Date 30-11-2017 Operational Temperature 850°C Dimensions (l, w, h) 6.04m x 1.91m x 5.75m
Gas Retention 2 seconds Door Size (m) 4.58m x 1.50m T: +44(0)1704 884020 FIRST ANGLE PROJECTION E: www.inciner8.com
* PLEASE NOTE: Fuel Consumption 40 - 50 ltrs per hour Actual burn rates & emissions will depend on a number of factors including waste type, volume of waste, moisture content, fuel used and local environmental conditions.
Average emissions / EU standards * All our incinerators’ chambers are lined with high grade (On basic incinerators with secondary chamber) refractory concrete rated to 1600°C. Our secondary chamber technology prevents dioxins from cracking into smaller but more reactive molecules, Parameter (1/2 hr av) Limits Measured this is known as de novo formation.
Total dust 30 mg/m3 12 mg/m3 This can be especially apparent in the presence of Sulphur dioxide 200 mg/m3 2,4 mg/m3 heavy metals, which can act as a catalyst. Nitrogen dioxide 400 mg/m3 60 mg/m3 Carbon monoxide 100 mg/m3 78,3 mg/m3 The prevention method can be explained as follows: system design forces the micro particulates to pass through a flame curtain, this burns harmful emissions, *The above figures are guidelines ONLY. gas remnants are then retained in the secondary chamber, through thermal decomposition, and complex, Actual emissions will depend on a number of factors controlled air distribution to ensure a clean odourless including waste type, volume of waste, moisture content, emission. fuel used and local environmental conditions. Site Preparation
Sheltered Skid-mounted Trailer-mounted
Ideal weather protection for equipment and For larger models skid-mounting is the most The trailer is rated to carry up to 32000kg , operator. Our shelters are designed for easy feasible and viable option ito allow mobility. therefore there is plenty of additional space and quick installation on a standard reinforced to carry extra items of equipment including concrete slab. The units arrive complete with electrical generator sets, fuel and any other equipment. power generators and fuel supply with further Chassis, framework and panels are galvanized Certain regions require some sort of shelter customization available to suit all needs, for maximum durability. from adverse weather conditions or localised regardless of local resources available. problems. Our products are used in diverse The system is available in 20ft and 40ft These trailers have been built to withstand the locations from the freezing camps of Antarctica skids, depending on capacity and optional rigours of the construction industry. The beam to sweltering temperatures of Sierra Leone. requirements. axle system features sealed, specialised wheel bearings and powerful auto-reverse brakes and is unequalled for strength and durability.
All containers supplied are ISO 6346 certified, so they can be used for the shipping and housing of incinerators and any other related equipment. CE DECLARATION.
MACHINE LISTED BELOW HAS BEEN TESTED BY MANUFACTURER IN FACTORY BEFORE DISPATCH
PRODUCTION DATE: 2018 CONFORMS TO ALL SAFETY NORMS WHEN USED ACCORDINGLY “CE DECLARATION OF CONFORMITY” “CE DECLARATION DE CONFORMITE” “CE DECLARACION OF CONFORMIDAD” “CE ATTESTATO DI CONFORMITA” “EG- KONFORM IT A TSERKLARUNG”
INCINER8 LTD, UNIT 2, CANNING ROAD INDUSTRIAL ESTATE, CANNING ROAD, SOUTHPORT PR9 7SN, UNITED KINGDOM
Has declared that the machinery described: Declares que les machines descrits: Declaramos que la maquinaria descrita: Dichiara che la macchina di seguito descrito: Bestatigt daB die hierunter beschreibt Maschine: Model (Modele; Modelo; Modello; Modell) :
CE INCINERATOR I8-700G C/W Eco Flam Burners
Serial Number (Numero de Serie; Numero de Fabricacion; Numero di Serie; Registriernummer) : INCIN8(ABP)845 Conforms to the following directives: Est conforme aux Directives suiventes: Es conforme a las Directivas seguientes: E conforme alle disposizioni contenute nelle seguenti direttive: Ist gemaB folgenden Richtlinien hergestellt worden:
1.BS EN 746-2:1997 (industrial thermoprocessing equipment – part 2. Safety requirements for combustion and handling systems)
2.Low Voltage Directive 73/23/EEC Directive Basse Tension Directive Baja Tension Direttiva Sulla Bassa Tensione Niedrige Sapnnung – Richtlinie Diretivas
3.EMC Compatibility Regulation 89/336/EEC Directive CEM Directiva CEM Direttiva Compatibilita Elettromagnetica Elektromanetische Vereinbarkeit – Richtlinie Directive EMC
4.Machinery Directive 2006/42/EC (including amendment) Directive Securite Machines Directiva Seguridad Maquinas Direttiva Macchine Maschinen – Richtlinie Directiva De Maquinario
5. (EC) No 1005/2009 on substances that deplete the ozone layer The i8-250A is one of our mid-sized models that can be used for a variety of applications. Large enough to o er impressive burn rates and batch sizes, while still being small enough to t all our mobile options. The i8-250A features a top loading design with a large opening for bulky waste items.
Industry Leading Insulation Coretex© insulation is a specially formulated substrate containing various levels of material that ensure almost all of the heat generated within our incinerators stays inside them - increasing performance and CORETEX e ciency to another level. INSULATION Rigid, Long Lasting Construction 4mm All our incinerators are constructed from British made high quality 4mm mild steel plate. They are fully welded for maximum strength by our time-served coded welders. Meaning you get years of trouble-free STEEL operation. GAUGE AS STANDARD www.inciner8.com Fully Compliant Range 850°C Each of our incinerators has been tested to exacting standards ensuring they meet all required guidelines. They are CE declared to BS E7N4 6-2:1997 (industrial thermo processing equipment – part 2). This machine can reach in excess of 850oC in the secondary chamber and also retains the gases for the 2 seconds required. 2 SECONDTEMP RETENTION
INCINER8Remote Ltd Monitoring is one &of Pro-active the largest Analysis suppliers(optional extra) of incinerators through- We have developed this control panel to allow trouble-fee operation. Data can be fed back to our HQ where out the world.our team of Manufacturing engineers monitor and provide in a advice factory when required in Southport on optimum operation and of shippingyour incinerator. It SMARTPANEL also allows us to advise when your service is due to ensure longevity of the unit. outREMOTE MONITORINGproducts all over the world through our dedicated sales team & Global Dealership Network. Technical Specifications AnCombustion experienced Chamber team of Volume researchers, (m3) 2.4m3 designers and engineers Ahaveverage made ash rINCINER8esidue (%) an innovator3% in the waste incineratorMetal Thickness sector, achieving two Queens4mm Awards and many regionalThermostatic business Device awards. Yes
Burn Rate up to 300kg per hour** Shipping Weight 6000kg Our hand engineered machines can process municipal, medical and animal waste streams, providing the best Operational Temperature 850°C* Dimensions (l, w, h) 3.6m x 1.3m x 4.4m solutions to waste problems around the world. Gas Retention 2 secs ** Dependent on calorific value of waste and local conditions.
All our incinerators’ chambers are lined with high grade refractory concrete rated to 1600C.
Our secondary chamber technology prevents dioxins from cracking into smaller but more reactive molecules, this is known as de novo formation. This can be especially apparent in the presence of heavy metals, which can act as a catalyst. The prevention method can be explained as follows: a self-ignition process forces the micro particulates to pass through a ame curtain, this burns all harmful emissions, gas remnants are then retained in the secondary chamber, through thermal decomposition, and cyclonic air distribution to ensure a clean odourless emission in the form of vapour.
Speak to the Experts
Our technical sales team are always on hand to answer any questions you may have.
Call +44 1704 884020 or email [email protected]
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21 Annex: Proposed location of the Incinerator
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22 Annex: Proposed Incinerator Shed
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23 Methodologies used
Prepared by Water Solutions Pvt. Ltd, February 2020 Page 75 1 . 1 Introduction
The annex describes detail methodologies used to collect data on the existing environment for EIA studies in the Maldives. For EIA studies in the Maldives, various methodologies are used and the type and methods vary for different projects. Almost all projects will utilize some general data collection methodologies in combination of various other methods. The following section outlines the data collection methodologies that are used in Maldives and their description.
1 . 2 General Methodologies of Data Collection
In this method, the condition of the existing environment is analyzed using appropriate scientific methods. The environmental components of the study area are focused for terrestrial, marine and coastal environment depending on the specific projects. In general, for any project that requires the study of the marine environment, the marine environment of the island is studied including the coral reef and the lagoon. Focus is given on specific areas of the island’s reef which is expected to have the greatest impact as a result of the proposed project. Coastal environmental data collection involves mapping the shoreline, taking beach profiles from selected locations, identifying and mapping costal defense structures and assessing the coastal environment for erosion or accretion. Terrestrial data collection usually includes creating a terrestrial map of the island or a specific area.
1 . 3 Mapping and Location Identification
The island, lagoon, reef or specific areas of islands or a project site is mapped, including shore line, vegetation line, reef lines, existing mature trees, coastal defense structures or other significant topographic features. Mapping is undertaken using hand held differential GPS and available aerial photos. The location of data collection sites are marked using handheld GPS. These data collection points includes marine water sampling locations, marine survey locations, existing groynes and sea walls, mature trees, breakwaters, protected or archaeological sites, erosion prone areas, sand spits, beach rocks etc.
1 . 4 Marine Environment Surveys
Marine environmental surveys were conducted to collect data on key environmental components (i.e. the coral reef system and the lagoon), that will be impacted due to the project. Four methods are primarily used to collect data, namely: Line Intercept transects (LIT’s) Detail photo quadrate analysis, Fish census and Visual observations.
Purpose of the survey is to define and establish marine environmental baseline conditions for impact evaluation during and after a project. Surveys are based on standard marine environmental surveys so that they can be repeatedly carried out to monitor and record changes and assess possible impacts on the marine environment from the proposed work activities. Surveys include quantitative and qualitative methods. In addition, photos are taken along the reef survey sites and the length of the lagoon.
1 . 5 Line Intercept Transects (LIT)
Line Intercept Transect (LIT) surveys are carried out to assess the benthic types and species at the survey sites. This method uses life form categories to assess the benthic sessile community of reefs and it is possible to incorporate taxonomic data as well. LIT surveys can be used to evaluate the community structure of corals in terms of species composition and
Annex: Methodology - Page 2 diversity patterns in different zones on a reef. LIT method also provides a rapid estimate of percent cover of corals, algal cover, and cases of other prominent organisms as well as bare substratum.
Quantitative percent cover of the reef community can be obtained using this method and it can be repeated over time to obtain changes over a period of time. Disadvantages of this method include difficulty in standardizing the life form categories and the limitation of the data collected, to information on percent cover and relative abundance (English et al. 1997). LIT surveys produce valuable data even though they are time consuming and require considerable effort and skills to record notes underwater (Segal & Castro 2001). A line transect of 20m length is normally used, but transect lengths can vary depending on the surveyor.
1 . 6 Photo quadrate analysis
Photo transect coral reef survey method is used to quantify the data of coral reef benthic communities i.e. live corals and their types, other benthos, dead corals and other reef substrate. This method is used to support the LIT surveys or as an alternative to line transect. A series of photographs are taken along the transect line (usually 20 m each) using an underwater camera. These photographs are combined to form a photo-composite. Photo- composite of the mapped area of the reef are then analyzed using computer software. It provided a detail record of individual corals, sandy or rubble area and other benthos to a mapped area. The photographs not only allowed speedy collection of data in the field, but also provided a permanent record of the transect line, which is useful for long-term monitoring of growth, mortality and recruitment.
Figure 1: Typical photo quadrate analysis
1 . 7 Qualitative assessment
Qualitative assessment of the reef or lagoon is based on visual observation by snorkeling and then comparing the result with underwater photos and aerial photographs.
Annex: Methodology - Page 3 1 . 8 P e r m a n e n t Photo Quadrats
This method involves taking still photographs of a fixed quadrat that are analyzed in the lab. It is useful to determine temporal change in shallow macrobenthos communities. Permanent photo-quadrats can also complement LITs and are suitable for small-scale questions and to follow the fate of individual colonies. Detailed temporal change can be determined for individual corals for biological condition, growth, mortality and recruitment. Data can be used to estimate percent cover, species diversity, relative abundance, density and size. Percentage cover of target organisms can be determined in the lab by either point sample methods by placing a grid cover the quadrat or by digitizing the image (digitizing is more expensive, time-consuming, requires special software and expertise). The precision depends on the apparatus used and the ability to take photo from exactly the same spot as well as observer differences for analysis.
On each designated Impact Sites squares of 50x50cm side length are placed randomly along the coral patches in about 1,5m depth. Still photos are taken and analyzed using the software CPCe 3.4 (Kohler and Gill 2006) with an equally spaced grid overlaid in 10 columns and 10 rows (100 points) per 50x50cm quadrat. Substrate categories are recorded and described. Statistical analysis is then undertaken using PAST software (PAlaeontological Statistics ver. 1.90, Øyvind Hammer).
All quadrats at the survey sites are permanently marked with square plastic markers for further monitoring studies. In addition, when possible, sub-surface buoys are installed at each Site close to the quadrats.
1 . 9 Reef fish Visual Census
Under water counts of reef fishes or underwater visual census (UVC) method is used to assess the fish population at an Impact Site and a Control Site. Visual counts appear to give reasonably reliable results provided that they are applied to fish that are non-cryptic and either diurnally active or at least evident by day. In this method, the surveyor swims along the transect paths above the reef, counting fish that were observed within 1,5m either side of the transect and above up to the water column. The same transects line as for the Visual Quadrat survey is normally utilized to carry out the fish census. Fish are counted along the 20 m transect path (that is in a belt of 1.5 m on either side and up to the water surface). To count the fish, the surveyor swims slowly along, counting fishes that are seen within the defined band transect, 20m long by 3m wide (i.e. one with a total area of 60m²). All fish encountered are recorded at least up to family level, some up to genus and species level, noted on the underwater slate immediately after they are seen. Counting any fish more than once is avoided by training and experience. Speed at which the path swum is controlled so as to standardize the efficiency of search. If the surveyor swims too fast it is easy to miss fish, especially of smaller species, that may be temporarily obscured by corals or rock or be taking shelter. Experience shows that the slower the surveyor swims, more fish that is recorded up to a point. However, the highest number recorded by moving along very slowly may actually be an over estimate of fish density. Hence it is necessary to standardize swimming speed to a slow but not too slow pace. The standard speed of swimming practiced is at a mean rate of 8m a minute. For results, only the most abundant fish families are taken into account, each representing one of the following functional groups: herbivores (Acanthuridae, Scaridae), omnivores (selected Labridae), corallivores (Chaetodontodae) as well as habitat specialists (Pomacentridae).
1 . 1 0 Marine Water Quality
One of the main environmental components that is affected by implementing a number of projects in Maldives is the marine water quality. Water quality is assessed during the field trip by collecting samples and testing them at National Health Laboratory. Water quality is
Annex: Methodology - Page 4 assessed from multiple locations depending on the project. The locations, frequency and parameters to be monitored are given in the EIA report.
1 . 1 1 Coastal environment
1 . 1 2 Shoreline and vegetation line mapping
The island’s shore line and vegetation lines are mapped during low, high and mid tides using a handheld GPS assisted by aerial photos. The data is then entered in to a GIS database and maps are generated.
1 . 1 2 . 1 Coastal structures mapping
Similar to the island’s shore line and vegetation lines, all the coastal infrastructures such as groynes, sea walls, revetments, offshore and near shore breakwaters are mapped using a handheld GPS assisted by aerial photos. The data is then entered in to a GIS database and maps are generated.
1 . 1 2 . 2 Erosion and Accretion areas mapping
Areas where severe erosion and accretion occurring are mapped using a handheld GPS. The data is then entered in to a GIS database and maps are generated and compared with previous available maps and satellite photos.
1 . 1 2 . 3 Beach Profiles
Dumpy levels were also used to survey around selected locations around the island and beach profiles were generated from these data. The location along the which the beach profiles were taken was marked using a GPS for future monitoring. When selecting locations, a permanent structure or object such as a building corner, larger mature tree or any other similar benchmark were identified for future reference. The final beach profiles are corrected to MSL and graphs developed.
1 . 1 2 . 4 Drogues and currents
Nearshore currents in the lagoon or reef were measured by deploying a handheld GPS in a watertight casing with a fin attached at the bottom. The GPS is deployed for a period of minimum 15 minutes during which time its displacement from the original position are recorded as a line. After 15 minutes, it is removed and deployed at another location. Once the data is collected, currents in a particular area is calculated by measuring the distance it has travelled by 15 minutes.
1 . 1 3 Terrestrial environment
1 . 1 3 . 1 Terrestrial floral survey
The baseline terrestrial environment of the project location is studied in detail by counting trees existing in the area, and gathering information available from island office or from other available sources. The survey concentrates on identifying vegetation types, their abundance and occurrence in a given area. The methods used to assess the tree types and abundance are using line transects. A measuring tape is used to set up the transect line which is selected randomly from within the project boundary. The surveyor measures and records the type of trees and their average heights. Average heights are estimated and so there is a greater degree of error in estimating the tree heights. The results are then tabulated to calculate the
Annex: Methodology - Page 5 percentage of different trees. In addition, records from island office / resort or other sources are also used to cross check the figures.
1 . 1 3 . 2 Terrestrial faunal survey
In depth faunal survey is not assessed but the types of fauna encountered during the floral transect is identified and recorded. Focus in given on specific fauna such as turtles, fruit bats, sea birds and other sensitive birds. Birds and their habitation patterns are also observed and recorded during the survey.
1 . 1 3 . 3 Ground Water Assessment
Groundwater quality is assessed by collecting samples from given locations selected randomly or from available points within the island using YSI 6820 multi parameter handheld water quality meter. In addition, water quality is also tested at the National Health Laboratory.
1 . 1 4 Coastal Environment
Data collected on coastal environment includes beach profiles, existing coastal structures (sea walls, breakwaters, groyns etc.), beach composition, beach width, shore line and vegetation line. All beach profile locations are marked on GPS maps and their geographical coordinates are marked on a map. Beach profiles are taken as baseline data to make comparisons during monitoring programme so that any changes resulting from the coastal or any other component of a project can be assessed accurately. Beach profiles are measured using auto levels, GPS and a staff.
1 . 1 5 B a t h y m e t r y
Bathymetric survey are undertaken in the lagoon or reef using Echosounder attached to a boat. The levels are then corrected for mean sea level and represented in a map. Bathymetric maps provide accurate estimates of depths in a particular lagoon or a reef.
1 . 1 6 Aerial photos
Aerials photos provide useful information such as assisting the analysis of marine environment, identifying wave patterns and changes to shoreline and also vulnerable areas of the island for all kinds of projects. Aerial photos are purchased from DigitalGlobe.
1 . 1 7 Available long term weather data
Long term available weather data is obtained from the nearest weather station to a project in Maldives, which is based in Male’ International Airport (Male’ atoll), Hanimaadhoo (Haa Dhaal Atoll), Kaadehdhoo (Gaaf Dhaal atoll and Gan island in Seenu atoll . These data sets are used to develop a regional model in ArcGIS to assess the vulnerable areas of the island or any other project during both monsoons, thus helping the EIA team to assess the vulnerable areas of the island for erosion and various other weather related issues.
Annex: Methodology - Page 6 EIA for the Installation of an Incinerator at Kulhudhuffushi, Haa Dhaalu Atoll, Maldives
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24 Annex: EIA submission letter from Atoll Council
Prepared by Water Solutions Pvt. Ltd, February 2020 Page 77 P3'? Water Solutions Pvt. Ltd Reg No: C-34412W5 M. Niyadhurumaage,4h Floor, Alimas Magu, Male', Maldives
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Tel: (960) 334 1643, Fax: (960) 333 1643 www.water-solutions.biz; [email protected] EIA for the Installation of an Incinerator at Kulhudhuffushi, Haa Dhaalu Atoll, Maldives
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25 Annex: Stakeholder Meeting Attendees
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26 Annex: Work Schedule
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EIA for the Installation of an Incinerator at Kulhudhuffushi, Haa Dhaalu Atoll, Maldives
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27 Annex: MWSC letter for unavailability of water testing
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28 Comments from NDMA
Prepared by Water Solutions Pvt. Ltd, February 2020 Page 85 a
National Disaster Management Authority ޓިރޯތޮއ ްޓްނަމްޖޭނެމ ރަޓްސާޒިޑ ްލަނަޝޭނ ، G. Rihijehi koshi, Ameenee Magu, Malé, Maldives ގ.ރިހިޖެހިކޮށި އަމނ މަގު، މާލެ، ދިވެހިރާއްޖެ
General comment from NDMA for Environment Impact Assessment scoping/stakeholder meetings.
The National Disaster Management Authority advices and encourages proponents and consultants working on development projects to carry out a study to identify, predict and evaluate hazard impacts associated with a new development or the extension of an existing facility (from existing hazards as well as those which may result from the project).
This is achieved through an assessment of the hazards that are likely to affect or result from the project and an assessment of the project’s vulnerability and risk of loss from hazards.
NDMA believes that Hazard impact assessment is an integral component of and extension to the environmental review process and environmental impact assessment in that it encourages explicit consideration and mitigation of hazard risk.
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Hazard1
Hazard: A process, phenomenon or human activity that may cause loss of life, injury or other health impacts, property damage, social and economic disruption or environmental degradation.
Annotations: Hazards may be natural, anthropogenic or socio-natural in origin. Natural hazards are predominantly associated with natural processes and phenomena. Anthropogenic hazards, or human-induced hazards, are induced entirely or predominantly by human activities and choices. This term does not include the occurrence or risk of armed conflicts and other situations of social instability or tension which are subject to international humanitarian law and national legislation. Several hazards are socio-natural, in that they are associated with a combination of natural and anthropogenic factors, including environmental degradation and climate change.
Hazards may be single, sequential or combined in their origin and effects. Each hazard is characterized by its location, intensity or magnitude, frequency and probability. Biological hazards are also defined by their infectiousness or toxicity, or other characteristics of the pathogen such as dose-response, incubation period, case fatality rate and estimation of the pathogen for transmission.
Multi-hazard means (1) the selection of multiple major hazards that the country faces, and (2) the specific contexts where hazardous events may occur simultaneously, cascading or cumulatively over time, and taking into account the potential interrelated effects.
Hazards include (as mentioned in the Sendai Framework for Disaster Risk Reduction 2015-2030, and listed in alphabetical order) biological, environmental, geological, hydro-meteorological and technological processes and phenomena.
1 United Nations office of Disaster Risk Reduction, UNDRR Terminologies: https://www.unisdr.org/we/inform/terminology#letter-h 1/2 :ާޙްފަޞ
@ndmamv /NDMAmv www.ndma.gov.mv [email protected] +960 3333456
Biological hazards are of organic origin or conveyed by biological vectors, including pathogenic microorganisms, toxins and bioactive substances. Examples are bacteria, viruses or parasites, as well as venomous wildlife and insects, poisonous plants and mosquitoes carrying disease-causing agents.
Environmental hazards may include chemical, natural and biological hazards. They can be created by environmental degradation or physical or chemical pollution in the air, water and soil. However, many of the processes and phenomena that fall into this category may be termed drivers of hazard and risk rather than hazards in themselves, such as soil degradation, deforestation, loss of biodiversity, salinization and sea-level rise.
Geological or geophysical hazards originate from internal earth processes. Examples are earthquakes, volcanic activity and emissions, and related geophysical processes such as mass movements, landslides, rockslides, surface collapses and debris or mud flows. Hydro-meteorological factors are important contributors to some of these processes. Tsunamis are difficult to categorize: although they are triggered by undersea earthquakes and other geological events, they essentially become an oceanic process that is manifested as a coastal water-related hazard.
Hydro-meteorological hazards are of atmospheric, hydrological or oceanographic origin. Examples are tropical cyclones (also known as typhoons and hurricanes); floods, including flash floods; drought; heatwaves and cold spells; and coastal storm surges. Hydro-meteorological conditions may also be a factor in other hazards such as landslides, wildland fires, locust plagues, epidemics and in the transport and dispersal of toxic substances and volcanic eruption material.
Technological hazards originate from technological or industrial conditions, dangerous procedures, infrastructure failures or specific human activities. Examples include industrial pollution, nuclear radiation, toxic wastes, dam failures, transport accidents, factory explosions, fires and chemical spills. Technological hazards also may arise directly as a result of the impacts of a natural hazard event.
2/2 :ާޙްފަޞ
@ndmamv /NDMAmv www.ndma.gov.mv [email protected] +960 3333456 EIA for the Installation of an Incinerator at Kulhudhuffushi, Haa Dhaalu Atoll, Maldives
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29 Letter Sent To Maldives Land Survey Authority
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Yumin Naseem
Fuvahmulah Incinerator EIA Consultation
Juma Ahmed
Dear Sir/Madam,
Find attached below the project brief for Fuvahmulah Incinerator Installation EIA and a letter requesting for a consultation meeting.
-- Regards, Juma Ahmed Environmental Intern
Water Solutions Pvt. Ltd. 4th floor, M. Niyadhurumaage, Alimas Magu, Male', Maldives Mobile: (960)7951559 Tel: (960)3341643 Fax : (960)3331643 E-mail: [email protected] Website: www.water-solutions.biz
2 attachments 2019-12-16 Project Brief Fuvahmulah Incineration Installation EIA.pdf 302K 2020-01-27 WS-LTR-019 - Fuvahmulah Incinerator EIA Stakeholder - Land Survey Authority.pdf 536K
https://mail.google.com/mail/u/0?ik=3f5f371243&view=pt&search=all&permmsgid=msg-f%3A1656860774784676581&simpl=msg-f%3A165686077478… 1/1 EIA for the Installation of an Incinerator at Kulhudhuffushi, Haa Dhaalu Atoll, Maldives
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30 Letter sent to Health Protection Agency
Prepared by Water Solutions Pvt. Ltd, February 2020 Page 89 2/5/2020 Water Solutions Mail - Fuvahmulah Incinerator EIA Consultation
Yumin Naseem
Fuvahmulah Incinerator EIA Consultation 1 message
Juma Ahmed
Dear Sir/Madam,
Find attached below the project brief for Fuvahmulah Incinerator Installation EIA and a letter requesting for a consultation meeting.
-- Regards, Juma Ahmed Environmental Intern
Water Solutions Pvt. Ltd. 4th floor, M. Niyadhurumaage, Alimas Magu, Male', Maldives Mobile: (960)7951559 Tel: (960)3341643 Fax : (960)3331643 E-mail: [email protected] Website: www.water-solutions.biz
2 attachments 2019-12-16 Project Brief Fuvahmulah Incineration Installation EIA.pdf 302K 2020-01-27 WS-LTR-018 - Fuvahmulah Incinerator EIA Stakeholder - HPA.pdf 463K
https://mail.google.com/mail/u/0?ik=3f5f371243&view=pt&search=all&permthid=thread-f%3A1656861529037129101&simpl=msg-f%3A165686152903… 1/1 EIA for the Installation of an Incinerator at Kulhudhuffushi, Haa Dhaalu Atoll, Maldives
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31 Site Plan
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