Ebeye Solid Waste Management Project (RRP RMI 53082)
Initial Environmental Examination
Project Number: 53082-001 November 2020
Republic of the Marshall Islands: Ebeye Solid Waste Management Project
Prepared by the Ministry of Works, Infrastructure, and Utilities (MWIU) for the Asian Development Bank.
The initial environmental examination is a document of the borrower. The views expressed herein do not necessarily represent those of ADB’s, Directors, Management, or staff, and may be preliminary in nature. Your attention is directed to the “terms of use” section of this website.
In preparing any country program or strategy, financing any project, or by making any designation of or reference to a particular territory or geographic area in this document, the Asian Development Bank does not intend to make any judgments as to the legal or other status of any territory or area.
ABBREVIATIONS
3R – Reduce, Reuse, and Recycle (waste management hierarchy) ADB – Asian Development Bank AFD – French Development Agency (“Agence française de développement”) APC – Air Pollution Control CBO – Community Based Organization CDL – Container Deposit Legislation CEMS – Continuous Emission Monitoring System CEMP – Construction Environmental Management Plan CO2-eq. – Carbon Dioxide equivalents dscm – Dry Standard Cubic Meter EIA – Environmental Impact assessment EMP – Environmental Management Plan EPA – Environmental Protection Authority (RMI) EPR – Extended Producer Responsibility ENSO – El Niño Southern Oscillation ESWMP – Ebeye Solid Waste Management Project ETOSS – Engineering, Technical and Operational Support Services (US Army) GDP – Gross Domestic Product GEF-PAS – Global Environment Fund - Pacific Alliance for Sustainability GHG – Greenhouse Gases GRM – Grievance Redress Mechanism HSP – Health and Safety Plan HCW – Healthcare Waste HCWM – Healthcare Waste Management IEE – Initial Environmental Examination J-PRISM – Japanese - Promotion of Regional Initiatives on Solid Waste Management in the Pacific Island Countries JICA – Japan International Cooperation Agency KADA – Kwajalein Atoll Development Authority KAJUR – Kwajalein Atoll Joint Utilities Resources Inc. KALGOV – Kwajalein Atoll Local Government MAWC – Majuro Atoll Waste Company MEC – Marshalls Energy Company Inc. mg – Milligram MSW – Municipal Solid Waste MWIU – Ministry of Works, Infrastructure and Utilities, RMI NDC – Nationally Determined Contribution NEPA – National Environmental Protection Act 1984 ng – nanogram NGO – Non-Governmental Organization O&M – Operation & Maintenance OH&S – Occupational Health and Safety PacWaste – Pacific Hazardous Waste Management Project (SPREP) PIU – Project Implementation Unit POP – Persistent Organic Pollutant PPE – Personal Protective Equipment ii
ppmv – Part Per Million by Volume PRF – Project Readiness Financing RDF – Refuse Derived Fuel RMI – Republic of the Marshall Islands RP – Resettlement Plan SCC – Secondary Combustion Chamber SPC – Secretariat of the Pacific Community SPREP – Secretariat of the Pacific Regional Environment Program SPS – Safeguards Policy Statement, 2009 SWM – Solid Waste Management tpd (or tpy) – Tons per day (or year) USEPA – United States Environmental Protection Agency WHO – World Health Organization WMO – Waste Management Officer WtE – Waste to Energy
WEIGHTS AND MEASURES
dB – decibels ha – hectare km – kilometer km2 – square kilometer m – meter 2 m – square meter 3 m – cubic meter m3/d – cubic meters per day m3/s – cubic meters per second mg/m3 – milligrams per cubic meter mg/dscm – milligrams per dry standard cubic meter mm – millimeter ppmv – part per million by volume. % – percentage
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CONTENTS ABBREVIATIONS EXECUTIVE SUMMARY ...... 5 I. INTRODUCTION ...... 8 A. Background and rationale ...... 9 II. PROJECT DESCRIPTION ...... 12 A. Landfill closure operations ...... 14 B. Thermal treatment and disposal of residues ...... 14 1. Waste quantity and characteristics...... 15 2. Site layout and preparation ...... 15 3. Waste reception and Feed system ...... 17 4. The Thermal Plant ...... 18 III. POLICY, LEGAL AND ADMINISTRATION FRAMEWORK ...... 29 A. National and Local Legal Framework ...... 29 1. National Environmental Framework ...... 29 2. International Conventions and Treaties ...... 30 3. ADB Safeguard Policy ...... 31 IV. DESCRIPTION OF ENVIRONMENT ...... 32 A. Physical Environment ...... 32 1. Climate ...... 32 2. Climate Change ...... 32 3. Geology and Geomorphology ...... 36 4. Soils ...... 37 5. Freshwater Resources ...... 37 6. Marine Water Quality ...... 37 7. Air Quality ...... 37 B. Ecological Environment ...... 37 1. Terrestrial Flora and Fauna ...... 37 2. Marine Flora and Fauna ...... 38 3. Threatened, Rare, or Protected Species ...... 38 C. Social Environment ...... 38 4. Socioeconomic Environment ...... 38 5. Population ...... 39 6. Ethnography ...... 40 vii
7. Land Ownership and Use ...... 40 8. Education ...... 40 9. Poverty ...... 41 10. Cultural and Traditional Features ...... 41 11. Noise ...... 41 12. Traffic ...... 42 13. Public Health ...... 42 V. ANALYSIS OF ALTERNATIVES ...... 45 A. No Project Alternative ...... 45 B. Project Alternatives - Discussion of Alternative Solutions ...... 45 1. Waste Treatment and Disposal ...... 45 2. Considered Approaches to Waste Treatment and Disposal ...... 45 3. Treatment at the U.S. Army Garrison - Kwajalein Atoll ...... 45 4. Transport of Ebeye Waste to the Proposed Majuro Incinerator ...... 46 5. Less Viable Options ...... 48 6. Thermal Treatment and Disposal of Residues ...... 48 VI. ANTICIPATED ENVIRONMENTAL AND SOCIAL IMPACTS ...... 50 AND MITIGATION MEASURES ...... 50 A. Design and Pre-construction Impacts ...... 50 1. Impacts on Physical Resources ...... 50 2. Impacts on Ecological Resources ...... 51 3. Impacts on Socioeconomic Resources ...... 51 B. Construction Impacts ...... 52 1. Impacts on Physical Resources ...... 52 2. Impacts on Ecological Resources ...... 52 3. Impacts on Socioeconomic Resources ...... 52 C. Operational Impacts ...... 53 1. Impacts on Physical Resources ...... 53 2. Impacts on Ecological Resources ...... 54 3. Impacts on Socio-economic Resources ...... 54 VII. INFORMATION DISCLOSURE AND PUBLIC CONSULTATIONS ...... 55 A. Legislative Framework for Public Consultation ...... 55 B. Public Consultation Activities ...... 55 C. Information Disclosure ...... 55 vii
VIII. GRIEVANCE REDRESS MECHANISM ...... 56 A. Objective ...... 57 B. Scope ...... 57 C. Principles ...... 57 D. Confidentiality ...... 57 E. Procedures ...... 57 (i) Date ...... 58 (ii) Manner in which the grievance claim was received (phone, email, letter, in-person etc.) ...... 58 (iii) Name of the person who received the grievance claim ...... 58 (iv) Summary of the grievance claim ...... 58 (v) Name and contact details of the claimant/s ...... 58 F. Communication of the GRM ...... 59 G. Resources ...... 59 IX. ENVIRONMENTAL MANAGEMENT PLAN ...... 60 A. Introduction ...... 60 B. Institutional Arrangements ...... 60 1. Institutional Arrangements, Roles and Responsibilities ...... 60 2. Project Implementation Unit ...... Error! Bookmark not defined. 3. Construction Contractors ...... 60 4. RMIEPA ...... 60 C. Environmental Mitigations and Monitoring Matrix ...... 63 X. MONITORING AND REPORTING ...... 79 XI. CONCLUSION AND RECOMMENDATIONS ...... 80 XII. BIBLOGRAPHY ...... 25 XIII. Annex 1: Summary of Consultations ...... 25
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TABLES
TABLE 1. FEED STREAM TO A THERMAL UNIT ...... 15 TABLE 2: MEASURED EMISSIONS FOR A PENNRAM ONE TON/HOUR UNIT IN EQUATORIAL GUINEA...... 22 TABLE 5: SUMMARY OF ENVIRONMENTAL MANAGEMENT RESPONSIBILITIES ...... 61 TABLE 6: ENVIRONMENTAL MITIGATION AND MONITORING PLAN FOR THE EBEYE SOLID WASTE MANAGEMENT PROGRAM – INCINERATOR ...... 64 TABLE 7: ASSOCIATED WORKS AT LANDFILL PRIOR TO INCINERATOR INSTALLATION (LANDFILL CLOSURE AND SEA WALL CONSTRUCTION) ...... 73
FIGURES
FIGURE 1: EBEYE LOCATION MAP ...... 8 FIGURE 2: LOCATION OF SOLID WASTE DISPOSAL AREA IN EBEYE ...... 10 FIGURE 3: AERIAL VIEW OF SOLID WASTE DISPOSAL AREA ...... 10 FIGURE 4: A ONE-TON-PER-HOUR THERMAL PLANT ...... 16 FIGURE 5: PRIMARY COMBUSTION CHAMBER (ABOVE) ...... 17 FIGURE 6: FEED SYSTEM (AT LEFT), THE PRIMARY COMBUSTION CHAMBER (AT RIGHT) ...... 19 FIGURE 7: WET BOTTOM ASH CONVEYOR ...... 19 FIGURE 8: AVERAGE MEAN TEMPERATURE AT KWAJALEIN ...... 32 FIGURE 9: KWAJALEIN ANNUAL RAINFALL ...... 32 FIGURE 9: KWAJALEIN ANNUAL RAINFALL ...... 33 FIGURE 10: ENSO EVENTS AND IMPACTS ON RAINFALL AND TEMPERATURE ...... 35 FIGURE 11: PACIFIC NORTH EQUATORIAL CURRENT (NEC) ...... 36 FIGURE 12: KEY NATURAL AND HUMAN INDUCED HAZARDS ...... 39 FIGURE 13: GOALS OF THE NATIONAL HEALTH STRATEGY 2012-2014 ...... 42 FIGURE 14: EBEYE SOLID WASTE FACILITY CONDITIONS ...... 43 FIGURE 15: EBEYE WASTE FACILITY LOCATION ...... 44 FIGURE 16: THE 2019 REFURBISHMENT OF THE KWAJALEIN INCINERATOR ...... 46
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EXECUTIVE SUMMARY
The Republic of Marshall Islands (RMI) government has requested assistance from the Asian Development Bank for the proposed Ebeye Solid Waste Management Project. The project will upgrade the waste disposal site and recycling facility and improve the coverage and sustainability of the integrated solid waste management service delivery in Ebeye, thereby protecting public health and the environment. ADB’s assistance through the proposed project is critical to ensure proper management of waste, particularly infectious medical waste, and prevent the transmission of the coronavirus disease (COVID-19). The Project has three outputs: (i) a high-temperature incinerator constructed, and waste disposal site and recycling facility upgraded; (ii) municipal solid waste collection, transport, and disposal operations improved; and (iii) institutional capacity to sustain SWM service delivery and local engagement strengthened. The project is aligned with the following impact: efficient, effective, resilient, sustainable, and affordable services and facilities that promote sustainable economic growth provided. The Project executive agency is the Ministry of Finance, Banking, and Postal Services (MOF), and the implementing agency is the Ministry of Works, Infrastructure, and Utilities (MWIU).
This initial environmental examination (IEE) presents the potential environmental impacts and appropriate mitigation for the proposed project. The IEE has been prepared in accordance with the requirements of the Asian Development Bank (ADB) Safeguard Policy Statement 2009 (SPS) and conforms to environmental assessment requirements as defined in the RMI National Environmental Protection Act 1984 (NEPA). Chapter 1 of NEPA contains a set of regulations for protection of surface and marine waters, air quality, and managing of potential impacts from earth works, sanitation systems, waste and new infrastructure development. These regulations provide the framework for protection of resources and environmentally sustainable development in Ebeye and are directly applicable to this project.
Background. Ebeye is an islet in the Kwajalein Atoll with a significantly altered terrestrial environment, consisting almost entirely of built environment. The solid waste management facility (SWM) is located at the northern end of the island and occupies an area of approximately 5.3 acres (2 ha). The site is adjacent to, or partially encroaching, on the reef flat. Open leachate filled pits within the site are seen to be tidally influenced, showing a significant hydraulic connection between the site and open sea to the west. The mixed waste is dumped in random piles and eventually burned. There are no burial cells or trenches at the site, and no compaction or covering of trash with fill material. Large amounts of waste oil are stored and require disposal. Given that there are outbreaks of dengue fever on the island, it seems likely that water accumulates in these discarded materials, allowing for the aedes mosquito to breed. This mosquito breeding could take place both in waste at the solid waste facility or in uncollected trash. A national emergency was declared in 2017 due to mosquito borne diseases1. In 2019, there was an outbreak of dengue fever.
Project description: The project will develop the introduction of an integrated waste management system for Solid Waste, Medical Waste and Waste Oil. The project will strengthen Municipal Solid Waste (MSW) collection, transportation, and landfill operations by the introduction of 3R Concept (Reduce, Reuse, Recycle); the introduction of high-temperature incinerator, by reducing the amount of waste at landfill, safely processing medical waste and investigate revenue generation for sustainability and community’s willingness to pay for services. Note - the terms incinerator and thermal plant may be used interchangeability throughout the document. Proposed
1 For Hepatitis A and the ZIKA virus, see file:///C:/Users/pbisb/Documents/2020%20Marshall%20Islands/ Background/Dengue%20State%20of%20Health%20Emergency.pdf
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works for the SWM facility comprises 2 major components of (a) landfill closure operations and (b) construction of an incinerator. In more detail, civil works will comprise of the following: (i) A bulldozer to stack the existing waste in one part of the solid waste facility with the waste to be covered in accordance with the RMI SWM regulations; (ii) Sea wall construction; and (iii) The installation of a thermal treatment unit that: (a) will process 9–13 tons of waste per day and expected to operate at least for 7,000 hours every year. The system will operate 24 hours per day, seven days per week; (b) will be built on a concrete foundation and housed under a roof with open sides. (c) will ensure bottom ash, after confirmation that it is classified as inert by the local EPA will be disposed in an organized manner within the site with a cover material daily for dust control
Categorization. The project's anticipated environmental impacts are classified as Category B under the SPS. Such projects are judged to be site-specific, have some adverse environmental impacts, but to a lesser degree, or significance, than those for category A projects. The IEE, and accompanying environmental management plans (EMPs), will be updated at the detailed design phase by the Project Implementation Unit (PIU) and supporting project implementation consultants responsible for implementing the project.
Assessment of impacts. The proposed works are assessed as having minimal and site-specific impacts on the local community and the significantly altered terrestrial environment which consists almost entirely of built environment. The near-shore marine environments, including water quality, have been negatively impacted by inadequate leachate collection and treatment, inadequate storm water management, and extensive litter. Project works will bring significant positive impacts to the Ebeye community with the improvements in the near field marine waters, storm water runoff, reduction in land fill waste, better operational control and disposal of solid waste. The emission of greenhouse gases would decrease by approximately 73 %. Public heath will also improve by the reduction in breeding habitat for Aedes mosquitoes and subsequent decrease in communicable disease transmission, a decrease in odor and improvements in visual amenity.
Climate change. Planning for future climate change scenario will help mitigate potential impacts to the project, vulnerable ecosystems, and quality of life indicators for Ebeye residents. Potential threats to solid waste management and associated public health benefits include: (i) Increased sea water inundation; (ii) Increased erosion and subsidence of coastal areas; (iii) Increased frequency of intense rainfall events, and subsequent flooding; and (iv) Increase in tropical cyclone intensity, though reduced frequency.
Environmental management plan. The PIU within the Ministry of Works, Infrastructure and Utilities (MWIU) and Kwajalein Atoll Local Government (KALGOV) will be responsible for setting up the environmental management system, consisting of inspection, monitoring, reporting, and initiating corrective actions or measures. Two EMPs have been prepared to cover the two major civil works components of landfill closure and seawalls and the thermal plant. These will be updated at the end of the detailed design and be forwarded onto the construction contractors. To ensure that contractors will comply with EMP provisions, the PIU will prepare and provide the following specification clauses for incorporation into the bidding procedures: (i) a list of environmental management requirements to be budgeted by the bidders in their proposals; (ii) environmental clauses for contractual terms and conditions, and (iii) the full IEE report for
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compliance. The PIU and contractors will each nominate qualified environment specialists to undertake environmental management activities and ensure effective EMP implementation. Implementation arrangements: The RMI Ministry of Finance, Banking, and Postal Services will be the executing agency and Ministry of Works, Infrastructure and Utilities (MWIU) will be the implementing agency for the project implementation. A project steering committee (PSC) will be established to provide strategic direction and guidance for detailed design and implementation of the project. A Project Implementation Unit (PIU) will be established within MWIU and KALGOV and will be responsible for the overall design and implementation of the project. Consultants will be recruited to assist the PIU implement the project. Overall responsibility for implementing the EMP rests with the PIU, which during design and construction will be supported by project implementation assistance consultants.
Information disclosure, consultation, and participation: Environmental information on the project was discussed with the general community and other key stakeholders. A summary of these consultations is attached in Annex 1. The IEE will be made available for review by interested stakeholders and the RMIEPA according to the provisions of the ADB Access to Information Policy, 2019, and by the requirements of the laws of the Republic of the Marshall Islands. The stakeholder consultation process disseminated information to the general public, project affected communities, and key environmental stakeholders. Information was provided on the scale and scope of the project, and the expected impacts and proposed mitigation measures, through consultation with government departments, local authorities, and the general public in meetings. The process also gathered information on relevant concerns of the local community for the project, so as to address these concerns in the project design and implementation stages. No significant environmental concerns were raised during consultations, and the local community anticipates the substantial benefits in solid waste management from the project.
Grievance redress mechanism. An effective and transparent channel for lodging complaints and grievances will be established. Public participation, consultation and information disclosure undertaken as part of the IEE process have discussed and addressed major community concerns. Continued public participation and consultation has been emphasized as a key component of successful Project implementation. As a result of this public participation and safeguard assessment during the initial stages of the project, major issues of grievance are not expected. However, unforeseen issues may occur. To settle such issues effectively, an effective and transparent channel for lodging complaints and grievances will be established as provided for in this IEE.
Conclusion and recommendations: The project is expected to bring significant positive impacts to the Ebeye community with the improvements in the near field marine waters, storm water runoff, reduction in landfill waste, better operational control and disposal of solid waste. Public heath will improve by the reduction in breeding habitat for Aedes mosquitoes, the decrease in odour and improvements in visual amenity. The potential environmental impacts arising from design, construction, operation and maintenance of the project will be minor, localized, and acceptable, with corrective actions and mitigation measures, as set out in the EMPs to be implemented. Key findings are summarized below: (i) Adverse environmental impacts will mainly be construction impacts, which are expected to be minimal for these land-based works. (ii) Climate change and vulnerability will be taken into consideration during final design and project implementation. Priority measures include 'climate proofing' for storm surge and long-term sea-level rise. This IEE, and accompanying EMPs, is considered sufficient to meet environmental safeguard requirements of ADB and the RMI, in respect to the management of solid waste in Ebeye.
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I. INTRODUCTION
1. This initial environmental examination (IEE) presents the potential environmental impacts and appropriate mitigation and enhancement measures for the implementation of the Ebeye Solid Waste Management Project (ESWMP), Republic of Marshall Islands (Figure 1). It provides an assessment of potential environmental benefits, potential adverse environmental impacts, and risks associated with the proposed solid waste management plan, and includes (i) a summary of the local, national, and international policies, standards, and guidelines; (ii) due diligence review of existing environmental impact assessments undertaken to meet local approval requirements; (iii) description of the project and anticipated environmental impacts and mitigations measures; (iv) information disclosure, consultation and participation, (v) a grievance redress mechanism, and (vi) and detailed environmental management plan (EMP) for solid waste management including an implementation schedule and performance indicators.
Figure 1: Ebeye location map
Source: USACOE Ebeye Infrastructure Survey (2010).
2. The IEE has been prepared in accordance with the requirements of the Asian Development Bank (ADB) Safeguard Policy Statement 2009 (SPS) and conforms to environmental assessment requirements defined in the RMI National Environmental Protection Act 1984 (NEPA) and RMI
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Environmental Protection Authority (RMIEPA) regulations and related guidelines. The project’s anticipated environmental impacts are classified as category B under the ADB SPS (2009).2
A. Background and rationale
3. The RMI located in the northern Pacific Ocean comprises 29 coral atolls and 5 coral islands and has a population of about 53,000 people. ADB classifies the RMI as a fragile and conflict- affected situation.3 The RMI is highly vulnerable to natural hazards and susceptible to climate change impacts. Unemployment is high and human development indicators are generally low. It is heavily dependent on external assistance, with annual grants averaging about 60% of gross domestic product, mostly from the United States (US). Marshallese citizens are allowed to live and work in the US without a visa under the RMI’s Compact of Free Association with the US and a significant portion of working age population leave RMI to pursue opportunities in the US. 4. As a result, the RMI has a younger population compared to the rest of the Pacific. Ebeye on Kwajalein Atoll is the second largest urban center in RMI and one of the most densely populated places in the world, with about 10,000 people living in an area of 36 hectares (over 32,000 people per square kilometer). With substantial migration to the US, the population in Ebeye has moderately increased at a rate of 0.4% per annum between 1999 and 2011.4 There is no airport on the island and most visitors access Ebeye through the US Army Garrison on Kwajalein Atoll. The US base is the major employer of the Ebeye residents as employment opportunities on Ebeye are very limited due to the lack of any industry. 5. The high population density in Ebeye creates urban and social challenges. With ADB’s ongoing support, residents in Ebeye are receiving improved water supply and sanitation services.5 However, municipal solid waste management (SWM) remains one of the atoll’s challenges. The outbreak of dengue fever in 2019 was linked to poor solid waste dumping, which highlights the urgency to address SWM in Ebeye.6 At present, with financial support from the donors, Kwajalein Atoll Local Government (KALGOV) is able to provide general waste collection services to its residents, which do not include medical and hazardous wastes. Around 8–12 tons of household waste per day are collected and transported to the dump site located in the northern end of the island (Figures 2 and 3). In 2018, KALGOV approved the Kwajalein Atoll Solid Waste Management Plan, which requires substantial investment to be implemented.
6. Due to the urgent need for improved solid waste management in Ebeye, the RMI government proposes to implement the Ebeye Solid Waste Management Project (the project). The project will support the establishment of a sustainable and integrated solid waste management for 1,200 households in Ebeye. Major outputs include: (i) maintenance of waste collection service; (ii) improvement of the disposal operation including potential waste volume reduction; and (iii) establishment of financially sustainable SWM system.
7. Ebeye has a significantly altered terrestrial environment, consisting mainly of built environment. The terrestrial and marine environment are negatively impacted by inadequate SWM collection and treatment. Inadequate storm water management leads to increase contaminated
2 As per the SPS a proposed project is classified as Category B if its potential adverse environmental impacts are less adverse than those of category A projects. These impacts are site-specific, few if any of them are irreversible, and in most cases mitigation measures can be designed more readily than for category A projects. An initial environmental examination is required. 3 ADB. Governance Issues: Fragile and Conflict-Affected Situations (FCAS). 4 RMI. 2012. The RMI 2011 Census of Population and Housing Summary and Highlights Only. Majuro. 5 ADB. Republic of Marshall Islands: Ebeye Water Supply and Sanitation Project. 6 Commander, US Pacific Fleet. Navy team helps Ebeye defend against mosquitoes.
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water losses to the marine environment and ponded water is a precursor to mosquito borne disease outbreaks. The visual amenity of the SWM disposal area is also poor. High population density entails urban and social challenges.
Figure 2: Location of solid waste disposal area in Ebeye
Figure 3: Aerial view of solid waste disposal area
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8. Waste collection and management vehicles and equipment operated by KALGOV are far from adequate, severely damaged, and often not functional. The short operating lifetime of such equipment is due to Ebeye’s harsh marine environment and lack of adequate and timely maintenance. Unavailability of replacement parts for existing equipment exacerbates the problem. To renew the equipment in a timely manner, KALGOV needs to develop and implement asset management with sufficient financing.
9. To encourage recycling and reduce littering, the administration of RMI has introduced a Container Disposal Legislation (CDL) system in Majuro, RMI’s capital city, in 2018.7 While the necessary law and regulations are already in place, in Ebeye, however, the CDL system is not yet operational there. Final steps, such as financial arrangements, procurement of recycling machines, provision of training to key officials, and awareness raising among citizens, are still to be undertaken. KALGOV is expected to play a key role in the expected implementation of the CDL system in Ebeye.
10. In response to these issues, KALGOV developed and approved the Kwajalein Atoll SWM Plan in 2018, which includes a five-year action plan for the period 2019 to 2023 and comprises four major actions: (i) enhancing waste reduction and recycling through the CDL program; (ii) managing and improving the current final disposal site; (iii) sustaining the operation and maintenance (O&M) of waste collection services; and (iv) improving financial sustainability of SWM services. These actions require substantial investment to be implemented. Further, given the scarcity of land available for a new dump site, more options need to be explored for solid waste disposal to reduce the waste volume and achieve sustainable and effective SWM.
11. COVID-19 outbreak and proper management of medical waste. ADB’s assistance through the proposed project is critical to ensure proper management of waste, particularly infectious medical waste, and prevent the transmission of the coronavirus disease (COVID-19) and other transferable diseases. Poor SWM can cause serious health issues. At the outbreak of dengue fever in 2019, the uncompacted dump site became one of the prime locations of mosquito breeding and exacerbated the local situation. While medical waste generated by the Ebeye hospital is currently segregated and managed by a contractor, safety standards for the handling and transportation of medical waste need to be improved. Improper management of infectious medical waste poses a risk of spreading transmissible diseases, such as COVID-19. To prevent the proliferation of vectors and the outbreak of transmissible diseases and to mitigate the public health risk, the introduction of an integrated waste management system including appropriate disposal of medical waste is critical.
7 The legal framework necessary to inaugurate CDL was set through the legislation of the StyrofoamTM Cups and Plates, and Plastic Products Prohibition, and Container Deposit (Amendment) Act 2018 in January 2018, and the CDL Regulations were promulgated in June 2018.
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II. PROJECT DESCRIPTION
12. The projects objectives are to introduce an integrated waste management system for Solid Waste, Medical Waste and Waste Oil for the atoll. The project will strengthen Municipal Solid Waste (MSW) collection, transportation, and landfill operations by the introduction of 3R Concept (Reduce, Reuse, Recycle); the introduction of a high-temperature incinerator, reducing the amount of waste at landfill, safely processing medical waste and ensuring revenue generation for sustainability and the community’s willingness to pay for services. The project outcomes will bring significant positive impacts to the Ebeye community with the improvements in the quality of marine waters, improvement in storm water runoff quality, reduction in land fill waste and better operational control and disposal of solid waste. Public heath will improve by the reduction in breeding habitat for Aedes mosquitoes, the decrease in odor and improvements in visual amenity.
13. Focusing on the integrated municipal solid waste management and aligned with the Kwajalein Atoll SWM Plan, the proposed project is expected to deliver the following three outputs:
14. Output 1: A high-temperature incinerator constructed, and waste disposal site and recycling facility upgraded. The project will accomplish the following: (i) Upgrade the existing dump site and construct a seawall along the site’s shoreline. The dump site will be converted to a managed landfill for installation and operation of the incinerator and disposal of the bottom ash and construction waste. Existing solid waste will be shaped into a mound and covered with a layer of material in accordance with the RMI SWM regulations. The seawall to be constructed in the western and northern part of the dump site will stop inundation and prevent solid waste from polluting the lagoon. (ii) Construct a high-temperature incinerator capable of burning 9–13 tons a day in the landfill site using a design–build–manage contract. The incinerator will process all the municipal solid waste in Ebeye and generate bottom ash. The contractor will be responsible for the performance of the incinerator and the training of the KALGOV staff. KALGOV will undertake the daily operation and the contractor will provide remote monitoring and management. In response to COVID-19, the project will ensure that the incinerator will process hazardous medical waste and menstrual waste properly. (iii) Construct a recycling facility house in the landfill site to store recycling equipment procured by KALGOV.
15. Output 2: Municipal solid waste collection, transport, and disposal operations improved. The project will (i) upgrade and replace vehicles and equipment for solid waste collection, transport, and disposal; and (ii) replace waste collection containers for more efficient operation. KALGOV will adopt cost-effective procurement to ensure the sustainability of vehicles and equipment, such as a multiyear maintenance and repair service agreement for the purchased equipment. In response to COVID-19, specific equipment and supplies will be procured in a timely manner for safe medical waste management, including waste classification, segregation, storage, transport, and disposal. The project will help Ebeye Hospital and its contractor strengthen the existing medical waste management system, starting from the period before construction until the operation of the incinerator, including the first 12 months of project implementation.
16. Output 3: Institutional capacity to sustain SWM service delivery and local engagement strengthened. The project will accomplish the following:
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(i) Improve the technical capacity of KALGOV, develop and implement a waste collection and transport plan,8 develop and implement an operation plan for the managed waste landfill, and formulate and implement an asset management plan for vehicles and equipment for waste management. The asset management plan will cover O&M of equipment and provisions to secure funding for O&M and capital equipment replacement, and build KALGOV’s capacity KALGOV to implement the CDL. (ii) Improve KALGOV’s financial sustainability to maintain the services. The project will develop and implement a gender-sensitive institutional reform plan for KALGOV, including actions to support women in leadership and/or technical positions, and help KALGOV develop and implement the SWM tariff framework. As practiced in many countries, an SMW tariff can be charged and collected with the electricity tariff, which exists in Ebeye and has a high collection ratio. (iii) Conduct a gender-sensitive public-awareness campaign on “reduce, reuse, recycle,” and increase public understanding of the importance of paying fees for sustainability.
17. In response to COVID-19, the project will start strengthening institutional capacities for proper handling and management of medical waste within the first 12 months of project implementation. The project will review the current medical waste management procedures, roles and responsibilities, and budget of Ebeye Hospital; develop new medical waste management procedures for the hospital; and design and implement training for the hospital staff and contractors who handle medical waste.
18. The project area is confined to the island of Ebeye and will be implemented over five years, it is expected to start in Jan 2021 and be completed by Dec 2027. The total project investment is $7.067 million (including taxes and duties). The executing agency for the project will be the RMI Ministry of Finance, Banking, and Postal Services and the implementing agency will be the MWIU. A project steering committee will provide oversight and a PIU will be established within MWIU and KALGOV.
19. Proposed works for the SWM facility comprises 2 major components of (a) landfill closure operations and (b) construction of an incinerator. In more detail, civil works will comprise of the following: a) A bulldozer or front-end loader to stack the existing waste in one part of the solid waste facility with the waste to be covered in accordance with the RMI SWM regulations; b) Sea wall construction; and c) The installation of a thermal treatment unit that: (i) will process 9–13 tons of waste per day and expected to operate at least for 7,000 hours every year. The system will operate 24 hours per day, seven days per week; (ii) will be built on a concrete foundation and housed under a roof with open sides; and (iii) will ensure bottom ash, after confirmation that it is classified as inert by the local EPA will be disposed in an organized manner within the site with a cover material for dust control
8 Collection operations to be reviewed include operational and safety procedures for collection workers. The plan covers disaster risk management, including measures to be taken in response to inundation and overtopping.
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A. Landfill closure operations
20. The proposed upgraded waste disposal site and recycling facility will involve undertaking civil works and construction activities. The facility will be located at the north end of Ebeye, where the existing dumpsite is located at present. The area will require some preparation, as the site is only slightly higher than the sea level and it is therefore in danger of inundation due to sea-level rise resulting from climate change. This will be addressed through site elevation using a seawall along the western and northern shorelines. The old waste accumulated on-site will be organized using a bulldozer or front-end loader. This will require shaping it into a mound in the best suited area of the site, presumably at the southern end. The waste will be covered with a layer of material accordance with the RMI SWM regulations. Old rusted equipment will also be moved to a permanent storage area.
21. A rainwater/ stormwater drainage system will also be installed to ensure that the site does not flood. The whole site will be enclosed by a fence with a gate for access, as well as emergency exit(s). This will keep unauthorized people and stray animals off the site. An office will be built close to the gate to record visitors to the site and keep records of waste deliveries. A roofed area on a concrete pad will be constructed for waste storage and sorting. A separate recycling facility will be located within the site.
B. Thermal treatment and disposal of residues
22. The preferred solution is the incineration of waste on Ebeye. This option would decrease the volume of waste/residues that have to be deposited on Ebeye, it would reduce the quantity of greenhouse gases emitted, and it would reduce the discharge of pollutants and odors. The most direct environmental benefits would be: (i) At present waste is dumped haphazardly within the site. There is frequent open burning of the waste, both intentional and unintentional. These fires are uncontrolled and a source of air pollution. The controlled burning of all solid waste from Ebeye in a high temperature incinerator will greatly reduce the release of pollutants to the atmosphere. The system would be in compliance with the regulatory requirements of the RMIEPA. (ii) The emission of greenhouse gases would be decreased by approximately 73%. (iii) The high temperature incinerator will allow for the destruction of infectious waste from Ebeye Hospital and waste oil from the Ebeye Island Power Station. (iv) The residues after incineration, the bottom ash, constitutes about 20% by weight of the feed, but it is only 7% of the feed by volume.9 (v) Environmental damage and nuisances would be greatly reduced by burning the waste. The thermal treatment of all waste would ensure that there is no rotting waste generating leachate and odors, no dumpsite fires, and no habitat for insects, rodents, and other vermin.
23. The expected expenses associated with burning the waste generated in Majuro are high. A similar system in Ebeye would be even less cost effective, as the waste quantities are smaller, so the treatments costs per ton or per household would be even higher. If the population, or local government, is unable to pay for the operation of a waste treatment plant, there will be eventually be problems in terms of inability to keep the facility maintained or to pay all operational costs. This is a situation that would result in a facility either not operating as intended or ceasing to operate altogether.
9 Adapted from Review of State-of-the-Art Waste-to-Energy Technologies by WSP Environmental Limited (2013).
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24. Therefore, it is vital that the proposed Waste Treatment Facility for Ebeye is affordable. This Feasibility Study endeavors to provide a system that offers good occupational health, safety, and environmental standards, whilst keeping operating and maintenance costs at a minimum. The system proposed for Majuro is costly as the thermal plant includes energy recovery to produce electricity. In the associated cost calculations, the revenues from the sale of electricity may just cover the additional costs of operating the waste-to-energy system, though that does not seem likely. The presence of the energy recovery system greatly increases the technical demands on those responsible for plant operation and maintenance.
1. Waste quantity and characteristics
25. The expected waste feed characteristics for the year 2030 can be found in 26. Table 1Error! Reference source not found..
Table 1. Feed stream to a thermal unit
Quantity LHV Quantity Waste Stream tons/year MJ/kg kg/hour a
Solid waste 9.3 54,7 673.4 Healthcare waste 15 8.8 1.3 Waste Oil 47 57 8.1 Total 682.8 a Based on 7,000 hours of operation per year.
27. It must be emphasized that the quantity of waste must be verified. If the quantity assumptions in this report are correct, a smaller model of the incinerator should be purchased, as the system would otherwise have to either: (i) compensate for the lack of waste feed by burning fuel, something that is very costly; or (ii) frequently shut down and wait for more waste to be delivered. Again, fuel would be required for the start-up and the frequent start-ups/ shutdowns will cause excessive thermal wear on the refractory bricks.
28. So, selecting a thermal plant sized for the correct thermal load and throughput capacity is essential.
2. Site layout and preparation
29. The Waste Treatment Facility would be located at the north end of Ebeye, where the dumpsite is located at present. The area would require some preparation and include the following features: (i) The site is only slightly higher than the sea level, it is therefore in danger of inundation due to sea-level rise resulting from climate change.10 It must be evaluated whether any sea walls or berms are required around the site. (ii) The old waste accumulated on-site will be organized using a bulldozer or front-end loader. This will require shaping it into a mound in the best suited area of the site, presumably at the southern end. The waste should be covered with a layer of material
10 ADB Project Concept Paper for Proposed Grant Marshall Islands, RMI: Ebeye Solid Waste Management Project (April 2020.)
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accordance with the RMI SWM regulations. It could be considered whether to plant grass or other vegetation. A plant cover will help prevent erosion. Judging from aerial photos, as well as from photos taken at ground level, about 15,000 m3 of old waste will have to be rearranged. This material has a high moisture content and is unsuitable to feed into the incinerator, over time, the biodegradable material will decay in the tropic climate. (iii) The possibility of removing all the old rusted equipment that has accumulated should be considered. Otherwise, it should be prepared for permanent storage at the disposal site. In this case, all fuel, oil and batteries should be removed from the old equipment. (iv) There must be a rainwater/ stormwater drainage system to ensure that the site is never flooded. (v) The whole site should be enclosed by a fence with a gate for access, as well as emergency exit(s). This will keep unauthorized people and stray animals off the site. (vi) There must be some form of office close to the gate. This spot will serve as office for controlling access to the site and making records of waste deliveries. (vii) A roofed area on a concrete pad for waste storage and sorting (viii) A thermal treatment unit on a concrete foundation and housed under a roof with open sides (Error! Reference source not found.). (ix) Thermal plant control room (Error! Reference source not found.) (x) A disposal site for the bottom ash (xi) Optionally, the site could include an overnight parking area for the compactor truck(s), as well as other KALGOV vehicles. There could be a workshop for maintenance of the thermal plant, vehicles, waste bins and other equipment. (xii) Storage tanks for fuel, waste oil and a connection to utilities.
Figure 4: A One-ton-per-hour Thermal Plant
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Figure 5: Primary combustion chamber (above) and feed ram on a 1 ton-per-hour Thermal Plant
Note: Picture supplied by Pennram.
3. Waste reception and Feed system
30. Waste arrivals will be logged by an operator, recording the vehicle’s ID, driver, waste quantity (e.g., full load, 2 m3, etc.), time and date. The waste will be unloaded on a concrete pad in a roofed area. From here workers will manually load the waste into wheeled carts that have a volume of 300 - 400 liters. There are several advantages to manually transferring the waste into carts: (i) this will create some employment; (ii) the workers will sort the waste, so that the waste fed to the thermal plant is relatively homogeneous. for example, a batch of wet waste will be distributed over several carts; (iii) glass should be removed where possible, otherwise it will gradually lead to build-up of clinker in the combustion chamber, a nuisance that increases the need for maintenance; (iv) aluminum cans can be removed for recycling; (v) any cans of paints or solvents should be removed; and (vi) to prevent pollution, batteries should not be fed to the thermal plant. If batteries are burnt in the system, this can lead to the emission of heavy metal pollutants to the atmosphere, and metals would also be in the ash residues, from where they could leach into the ground and eventually into the ocean.
31. The filled carts will be stored next to the thermal plants feed unit, so that they are readily available when needed. A sufficient number of carts will be supplied, so that all waste sorting can take place during the daytime.
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4. The Thermal Plant
32. The thermal plant would be designed to treat 9–13 tons of waste per day and expected to operate at least for 7,000 hours every year. The system will operate 24 hours per day, seven days per week. This manner of operating minimizes emissions to the atmosphere, wear on the refractory and the fuel consumption.
33. The system would be specified to: (i) be in full compliance with government environmental and safety regulations; (ii) treaty all municipal solid waste; (iii) handle infectious waste; (iv) burn waste oil from the KAJUR; (v) have a highly automated control system that accurately controls the temperature of the secondary chamber temperature to ensure the complete destruction of organic materials and other harmful substances. The control system also must include safety interlocks, alarms, and an automatic emergency shutdown procedure to assure the operator's safety, protect the environment and to avoid damage to the equipment; (vi) a mechanical waste feed system and automatic removal of bottom ash; and (vii) be manufactured from stainless steel.
34. Given the location, Ebeye has a salty environment. Salt acts as a corrosion agent, deteriorating metal, paint, and finishes. It is therefore recommended that all parts of the thermal unit be from stainless steel, to protect from corrosion. Financially, this increases the cost of the thermal unit by about 70% ($0.7 million to $1.2 million) but there are tremendous benefits in terms of the durability of the equipment and in reduced maintenance costs.
5. General
35. The thermal plant would consist of an automatic hydraulic loader, an automatic ash removal system, and the necessary instrumentation for 24-hour continuous operation. The destruction of waste takes place in two stages. The waste is fed into the primary combustion chamber by the automatic hydraulic loader. The primary chamber maintains starved-air (“sub-stoichiometric”) atmosphere at approximately 800OC under which conditions volatile hydrocarbon gases are driven from the waste. The residues from the waste will be ash with a very low content of carbons. The ash is automatically removed from the unit. The hydrocarbon containing gases flow from the primary chamber into the secondary combustion chamber. The secondary chamber would maintain an operating temperature that is always above the regulatory requirements. The combustion gases will be clean and will be emitted to the atmosphere through a stack. The individual elements of a thermal treatment plants are described in the following subsections.
6. Feed System
36. To ensure a clean waste combustion at all times, the incinerator must maintain control of the air directed into the unit and ensure there are no fugitive emissions. Therefore, all waste is fed into the combustion chamber through an airlock. The hydraulic loader operates in a fully automatic manner. Waste contained in small carts is unloaded into a feed hopper using a hydraulic lift system ( Error! Reference source not found.), where the yellow bin is tipping waste into the ram feeder). F rom the hopper, a ram pushes the waste through an airlock and into the first combustion chamber. The thermal plant is operated under a slight negative pressure, so there are no leaks of fumes from the system.
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7. Primary Combustion Chamber
37. As stated previously, the primary combustion operates at around 800OC and with a slightly negative pressure to prevent fugitive emissions. The chamber is lined with refractory brick that is about 23 cm thick (9”) and the hearth has three levels, ordered in downward steps toward the discharge end. Inside the chamber, two rams help move the waste through the combusting chamber, ensuring that the waste is rolled and stirred as it moves through the system, thereby, ensuring even combustion ( 38. Figure 6).
Figure 6: Feed System (at left), the Primary Combustion Chamber (at right) and the Secondary Combustion Chamber behind the upper work platform
Note: Picture supplied by Pennram.
Figure 7: Wet Bottom Ash Conveyor
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Note: Picture supplied by Pennram.
39. Combustion air is introduced from below to ensure even burning and a high level of burnout in the residues. The bottom ash drops into a water lock, from there a wet ash conveyor (Figure 7) will slowly drag the materials out, so that they are dewatered by the time they drop onto the receiving container. The container containing the bottom ash will be emptied at the disposal site.
8. Secondary Combustion System
40. The secondary combustion chamber (SCC) would be designed so that it maintains a temperature above the regulatory requirements whenever waste is being incinerated. Common operating temperatures would be above 850OC (Europe) or 1,600OF (USEPA). Any temperature in this range will ensure an excellent destruction of all hydrocarbons, assuming that the chamber is well designed, so that there is good mixing of the gases.
41. Here, the key parameter is very turbulent conditions that ensure that all hydrocarbon gases reach the desired temperature and are oxidized. In the SCC long residence times with poor mixing serve little purpose, as some pollutants will flow through the chamber without being heated sufficiently and coming into contact with oxygen.
42. This observation is made, as a shorter residence time in the SCC reduces the required volume of the chamber. Thereby reducing both capital and operating costs, the latter through lower fuel consumption. In a well-designed incinerator with good turbulence, a two second residence time, as opposed to one second, has no impact of the destruction of hydrocarbons, or the emission of pollutants in general.
43. Therefore, the SCC must be designed to ensure turbulent conditions. The flow of fuel and combustion air to the SCC must be well controlled to maintain the desired temperature and oxygen content.
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9. Flue Gas Discharge
44. Gases from the SCC will be discharged to the atmosphere through a stack. There are quite high radiant heat loses in the stack, so the gases will be emitted at around 600-700OC.
10. Bottom Ash Disposal
45. The thermal unit can be expected to generate 1,000 tons of solid residues (bottom ash) annually. It is recommended that the existing dumpsite be re-organization as described under “Site Layout and Preparation.” The size of the site should allow for the bottom ash to be stored there for many years to come.
46. It is recommended that the bottom ash be tested to ascertain whether there is any leaching of pollutants. It can be expected that these numbers will be low, so that the bottom ash can be classified as inert by the local EPA. This would mean that these residues can be deposited within the site in an organized manner without requiring a liner or other measures to protect the environment. There is a likelihood that the EPA would request that some kind of cover material be used to cover the deposited bottom ash.
47. If the waste is well sorted prior to incineration, so that hazardous materials such as batteries are never fed to the thermal plant, the bottom ash could be approved as a material suited for use as backfill, especially if backfill materials are in short supply on Ebeye.
48. The density of bottom ash is around 1,500 kg/m3, so about 700 m3 of bottom ash would be produced annually. Over a 20-year period, about 14,000 m3 of bottom ash would be produced. If this is deposited in a 3-meter thick layer, an area of 5,000 m2 would be required, or about one-third of the total site area (1.6 hectares). Obviously, the bottom ash can be piled higher, and that would probably be what is required if some form of cover material is necessitated over the residues.
11. Air Emissions and Greenhouse Gases
49. The destruction of all generated waste in a thermal treatment plant greatly reduces the nuisances and pollution caused by the garbage. Only bottom ash will be deposited on the disposal site, so there will be no breeding grounds for insects or rodents. Likewise, the bottom ash is mostly or fully inert, thereby greatly decreasing both soil and water contamination.
12. Emission Data for a Pennram Incinerator
50. In 2015, emissions testing was undertaken on a 24 ton/day thermal plant built by Pennram that is operated by an oil company in Equatorial Guinea. This is a plant without an air pollution control system, so slightly smaller in design and capacity to the system proposed for Ebeye. At the time of the testing, the incinerator was burning a mixture of household solid waste and waste engine oil.
51. During the incinerator emissions testing, a continuous emission monitoring system (CEMS) measured the carbon monoxide (CO) and nitrogen oxides (NOX) emissions continuously. Manual sampling collections systems were used to analyze for particulate matter (dust), sulfur dioxide (S02) and two selected metals (Cd and Pb).11
11 Data from the PDF file “Emission Test 2200 redacted condensed for email” received from Pennram May 10, 2020.
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Table 2 gives the results of the emissions testing, as well as the testing method used to obtain the results.
Table 2: Measured Emissions for a Pennram One Ton/hour Unit in Equatorial Guinea
Testing Emission Test 40 CFR Part 60, Test Parameter Units Procedure Results Subpart AAAA Particulate Matter EPA 5 mg/dscm 25.2 24 Fugitive emissions Observation % n/a [2] 5 [1] CO EPA 10 ppmv 4.13 50 NOx EPA 7E ppmv 42.8 150
SO2 EPA 6/6C ppmv 1.28 30 HCl EPA 26A ppmv n/a 25 Cd EPA 9 mg/dscm 0.011 0.020 Pb EPA 9 mg/dscm 0.195 0.200 Hg EPA 9 mg/dscm n/a 0.080 Dioxins/Furans [3] EPA 23 ng/dscm n/a 13 Notes: 1. The requirement is “visible emissions for no more than 5 percent of hourly observation period.” 2. Not available, i.e., not measured. 3. The limits are numerically higher for the US standards, as the USA does not convert using toxicity equivalence factors to measure in terms of the most harmful dioxin.
52. The last column of Table 2lists the requirements set out in the US EPA’s New Source Performance Standards for New Small Municipal Waste Combustion Units.12 These regulations were issued in 2000, after it was found that the regulations governing all municipal waste combustion plants were too stringent for small facilities, as the air pollution control costs become excessive, making small facilities financially unsustainable. The Performance Standards apply to municipal waste combustion plants with a capacity between 35 and 250 tons per day. Any plant with a treatment capacity over 250 tons per day must follow the more stringent regulations governing Large Municipal Waste Combustors.13 The 2015 stack emissions report also confirms that the results are in accordance with the International Finance Corporation World Bank Group's Environmental, Health and Safety Guidelines for Waste Management Facilities.
53. The thermal plant proposed for Ebeye has a capacity that is less than 35 tons per day, so the Performance Standards for New Small Municipal Waste Combustion Units would not specifically apply if the unit was located within the USEPA’s jurisdiction. In the USA, the unit would be licensed by the local/ regional EPA office and this office would set the emission standards.
54. The IFC Environmental, Health, and Safety Guidelines : Environmental Air Emissions and Ambient Air Quality (2007)[1] apply to small combustion facilities designed to deliver electrical or mechanical power, steam, heat, or any combination of these, regardless of the fuel type, with a total, rated heat input capacity of between 3 Megawatt thermal (MWth) and 50 MWth. The incinerator to be purchased for Ebeye is rated at 1.7MWth and therefore does not trigger these IFC
The testing was undertaken by the Emissions and Source Testing Company (EST Co, LLC), a certified emissions monitoring firm based in Morgantown, WV, USA. 12 USEPA 40 CFR part 60, subpart AAAA (December 6, 2000). 13 USEPA 40 CFR Part 60 (Amended May 10, 2006).
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Guidelines.
55. The Directive (EU) 2015/2193 of the European Parliament and of the Council of 25 November 2015 on the limitation of emissions of certain pollutants into the air from medium combustion plants i.e. this Directive should apply to combustion plants, including a combination formed by two or more new medium combustion plants, with a total rated thermal input equal to or greater than 1 MW and less than 50 MW.
56. It is noted that “ the emission limit values set out in Annex II should not apply to medium combustion plants located in the Canary Islands, French Overseas Departments, the Azores and Madeira, because of the technical and logistical issues associated with such plants' isolated location. The Member States concerned should set emission limit values for such plants in order to reduce their emissions to air and the potential risks to human health and the environment.”
57. This note would also apply to the Marshall Islands and as such the recommended visual monitoring program as proposed will be undertaken.
13. Emission Standards for Ebeye
58. The testing of stack gases is very costly, especially in a remote location. So, for this small thermal unit, the recommendation is to avoid testing to the extent possible. In the past, there have been uncontrolled fires at the Ebeye dumpsite. Such fires, with low combustion temperatures, insufficient oxygen and the presence of plastics (and perhaps metals that can act as catalysts), will cause the formation of dioxins and furans.
59. So, using a thermal plant to treat the waste from Ebeye, rather than using the present dumpsite, will greatly reduce the emission of dioxins and furans. Therefore, it seems rather pointless to spend a large sum of money to determine the annual emissions of dioxins and furans from an incinerator.
60. A CEMS is costly with a price of around $250,000. A CEMS is very demanding in terms of operation and upkeep, there are considerable running costs and a capable technician is required. Less costly would be occasional testing, where the stack must be equipped with dedicated extraction plumbing, so that samples can be taken when desired. A handheld monitor would then allow to take samples and analyze for O2, CO, CO2, SO2, NOX, and hydrocarbons. Extraction plumbing would also have to be installed, if the incinerator is to undergo emissions testing during the commissioning stage or to obtain its operating license.
61. Safeguards undertakings to ensure incinerator performance include the inclusion of the US EPA’s New Source Performance Standards for New Small Municipal Waste Combustion Units (2000) in the bid documents. These air quality performance standards are listed in Table 2 of the IEE.
62. The BOT (Build Own Operate) arrangement of the contract will ensure that a skilled operator will be available for five years to assist capacity building and knowledge transfer to local staff in the operation and maintenance of the incinerator. The contractor will be able to access key operating parameters of the incinerator remotely. This will enable ongoing review of incinerator performance, maintenance requirements and troubleshooting to ensure optimal performance.
63. In addition, the Performance Standards for New Small Municipal Waste Combustion Units allow for visible emissions for no more than 5 percent of hourly observation period. This is a lenient
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requirement; there should only rarely be visible smoke from the incinerator. Visible emissions for 5% or more of the operating time will indicate poor operational practices, such as: • feeding too big loads at one time; • introducing excessive quantities of wet waste; • operating at low temperatures; • a malfunctioning control system; and • broken equipment, such as burners, combustion air fans or sensors.
64. So, a sound approach to verifying that the thermal unit is operating well and emitting a minimum of pollutants, is to ensure that there are no visible emissions. Should there be visible emissions on a regular basis, the authorities should verify that the system is being operated as intended by the manufacturer. If there are doubts about the operating standards, a spotlight can be installed on the stack, so that it is possible to check for visible emissions 24/7. This is the simplest, least costly and most reliable approach to ensuring that the thermal system is always operated correctly.
14. Greenhouse Gas Emissions
65. Waste incineration is a technology that results in a significant reduction in greenhouse gas emissions (GHG) and hence offers considerable environmental benefits. It reduces the GHG emissions, as the thermal combustion of the waste content in a controlled environment prevents the release of methane to the atmosphere that occurs during decomposition of the organic waste at the landfill. A calculation was undertaken using KfW’s Solid Waste Management Greenhouse Gas Calculator 14 to estimate the GHG emissions for incineration and to compare the emissions with the current situation base case. The inputs were as follows: (i) Waste Quantity for 2030 – 4,714 tpy; (ii) Waste Composition - Average from (iii) Table 1; and (iv) Percentage of waste to treatment - 100%.
66. The calculation compares the present situation with the scenario where the same quantity of waste is incinerated, computing the GHG emissions for each instance. The waste quantities for the year 2030 are used, as this will represent an average number over the anticipated 15-year lifespan of the thermal plant. The calculated annual 67. GHG emissions are: (i) GHG emissions from dumpsite - 3,677 tons CO2-eq./year; and (ii) GHG emissions from thermal plant – 989 tons CO2-eq./year.
68. Hence, the GHG emissions would be reduced by about 73% or 2,688 tons CO2-eq. annually. Under the Paris Agreement on Climate Change, the RMI commits to reduce the country’s emissions of GHGs. Under the “moderate” scenario projection, the RMI proposes to reduce the emissions of GHGs from around 60,000 tons in CO2 equivalents to 30,000 tons CO2-eq by the year 2050. Under the “significant” scenario projection, the goal is about 20,000 tons CO2-eq. emissions by 2050. Hence, a reduction in GHG emissions by 2,688 tons CO2-eq. in 2030 would represent a sizeable contribution to achieving these national goals. The 2,688 tons CO2-eq. of GHG represent 9% of the “moderate” scenario emission reduction target and 7% of the “significant” target.
69. If the CDL schemes are made fully operational, so that recovered cans and plastic bottles
14 https://www.ifeu.de/en/project/tool-for-calculating-greenhouse-gases-ghg-in-solid-waste-management-swm/
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are reprocessed, there would also be carbon credits for these activities.
15. Management of Healthcare and Hazardous Waste
70. The proposed thermal plant can treat healthcare waste and some types of hazardous waste generated on Ebeye. The following discusses these options, as well as the need for a sound HCWM system at the Ebeye Hospital. The handling of infectious waste within a hospital requires a dedicated system that keeps staff, patients and visitors safe. Such a waste management system is seemingly lacking at Ebeye Hospital at present. An earlier study gives a thorough description of all that is required to establish a sound HCWM system in the RMI. 15
71. Healthcare waste requires special measures of separation, packaging, marking/coding, temporary storage, and collection. The separation is made at the source in accordance with the defined waste categories, usually there are three groups: ordinary waste, infectious waste and sharps (syringes, scalpels and the like). It is essential that all personnel who are exposed to the waste fully understand the separation criteria. This means that all staff who come into contact with healthcare waste must be thoroughly trained. The separation of the waste categories starts right by the patient’s bed, were the waste is sorted as it is placed on the nurse’s trolley, the segregation continues through the nurses’ station and eventually the waste will reach the hospital’s locked storage area. From there the waste can be transported to its final destruction at the thermal plant.
72. It is important that all personnel handling healthcare waste receive thorough training. They must know their hospital’s or institution’s procedures, packaging types, personal protection measures, first aid, and how to respond in case of accidents or damaged packaging. Placing posters on the walls of all nurses’ stations instructing how the waste should be sorted and handled can assist with keeping the hospital’s staff’s knowledge up to date. Such instruction materials must be prepared when implementing healthcare waste source separation in the Ebeye Hospital.
73. Considerable work goes into setting up a proper healthcare waste management system. The appropriate management of healthcare waste requires good administration and organization, as well as active participation by trained and aware staff. Expert Consultants can help draft and set up such system, but for the system to be sustainable, it must be closely monitored by the hospital management. The first step is usually for the Hospital Director to form a Waste Management Team that will develop a Waste Management Plan. The team can have the following composition: Hospital Director (chairperson); Department Heads; Infection Control Officer; Chief Pharmacist; Radiation Officer; Senior Nursing Officer; Hospital Manager; Hospital Engineer; Financial Controller and the Waste Management Officer (if the position already exists).
74. A Waste Management Officer (if not already designated) should be appointed with overall responsibilities for the development of the hospital waste management plan and for the subsequent day-to-day operation and monitoring of the waste disposal system. Depending on the organizational structure, this responsibility can be assigned to the Hospital Engineer, to the Hospital Manager, or to any other appropriate staff member at the discretion of Hospital Director.
75. The Waste Management Officer (WMO) is responsible for the day-to-day operation and monitoring of the waste management system. He or she must have direct access to all members of the hospital staff (see the list of the members of the Waste Management Team above) and the WMO should report directly to the Hospital Director. The WMO should work with the Infection
15 Baseline Study for the Pacific Hazardous Waste Management Project - Healthcare Waste in RMI, prepared by ENVIRON Australia Pty Ltd for SPREP (2014).
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Control Officer, the Chief Pharmacist and the Radiation Officer to become familiar with the correct procedures for handling and disposing of pathological, pharmaceutical, chemical and radioactive wastes. In the area of waste collection, storage and disposal, the WMO’s responsibilities are to (i) control internal collection of waste containers and their transport to the central waste storage facility of the hospital on a daily basis; (ii) liaise with the Supplies Department to ensure that an appropriate range of bags and containers for health-care waste, protective clothing, and collection trolleys are available at all times; (iii) ensure that hospital attendants and ancillary staff immediately replace used bags and containers with the correct new bags or containers; (iv) directly supervise hospital support staff assigned to collect and transport healthcare waste; (v) ensure the correct use of the central storage facility for healthcare waste (it should be kept locked but should always be accessible to authorized hospital staff); (vi) monitor methods of transportation of wastes both on- and off-site; and (vii) ensure that the waste is collected in a timely manner and that the transport organization collects the waste with the required frequency.
76. For staff training and awareness, the WMO must liaise with the Senior Nursing Officer and the Hospital Director to ensure that the nursing staff and medical assistants are aware of their responsibilities for segregation and storage of waste and that the responsibilities of hospital support staff are limited to the handling and transport of sealed waste bags and containers. Furthermore, the WMO should ensure that there are written emergency procedures available, that these are in place at all times and that staff is aware of the action to be taken in the event of an emergency. The WMO should report to the Hospital Manager on a monthly basis regarding waste quantities, costs, training, incidents resulting in injury, and so forth. To establish such a system requires the development of a Waste Management Plan for the Ebeye Hospital and its gradual implementation.
16. Management of Hazardous Waste
77. This report estimates that a little over 50 tons per year of waste oil is generated at the Ebeye Island Power Station. This waste oil can be burned in the thermal plant, where it will serve as a fuel. The capacity to burn waste oil will require a dedicated feed system with a storage tank that is heated and equipped with an impeller, as well as a specialized nozzle into the incinerator. If not all the stored legacy used oil is sold by the Ebeye Island Power Station to South Korea, this old waste oil can also be handled by the thermal plant, though more equipment, such as a filtration system, may be required.
78. In a remote location, such as Ebeye, it is very difficult to properly handle and treat most hazardous waste. There is simply so little waste that the unit cost becomes prohibitive. Storing hazardous waste for later treatment can be done, but when the ultimate treatment costs can easily be in the thousands of dollars per ton, this is a difficult approach. Furthermore, unless the hazardous waste is segregated in accordance with the future treatment facility’s requirements, the “mixed” waste will be even costlier to treat. 16
79. To minimize undesirable air emissions, batteries should not be fed to the incinerator. If possible, there should be a system in place where any shop that sells batteries also takes back old batteries for free. This would mean that when a person goes to purchase replacement batteries,
16 It is basically impossible for local authorities to collect, segregate and store hazardous waste in a manner where each category of waste can be treated in the least costly manner possible.
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he or she can take back the old batteries to the point of sale for disposal. With a sound regulatory system, an EPR system could ensure that any supplier of batteries to the RMI must also take back all old batteries.
17. Implementation Plan
80. It takes time to establish a thermal treatment system. From when the order is placed, it will take 10 months till the containers holding the equipment arrive in Ebeye. An International Expert, working in collaboration with (a) National Expert(s) and KALGOV, will have to ensure that a number of issues are addressed as the project moves ahead. The quantity of waste generated on Ebeye and intended for the thermal plant must be validated. The key consideration is to confirm the quantity of waste to be treated in terms of solid, hazardous and healthcare waste.
81. The estimate made over two weeks for this Feasibility Study found that the solid waste generation rate was 0.75 kg/ inhabitant/day; whereas the (presumably) more reliable Pacific Regional Waste and Pollution Management Strategy 2016–2025 came to 1.3 kg/inhabitant/day. This latter figure is used in this report and a lower waste generation rate will have a significant impact on the required size of the incinerator.
82. It is vital that the thermal plant is sized correctly for the anticipated heat release and the expected waste quantities, as the system will otherwise be very inefficient. An incinerator that is too large, will either have to burn virgin fuel while waiting for more waste to be delivered (costly fuel expenses) or continuously start and stop operations, causing damage to the system from the repeated temperature changes between operating temperatures at 850OC and the ambient temperature.
83. At present, the existing 1,500 wheelie bins are being replaced and 50 waste containers on wheels are being provided. The storage capacity of these wheelie bins exceeds the requirements, so a more thorough study should make it possible to reduce the number of bins and there are presumably a number of households that do not require such a large bin! A 240-liter bin emptied twice a week, the assumptions used in this Feasibility Study, is ideal for a household with 11 members. Presumably, many households would be well served by 120- or 140-liter waste bins, and presumably even smaller bins if they receive frequent waste collection services. The volume and number of large containers provided to businesses should also be verified in the field. Furthermore, as noted earlier, both the waste collection and the waste treatment system (the incinerator) are sized for an expected waste generation rate of 1.3 kilograms per person per day. Therefore, if this Consultant’s estimate of 0.75 kg/person/day should be closer to the truth, the required total volume of waste bins has been greatly overestimated and will need to be adjusted. During the project preparation phase, where the waste quantities are validated, the options for encouraging composting and other measures for strengthening 3R activities can also be addressed.
18. Technical Support, Training and Capacity Building
84. Throughout the project, from the current Feasibility Study and right through to the start-up and operation of the integrated waste management system, there is a need for support in terms of technical advice and capacity building. Here much of the support from an International Expert comes early in the project: (i) design basis for the project; (ii) technical specifications for all equipment and works; (iii) strengthening the CDL and 3R activities in Ebeye; and
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(iv) specifying and implementing a HCWM system in Ebeye Hospital (including training of staff). The suppliers can be expected to provide training in the following: (i) operation and maintenance of incinerator; and (ii) maintenance of vehicles. There are also areas where either technical support or training may be needed: (i) licensing and permitting of the thermal plant; (ii) accounting and reporting; (iii) awareness raising for the citizens (no littering, composting, CDL, 3R, handling of batteries, etc.); (iv) repair of bins and containers; and (v) HCWM (at hospital and for treatment operators in safety).
85. So, there are a number of areas where national and international support will be beneficial. Suppliers of thermal plants will normally send some technicians to assemble their equipment on site. These technicians will also take part in the start-up of the system and train the local operators. The duration of such support would be around three weeks. Support over a longer duration during the start-up can be agreed to, just as follow-up visits by the technicians can be arranged.
86. A supplier will usually build and assemble the complete thermal plant in their workshop and test all its functions. So, they will operate the complete system, except for feeding waste, as they have no environmental license for that. If deemed advantageous, the future chief operator of the thermal plant and/or the future mechanical/ electrical engineer can participate in the full cycle of the construction of the incinerator. That would involve following the building of all modules in the manufacturer’s workshop, participation in the assembly and testing of the incineration system at the workshop, the dismantling of the system and packaging into shipping containers. Such training at the manufacturer’s premises would last about 6 months.
87. Modern control systems can generally be connected to the internet and monitored from a remote location. This means that real-time operating data can be sent to both the chief operator’s laptop, as well as back to the supplier’s offices if desired. This allows for technical support and troubleshooting by the experts in the manufacturer’s home office.
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III. POLICY, LEGAL AND ADMINISTRATION FRAMEWORK
A. National and Local Legal Framework
1. National Environmental Framework
88. The Ministry of Environment, the Ministry of Natural Resources and Commerce, and the Ministry of Internal and Social Affairs assume primary responsibility for environmental issues. Under the Ministry of Environment, the Environmental Protection Authority (EPA) is established through the Environment Protection Act. This Authority is responsible for pollution control, inclusive of the administration of the Solid Waste Management Regulations. The EPA also administers Environmental Impact Assessment Regulations and the Coastal Conservation Act. The Ministry of Health and Human Services, through the Public Health, Safety and Welfare Act, is responsible for ensuring waste management activities do not present a risk to public health.
89. The RMIEPA is the governing body for environmental protection in the RMI. The National Environmental Protection Act 1984 (NEPA)17 is administered by the RMIEPA and contains a set of regulations for protection of surface and marine waters, and air quality, and managing of potential impacts from earth works, sanitation systems, waste, and new infrastructure development. These regulations along with the Coast Conservation Act 2008, provide the framework for protection of resources and environmentally sustainable development in Ebeye, and are directly applicable to this project.
90. Environmental Impact Assessment Regulation. The environmental impact assessment (EIA) Regulation (Section 21, NEPA) is the central environmental planning legislation with the aim of ensuring that environmental concerns are given appropriate consideration in decision making for all new infrastructure projects. The EIA regulation applies a two-step assessment process to determine the level of assessment required, similar to the ADB environmental safeguard policy. Initially, a preliminary proposal is required for “each and every proposed development activity.” The preliminary proposal is an initial evaluation to determine whether an action may have a significant environmental effect. The preliminary proposal is evaluated by the RMIEPA General Manager to determine if the action has the potential to have a ‘significant effect on the environment’, if so, a second stage of assessment is required and an EIA must be completed. This IEE compares satisfactorily with the EIA as required by RMIEPA.
91. The regulations also require any point source pollution discharge to maintain a pollution discharge permit issued by RMIEPA. The permit includes specific point source discharge limits, along with monitoring and reporting requirements.
92. Solid Waste Regulation. In 1989, the EPA issued the Solid Waste Management Regulations,18 these provide the legal and policy framework for waste management. Within this structure, the EPA regulates and monitors standards for the design, construction, operation, and management of solid waste storage, collection, and disposal facilities. These regulations cover solid, healthcare and hazardous waste and the following key requirements can be noted: (i) For solid waste, all containers over 55 gallons must be equipped with wheels, so they can be rolled to the collection vehicle and be emptied mechanically; (ii) Personal protective equipment (PPE), such as gloves, safety glasses, respirators, coveralls, and footwear shall be used by collection employees, as appropriate;
17 Marshall Islands Revised Code 2004, Title 35-Environment, Chapter 1 National Environmental Protection Act (1984). 18 The Regulation can be found here: https://rmi-data.sprep.org/system/files/Solid%20waste%20Regulations.pdf
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(iii) Solid wastes must be collected with frequency “sufficient to inhibit the propagation or attraction of vectors and the creation of nuisances.” Solid waste containing food must be collected of once a week at a minimum. Bulky waste is to be collected at least on a quarterly basis; (iv) The waste generator has the responsibility of removing accumulated solid waste to an approved disposal facility. A contractual agreement does not relieve a person of this responsibility. (v) A permit from the EPA is required to establish, modify, or operate any solid waste disposal facility; (vi) A solid waste disposal facility must be clearly signposted, have an all-weather road, have firefighting equipment, and safely store all received waste; (vii) A disposal facility may be required to control access, to submit monitoring results, and to submit operating reports; (viii) In a landfill waste must the deposited above the high level of the ground water “sufficient to prevent contamination of the water;” surface water must be managed, and waste must be deposited in a manner to protect both ground and surface water; (ix) In a landfill, a new waste layer cannot exceed a depth of 2 feet before being compacted, any layer of waste must be covered with at least 1 foot of compacted intermediate earth, or other approved cover material, before it reaches 8’ depth; (x) Processed waste must be compacted and covered with at least 4 inches of earth, coral or other approved material; (xi) At closure, a landfill must be covered with at least 18 inches of compacted earth or coral material, graded with proper drainage and planted; (xii) The only requirement to incineration is that fly ash and other generated residues be treated and disposed of in a manner to prevent odor and dust nuisance. (xiii) For the disposal of any hazardous waste a written authorization is required from the EPA. Toxic, caustic, volatile and flammable chemical waste can be incinerated or disposed of in another manner approved by the EPA. Inorganic waste must be rendered non-hazardous by chemical neutralization or stabilization before final disposal. A dedicated cell that protects both ground and surface waters must be used for this waste and records kept of where the waste is deposited; (xiv) Waste oil generators must adopt all practical measures to reduce the waste quantity and maximize reuse. Waste disposal routes must be approved by the EPA, and the possibility of spreading waste oil on roads, airports and other areas for dust control is mentioned; and (xv) Infectious and pathological waste must be incinerated, sterilized, or otherwise rendered safe before final disposal.
93. The requirements set out by the EPA are practical and feasible, the only concern could be to find suited cover materials for both the operation and closure of landfills.
2. International Conventions and Treaties
94. RMI is a signatory to the following conventions: (i) Basel (Transboundary Movement of Hazardous Waste), (ii) Rotterdam (Movement of Hazardous Chemicals), (iii) Stockholm (Persistent Organic Pollutants), (iv) MARPOL (Prevention of Pollution from Ships) (v) United Nations (UN) 64th General Assembly Resolution on the Human Right to Water and Sanitation; (vi) UN Framework Convention on Climate Change;
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(vii) UN Convention on Biological Diversity; (viii) UN Barbados Program of Action and Mauritius Strategy; (ix) UN Convention to Combat Desertification; and (x) The Micronesian Challenge.
3. ADB Safeguard Policy
95. All projects funded and/or administered by ADB must comply with the SPS. The purpose of the environmental safeguards is to ensure the environmentally soundness and sustainability of projects and to support the integration of environmental considerations into project decision- making. The policy is accompanied by the Environmental Safeguards Good Practice Sourcebook (2012). The policy promotes international good practice as reflected in recognized standards such as the World Bank Group’s Environmental, Health and Safety Guidelines.
96. The SPS requires several additional environmental considerations to that generally undertaken in accordance with the NEPA and related legislation. These include: (i) identification of project environmental risks and respective mitigation measures and project assurances; (ii) development of a project level grievance redress mechanism (GRM) including documentation in the EMP; (iii) definition of the project area of influence; (iv) undertaking a physical cultural resources damage prevention analysis; (v) identification of climate change mitigation and adaptation strategies; (vi) identification of biodiversity conservation and natural resources management requirements; and (vii) ensuring that the EMP includes an implementation schedule and (measurable) performance indicators.
97. ADB will not finance projects that do not comply with the SPS and the host country’s social and environmental laws and regulations, including those laws implementing host country obligations under international law. The SPS also contains a prohibited activities list identifying specific activities that ADB will not finance.
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IV. DESCRIPTION OF ENVIRONMENT
A. Physical Environment
1. Climate
98. Located at latitude: 8⁰ 47' 33" north and longitude: 167⁰ 44' 56" east, Ebeye island is at the southern end of Kwajalein atoll, the world’s largest atoll. The atoll has a total land area of 16 km2, with about 90 islands surrounding a 1,700 square kilometer lagoon. Ebeye is a small low-lying coral islet comprised of a land area of 32 hectares (80 acres), with a maximum elevation of about 3 meters (10 feet) above mean sea level. The climate is maritime tropical with slight seasonal and daily variations, with temperatures averaging about 27 degrees Celsius (Figure 8).
99. The rainfall of the RMI varies greatly from north to south. The atolls at >10⁰ north receive less than 1250 mm (50 inches) of rain annually and are very dry in the dry season. Atolls < 7⁰ north (closer to the equator) receive more than 2500 mm (100 inches) of rain annually. Both Majuro and Kwajalein have a dry season from around December to April and a wet season from May to November (Figure 9).
Figure 8: Average Mean Temperature at Kwajalein
Note: Light blue, dark blue and grey bars denote El Niño, La Niña and neutral years respectively. Source: Pacific-Australia Climate Change Science and Adaptation Planning Program Technical Report, 2014.1
2. Climate Change
100. The International Panel on Climate Change (IPCC) recognizes that developing countries particularly small island developing states such as the RMI are particularly vulnerable to climate change\ .19 Projected sea level increases to the year 2100 are 0.35m to 0.70m, this rise, in combination with extreme sea level events, such as swell waves, storm surges, and El Niño- southern oscillation (ENSO) events, present severe sea inundation and erosion risks for low lying atoll islands. Locations currently experiencing adverse impacts such as coastal erosion and inundation will continue to be affected due to increasing sea levels. The contribution of mean sea
Figure 9: Kwajalein Annual Rainfall 19 IPCC. Assessment Report 5 (2014).
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level rise to increased coastal high-water levels, coupled with the likely increase in tropical cyclone maximum wind speed, is a specific issue for tropical small island states.20
Figure 10: Kwajalein Annual Rainfall
Source: Pacific-Australia Climate Change Science and Adaptation Planning Program Technical Report, 2014.1
101. Based on the recent Technical Report 21, for the period to 2100, the latest global climate model projections and climate science findings indicate: (i) El Niño and La Niña events will continue to occur in the future (very high confidence), but there is little consensus on whether these events will change in intensity or frequency; (ii) annual mean temperatures and extremely high daily temperatures will continue to rise (very high confidence); (iii) average rainfall is projected to increase (high confidence), along with more extreme rain events (high confidence); (iv) droughts are projected to decline in frequency (medium confidence); (v) ocean acidification is expected to continue (very high confidence); (vi) the risk of coral bleaching will increase in the future (very high confidence); (vii) sea level will continue to rise (very high confidence); and (viii) wave height is projected to decrease in the dry season (low confidence) and wave direction may become more variable in the wet season (low confidence)
102. Temperature. While relatively warm and cool years and decades will still occur due to natural variability, there is projected to be more warm years and decades on average in a warmer climate.
103. Rainfall There will still be wet .and dry years and decades due to natural variability, but
20 IPCC. Managing the Risks of Extreme Events and Disasters to Advance Climate Change Adaptation (SREX): Summary for Policy Makers (November 2011).
21 Pacific-Australia Climate Change Science Program, op cit.
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most models show that the long-term average is expected to be wetter. The effect of climate change on average rainfall may not be obvious in the short or medium term due to natural variability. These projections are similar to those in Australian Bureau of Meteorology and CSIRO (2011).
104. Drought. For both the northern and southern RMI the overall proportion of time spent in drought is expected to decrease under all global climate model scenarios.
105. Tropical cyclone (typhoon). There is a growing level of agreement among models that on a global basis the frequency of tropical cyclones is likely to decrease by the end of the 21st century. These projections are consistent with those of Australian Bureau of Meteorology and CSIRO (2011).
106. Sea level rise. Mean sea level is projected to continue to rise over the course of the 21st century. There is very high confidence in the direction of change. Several global climate models (CMIP5, RCPs) simulate a rise of between approximately 3 to 7.5 inches (7–19 cm) by 2030. Inter- annual variability of sea level will lead to periods of lower and higher regional sea levels. In the past, this year to year variability has been about 8 inches (20 cm), and it is likely that a similar range will continue through the 21st century. The sea level rise near the Marshall Islands measured by satellite altimeters since 1993 is about 0.3 inches (7 mm) per year.22
107. Sea level is also generally higher around the Marshall Islands during La Niña events, with three of the top 10 water levels recorded at Kwajalein occurring during La Niña and none during El Niño (Australian Bureau of Meteorology and CSIRO, 2011). Tide gauge data show the strong annual variability in tide heights and indicate that ENSO events are a significant component of high-water levels. The Weather Service Office has recorded that roads in both Majuro and Ebeye are affected by significant inundation on almost every equinox tide during La Niña conditions. During December 2008, a State of Emergency was declared following weeks of high seas which resulted from storm surges coinciding with high tides and two tropical depressions (UNOCHA, 2009). The populated areas of Majuro and Ebeye suffered damage to roads, houses, and other infrastructure on the low-lying atolls. A similar event occurred in June-July 2013, mainly affecting Majuro.
108. Tropical cyclones (typhoons) usually form between September and November but are often weak when they pass through the Marshall Islands’ region. Nevertheless, RMI was affected by devastating cyclones several times in the last few decades. For example, typhoon Paka in 1997 caused severe damage to crops and damaged 70% of houses on Ailinglalap Atoll, with total damage estimated at US$80 million for the entire nation. Typhoons Zelda, Axel and Gay each caused significant damage and losses with the space of one year (1991-1992).23 Tropical Storm Roy impacted Kwajalein in 1988.
109. ENSO events also modulate temperature and rainfall in the western equatorial Pacific Ocean. Droughts generally occur in the first four to six months of the year following an El Niño. During severe El Niño events, rainfall can be suppressed by as much as 80%. The dry season begins earlier and ends much later than normal. Variability in temperature and rainfall, during ENSO events is shown in Figure 10.
22 Pacific Climate Change Science Program. op cit.
23 Pacific Catastrophe Risk Assessment and Financing Initiative. Country Risk Profile: Marshall Islands, September 2011.
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Figure 11: ENSO Events and Impacts on Rainfall and Temperature
Observed time series of annual average values of mean air temperature (red dots and line) and total rainfall (bars) at Kwajalein. Light blue, dark blue and grey bars denote El Niño, La Niña and neutral years respectively. Solid black trend lines indicate a least squares fit.
110. Planning for climate change scenarios will help mitigate potential impacts to the project, vulnerable ecosystems, and quality of life indicators for Ebeye residents. Of additional concern, is if disasters occur more frequently and/or with greater magnitude. Subsequently, some local areas will become increasingly marginal as places to live and subsist, especially for locations such as atolls. In such cases, migration and displacement could become permanent and exacerbate pressures in areas of relocation, such as Ebeye. Potential threats to water, wastewater, and power infrastructure will likely include: (i) increased sea water inundation; (ii) increased erosion and subsidence of coastal areas; (iii) increased frequency of intense rainfall events, and subsequent flooding; (iv) increase in tropical cyclone intensity, though reduced frequency; and (v) increase in drought intensity, though reduced frequency.
111. Planning for the potential impacts of climate variability will help to mitigate against potential impacts which may include (i) sea water inundation resulting in failure of near shore sanitation infrastructure, and (ii) increased risk of contamination of near shore marine waters. Planning considerations should include: (i) planning new infrastructure at a suitable elevation above the current high tide level (utilizing accurate topographic survey), (ii) provision for protective flood berms around existing above ground infrastructure at low elevations above the current hide tide level, (iii) ensuring new infrastructure is designed to withstand extreme weather events.
112. Although stormwater management improvements are not part of the project’s scope of works, a non-functioning storm water drainage system, as described in the 2010 USACOE Ebeye Infrastructure Survey, may have serious impacts on water and sewer infrastructure, especially considering predicted climate change variability, such as increased sea level rise and rainfall
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intensity. Rehabilitation of the drainage system is a prime example of a climate change adaptation measure that would qualify as a cost effective, "no regrets", investment.
113. Increasing sea level rise, with more frequent episodes of inundation and coastal erosion, will severely impact the existing Ebeye solid waste dump site. The facility was constructed on the northern end of the island and extends out over the nearshore lagoon reef. Though a berm and concrete block seawall extend around the perimeter, it is breached in several locations. The tidal water table is exposed in several areas inside the site. The vulnerability of fragile ecosystems such as coral reefs and coastal zones, as well as rare or endangered species is further increased by climate variability, droughts, water pollution, soil erosion, poor land management and land degradation, and unsustainable development.
3. Geology and Geomorphology
114. The atolls of the Marshall Islands are made up of calcareous remains of coral growth that have accumulated over millions of years on the peaks of submerged mid-oceanic volcanic islands. The atoll and islands lie in two parallel chains: Ratak (meaning sunrise) to the east, and Raliik (sunset) to the west. The two atoll chains are approximately 130 miles (209km) apart and are aligned diagonally northwest to southeast between 160o east-173o east and 04oN-15o north.
115. Most atolls of the Marshall Islands consist of an irregular shaped reef-rim with numerous islets encircling a lagoon with water depths that can reach 200 feet (60 m). The islets are more prevalent on the windward side. The atolls vary in size from Kwajalein, the largest Pacific atoll with 6.3 square miles (16.4 km2) of dry land and a lagoon of 840 square miles (2,174 km2). Ebeye Island is located at the lower, southeastern area of Kwajalein atoll.24 Ebeye lies at the southern edge of the Pacific North Equatorial Current (Latitude: 8° 47' 33" N, Longitude: 167° 44' 56" E); as such, ocean prevailing currents flow easterly, and towards the eastern shore of the island (Figure 11). Figure 12: Pacific North Equatorial Current (NEC)
24 State of Coral Reef Ecosystems of the Marshall Islands, NOAA 2008.
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4. Soils
116. According to the US Department of Agriculture - Natural Resources Conservation Service, survey of soils in Majuro and several other islands in the Ratak chain, the main soil component in the atoll islands is classified as the Majuro series. With the climate, parent material, topography, vegetation, and age of soils being fairly uniform throughout the atoll islands, we can extrapolate that soils on Ebeye Island are similar.25 The Majuro series consists of very deep, somewhat excessively drained soils that formed in water deposited coral rubble and sand. Slope is 0-2%. These soils are sandy-skeletal, carbonate in composition. The water table (saltwater) is typically encountered at 1 to 1.8 meters depth.
5. Freshwater Resources
117. Groundwater exists as a basal aquifer, often called a freshwater lens—the Ghyben-Herzberg lens--on many atoll islands. Water quality varies from somewhat fresh to brackish. The lens is recharged by rainfall that percolates through the highly permeable coral soil. The groundwater level and salinity fluctuates with the sea tidal level. There are a few private wells in use in Ebeye, the water being brackish to mildly brackish, the well water is typically bailed by bucket. High groundwater salinity was found during the hydrology investigation in March 2014, despite high rainfall during the previous month. This indicates there is low potential for fresh groundwater use, and given the minimal lens formed under the narrow island, the width of which averages 250 meters across. There are no surface water resources existing in Ebeye.
6. Marine Water Quality
118. Marine water quality in Ebeye is monitored by the RMIEPA. Recent years sample test results for period 2011 to 2014, at numerous sampling locations along the near shore reef of the western lagoon, greatly exceed the Class B water quality standard for microbiological pollution indicators (Enterococci).
119. Coastal erosion is a serious concern in Ebeye, where construction of sea walls, coastal dredging, and beach sand mining has severely impacted the natural beach barrier.
7. Air Quality
120. Only minor ambient air quality impacts tend to occur from sources such as sewage pump stations, the power plant, and from motor vehicles. The practice of burning trash at the solid waste facility at the north end of the island may contribute to possible poor air quality air in nearby areas, including some residences south of the solid waste facility. Otherwise, consistent trade winds from the northeast predominate enhancing air quality on Ebeye. The RMI has not promulgated air quality regulatory standards.
B. Ecological Environment
1. Terrestrial Flora and Fauna
121. Well over 90% of the Ebeye community area is built environment. Vegetation primarily consists of plantings amongst residences and yards, such as: coconut, Terminalia catapp, tropical almond ('kotel'), Morinda citrafolia, noni, ('nin'), and ornamentals. Casuarina litorea, ironwood
25 USDA/NRCS. Soil Survey of Airik, Arno, Majuro, Mili and Taroa (July 1989).
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pines, are also common, planted as windbreaks, and along property boundaries. Scaevola taccada 'beach cabbage' or 'naupaka' dominates the shoreline north of the community, on the causeway to Gugeegue village. Observed fauna consisted mainly of introduced species such as dogs, cats, and rats. Resident and migratory shorebirds are common along the fringing reef26.
2. Marine Flora and Fauna
122. Most coral reef ecosystems in the Marshall Islands are in excellent condition, with the outer atolls supporting healthy and diverse communities of marine life. Increasing threats from fisheries, including illegal fishing methods, climate change, and increasing urbanization, are impacting coastlines and coral reefs, especially near the population centers of Majuro and Ebeye.27
123. A survey of the benthic morphology and marine life of the lagoon reef was conducted in 2015, for a proposed route for a new sewer outfall pipeline. The survey findings raised several ecological concerns including: (i) non-coral invertebrates are largely absent from the reef, especially giant clams; (ii) large (>20cm) and medium (10-20cm) fish are also largely absent from the reef; (iii) coral cover varies from 5-50% across the survey sites. The high average is largely due to the particularly good coral in proximity to the middle part of the existing wastewater line. The area of primary concern for protection, however, is the shallow rise in the reef along the proposed wastewater route, where live corals are situated within a field of unconsolidated coral rubble. The deeper coral heads have already shifted to macroalgal dominance, with low coral biodiversity; and (iv) upwards of 25% of the sandy substrate beyond the outfall is covered with cyanobacteria algae and fine silty sediment 2-3mm thick. This is a significant amount and is largely responsible for the supply of nutrients and silt to the deeper coral heads.
3. Threatened, Rare, or Protected Species
124. No threatened, rare, or protected species (terrestrial or marine) were identified by the project. The RMI Endangered Species Act 1975 has not developed a list of species to be specified as endangered under the Act. Additional identification and description of marine species and habitat is found in Appendix B: Sewer Outfall Benthic Habitat Survey. No conservation or protected areas have been established for Ebeye Island.
C. Social Environment
4. Socioeconomic Environment
125. Public sector spending and contributions from the United States, via the Compact of Free Association, largely drives the RMI’s relatively small national economy. The government sector accounts for 41% of formal employment and 40% of GDP (including state owned enterprises). The US Test Site on Kwajalein also accounts for one-third of economic activity. The fragile nature of energy and food security was evident when a State of Economic Emergency was declared in 2008 following rising inflation which peaked at 30.1%. High food and fuel prices resulted, highlighting the vulnerability of the RMI to external market variations.
126. Some 94% of the employed Marshallese population worked in paid employment (11,932),
26 ADB TA6204-REG, 2007, Republic of Marshall Islands, Country Environmental Analysis. 27 RMIEPA. The State of Coral Reef Ecosystems of the Marshall Islands (2008).
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with the private sector employing 41% of paid employees, ahead of the government sector at 35%. In all forms of employment males are more prevalent than females, at 65% male to 35% female. From 1999 to 2011, formal employment, in both the private and public sectors, increased by 1,848, with public sector growth (1,074) ahead of private sector job creation (772).
127. The 2011 Census reports that 15.2% of all Kwajalein households reported no income and another 7.8% reported less than $3,000 annual income. In total, 23% of all households thus reported incomes of less than $3,000 per year or less than $8.22 per day. With an Ebeye census average of 8.7 people per household (likely higher for poorer households), that means 23% of the Ebeye population is living on less than $0.94 per day with little or no subsistence income.28
128. Vulnerabilities are linked to both physical and social characteristics of its islands and people, in addition to ongoing unsustainable development practices. Key drivers of the RMI’s vulnerability include: (i) rapid population growth and over-population in urban centers (ii) low elevation and small atoll islands (iii) unsustainable development (iv) localized pollution (including contamination of water supply), poor waste management, sanitation, and environmental degradation (v) climate change impacts including accelerated sea level rise, which may increase vulnerability and exposure to shocks and stresses, as well as increase intensity of extreme events (vi) limited resources (particularly food, water and fuel) (vii) limited economic potential due to small size and remoteness (viii) high exposure to external market shocks (demonstrated by the State of Economic Emergency declared in 2008 following unprecedented increases in costs of imported food and fuel) (ix) sparse and scattered nature of islands and atolls, making communication and transportation to outer islands more difficult, with infrequent and unreliable transport links
129. The key natural and human-induced hazards were listed in the RMI Joint National Action Plan below. All are specific concerns for Ebeye residents (Figure 12).
Figure 13: Key Natural and Human Induced Hazards29
5. Population
130. The 2011 Census Report highlighted several population statistics, for RMI in general, and specific to Ebeye, which are causal for the human induced hazards and vulnerabilities noted above: (i) The 2011 Census recorded a total population of 53,158 persons (27,243 males and
28 RMI. Census of Population and Housing Summary Report (2011). 29 Source: RMI Joint National Action Plan for Climate Change Adaptation and Disaster Risk Management 2014-2018.
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25,915 females) currently residing in the RMI. (ii) The last Census, or the 1999 Census, revealed 50,840 people so there are 2,318 more persons in the RMI or 0.4% population growth rate during the inter-censual period. (iii) Prior to the Census, there were projections that the RMI population would have 55,000 to over 60,000 people, but due to massive outmigration in recent years, it is estimated that around 11,000 Marshallese have left the country. (iv) Majuro and Ebeye continue to contain the largest population share (i.e., 74% or 39,337 people) and the populations have increased indicating people moving from the outer islands. (v) All outer islands’ populations, except Jaluit, Lae, and Lib, have decreased since 1999. (vi) Ebeye is the most densely populated/crowded area in the RMI with 9,614 people per square mile.30 (vii) Small and young children, ages 0-14, continue to constitute the largest portion of 40%, or 21,263 of the population indicating RMI has very high fertility rates although this has come down from 43% and 51% revealed by the 1999 and 1988 censuses, respectively. (viii) Of total occupied houses more than three-quarters (79%) use rainwater collected from roofs of their houses and stored in water-catchment as their main source of drinking water.
6. Ethnography
131. The safeguards assessment for indigenous people, prepared for the project, found that “Ebeye people” do not constitute a distinct cultural group, “Ebeye people” are not dominated by another Marshallese cultural group or groups, and “Ebeye people” do not speak a language that is distinct from the Marshallese language spoken by other Marshallese. Thus, “Ebeye people” are not defined as Indigenous Peoples under the SPS.
7. Land Ownership and Use
132. Most land in the urban area of Ebeye is occupied with permission from the traditional chiefs (Iroji/Alap): 71% with permission from Iroji/Alap, 21% by family rights or closely related to title holder, 4% hold land title. The Public Lands Act 1966 declares that all marine areas below the high watermark belong to the national government. The owner of land abutting the ocean or lagoon shall have the right to fill in, erect, construct and maintain piers, buildings, or other construction on or over the water or reef abutting his land and shall have the ownership and control of such construction; provided, that said owner first obtains written permission of the Chief Secretary before beginning such construction.
8. Education
133. The 2011 Census shows 17% of the population six years and older have completed either high school (Grade 12) or GED, while another 12% have completed some college or higher. Almost one-fourth (24%) have completed grade 9–11, while those who have completed grade 8 comprise 14 percent. Over a quarter of the population (28%) six years and older have completed elementary grades 1–7, and 3 percent have competed pre-school. Only 2% were reported to have never been to school. More males than females were reported to have completed a higher level of education. While 13.1 percent of males have at least some college education as compared to 9.9% of females, there is very little difference in the percentage of those who have completed high school or GED
30 Note the populated area of Ebeye encompasses only 1/8th of a square mile (or 80 acres/32 ha).
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by sex. However, more females than males were reported to have completed grade 8–11. The proportion of the Kwajalein population having completed at least a secondary level of education is 27.5%.
9. Poverty
134. As in most Pacific countries, cash or material poverty is a sensitive and often controversial topic. This stems from strong cultural beliefs and practices of ‘caring and sharing’ for those vulnerable and where no one gets hungry. Acknowledging the presence of poverty challenges the traditional foundation of the society and strength of its culture.
135. In a recent RMI national report, in preparation for the 2014 Small Island Developing States (SIDS) conference in Samoa, the issue of 'economic inclusiveness' was addressed, stating "Inclusive economic development is predicated upon eradicating income poverty and hunger, reducing inequalities, and ensuring decent work and productive employment.” In 2009, the RMI’s progress on Millennium Development Goal 1, Eradicate Extreme Poverty and Hunger, was mixed. While the RMI did not yet have abject or extreme poverty, the RMI was not on track to meeting the three targets under Millennium Development Goal 1. More recently, the 2010 Majuro and Kwajalein Household Water Survey concluded that poverty was a real and serious problem in urban areas of the RMI, with households facing problems such a no water, no electricity, high unemployment, stagnant wages, rising prices, a need for improved government services, and access to information.31
10. Cultural and Traditional Features
136. Initial response from Historic Preservation Office (HPO) indicated that the presence of cultural or traditional features of significance were highly unlikely in the project area, especially as the project works will lie wholly within the footprint of the existing infrastructure. HPO will issue a letter of guidance to the project advising that if any features are encountered during Project works, that works will stop immediately and the HPO be notified as soon as possible. The project's national community participation and development specialist, and long-time Ebeye resident, affirms that no resources of cultural significance have been identified.
11. Noise
137. Vehicle traffic consists of private and commercial cars and trucks; and taxis (typically pickup trucks). It is observed that most residents do not own private vehicles and the main mode of transportation is by bicycle or walking. Given this situation it can be reasonably assumed that traffic levels do not exceed 100 vehicles per hour, or an average of 15 miles per hour (24 kph), which are thresholds, above which traffic generated noise dominates ambient noise levels. Below these thresholds, ambient noise levels would be controlled by non-traffic noise sources such as voices, animals (dogs, chickens), wind, foliage, etc. Noise levels are generally low from commercial activities in the area, such as markets, auto repair shops, and port activities (the port area being offset from the residential areas by about 130m).
138. The US State of Hawaii Department of Health regulations set a maximum permissible sound level in general residential areas at 60 dB (decibels). Construction works in the congested Ebeye community area will likely exceed this level and raise noise impacts to the “nuisance” level, defined
31 RMI-Ministry of Foreign Affairs. National Report to 2014 SIDS Conference (2013.).
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as 15dB (decibels) above ambient noise levels.
12. Traffic
139. Motor vehicle traffic levels are typically light, though minor traffic congestion is encountered along the main streets at the end of the workday, mostly due to taxi vehicles. One-way traffic is routed in a clockwise direction around the island's perimeter road.
13. Public Health
140. In the RMI, the health care system is comprised of two hospitals, one in Majuro and one in Ebeye, and fifty-eight (58) health care centers in the outer atolls and islands. Both hospitals provide primary and secondary care but limited tertiary care. Patients who need tertiary care are referred to Honolulu or the Philippines (off-island referrals consume much of the health resources). Over the last decade, the people of the Marshall Islands have seen improvements in health indicators with decreases in maternal and child mortality.
141. A sedentary lifestyle and processed foods have brought about a sharp rise in the levels of adult obesity and non-communicable diseases (NCDs). Diabetes-related diseases and cancer are now the leading causes of death. High population growth and crowded conditions in urban areas have also contributed to the re-emergence and/or rise of certain communicable diseases, such as tuberculosis and leprosy. Other areas of concern include malnutrition in children, immunization coverage, a high teen pregnancy rate, and alarming rates of STIs.
142. The Ministry of Health recently developed a revised National Health Strategy 2012-2014. This strategy acknowledges the national goals and objectives stated in the Vision 2018 while providing insight on current priorities in the health sector (Figure 13).32
Figure 14: Goals of the National Health Strategy 2012-201433
32 RMI-Ministry of Foreign Affairs. National Report to 2014 SIDS Conference (2013).
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143. Ministry of Health has partnered with the World Health Organization (WHO) to incorporate climate change impacts into its plans and policies, focusing particularly on improved drinking water safety planning and rainwater harvesting, as well as household and community-based water quality monitoring.
144. The solid waste program on Ebeye is managed by the KALGOV Department of Public Works (DPW). They are responsible for the collection and disposal of all the solid waste generated on the island, and also manage and operate the solid waste facility. Currently, the program is fully subsidized by the government and no fees are charged to the residents for the service. Most of the trash generated on the island can be categorized as municipal solid waste and comes from the residential areas which include several schools, grocery/clothing stores, and restaurants. In addition, there is also a hospital that generates medical waste (Figure 14).
145. The solid waste facility (Figure 15) is located at the northern end of the island and occupies an area of approximately 5.3 acres (2 ha). The site is adjacent to, or partially encroaching, on the reef flat.
Figure 15: Ebeye Solid Waste Facility Conditions
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Figure 16: Ebeye Waste Facility Location
146. A solid waste management plan has not been developed. Currently, there are no written procedures or information available regarding: (i) solid waste facility operations plan (waste cover, vector control, site access control, leachate control, health and safety plan); (ii) trash burning procedures; (iii) trash collection procedures; (iv) waste minimization and recycling (removal of metals, junk cars and plastics); and (v) special waste collection and handling (hazardous materials and medical waste).
147. The dump is operating without an EPA permit. RMI EPA Solid Waste Regulations (Part V 19 (c)) do not allow for any disposal sites to be 'grandfathered'. Disposal sites that were operating prior to the effective date--August 25 1989--of the regulations were required to apply for a permit within sixty days of the effective date.
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V. ANALYSIS OF ALTERNATIVES
A. No Project Alternative
148. Solid waste management on Ebeye poses health concerns because they do not have a hygienic, sustainable means of disposing solid waste. Solid waste is collected and deposited into an unsecure open solid waste facility, prior to being burned for volume reduction. The burning is often inadequate leaving a source for bacterial growth and promotion of disease vectors. There is a risk of toxic material contamination to adjacent and underground waters. Additionally, there are health risks to residents bordering the solid waste facility (USCOE 2010).
149. These issues will continue to exist unless there is some intervention to minimize or eliminate these risks.
B. Project Alternatives - Discussion of Alternative Solutions
1. Waste Treatment and Disposal
150. Collected solid waste must be treated and/or disposed of. The basic proposition is to examine the possibility of establishing an incinerator on Ebeye to treat all generated solid waste from the town and its surroundings. This solution would offer significant environmental and social benefits over the present dumping of waste on Ebeye.
151. The calculated costs for waste collection and incineration for Majuro is around $322 per year for each household, such costs may not be affordable for the average Ebeye home. Treatment costs are very high, as there is no economy of scale. It is common for waste-to-energy facilities to burn thousands of tons of waste every day, whereas only 8–12 tons are generated daily on Ebeye. As the total population is lower on Ebeye than on Majuro, the annual operating can be expected to be higher per ton of waste, if the same incineration technology is used.
152. So, although a thermal plant is advantageous in terms of reducing the volume of waste, eliminating odors and so forth, its downside is that for modest quantities of waste, it is a costly technology. Other solutions that are less costly on a unit cost basis are discussed below. Secondly, for an incinerator on Ebeye, the study makes all possible efforts to minimize future operating and maintenance costs.
2. Considered Approaches to Waste Treatment and Disposal
153. The recommended option for Ebeye is a thermal plant. The following description examines two other options that, if they were feasible, would most likely have offered financial advantages over the planned solution for Ebeye.
3. Treatment at the U.S. Army Garrison - Kwajalein Atoll
154. The most efficient solution would be to ship all waste to the incinerator at the U.S. Army Garrison - Kwajalein Atoll. Using an existing incinerator, especially one with a relatively large treatment capacity such as the one on the U.S. Army Base, should greatly reduce the costs per ton of waste. The costs of transporting the waste to Kwajalein should be minimal when compared with the costs of establishing and operating an incineration system on Ebeye.
155. Judging by the pictures found online, the system has a treatment capacity of several tons per
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hour and should hence be capable of handling all waste from Ebeye, as this would only correspond to about 500 kg/hour. The base upgraded their waste incinerator in 2019,34 Figure 17 shows the plant prior to the refurbishment.
Figure 17: The 2019 refurbishment of the Kwajalein Incinerator
156. Waste could be transported by boat to Kwajalein, this is not an unusual practice. In Indonesia, Gili Air is one of the three Gili Islands off Lombok Island. It transports all generated waste to the mainland (Lombok) by boat for disposal. Local island transport (there are no motor vehicles on the islands) brings the waste to a beach, from where it is loaded onto one of two designated boats. The waste is transported to Lombok Island (the island can be seen in the background in Error! R eference source not found.), where it is loaded onto a truck and transported to the local landfill. Gili Air has a little under 2,000 inhabitants.
157. In practice, it seems very unlikely that a collaboration with the U.S. Army Base incinerator can be achieved.35 The US military is of the opinion that the “Compact grant funding” to the RMI covers all their obligations, so the base is generally very reluctant to assist Ebeye, even in cases or life or death, such as medical emergencies. Should the base be willing to accept waste from Ebeye for treatment, this is likely to be at cost with an additional 100% mark-up. So, at present this is not a feasible option.
4. Transport of Ebeye Waste to the Proposed Majuro Incinerator
158. The RMI commitments to the Paris Agreement recommend the possibility of shipping waste
34 The Kwajalein Hourglass Volume 60 Number 23, June 8, 2019. 35 Removal Action Memorandum Kwajalein Landfill (Final Report January 2017). Prepared by Bering-KAYA Support Services for the US Army Engineering, Technical and Operational Support Services (ETOSS).
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from Ebeye to the proposed Majuro incinerator. The distance is great, almost 500 km, but if waste is transported by ship or train over large distances, the greatest cost is usually the loading and unloading of the waste. This cost principle may not apply when only modest quantities of waste are involved, as the handling costs could then be excessive.
Figure 17: Waste transport
159. For over 100 years waste generated within London was transported downstream in barges and disposed of in the Thames estuary east of London. Today approximately 500,000 tons per year of MSW is transported by barge from central London to the Riverside Recovery Resource plant east of the city, an 1,800 tpd waste-to-energy facility. The waste is transferred through four transfer stations, where the waste is unloaded from the garbage trucks and placed in large sealed containers. With a fleet of 5 tugboats, 47 barges and 1,500 waste containers the waste is transported up to 25 km to the incinerator. Here large dock cranes unload the containers, and these are placed on specialist container vehicles which transports them to the incinerators’ feed bunker, where they are emptied by tipping.
160. Hong Kong also transports waste from all its islands to landfills on the mainland. This includes waste from Hong Kong Island with a population of over 1 million people, but waste is also collected by ship from islands with almost no population.
161. Since 1991, the waste generated in Seattle (Washington State, USA) has been transported by rail to the Columbia Ridge Landfill in Oregon. The distance from Seattle to the landfill is over 500 km and more than 500,000 tpy of waste is transported by railroad to the disposal site.
162. Obviously, the quantities mentioned above are very different from Ebeye’s 8–12 tons per day. For London, Hong Kong and Seattle, the significant waste management cost is not in the distance transported, but rather the costs of loading, unloading and handling the containers of
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waste. Obviously, given the small quantities of waste generated in Ebeye, a system where waste is compacted into 20’ or 40’ shipping containers is not realistic. Ebeye does not qualify for the economies of scale. That said, with a regular boat service between Majuro and Ebeye, there is the possibility of shipping waste to Majuro for treatment.
163. Should the Majuro Waste-to-Energy project move ahead, the option to ship Ebeye waste there should be considered. At first sight, the prospects do to seem overly positive. There is a biweekly connection between Majuro and Ebeye by a ship that transports containers. To avoid odors and other nuisances, the waste should be shipped away from Ebeye on a far more frequent basis, so this may not be a desirable solution.
5. Less Viable Options
164. If incineration of the waste, is not a viable option, other possibilities must be considered. The Ebeye waste disposal site can be upgraded to become a controlled disposal site or a managed landfill. This would reduce the environmental nuisances from the site.
165. If a managed landfill is established, there is the possibility of landfill gas recovery, where the collected methane gas could be used for cooking or energy production. Given the quantities of waste involved, and landfill gas recovery would solely be to showcase waste-to-energy. In practice, given the low percentage of organic material in the waste, there will be very little benefit from any form of energy recovery.
166. The possibility of producing RDF (refuse derived fuel) from the waste can also be considered, but that would require that MEC’s electricity generators can burn pellets (very unlikely) or that another user of RDF pellets can be identified within RMI. Again, given the small quantities of waste, this is not a financially attractive solution.
6. Thermal Treatment and Disposal of Residues
167. The preferred solution is the incineration of waste on Ebeye. This option would decrease the volume of waste/ residues that have to be deposited on Ebeye, it would reduce the quantity of greenhouse gases emitted, and it would reduce the discharge of pollutants and odors. The environmental benefits would be: (i) the residues after incineration, the bottom ash, constitutes about 20% by weight of the feed, but it is only 7% of the feed by volume;36 (ii) the emission of greenhouse gases would decrease by 73%; and (iii) environmental damage and nuisances would be greatly reduced by burning the waste. The thermal treatment of all waste would ensure that there is no rotting waste generating leachate and odors, no solid waste facility fires, and no habitat for insects, rodents and other vermin.
168. As discussed, the expected expenses associated with burning the waste generated in Majuro could be very high. A similar system in Ebeye would be even less cost effective, as the waste quantities are smaller, so the treatments costs per ton or per household would be even higher. If the population, or local government, is unable to pay for the operation of a waste treatment plant, there will be eventually be problems in terms of inability to keep the facility maintained or to pay all operational costs. This is a situation that will result in a facility either not operating as intended or
36 Adapted from Review of State-of-the-Art Waste-to-Energy Technologies by WSP Environmental Limited (2013).
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ceasing to operate altogether.
169. Therefore, it is vital that the proposed waste treatment facility for Ebeye is affordable. This Feasibility Study endeavors to provide a system that offers good occupational health, safety and environmental standards, whilst keeping operating and maintenance costs at a minimum. The system proposed for Majuro is costly and there are ways to reduce the overall costs: (i) The proposed Majuro thermal plant includes energy recovery to produce electricity. In the associated cost calculations, the revenues from the sale of electricity may just cover the additional costs of operating the waste-to-energy system, though that does not seem likely. The presence of the energy recovery system greatly increases the technical demands on those responsible for plant operation and maintenance. (ii) The proposed system meets all RMIEPA regulatory requirements. It is important that the design and permitting of the future waste treatment facility be mindful of costs. For example, a requirement for annual stack emissions testing can easily increase the annual operating costs by $200,000.
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VI. ANTICIPATED ENVIRONMENTAL AND SOCIAL IMPACTS AND MITIGATION MEASURES
170. The potential environmental and social impacts of the proposed subprojects have been assessed in line with ADB's Safeguard Policy Statement, including assessment of the possible benefits and impacts with regards to (i) sustainable natural resource management; (ii) pollution prevention and abatement; (iii) health and safety; and (iv) climate change. Similar to previous ADB initiatives that improved water and sanitation services in Ebeye (Ebeye Health and Infrastructure, 2002 and 2015), the project will clearly generate significant environmental and related benefits, in excess of the adverse environmental impacts incurred during Project implementation and operations.
171. The project will rehabilitate the existing land disposal waste site and install an incinerator, in an environment setting where the habitat has been highly modified by the existing land use.
A. Design and Pre-construction Impacts
1. Impacts on Physical Resources
172. These impacts relate to management at the design and pre-construction stage of the incinerator, and the management of the existing waste disposal facility including the potential movement of and coverage of existing waste and scrap with consideration of climate change. Also considered, is the appropriate implementation of mitigation measures, to monitor and ensure compliance with environmental regulations and provide environmental and social protection. There are no land resettlement issues.
173. Proper implementation will ensure continuously improving environmental protection activities during design, construction, and operation in order to prevent, reduce, or mitigate adverse impacts. Inclusion of mitigation measures in contract documents for all subprojects, and assurance that the PIU, has adequate capacity to implement the EMP, including training of contractor personnel in the requirements of the EMP, will eliminate or minimize anticipated impacts. The EMP will require updating following the detailed design phase.
174. Mitigation measures include: (i) all projects will pass through the RMIEPA Environmental Impact Assessment (EIA) process under the Environment Protection Act (NEPA, 1984). The IEE report will reviewed by the Chairman of the RMIEPA; (ii) appropriate environmental mitigation and monitoring measures are included in the environmental management plan (EMP). The proposed environmental mitigation measures will form part of the design documents for the project and will be adequately budgeted FOR and included in the contracts for procurement of goods and services. All contractors and subcontractors will be required to comply with the EMP; (iii) contract tender documents will direct the contractor to provide qualified staff for environmental, safety and health, management and monitoring, as specified in the construction EMP (CEMP); and (iv) submission of a construction environmental management plan will be required by the contractor, through the PIU. The plan will address erosion and sedimentation control, waste and materials management, control plans for traffic, noise, and dust.
175. Climate Change/Natural Hazard considerations: Planning for the potential impacts of climate variability, and natural hazards, will help to mitigate against potential impacts which may
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include sea water inundation resulting in the operational failure of the incinerator.
176. Mitigation measures include: (i) planning new infrastructure at a suitable elevation above the current high tide level (utilizing accurate topographic survey); and (ii) ensuring new infrastructure is designed to withstand extreme weather events, such as sea water storm surge and sea level rise.
177. Topography, geology, and soils. For this project, land based earthworks will not have significant impacts on the existing topography, geology, and soils; the site works will be located in the same footprint as the existing waste disposal site. Ebeye, being an atoll island is very flat, with elevation differences of about six meters. Soils are uniform, extremely well drained, coral rubble and carbonate sand.
178. Construction permits. Permits will be obtained from RMIEPA for Earthmoving. A preliminary proposal is required for “each and every proposed development activity.” The preliminary proposal is an initial evaluation to determine whether an action may have a significant environmental effect. The preliminary proposal is evaluated by the EPA General Manager to determine if the action has the potential to have a ‘significant effect on the environment’, if so, a second stage of assessment is required and an EIA must be completed. Submission of the IEE, and accompanying project design plans, to RMIEPA, would serve as the required preliminary proposal.
179. Biosecurity of Imported Plants on Machinery. All construction equipment i.e. bulldozers, excavators, backhoes will be sourced locally where possible or from Gaum and as such will limit any bio-security concerns focusing on plant invasive species control. International bio-security controls for shipping of machinery is required to meet the acceptable cleanliness standards of the relevant countries’ Department of Agriculture or be refused entry into that country. It is the importer’s responsibility to ensure all machinery that arrives in the Marshall Islands to be free from biosecurity risk material, such as soil, seeds, plant and animal materials.
2. Impacts on Ecological Resources
180. The project design proposes that the construction of the site works will be in the same footprint as existing solid waste disposal site where the terrestrial ecology has been extensively modified by the built environment. There are no protected sites in the project area. No mitigation for terrestrial ecological impacts is necessary
3. Impacts on Socioeconomic Resources
181. Land acquisition and resettlement. There are no land acquisition or resettlement issues as the incinerator will be constructed on the footprint of the existing waste disposal site.
182. Construction Impacts. The project construction phase has the potential to result in minimal adverse environmental impacts. The construction phase will occur over a one year period involving construction of the infrastructure previously described.
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B. Construction Impacts
1. Impacts on Physical Resources
183. Climate Change/Air Quality: Construction vehicles, equipment, and generators will emit greenhouse gases during the period of construction but will not be a significant contributor to overall greenhouse gases.
184. The RMI does not have air emissions standards, though solid waste regulations refer to the prevention of air pollution from the collection and disposal of solid waste. Construction vehicles, equipment, and generators will be serviced regularly to reduce emissions.
185. Water Quality: Earthworks associated with the project have the potential to result in increased sediment runoff entering the coastal marine environment. Earthworks will be required for the construction of the concrete pads and associated components for the incinerator. In addition, closure of some of the existing landfill will require coverage of waste using soil or the locally available material to rehabilitate
186. Water quality impacts from earthworks can be mitigated as follows: (i) use of sediment retention fencing, berms, and sandbags around excavations to restrict the release of sediment from the construction site; (ii) immediately re-vegetate and/or stabilize exposed surfaces and stockpiles of excavated materials; and (iii) monitor water quality for near shore waters adjacent to land base earthworks and for waters adjacent to reef trenching works.
2. Impacts on Ecological Resources
187. Terrestrial ecology. The project will not impact on the terrestrial ecology of Ebeye as all construction work will be in the footprint of the existing solid waste landfill site.
3. Impacts on Socioeconomic Resources
188. Construction camp, offices, and laydown areas: It is doubtful that a construction camp will need to be built, as the workforce will be small, but public accommodations are also very limited. There is one hotel in Ebeye and limited apartment rentals available. Given the density of development in the Ebeye residential area, any construction camp would need to be located at either the extreme north or south ends of the island, to avoid disturbance to residents. The KAJUR utility has sufficient laydown area at the power plant site to accommodate storage of materials and equipment. Impacts can be mitigated by the following: (i) laydown areas are established within KAJUR facilities; (ii) workforce accommodations and office facilities utilize the hotel or rental properties; (iii) any camps established are through the approval of KALGOV, traditional leadership, and landowners; (iv) camps are provided with sufficient potable water, shower and toilet facilities (designated male and female); (v) all sites utilized for contractor facilities are restored to the landowner’s satisfaction at end of project. Site cleanup will be inspected and approved by MWIU and KALGOV’s environmental manager; and (vi) the use of local labor to the greatest extent possible.
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189. Worker health and safety: Worker health and safety requirements must comply with the Public Health and Sanitation Act, 1966. The contractor will prepare a health and safety plan (HSP), including an activity hazard analysis (AHA); these will be subject to approval by MWIU and KALGOV’s environmental manager prior to the start of any works. The contractor will appoint a competent person as safety manager, who will conduct initial training for workers, prior to the startup of works, and hold weekly safety meetings through the project duration. Training topics will include review of the HSP and AHA, first aid.
190. Personal protective equipment (PPE) will be provided by the contractor and will include at minimum, safety boots, hardhats, high visibility vests, eye and ear protection, gloves and other protective clothing as necessary.
191. Potential impacts to worker health and safety include (i) unsanitary living and working conditions; (ii) contaminated food and water; (iii) communicable disease; (iv) air and noise pollution; (v) work site accidents. These potential impacts and prevention measures will be addressed in the HSP.
192. Mitigation measures proposed to ensure worker health and safety include: (i) Contractor prepared Health and Safety Plan, including an Activity Hazard Analysis, approved by MWIU and KALGOV’s environmental manager; (ii) Contractor appoints a competent person as safety manager, supervising all health and safety matters; (iii) Contractor safety manager conducts initial worker training and review of AHA. Weekly safety meetings are conducted through the duration of project; (iv) All workers provided with appropriate PPE, as issued by the safety manager. The safety manager trains all workers in the proper use of PPE.
193. Community safety. Impacts of concern to the crowded residential community of Ebeye will focus on contractor vehicle and equipment traffic safety, and work site safety. Residential streets are typically crowded, especially with the large child population on the island. As most residents do not own private vehicles and the main mode of transportation is by bicycle or walking, impacts on residential vehicle access will be minor. The road system is circular around the island, so if vehicle traffic is restricted in one area, locations can be accessed by traveling in the opposite direction. The contractor safety manager must prepare a comprehensive traffic safety plan for the transport of the incinerator to site, to be included in the HSP, with review and approval by MWIU and KALGOV. The safety manager will appoint full time traffic control personnel with stop and go signs, to direct local and construction traffic around all work sites. Mitigation for impacts includes: (i) contractor traffic safety plan, included in the HSP, and approved by MWIU and KALGOV. (ii) full-time traffic control personnel during transport of the incinerator from the wharf to the solid waste disposal site; and (iii) restricted and controlled work site access.
C. Operational Impacts
1. Impacts on Physical Resources
194. Greenhouse gases emissions. The emission of greenhouse gases would decrease by
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approximately 73% by the burning of waste when compared with landfill.
195. Litter Control. In addition, litter losses will be minimized because of the greater control of waste from the site improving both the amenity of the island and local marine ecology.
2. Impacts on Ecological Resources
196. Terrestrial ecology. The project will not introduce impact on the terrestrial ecology of Ebeye as all construction will be in the footprint of the existing solid waste landfill site.
197. Marine ecology. There will be reduction in contaminated water losses generated from the uncontrolled solid waste disposal area to the marine environment. This will lead to an improvement in water quality and marine ecology.
3. Impacts on Socio-economic Resources
198. Potential impacts from incineration of solid wastes - Medical wastes and waste oil: The capacity to dispose of medical wastes and waste oil safely is greatly enhanced by incineration. Medical wastes are presently disposed to the solid waste facility in an unhygienic manner. A large store of waste oil is stored on site and can be used be burnt safely with incineration. Incineration also quickly removes large amounts of solid waste materials form the site, enhancing the visual amenity.
199. Potential impacts from incineration of solid wastes - Air quality: The potential to produce odors is also greatly reduced as the amount of decaying organic matter will be largely removed from the site daily.
200. The control of air quality from emissions will require trained operators to manage operational loads and maintenance schedules so that the incinerator is always working in its optimal range.
201. This would include management: (i) of feeding too big loads at one time (ii) of Introducing excessive quantities of wet waste (iii) of operating at low temperatures (iv) a malfunctioning control system and (v) broken equipment, such as burners, combustion air fans or sensors.
202. The emissions from the stack should be observed each day of operation by the incinerator team on at least two occasions. These observations should be undertaken for one morning and afternoon observation during a combustion cycle.
203. Where black smoke is emitted during the incinerator cycle, this indicates that the incinerator may have been overloaded and smaller loads are required to enhance complete combustion of the load. This knowledge will come with experience of operating the incinerator. Should incomplete combustion i.e. black smoke occur regularly during the incinerator cycle e.g. 2 weeks, a maintenance service outside the regular, maintenance program is required.
204. Poverty analysis: The project will assist KALGOV to implement institutional reforms to enhance the financial and technical sustainability of the solid waste management. The result will be a healthier and more productive population with fewer private and public funds spent on medical services and fewer work and school days lost to illness. Reduction of income poverty will thus be indirect through greater lifetime productivity and earnings together with lower medical expenses.
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VII. INFORMATION DISCLOSURE AND PUBLIC CONSULTATIONS
A. Legislative Framework for Public Consultation
205. Public participation and consultation in the evaluation of project design, planning and implementation is an important part of environmental impact assessment; it can directly reflect the public’s perceptions on environmental quality in the project’s area of influence. Relevant provisions in the local RMIEPA EIA regulation require public consultation through public disclosure, provision for submission of written comments, design review and RMIEPA approval.
206. ADB’s environmental guidelines also have detailed and strict requirements on public participation and consultation. The public consultation processes for this project therefore follow both the RMI requirements and the ADB requirements (Access to Information Policy, 2019).
B. Public Consultation Activities
207. Project preparation included (i) information dissemination, (ii) stakeholder consultation, and (iii) information disclosure.
208. Public consultation. During preparation of the project, consultations were carried out with key project stakeholders on Ebeye to ensure that the final project design has stakeholder ownership and sustainably addresses the needs of project beneficiaries including the Government of RMI, the Kwajalein Leadership, the Kwajalein Atoll Local Government, MWIU and more importantly, the wider Ebeye community. The affected people showed very strong support for the project as it would alleviate ongoing environmental impacts on odor, vector borne diseases, visual amenity as well as mitigate impacts to the marine environment.
209. Results from these consultations were shared with the project feasibility team and incorporated into design. A summary of consultations held are included in Annex 1. During project implementation, MWIU will also undertake the following: (i) consultations with nearby residents before construction activities; (ii) quarterly meetings with the Project Steering Committee; and (iii) community-wide communications campaign encouraging recycling, reducing littering and better hygiene practices with regards to solid waste management.
C. Information Disclosure
210. Separate consultations were held with the RMIEPA to ensure the environment assessment carried out for the project met all the necessary requirements of relevant provisions and regulations of the RMI. Environmental information on the project will be disclosed and this IEE will be made available for review by interested stakeholders at the RMIEPA upon submission. In accordance with the requirements under the SPS, ADB shall post on its website the following documents submitted by MWIU: (i) the final IEE, upon receipt by ADB; (ii) a new or updated EIA or IEE, and a corrective action plan, if any, prepared during project implementation, upon receipt by ADB.
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VIII. GRIEVANCE REDRESS MECHANISM
211. To settle unforeseen issues effectively, an effective and transparent channel for lodging complaints and grievances has been established. Public participation, consultation and information disclosure undertaken as part of the IEE process have discussed and addressed major community concerns. Continued public participation and consultation has been emphasized as a key component of successful project implementation. As a result of this public participation and safeguard assessment during the initial stages of the project, major issues of grievance are not expected. However, unforeseen issues may occur. To settle such issues effectively, an effective and transparent channel for lodging complaints and grievances has been established.
212. This Grievance Redress Mechanism (GRM) serves to address complaints or concerns by persons that may be impacted by the Ebeye Solid Waste Management Project. A grievance is an issue, concern, problem or claim (perceived or actual) that an individual or group wants Ministry of Works, Infrastructure, and Utilities (MWIU), the Project Implementation Unit (PIU) or one of its contractors to address and resolve. The GRM outlines the procedures in which grievances concerning the performance or behaviour of MWIU, PIU, its contractors or employees will be accepted, assessed, and resolved. The GRM aims to reduce impacts and risks of the project and promote mutually constructive and trust-based relationships with the residents of Ebeye.
213. The purpose of this GRM is uphold the project’s social and environmental safeguards performance. It must be noted, however, that existing grievance mechanisms already exist for residents of Ebeye, which should be integrated with processes relating to project-specific grievance claims.
214. Island Level. The community on Ebeye is an established society with existing traditional and cultural grievance redress mechanisms. Community leaders play an active role in resolving everyday community or social disputes on the island. These mechanisms involve the traditional landowners, which under Republic of the Marshall Islands (RMI) law includes the Iroij, Alaps, and Senior Dri Jerbal. It is customary for land-related grievances and/or issues pertaining to structures on land, or relocation or resettlement of persons, to be resolved by traditional landowners. This may also extend to involve local legal systems (such as the Ebeye Police) and/or community level committees, such as the Party of Five and church groups.
215. There may be issues caused by the project that are raised and resolved through these existing community level grievance redress mechanisms. In such cases, the PIU will coordinate with the relevant traditional leaders and authorities to provide assistance, as required, and will record the complaint/outcomes of any dispute. A grievance committee will be established by MWIU General Manager, if required due to the nature and number of grievances. This grievance committee will be established with permission from the traditional landowners to aid in their ability to hear and resolve community level complaints about the project. It will include female representatives of the community. Nonetheless, residents will be encouraged to raise project grievances firstly through project representatives as detailed in this GRM.
216. Project representatives are from Ebeye and are familiar with traditional island-level grievance processes. When the project representative feels the grievance needs to involve traditional landowners and/or local legal systems/committees, they will consult MWIU General Manager first, before inviting traditional landowners, local legal systems or committees to provide support in resolving grievances.
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217. Judiciary Level. The project level process detailed below will not impede affected persons access to the RMI legal system. At any time, the complainant may take the matter to the appropriate legal or judicial authority as per the laws of RMI.
A. Objective
218. The objective of the project GRM is to establish guidelines for accepting, assessing, resolving, monitoring and evaluating grievances concerning the project. B. Scope
219. This mechanism covers policies and procedures related to the management of grievances. It is intended for MWIU/PIU/contractor employees who will process grievance claims, as well as persons wishing to file grievances. C. Principles
220. The GRM has been developed in accordance with the government’s policies and procedures, as well as ADB Safeguards Policy Statement. The GRM is designed to work within existing legal and cultural frameworks, providing an opportunity to resolve grievances at the project level. Specifically, the project GRM has been designed to: (i) Be understandable, culturally appropriate and accessible to project-affected persons, with its availability communicated to residents of the island; (ii) Address a wide range of grievances and concerns – both those based in factual data and those arising from perceptions or misperceptions; (iii) Be transparent, and allow persons to submit a grievance at no cost and without retribution to the party that expressed the issue or concern; (iv) Protect the identity of the persons raising the grievance; (v) Resolve concerns in a timely manner, via consultation with stakeholders, or forward any unresolved cases to the relevant authority; (vi) Report back to the community (through the Project Steering Committee) periodically on the types of cases and how they were resolved; and (vii) Be revised if it is not working effectively.
D. Confidentiality
221. All MWIU and PIU employees, contractor and subcontractor personnel involved in the resolution of grievances are required to keep confidential the nature of the claim, the claimants and the outcomes of the resolution process. MWIU will periodically report back to stakeholders (through the Project Steering Committee) on the types of issues raised and how they were resolved, but this reporting will not feature the names of the aggrieved person/s or claimants, nor provide specific details of the issue/s. E. Procedures
222. Implementing the GRM involves five steps, which are described below in further detail. A project representative will be nominated to act as the grievance officer to receive, review and address project related concerns. The person will be a trusted member of the community and
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knowledgeable about the project, as well as local and legal forms of grievance redress mechanisms on Ebeye.
223. Step 1: Receive grievance claims. Grievances, complaints, and concerns are to be submitted to grievance officer. This can be via MWIU’s contractor or the sub-contractors. Contractor’s and subcontractors will be informed of the GRM, as well as who to notify in PIU/MWIU when a grievance claim has been made. In addition, grievances and concerns can be made: (i) In person at the MWIU office, (ii) verbally via telephone, (iii) In writing by email to MWIU nominated email address, (iv) in writing by letter sent or delivered to MWIU.
224. Step 2: Record and acknowledge grievance claims. Any person (other than the two grievance officers) receiving the grievance claim will notify the grievance officer who will complete a Grievance Claim Reporting Form. The grievance officer will provide the claimant with information about the process, their assigned reference number and the timeframe in which a response can be expected. The following details will be recorded when receiving grievance claims: (i) Date (ii) Manner in which the grievance claim was received (phone, email, letter, in-person etc.) (iii) Name of the person who received the grievance claim (iv) Summary of the grievance claim (v) Name and contact details of the claimant/s
225. All incoming claims to the grievance officer will be acknowledged within three working days, by the quickest method available. If the claim is received by the grievance officer in person or verbally over the telephone, it will be acknowledged on the spot. If the claim is in writing, then an email, telephone call or text message will be returned acknowledging that the grievance claim has been received, with details of the process and timeframe in which a response can be expected.
226. Step 3: Screen and assess grievance claims. Received grievance claims are then screened, assessed and investigated (if required) by the grievance officer to verify validity. This includes establishing the nature of the grievance to determine the measures needed for review and investigation. The grievance officer will either: (i) Assign personnel (including themselves) to complete actions to resolve the grievance, or (ii) Elevate the claim directly to the MWIU General Manager to resolve or facilitate the resolution of the grievance. The General Manager will meet with the claimant and then assign personnel to complete actions or establish a grievance committee to aid in the resolution of the grievance. If required, the General Manager will convene a meeting with the Grievance Committee to assist in resolving grievances. The Grievance Committee will include one landowner, and representative of the Mayor of Kwajalein. Grievances which do not apply to the project will be referred to the appropriate entity, and the claimant notified that this has occurred. The Grievance Claim Reporting Form will be kept up to date regarding the status of the grievance claim and the actions required and completed.
227. Step 4: Decide on a response or resolution and monitor issues. The grievance officer (and the relevant GRM committee when needed) will decide on the response or resolution of the grievance claim and notify the claimant within 20 working days. The response may be in the form of a written letter/email or verbally through a meeting with the claimant/s or a telephone call. The Grievance Claim Reporting Form will be amended to reflect the closure of the grievance claim and future dates for monitoring. All documentation will be filed according to the reference number assigned and remain confidential. Where an agreement on the resolution cannot be reached or if
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the claimant is not satisfied with the resolution, the grievance officer will provide the claimant with the details of the Ministry of Finance, Banking, and Postal Services (Executing Agency).
228. Step 5: Evaluate the GRM and report periodically. On a periodic basis, the grievance officer is to publish an evaluation report on the types of grievance claims and cases that were received and how they were resolved. The evaluation will include a report on the: (i) number and types of grievance claims received; (ii) number of claims that have been resolved/reached agreement; (iii) number of claims that have gone to grievance committee; and (iv) number of claims unresolved. The report should also include an assessment of the effectiveness of the GRM and PIU in responding to the grievance claims. This report will be shared with the Project Steering Committee.
F. Communication of the GRM
229. It is the responsibility of the PIU to ensure the Ebeye community is informed of the GRM. The PIU has translated the GRM into Marshallese and will provide details/training about the GRM to new contractors and the Project Steering Committee (scheduled for month year). Information about the GRM will be publicized at the following locations or events: (i) at MWIU office; (ii) at construction sites or at the contractor’s management office (if one is set up); (iii) notice boards on the island; and (iv) at meetings held with stakeholders.
G. Resources
230. Financial resources to cover the operational costs of the GRM are part of the project budget. Costs for resolving grievance claims will come out of contingency funds set-aside for unanticipated social and environmental impacts during design and construction. Costs for grievances made during the operation phase will be shouldered by MWIU.
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IX. ENVIRONMENTAL MANAGEMENT PLAN
A. Introduction
231. The environmental and social assessment has determined that the Project will have less than significant impacts on the local environment. The project can be implemented in an environmentally acceptable manner with appropriate mitigation measures to avoid or minimize the environmental impacts.
232. The EMP includes: (i) implementation arrangement, mitigating measures to be implemented, and (iii) required monitoring associated with the mitigating measures. It also describes institutional roles and responsibilities during pre-construction, construction, and operation phases. Given that there are two major civil work activities that require separate expertise, two EMPs have been prepared to cover both landfill closure and seawall activities as well as the construction and operation of the new thermal plant.
B. Institutional Arrangements
1. Institutional Arrangements, Roles and Responsibilities
233. The Ministry of Finance, Banking, and Postal Services, RMI is the Project executing agency and MWIU is the implementing agency, operating through a PIU which will include various specialists.
2. Project Implementation Unit
234. MWIU will establish a PIU to prepare and implement the Project. The PIU will include an environment safeguards officer (ESO) who will receive training and capacity building form the international environmental specialist (IES). Together the ESO and IES will ensure that all subprojects are implemented in accordance with the Project’s EMP, environmental assessments are prepared, and development consents are obtained, and compliance with each subproject EMP and development consent conditions is monitored and reported.
3. Construction Contractors
235. The contractors undertaking the works will be responsible for ensuring that their activities comply with the environmental safeguard requirements of the contract including the technical specifications. The contractor will prepare a CEMP for review and approval by the PIU. The CEMP will be activity, site and subproject-specific and detail how the contractor intends to meet the environmental management requirements identified in the EMP of the IEE. It will be designed to ensure that appropriate environmental management practices are applied throughout the construction period. The CEMP will include all of the site-specific and sub- plans necessary to meet the standards and targets set out in the EMP. The contractor will be required to employ a full-time environmental health and safety officer (EHSO) to ensure compliance with all requirements concerning environmental, health and safety, and labor regulations during construction.
4. RMIEPA
236. The RMIEPA will review the development consent applications and issue, either with or without conditions. The RMIEPA will be invited to participate in joint inspections and audits during
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construction activities.
237. A summary of the environmental management responsibilities for the Project is presented in Table 3.
Table 3: Summary of Environmental Management Responsibilities in the Project
Project Implementation Management Roles and Responsibilities Organization Asian Development Bank • Review and approve IEEs/EMPs • Review bidding documents • Review executing agency and implementing agency’s submissions for procurement of goods, equipment, works and services • Conducts project review missions, midterm review mission and project completion review mission to assess project implementation progress of all outputs, compliance of project to covenants including safeguards requirements • Review semi-annual and annual EMR • Provide environmental and social safeguards capacity building to the PIU during missions and remotely. Ministry of Finance, Banking, and • Guide and monitor overall project execution Postal Services • Financial oversight • Ensure flow of funds to the implementing agency and the timely availability of counterpart funding
Project Steering Committee • Responsible for oversight and providing guidance and (PSC) strategic direction to MWIU and PIU with respect to project implementation • Ensure that the PIU is provided with the necessary resources to effectively carry out its duties and responsibilities. Ministry of Works, Infrastructure and • Responsible for overall project implementation and monitoring Utilities (MWIU) at the implementing agency level • Ensure adequate funding available for the PIU • Submit semi-annual and annual monitoring reports to ADB • Assist in resolving complaints brought through the GRM that have not been resolved at lower levels
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MWIU, Project Implementation • Responsible for overall project management, implementation Unit (PIU) and monitoring • Review and coordinate evaluation of bids for works, goods, and consultant services • Responsible for SW’s application for a Development Consent • Prepare the IEEs and EMPs based on the detailed design and submit to ADB for clearance • Ensure environmental safeguard concerns are incorporated in the detailed engineering design • Disclose safeguard documents, as appropriate • Conduct awareness and consultations as per the CCP • Monitor on site construction progress and quality • Engage as appropriate specialist consultants in order to complete specific engineering inspections as required • Receive and answer all contractor related requests for information, extensions of time and variations. • Arrange and attend regular progress meeting on site • Recommend changes to the drawings, specifications and program for the employer’s approval. • Submit monthly, quarterly, semi-annual, and annual monitoring report to SW Management • Review and clear the CEMP of contractors • Review contractor’s monthly reports • Implement the GRM and maintain records of complaints/grievances • Ensure the contractor observes the GRM requirements • Ensure contractor compliance with required resources for mitigation measures as reflected in the CEMP PIU Environment Officer • Ensure IEEs/EMPs are updated based on changes in site conditions, if required, and ensure their disclosure in locations and form accessible to the public; • Coordinate with the preparer of bid documents for the inclusion of IEEs/EMPs and CEMP frameworks in the bidding documents and civil works contracts; • Provide training for contractors’ environment and safety officers to ensure they understand the EMP requirements • Ensure required government permits and clearances acquired by SW prior to actual construction activities; • Establish system for monitoring environmental safeguards of the Project as described in the IEEs/EMPs; • Review, monitor, and evaluate the effectiveness of implemented mitigation measures and recommend corrective actions whenever necessary; • Prepare monthly environmental monitoring reports for consolidation to the semi-annual monitoring reports for SW and ADB; • Ensure grievance redress mechanism is activated prior to the start of construction; • During construction, conduct site visits and coordinate with the project engineers to ensure that required environmental mitigation measures are implemented at the construction sites, and • Coordinate with the contractors’ environment and safety officers to ensure that environmental awareness trainings for workers are done.
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Contractor • Prepares and submit prior to construction the CEMP for review by PIU’s Environment Specialist for approval by PIU • Environmental Health and Safety Officer (EHSO) also provides capacity building and training for workers on EMP requirements as needed • Activates an Environmental Health and Safety Officer (EHSO) to ensure that the contractor complies with all requirements concerning environmental, health and safety, and labor regulations during construction • Implement construction activities with the required mitigation measures • Conduct environmental monitoring as required by EMP • Act promptly on complaints and grievances concerning the construction activities in accordance with the project’s GRM • Submit monthly progress reports on CEMP/EMP implementation to PIU
RMIEPA • Responsible for processing of PIU ’s application for a Development Consent • Monitors construction progress for compliance with the terms of the issued Development Consent • Monitors implementation of the mitigation measures and the EMP in general
C. Environmental Mitigations and Monitoring Matrix
238. The two EMPs (including monitoring requirements) are presented below for the Ebeye Solid Waste Management Project (Table 4 and Table 5).
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Table 4: Environmental Mitigation and Monitoring Plan for the Ebeye Solid Waste Management Program – Incinerator
Environmental Means of Issues/ Potential Proposed Mitigation Measure or Mitigation Supervision/ Aspects/ Parameters Implementation Monitoring/ Monitoring Cost Enhancement Measure Cost Monitoring to be monitored Environmental Frequency Impact PRE-CONSTRUCTION Climate change Climate change adaptation measures Part of Contractor MWIU PIU engineering Verify To be undertaken vulnerability are to account for sea water detailed drawings and engineering as per contractor’s inundation as result of sea level rise design specifications drawings and contract and storm surge activity cost considered climate specifications . change adaptation features Implementation of Tender documents and construction Part of Contractor MWIU PIU CEMP CEMP submittal To be undertaken the project’s EMP contract of the for the project will contractor prepared by by contractors as per contractor’s include provisions that will: (i) require s' bid cost contractors to PIU/ prior to contract the contractors to prepare their commencement respective Contractor's Environmental of site works Management Plan (CEMP) prior to the start of the construction activities with details of staff, resources, implementation schedules, as well as monitoring and reporting procedures; (ii) issue a CEMP framework as guidance for the contractor in preparing a CEMP as part of his bid proposal; and (iii) require the PIU to review and approve the CEMP prior to site mobilization. Complaints due MWIU’s PIU and the contractors will: (i) Part of Contractor MWIU PIU Consultation Verify meetings To be undertaken to project- establish the approved project’s contractor and MWIU meetings; specific documentation; as per contractor’s related impacts grievance redress mechanism (GRM); s' bid cost PIU provisions in tender Verify tender contract (ii) publicize the existence of the documents on documents; project’s GRM through public nuisance & verify the in- awareness campaigns, website, problems to public; placed CACs/ billboards, public notifications, etc.; (iii) after ensure that the names and contact completion of numbers of representatives of the meetings; once contractors and SW’s PIU are placed after tender on notice boards at agreed locations documents and/or website. prepared
Environmental Means of Issues/ Potential Proposed Mitigation Measure or Mitigation Supervision/ Aspects/ Parameters Implementation Monitoring/ Monitoring Cost Enhancement Measure Cost Monitoring to be monitored Environmental Frequency Impact Disruption of SW and the contractors will: (i) Part of Contractor MWIU PIU contractor’s verify To be undertaken utilities and coordinate with the other utilities contractors' and MWIU coordination with the contractor’s as per contractor’s services companies regarding the potential bid cost PIU other utility coordination contract disruptions; (ii) make provisions to companies; meetings and preserve the operation of current notification of notifications/ facilities, and affected households after (iii) affected establishments will be and establishments completion of notified well in advance of such meetings and disruptions. notifications Environmental The PIU will employ an Part of MWIU MWIU Number of Visual As part of MWIU Capacity Environmental Officer. On the job MWIU operations Operations inspections and inspection of management Development training for inspections and auditing operational personnel Dept. Mgt. review of sites; plans of Contractor’s CEMP, review of cost contractors’ mid- verification. tender documents for environmental term reports/bid aspects, review of mid-term reports, documents. aspects of water quality monitoring and laboratory methodology and any other aspects of the operation of MWIU will be facilitated by the International Environmental Specialist and others members of SW and external agents. Biosecurity of Where possible, all construction Part of Contractor MWIU PIU Specific provision Verify tender As per contractor’s Imported Plants equipment i.e. bulldozers, excavators, specs in tender documents/ contract; on Machinery backhoes will be sourced locally and as preparation documents once after such will limit any bio-security concerns cost tender focusing on plant invasive species documents control. International bio-security prepared controls for shipping of machinery is required to meet the acceptable cleanliness standards of the relevant countries’ Department of Agriculture or be refused entry into that country. It is the importer’s responsibility to ensure all machinery that arrives in the Marshall Islands to be free from biosecurity risk material, such as soil, seeds, plant and animal materials.
Environmental Means of Issues/ Potential Proposed Mitigation Measure or Mitigation Supervision/ Aspects/ Parameters Implementation Monitoring/ Monitoring Cost Enhancement Measure Cost Monitoring to be monitored Environmental Frequency Impact CONSTRUCTION Soil erosion and The contractor will divert surface Part of Contractor MWIU PIU Disturbed sites; use Visual As per contractor’s sediment of runoffs away from the exposed areas contractors' of appropriate inspection of contract; construction sites and prevent sediments from moving bid cost sediment sites; plans controls verification/ offsite. Measures may include, as daily during appropriate for site conditions: (i) rainy small periods interceptor dikes, (ii) pipe slope drains, (iii) grass bale barriers, (iv) silt fence, (v) sediment traps, and (vi) temporary sediment basins; total exposed area will be minimized as the conditions allow. On-site air The contractor will be required to do Part of Contractor MWIU PIU dust generation, Visual As per contractor’s pollution due to the following: (i) regular water spraying contractor water spraying, inspection of contract construction of work area to minimize dust s' bid cost cover of stockpiles, sites/ daily activities smoke emitting generation; (ii) construction materials equipment, open stockpiles and spoils with potential for burning of materials significant dust generation to be covered or sprayed with water, as appropriate, to prevent fine materials from being blown Solid waste The contractor will be required to: (i) Part of Contractor MWIU PIU construction Visual As per contractor’s management separate solid waste into hazardous, contract wastes; waste inspection of contract non-hazardous and reusable waste ors' bid separation, sites/ daily streams and store temporarily on-site cost temporary on- site in secure facilities with weatherproof waste storage, flooring and roofing; (iii) ensure that regular disposal wastes are not haphazardly dumped records, surplus within the project site and adjacent materials not areas; (iv) regular disposal of wastes removed upon to Landfill; (vi) remove the construction completion wastes from the sites after work completion, and implement the required restoration of disturbed sites.
Environmental Means of Issues/ Potential Proposed Mitigation Measure or Mitigation Supervision/ Aspects/ Parameters Implementation Monitoring/ Monitoring Cost Enhancement Measure Cost Monitoring to be monitored Environmental Frequency Impact Construction noise The contractor will exert extra efforts in Part of Contractor MWIU PIU Noise levels not to Use of sound As per contractor’s reducing the noise generation from his contractors exceed 55 dB(A) levels meter; contract activities near residential areas. The ' bid cost near residential visual contractor will: (i) provide prior areas during inspection of notification to the community on daytime and 45 sites/ daily schedule of construction activities; (ii) dB(A) for nighttime; provide noisy equipment with noise noisy equipment reduction covers whenever applicable; not to be operated (iii) position stationary equipment that between 19:00 produce elevated noise levels, such as – 06:00hrs; diesel generators and air compressors, regular noise level as far as practicable from houses and monitoring by other receptors; (iv) prohibit operation contractor of noisy equipment and construction works in populated areas and where sensitive receptors are found during nighttime (19:00 – 06:00); (v) make prior notification and consultation with the affected people and local officials for necessary nighttime operation (vi) conduct regular noise level monitoring to determine compliance with WHO guidelines for noise which should not to exceed 55 dB(A) near residential areas during daytime and 45 dB(A) for nighttime
Environmental Means of Issues/ Potential Proposed Mitigation Measure or Mitigation Supervision/ Aspects/ Parameters Implementation Monitoring/ Monitoring Cost Enhancement Measure Cost Monitoring to be monitored Environmental Frequency Impact Vehicular The contractor to: (i) prepare a traffic Part of Contractor MWIU PIU contractor’s traffic traffic plans As per contractor’s traffic plan and provide traffic management contracto plan and traffic verification; contract congestion personnel to direct the flow of traffic in rs' bid management visual and hindrance the vicinity of the construction site and cost personnel; traffic inspection of to public construction-related facilities; (ii) signs in vicinity of sites/ daily access closely coordinate with local authorities construction sites; for any closure of roads or rerouting of contractor’s work vehicular traffic; (iii) provide traffic schedule related to signs in the vicinity of the construction festivities, sites to direct motorists and processions, pedestrians; and (iv) minimize parades, etc. disruption to local activities by timing the construction activities with consideration to the schedules of festivities, processions, parades, etc.
Community The contractor to: (i) use barriers and Part of Contractor MWIU PIU work sites safety work sites As per contractor’s health and install signage to keep the public and contracto plan; warning safety plan contract safety landfill workers away from rs' bid signs, barricades, verification; constructions sites and excavation cost and night visual sites; (ii) provide security personnel in lamps for open inspection of hazardous areas to restrict public excavations, lighting sites/ daily access; (iii) operate construction night system for nighttime light at the vicinity of construction sites; operations; adequate and (iv) whenever necessary, provide safe passageways adequate safe passageways for the for the public public crossing the construction sites crossing the whose access to properties, construction sites establishments, etc. has been disrupted or blocked by the ongoing construction activities
Environmental Means of Issues/ Potential Proposed Mitigation Measure or Mitigation Supervision/ Aspects/ Parameters Implementation Monitoring/ Monitoring Cost Enhancement Measure Cost Monitoring to be monitored Environmental Frequency Impact Occupational The contractor to implement good Part of Contractor MWIU PIU Health and safety Health and As per contractor’s health and practices on occupational health and contracto plan; first aid safety, plan contract safety at work safety at the construction sites by: (i) rs bid station; PPE, verification; sites implementing a construction site health cost sanitation, facilities; visual and safety management plan firefighting inspection of (CSHSMP), (ii) ensuring that an equipment and fire sites/ daily equipped first aid station is available at extinguishers all times, (iii) providing the workers with potable water and adequate sanitation facilities, (iv) providing the workers with personal protective equipment (PPE) to minimize exposure to a variety of hazards, and (v) providing firefighting equipment and fire extinguishers in workshops, fuel storage facilities, and any sites where fire hazard and risk are present. Potential Measures include: (i) induction of the Part of Contractor MWIU PIU Check Records As per contractor’s social issues workers on requirements of the contracto implementation verification contract due to influx project’s regarding community health rs' bid of worker’s and visual of imported and safety, grievance redress cost induction, inspection at workers mechanism, and consultation and required protocol, start of work communications plan; (ii) awareness and and monthly implementation of protocols prevention concerning the workers contact program on the between the local communities; (iii) risk of disease implementation of a communicable spreading disease awareness and prevention program on the risk of disease spreading including sexually transmitted diseases and HIV and (iv) contractor’s yard will be secured by a fence and provided with warning signs to control unauthorized access and prevent entry of the public. OPERATIONS Public health Mitigations include: (i) identification Part of MWIU MWIU Written Verify Visual inspection risk due to of potential causes of unplanned MWIU operations Operations management regular
Environmental Means of Issues/ Potential Proposed Mitigation Measure or Mitigation Supervision/ Aspects/ Parameters Implementation Monitoring/ Monitoring Cost Enhancement Measure Cost Monitoring to be monitored Environmental Frequency Impact unplanned outages and emergencies shall be operatio personnel Dept. Mgt. procedures for inspection outages and conducted during operation of the nal cost unplanned and emergencies incinerator and updated as outages and maintenanc of the SWM necessary; (ii) written management emergencies; e/ weekly; system procedures for unplanned outages schedule of verify and emergencies (iii) regular inspection and implementat inspection and maintenance of the maintenance of ion of incinerator to ensure that the incinerator, operating incinerator is in good working emergency procedures conditions; (iv) written standard backup systems manual/ operating procedures manual to be standard weekly; available at the facilities to provide operating guidance to the SWM system’s staff procedures on how to handle unplanned outages manual for and emergencies; (vii) regular unplanned training of incinerator system’s staff outages and on how to handle unplanned outages emergencies; and emergencies training of SWM system’s staff; Upgrade Measures to reduce the operational Part of MWIU MWIU visual visual inspection operational risk and safety to upgrades include: MWIU Operations Operations inspection, risk and (i) workers will be trained on operatio Dept. Dept. Mgt records safety health and safety aspects of nal cost verification/ operating an incinerator; (ii) a weekly facility health and safety manual will be prepared to address the prevention, reduction and control of occupational injury and illness. The manual will among others: clearly identify conditions that may cause acute worker’s health and safety problems, specify requirements that all workers should comply during normal operations and emergency situations, and specify training requirements for health and safety; (iii) provide the workers with the appropriate PPE for incinerator operation and (iv) provide the
Environmental Means of Issues/ Potential Proposed Mitigation Measure or Mitigation Supervision/ Aspects/ Parameters Implementation Monitoring/ Monitoring Cost Enhancement Measure Cost Monitoring to be monitored Environmental Frequency Impact facility with a five-foot- high fence to control access and avoid exposing the public to any hazard due to the presence of the incinerator. Operational phase impacts will Part of MWIU MWIU use of facility health visual visual inspection Operational phase include risks to employee and MWIU Operations Operations and safety manual, inspection, impacts for risks public safety; health hazards due to operation Dept. Dept. Mgt incinerator handling records to employee and incinerator operator. al cost procedures, workers’ verification/ public safety; PPE for incinerator weekly health hazards Operators will prepare health and operator due to poor solid safety maintenance manuals that waste include Health and Safety management considerations to address the control prevention, reduction and control of occupational injury and illness in operating the incinerator. The manuals will include information on: (i) clearly identifying conditions that may cause acute worker health and safety problems, (ii) requirements that all workers should comply during normal operations and emergency situations, and (iii) training requirements for health and safety in operating the incinerator. The control of air quality from Part of MWIU MWIU visual visual inspection Air quality of emissions will require trained MWIU Operations Operations inspection, emissions to be operators to manage operational operation Dept. Dept. Mgt records maintained loads and maintenance schedules so al cost verification/ that the incinerator is always working weekly in its optimal range.
This would include: (i) management of feeding too big loads at one time (ii) Introducing excessive quantities of wet waste (iii) Operating at low temperatures (iv) A malfunctioning control system and (v) broken equipment, such as burners,
Environmental Means of Issues/ Potential Proposed Mitigation Measure or Mitigation Supervision/ Aspects/ Parameters Implementation Monitoring/ Monitoring Cost Enhancement Measure Cost Monitoring to be monitored Environmental Frequency Impact combustion air fans or sensors
The emissions from the stack should be observed each day of operation by the incinerator team on at least two occasions. These observations should be undertaken for one morning and afternoon observation during a combustion cycle.
Where black smoke is emitted during the incinerator cycle, this indicates that the incinerator may have been overloaded and smaller loads are required to enhance complete combustion of the load. This knowledge will come with experience of operating the incinerator.
Should incomplete combustion i.e. black smoke occur regularly during the incinerator cycle e.g. 2 weeks, a maintenance service outside the regular, maintenance program is required.
Table 5: Associated Works at Landfill Prior to Incinerator Installation (Landfill Closure and Sea Wall Construction)
Environmental Aspects/ Means of Issues/ Potential Proposed Mitigation Measure or Mitigation Supervision/ Implementation Parameters to be Monitoring/ Monitoring Cost Enhancement Measure Cost Monitoring Environmental monitored Frequency Impact PRE-CONSTRUCTION Implementation of the Tender documents and construction Part of Contractor MWIU PIU CEMP CEMP submittal To be undertaken project’s EMP contract of the for the project will contractor prepared by by contractors to as per contractor’s include provisions that will: (i) require s' bid cost contractors PIU/ prior to contract the contractors to prepare their commencement respective Contractor's Environmental of site works Management Plan (CEMP) prior to the start of the construction activities with details of staff, resources, implementation schedules, as well as monitoring and reporting procedures; (ii) issue a CEMP framework as guidance for the contractor in preparing a CEMP as part of his bid proposal; and (iii) require the PIU to review and approve the CEMP prior to site mobilization. Complaints due to MWIU’s PIU and the contractors will: (i) Part of Contractor MWIU PIU Consultation Verify meetings To be undertaken project- related establish the approved project’s contractor and MWIU meetings; documentation; as per contractor’s impacts grievance redress mechanism (GRM); s' bid cost PIU specific Verify tender contract provisions in documents; verify (ii) publicize the existence of the tender the in-placed project’s GRM through public documents on CACs/ after awareness campaigns, website, nuisance & completion of billboards, public notifications, etc.; (iii) problems to meetings; once ensure that the names and contact public; after tender numbers of representatives of the documents contractors and SW’s PIU are placed prepared on notice boards at agreed locations and/or website. Disruption of SW and the contractors will: (i) Part of Contractor MWIU PIU contractor’s verify To be undertaken utilities and coordinate with the other utilities contractors' and MWIU coordination with contractor’s as per contractor’s services companies regarding the potential bid cost PIU the other utility coordination contract disruptions; (ii) make provisions to companies; meetings and preserve the operation of current notification of notifications/
Environmental Aspects/ Means of Issues/ Potential Proposed Mitigation Measure or Mitigation Supervision/ Implementation Parameters to be Monitoring/ Monitoring Cost Enhancement Measure Cost Monitoring Environmental monitored Frequency Impact facilities, and affected after (iii) affected establishments will be households and completion of notified well in advance of such establishments meetings and disruptions. notifications Environmental Capacity The PIU will employ an Environmental Number of Visual Development Officer. On the job training for inspections and inspection of As part of MWIU inspections and auditing of review of sites; plans management Contractor’s CEMP, review of tender contractors’ mid- verification. documents for environmental aspects, Part of term reports/bid MWIU MWIU review of mid-term reports, aspects of MWIU documents. operations Operations water quality monitoring and operational personnel Dept. Mgt. laboratory methodology and any other cost aspects of the operation of MWIU will be facilitated by the International Environmental Specialist and others members of SW and external agents. Biosecurity of Where possible, all construction Part of Contractor MWIU PIU Specific provision Verify tender As per contractor’s Imported Plants on equipment i.e. bulldozers, excavators, specs in tender documents/ contract; Machinery backhoes will be sourced locally and preparation documents once after as such will limit any bio-security cost tender concerns focusing on plant invasive documents species control. prepared
International bio-security controls for shipping of machinery is required to meet the acceptable cleanliness standards of the relevant countries’ Department of Agriculture or be refused entry into that country. It is the importer’s responsibility to ensure all machinery that arrives in the Marshall Islands to be free from biosecurity risk material, such as soil, seeds, plant and animal materials.
Environmental Aspects/ Means of Issues/ Potential Proposed Mitigation Measure or Mitigation Supervision/ Implementation Parameters to be Monitoring/ Monitoring Cost Enhancement Measure Cost Monitoring Environmental monitored Frequency Impact Management of Specifications to be provided so that MWIU MWIU MWIUPIU Design spec Monitor during MWIU existing landfill waste the existing waste will be stored in from solid waste construction one part of the solid waste facility with engineer and closure the waste to be covered in accordance with the RMI SWM regulations.
Management of Specifications to be provided so that MWIU MWIU MWIU PIU Design spec from Monitor during MWIU construction of 600m the any planned seawall will be marine/civil construction of sea wall constructed safely. and in accordance engineer with the RMI SWM regulations.
CONSTRUCTION Soil erosion and The contractor will divert surface Part of Contractor MWIU PIU Disturbed sites; Visual As per contractor’s sediment of runoffs away from the exposed areas contractors' use of appropriate inspection of contract; construction sites and prevent sediments from moving bid cost sediment sites; plans controls verification/ daily offsite. Measures may include, as during rainy appropriate for site conditions: (i) small periods interceptor dikes, (ii) pipe slope drains, (iii) grass bale barriers, (iv) silt fence, (v) sediment traps, and (vi) temporary sediment basins; total exposed area will be minimized as the conditions allow. On-site air pollution The contractor will be required to do the Part of Contractor MWIU PIU dust generation, Visual As per contractor’s due to construction following: (i) regular water spraying of contractor water spraying, inspection of contract activities work area to minimize dust generation; s' bid cost cover of sites/ daily stockpiles, smoke (ii) construction materials stockpiles emitting and spoils with potential for significant equipment, open dust generation to be covered or burning of sprayed with water, as appropriate, to materials prevent fine materials from being blown
Environmental Aspects/ Means of Issues/ Potential Proposed Mitigation Measure or Mitigation Supervision/ Implementation Parameters to be Monitoring/ Monitoring Cost Enhancement Measure Cost Monitoring Environmental monitored Frequency Impact Solid waste The contractor will be required to: (i) Part of Contractor MWIU PIU construction Visual As per contractor’s management separate solid waste into hazardous, contract wastes; waste inspection of contract non-hazardous and reusable waste ors' bid separation, sites/ daily streams and store temporarily on-site cost temporary on- in secure facilities with weatherproof site waste flooring and roofing; (iii) ensure that storage, regular wastes are not haphazardly dumped disposal records, within the project site and adjacent surplus materials areas; (iv) regular disposal of wastes to not removed Landfill; (vi) remove the construction upon completion wastes from the sites after work completion, and implement the required restoration of disturbed sites. Construction The contractor will exert extra efforts in Part of Contractor MWIU PIU Noise levels not Use of sound As per contractor’s noise reducing the noise generation from his contract to exceed 55 levels meter; contract activities near residential areas. The ors' bid dB(A) near visual contractor will: (i) provide prior cost residential areas inspection of notification to the community on during daytime sites/ daily schedule of construction activities; (ii) and 45 dB(A) for provide noisy equipment with noise nighttime; noisy reduction covers whenever applicable; equipment not to (iii) position stationary equipment that be operated produce elevated noise levels, such as between 19:00 diesel generators and air compressors, – 06:00hrs; as far as practicable from houses and regular noise other receptors; (iv) prohibit operation level monitoring of noisy equipment and construction by contractor works in populated areas and where sensitive receptors are found during nighttime (19:00 – 06:00); (v) make prior notification and consultation with the affected people and local officials for necessary nighttime operation (vi) conduct regular noise level monitoring to determine compliance with WHO guidelines for noise which should not to exceed 55 dB(A) near residential areas during daytime and 45 dB(A) for nighttime.
Environmental Aspects/ Means of Issues/ Potential Proposed Mitigation Measure or Mitigation Supervision/ Implementation Parameters to be Monitoring/ Monitoring Cost Enhancement Measure Cost Monitoring Environmental monitored Frequency Impact Vehicular traffic The contractor to: (i) prepare a traffic Part of Contractor MWIU PIU contractor’s traffic traffic plans As per contractor’s congestion and plan and provide traffic management contracto plan and traffic verification; contract hindrance to public personnel to direct the flow of traffic rs' bid management visual access in the vicinity of the construction site cost personnel; traffic inspection of and construction-related facilities; (ii) signs in vicinity of sites/ daily closely coordinate with local construction sites; authorities for any closure of roads or contractor’s work rerouting of vehicular traffic; (iii) schedule related to provide traffic signs in the vicinity of festivities, the construction sites to direct processions, motorists and pedestrians; and (iv) parades, etc. minimize disruption to local activities by timing the construction activities with consideration to the schedules of festivities, processions, parades, etc. Community health The contractor to: (i) use barriers and Part of Contractor MWIU PIU work sites safety work sites As per contractor’s and safety install signage to keep the public and contracto plan; warning safety plan contract landfill workers away from rs' bid signs, barricades, verification; construction sites and excavation cost and night visual sites; (ii) provide security personnel in lamps for open inspection of hazardous areas to restrict public excavations, sites/ daily access; (iii) operate construction night lighting system for light at the vicinity of construction nighttime sites; and (iv) whenever necessary, operations; provide adequate safe passageways adequate safe for the public crossing the passageways for construction sites whose access to the public crossing properties, establishments, etc. has the construction been disrupted or blocked by the sites ongoing construction activities
Environmental Aspects/ Means of Issues/ Potential Proposed Mitigation Measure or Mitigation Supervision/ Implementation Parameters to be Monitoring/ Monitoring Cost Enhancement Measure Cost Monitoring Environmental monitored Frequency Impact The contractor to implement good Part of Contractor MWIU PIU Health and safety Health and As per contractor’s Occupational health and safety at contracto plan; first aid safety, plan contract work sites practices on occupational rs bid station; PPE, verification; health and safety at the construction cost sanitation, visual sites by: (i) implementing a facilities; inspection of construction site health and safety firefighting sites/ daily management plan (CSHSMP), (ii) equipment and ensuring that an equipped first aid fire extinguishers station is available at all times, (iii) providing the workers with potable water and adequate sanitation facilities, (iv) providing the workers with personal protective equipment (PPE) to minimize exposure to a variety of hazards, and (v) providing firefighting equipment and fire extinguishers in workshops, fuel storage facilities, and any sites where fire hazard and risk are present. Potential social Measures include: (i) induction of the Part of Contractor MWIU PIU Check Records As per contractor’s issues due to influx workers on requirements of the contracto implementation verification contract of imported workers project’s regarding community health rs' bid of worker’s and visual and safety, grievance redress cost induction, inspection at mechanism, and consultation and required start of work communications plan; (ii) protocol, and monthly implementation of protocols awareness and concerning the workers contact prevention between the local communities; (iii) program on the implementation of a communicable risk of disease disease awareness and prevention spreading program on the risk of disease spreading including sexually transmitted diseases and HIV and (iv) contractor’s yard will be secured by a fence and provided with warning signs to control unauthorized access and prevent entry of the public.
X. MONITORING AND REPORTING
239. Environmental monitoring is required across all phases of subproject implementation. The monitoring meets two objectives to ensure: (i) that mitigation measures are effective in reducing/managing impacts, and identify corrective actions as required; and (ii) that safeguard requirements are being complied with by the contractor and the implementing agency (on behalf of government).
240. Pre-construction monitoring. During the pre-construction phase any gaps in the baseline will be filled. It is in the pre-construction phase where requirements for environmental monitoring in the construction phase can be legally required by placing specific provisions on environmental monitoring in the: (i) subproject specifications, (ii) bidding documents, and (iii) construction contracts. Relevant aspects of each subproject’s EMP shall be incorporated in these documents. The PIU shall verify if these aspects are incorporated in the said documents first during submission of the draft documents and later during submission of the draft final documents.
241. Construction monitoring. Contractors are expected to implement the relevant aspects of each subproject’s EMP as per their approved CEMP during execution of the construction activities as stipulated in their contracts. The contractors’ CEMP will detail the monitoring plan (based on the subproject EMP) with details on staff, resources, implementation schedules, and monitoring procedures (parameters, frequency etc.).
242. Compliance with the approved CEMP will be the basis for inspections and audits by PIU and ADB. The BCD will include provisions requiring the contractor to submit their CEMP which will include a section on monitoring which should be linked to allocation of budget and staff for implementation.
243. Reporting. Overall the Project will establish a system of reporting. The contractor will prepare monthly reports which will include a section on compliance with the approved CEMP, corrective actions, training and the like. This will also record any grievances lodged and project communications undertaken by the contractor. The PIU will review and consolidate information from the monthly reports of all subprojects. The quarterly progress report (QPR) prepared by the PIU will include a section on safeguards implementation summarizing the monthly reports (including training and capacity development activities).
244. A semi-annual safeguard monitoring report will be submitted to ADB. This report will be based on the QPR and will include the environmental performance of each subproject/component.
245. Institutional arrangements. The Ministry of Finance, Banking, and Postal Services and Treasury (MOF) is the executing agency, while MWIU is the implementing agency for the Project. The project steering committee (PSC), is responsible for oversight and providing guidance and strategic direction to MWIU with respect to project implementation. MWIU has established a Project Implementation Unit (PIU) to prepare and implement the project. The PIU is responsible for overall project management, project delivery, safeguards implementation, and monitoring.
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XI. CONCLUSION AND RECOMMENDATIONS
246. The project covered in this assessment offer benefits to Ebeye by ensuring a SWM program that will improve the near-shore marine environments, including water quality, which have been negatively impacted by inadequate leachate collection and treatment, inadequate storm water management, and extensive litter. Public heath will improve by the reduction in breeding habitat for Aedes mosquitoes, the decrease in odour and improvements in visual amenity. The control of air quality from emissions will require trained operators to manage operational loads and maintenance schedules so that the incinerator is always working in the optimal range.
247. The environmental screening process has identified and addressed the environmental and social issues of the proposed projects.
248. Based on the potential environmental impacts and risks of the proposed projects, there are no significant negative environmental impacts or risks that cannot be mitigated or managed. The EMP prepared was used as the basis for preparation of the CEMP prepared by the contractor. Monitoring and reporting of the approved CEMP will ensure that the project is being implemented in an environmentally acceptable manner.
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XII. BIBLOGRAPHY
Asian Development Bank, 2007. TA 6204-REG- Mainstreaming Environmental Considerations in Economic and Development Planning, Processes in Selected Pacific Developing Member Countries. Country Environmental Analysis. Republic of Marshall Island
Asian Development Bank, Safeguard Policy Statement, 2009
ADB Project Concept Paper for Proposed Grant Marshall Islands, RMI: Ebeye Solid Waste Management Project (April 2020)
Asian Development Bank, 2000, Ebeye Health and Infrastructure Project, Project Completion Report, PCR:RMI 32205
Australian Bureau of Meteorology and CSIRO (2014). Climate Variability, Extremes and Change in the Western Tropical Pacific: New Science and Updated Country Reports. Pacific-Australia Climate Change Science and Adaptation Planning Program Technical Report, Australian Bureau of Meteorology and Commonwealth Scientific and Industrial Research Organisation, Melbourne, Australia.
Australian Bureau of Meteorology and CSIRO, 2011. Climate Change in the Pacific: Scientific Assessment and New Research. Volume 1: Regional Overview. Volume 2: Country Reports.
K. E. Fabricius. 2005. Effects of terrestrial runoff on the ecology of corals and coral reefs: review and synthesis. Marine Pollution Bulletin. pp 50, 125-146.
K. Fellenius, D. Hess, April 2014, Benthic Morphology and Marine Life Assessment for the Siting of the Ebeye Wastewater Line, Prepared for the Asian Development Bank via submission to GHD Pty Ltd and Kwajalein Atoll Joint Utilities Resources, Inc. Prepared by University of Hawaii Sea Grant College Program and, College of Marshall Islands.
Coastal Management Framework, Republic of Marshall Islands, produced by RMI EPA, Coastal and Land Management Department, 2008
Ebeye Water Supply and Sanitation Project, Hydrology Report, Tony Falkland, Island Hydrology Services, prepared for GHD, May 2014
Guidance on the Health Hazards of Work Involving Exposure to Sewage in the Water Industry, Clear Water 2010, Water UK, December 2006
Marshall Islands Revised Code 2004, Title 35-Environment, Chapter 1 National Environmental Protection Act (1984).
Republic of the Marshall Islands, 2011. National Climate Change Policy Framework. Office of the Chief Secretary, OEPPC, National DRM NAP Task Force, National Climate Change Committee, SPREP and SOPAC.
Republic of the Marshall Islands, 2011 Census of Population and Housing, Final Report, Economic Policy, Planning and Statistics Office, Office of the President
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Republic of the Marshall Islands, 2013, National Report, Produced by the RMI Ministry of Foreign Affairs in preparation for the Third International Conference on Small Islands Developing States (SIDS) in Apia, Samoa 2014
Republic of the Marshall Islands, Joint National Action Plan for Climate Change Adaptation and Disaster Risk Management 2014-2018, 2014
Republic of the Marshall Islands, National Environmental Protection Act 1984 (Title 35) US Army Corps of Engineers, Ebeye Infrastructure Survey, 2010
US Army Corps of Engineers, Safety Manual EM 385-1-1, 2003
U.S. Army, Engineering District, 1998, Environmental Impact Statement for the Construction of the Palau Compact Road, Babeldaob Island, Republic of Palau. Fort Shafter, Honolulu, Hawaii
USDA NRCS, Soil Survey of Airik, Arno, Majuro, Mili, Taroa, July 1989
USEPA Drinking Water / Public Water System technical assistance and training mission to RMI EPA – September 27-October 10, 2005
United Nations Office for the Coordination of Humanitarian Affairs, 2009. Situation Report, December, 2008.
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XIII. Annex 1: Summary of Consultations
Introduction
The Asian Development Bank (ADB) is presently working on a Project Readiness Financing (PRF) undertaking in Ebeye to assist the Kwajalein Atoll Local Government in preparing the Ebeye Solid Waste Management Project (ESWMP) and assist KAJUR with the Ebeye Water Supply and Sanitation Project (EWSSP) – Extra Financing. Outputs from the PRF are intended to ensure a smooth transition from preparation to design and implementation of the projects, and to minimize contracting delays and guarantee rapid projects start-up. A Project Preparation Facilitator was engaged on 06 May with an estimated completion date of 14 August 2020. This report covers project preparation activities for the months of May and June 2020.
In general, the role of the Project Preparation Facilitator is to facilitate surveys, discussions and agreement with key project stakeholders on Ebeye to ensure that the final project design has stakeholder “ownership” and sustainably addresses the needs of project beneficiaries including the Government of RMI, the Kwajalein Leadership, the Kwajalein Atoll Local Government, KAJUR and more importantly, the wider Ebeye community. However, it was recognized at the onset that the narrow window of opportunity to secure project financing and the inability of international project experts to travel to Ebeye were huge challenges facing this project engagement. It was therefore a huge relief for national consultants in Ebeye to receive support from two local experts from the ADB office in Majuro who traveled to Ebeye for two weeks during this period to provide technical support to national consultants in Ebeye.
Community Consultations
Prior to engaging the community in survey and data collection activities, coordination meetings were held with KALGOV and the Kwajalein senior Alap (Jesse Riketa) to schedule consultations with Iroijlaplap Mike Kabua, the mayor and local council, and the senior land owners (Alaps) of Kwajalein Atoll. The list below outlines consultations that were completed during this period:
1. Asst Secretaty Glorine Jeadrik (MoHHS) …… May 12, 2020 (Romeo) 2. Iroijlaplap Mike Kabua ……………………………… May 14, 2020 (Romeo, Yumi & Alap Jesse) 3. Kwajalein Atoll Local Council & Alap ………… May 25, 2020 (Romeo, Yumi & Scott) 4. Business Community ……………………………….. May 28, 2020 (Romeo & Yumi) 5. Refuse Collection Crew ……………………………. May 31, 2020 (Romeo & Yumi) 6. Mayor Hirata Kabua …………………………………. June 11, 2020 (Romeo, Yumi, Ellen, Denise, Scott) 7. GM Joe Pedro (KAJUR) ……………………………… June 11, 2020 (Romeo, Ellen & Denise)
The primary focus of these initial consultations was to ensure that key government and traditional leaders are aware of the two projects being proposed for Ebeye. Additionally, in a small and closely-knit community such as Ebeye, it is culturally and politically appropriate, even necessary, that leaders are aware of these planned survey and community-wide consultations before these activities take place. Consequently, after project awareness and support was secured with the community leadership, national consultants and survey teams were able to seamlessly implement survey activities throughout the island community. Other planned consultations which have already been planned for the month of July after the ADB virtual mission include the following:
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1. Kwajalein Education Association (KEA) ..….. Pending 2. Kwajalein Atoll Development Authority …… Pending 3. Gugeegue Community ……………………………. Pending 4. Ebwaj Community …………………………………… Pending 5. Looj Community ……………………………………… Pending 6. North Camp Community …………………………. Pending 7. Rest of Ebeye (Community Gym)……………… Pending
The Project Preparation Facilitator had also proposed a Project Working Team with cross- representation from key organizations such as KALGOV, KAJUR, PSS, MOHHS, Youth, Kwajalein NGO’s, and Kwajalein Alaps. The proposed Project Working Team’s listing is with KALGOV awaiting membership confirmation. As conceptualized, this Project Working Team can later continue to serve as the Project Steering Committee during the project design and project implementation phases if KALGOV and KAJUR accept this arrangement.
Presentation Before the Local Council on the Ebeye Solid Waste Management Project (ESWMP) (1:00 PM, 25 May 2020)
The following is a brief synopsis of a presentation done by ESWMP National Consultant Team Romeo Alfred and Yumi Crisostomo before the Kwajalein Atoll Local Council on 25 May 2020 at the Local Government Conference Room in Ebeye, Marshall Islands. The Kwajalein Atoll City Manager, Scott Paul presented the request for this presentation to the Mayor. After receiving a positive response from Mayor Hirata Kabua, and with the understanding that there were other presenters at this council meeting including the Kwajalein Military Base Commander, The Minister of Health and Human Services, and the Kwajalein Atoll Development Authority, the ESWMP Team limited its presentation to only 15 minutes and reserved another five minutes to answer questions.
There were just three questions/comments raised by Iroijlaplap Iroij Mike Kabua, Councilman Telmong Kabua, and Alap Jesse Riketa. All three question/comments centered on sanitation services for communities along the causeway up to Gugeegue; primarily, whether sanitation services to these communities could somehow be included in the ESWMP. Iroij Mike Kabua’s comments were more pointed when he insisted that KADA and the Kwajalein Atoll Local Government seek budgetary allocations to provide for a larger sewage vacuum37 unit with greater capacity to service the needs of communities by the causeway as soon as practical. The full line- up of council members and alap (senior landowners) who were present at this meeting include the following:
Mayor Hirata Kabua 8. Council Member Conny Livai Iroijlaplap Michael Kabua 9. City Manager Scott Paul Council Member Telmong Kabua 10. City Clerk Capelle Antibas Council Member Morson James Jr. 11. Alap Jesse Riketa Council Member Tony Maika 12. Alap Nelson Bolkeim Council Member Michael Luther 13. Alap Rep. Juren Jatios Council Member George Luther 14. Alap Rep. Jerry Jacklick
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Council members listen to Iroijlaplap Mike Kabua explain the needs of communities by the causeway
Consultation with Ebeye’s Business Community on the Ebeye Solid Waste Management Project (ESWMP) (12:00 noon, 25 May 2020)
The following is a summation of a consultation between project team members in Ebeye and representatives from major business operations in Ebeye. The project team generated a list of ten questions to help promote lively discussion among the group. The list of questions is provided in attachment (A). Two major business operators (H2 Imports and Lucky Star) were not represented at this meeting as managers from these two business establishments were not available during the period this consultation was conducted. Businesses that were represented at this consultation included Triple J, DIY, Ebeye Fish Market, Best Choice, Bing’s Store, MIR (Ebeye Hotel), Bank of Marshalls, and Ralik Store.
General Description on the Existing Garbage Collection Service by the Business Community
Under the existing schedule, garbage in Ebeye is collected on Mondays, Wednesdays, Fridays, and Saturdays. On Tuesdays and Thursdays, garbage collection is done for communities along the causeway. Most businesses felt that the existing service is good, as long as equipment are functioning. Some businesses like Ebeye Hotel felt that their business generates waste much quicker than the frequency of collection service established under the existing collection schedule. Consequently, the hotel does its own garbage delivery daily and does not rely on the garbage collection service provided by KALGOV. Similarly, Bank of Marshalls who also operates a retail and food establishment, does its own garbage delivery on a daily to basis. By their estimation, both Ebeye Hotel and Bank of Marshalls generate an average of three full bins daily. Other than Ebeye Hotel and Bank of Marshalls, all businesses rely 90% of the time on the garbage collection
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service provided by KALGOV. The other 10% is for periods shortly after the arrival of the supply barge every two to three weeks when the stores generate more waste from new merchandise
Business operators present include from left: Bruce Bevin (Triple J), Tom Butler (Ralik), Jesse (Best Choice), Samantha Inok (Ebeye Hotel) Romeo Alfred (Consultant), Patrick Bing (Meko Store), Loen Pam (DIY), Lise Sheet (Fish Market), and Yumi Chrisistomo (Consultant). causing huge garbage pile-up in their collection areas. During these periods, business operators supplement the collection and disposal efforts using their own vehicles.
Large businesses operations such as Triple J and DIY were issued the larger size garbage bins. However, based on information shared by these two retail/wholesale operators, they returned the bins that KALGOV issued them and fabricate their own out of woods. Reason being that the bins issued to them were torn from improper use of forklift to lift the bin during garbage collection periods. The Ebeye Hospital ran into similar problem with its government issued garbage bin, and like Triple J, had to get rid of its plastic bin. The hospital now uses a fabricated wooden base garbage bin to contain its general wastes.
Overflowing garbage bins was also noted as a common occurrence among business operators. Some alluded this as another reason why they opted to build their own (larger) trash containers as oppose to using the large plastic container provided by KALGOV which all feel inadequate for their needs.
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A huge tear at bottom of large plastic bin issued to Triple J (left). The wooden garbage collection bin fabricated out wooden pallets (right) is what Triple J is using now.
RMI Legislation banning plastic bags and foam products
All businesses who spoke on the existing legislations on plastics and foams products confirmed that these legislations are being enforced to some extent in Ebeye. Special consideration is given to produce (plastic) bags whereby plastic bags are allowed in the produce section area and used to carry fruits and vegetables. The Ebeye fish market is appreciative of the existing loose enforcement of the ban on plastic bags as it still uses plastic bags to sell its fish and ice. At present, all businesses understand and support the ban on plastic bags given the flexible nature of its enforcement. On the other hand, all businesses present find it unfair that the Container Disposal Legislation (CDL) tax on beer and soda has been enforced in Ebeye for a year now with no mechanism for recycling in place. As the imposed tax is passed down to consumers and no recycling program nor any recycling machines are available on island, the intended benefits to the community is simply not there. A grace period in implementing this CDL tax would have been a more fair and equitable approach for the Ebeye community.
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Segregation of waste is NOT a common practice among business operators although Triple J does segregate its cooking oil. The main issue now is that they (Triple J) has no place to properly dispose of their used cooking oil. Open dumping is practiced by all the rest of the businesses when it comes to disposal of cooking oil. Oil from vehicles and equipment are being transported to the dumpsite for disposal.
On the subject of “Willingness to Pay”, the general feeling among business operators is that everyone should pay for that service. Based on their personal observation, all business felt that is much easier to collect payment for services from businesses than from individual members of the community. And that “everyone should pay a reasonable price” for the service. Unfortunately, some businesses observed that it is just as difficult to collect from the “needy” as it is from the “well off” members of the community. Commenting on pests and rodents, most businesses do not associate the existing problems with flies and rats in Ebeye with businesses’ garbage management practices. It is obvious there is currently an infestation of flies. It used to be seasonal, but it’s been bad for over a year now. Yet, none of the businesses thinks it is linked to their garbage management practices.
Consultation with Refuse Collection Crew (KALGOV)
The following information was taken from a consultation done between ESWMP national consultation project team and employees who are tasked with collecting solid waste throughout Ebeye and the communities along the causeway between Ebeye and Gugeegue. The crew consists of six employees. Only five employees are required to perform this daily operation, permitting normal operations to continue with one person out sick or on scheduled Paid Time Leave. Similar to the format used in the business community consultation, a set of eighteen basic questions were developed to generate discussions among the group. The set of questions are provided in attachment (B). This consultation was done on a Sunday, the only day that garbage collection is not performed.
Composition and Work Schedule
The six-man crew that makes up the Solid Waste Management team comprises of the following team members: 1. Hanner Nuka ………………………………………. Truck Driver & Team Leader 2. Romeak Leon ……………………………………… Truck Bin Operator 3. Kanel Benjamin ………………………………….. Truck Bin Operator 4. Ioseph Rowa ………………………………………. Refuse Collector 5. Takaio Hanchor ………………………………….. Refuse Collector 6. Tony Amlej …………………………………………. Refuse Collector
The crew’s work schedule starts at 8 AM and ends at 5PM Monday through Saturday. Overtime is allowed when the team falls behind schedule and needed additional time to complete their scheduled collection. Their pick-up schedule is broken down into two primary areas of Ebeye Proper and communities along the causeway. The image below shows the tip of Ebeye (farthest right) and the rest of the islands connected by the causeway.
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In any given week, garbage is collected in Ebeye on Monday, Wednesday, Friday, and Saturday. Tuesday and Saturday are set aside for communities along the causeway. There are no specified pick-up points for the garbage truck. During scheduled days for pick-up, families just drag their wheeled garbage bins close to the roadside for easy pick up. Roughly 30 – 40% of bins in Ebeye and communities along the causeway have lost their wheels. In this case it requires two persons to carry these bins with no wheels over to the roadside for collection.
Tools and Equipment
When asked about the adequacy of tools and equipment which are readily available for the Refuse Collection Team to use, the consensus among team members is that one garbage truck is adequate to do the job. However, one truck does not allow much time for the team to properly perform clean up and proper daily maintenance on the garbage truck. By the time they are done collecting, they are tired already and often delay cleaning the garbage truck to the next day or the following day. It is not uncommon for truck cleaning tasks to be delayed for three days. It is almost impossible to do maintenance on the truck because it is constantly used Mondays to Saturdays. The crew is forced to request repairs on the garbage truck only when they run into mechanical issues. In the event of mechanical break-down, the Refuse Crew uses a Front Loader and a regular Dump Truck (pictured below) to resume their island-wide garbage collection efforts.
On the topic of Personal Protective Equipment (PPE) the crew explained that they are providing for themselves. They do not have any protective coverall and had to provide for their own gloves, masks, and safety shoes. They understand that KALGOV is under much financial stress and so they have to do with what they can provide on their own in order to protect themselves on the job. In addition to Personal Protective Equipment, the crew also expressed needs with pressure washer, raincoats, coverall, cleaning tools and of course higher pay. They pointed out that the lowest paid person is being paid $3.15/hr while the highest paid refuse collector gets $3.95/hr.
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With the going price of rice on Ebeye at around $10.00, a waste collector will have to work 2-3 hours just to earn a bag of rice.
Some Challenging Aspects in the Job of the Refuse Collection Team
Improper handling of food waste products and especially adult and baby diapers that are tainted with human feces appears to be the number one undesirable aspect of their job. Some families just place these items in the garbage bins as they are, without using plastic or paper bags even to properly secure these wastes. Occasionally, these types of wastes would splatter on them if they are not careful. It was also noted that a common practice among families in Ebeye is dumping food wastes in the lagoon or ocean. Children are normally instructed by their older siblings to dump food waste products in this manner. We observed one such incident and took the photos below. In the incident we observed below, kids have somehow discovered an empty cooler a few yards from the ocean shoreline and uses it to dump their food wastes to avoid having to go all the way down to the shorelines. Flies and maggots were clearly visible, an indication that the cooler has been sitting there for several days.
Two kids were observed dumping their family food waste in a cooler they discovered among a pile of concrete rubbles close to the ocean. Lagoon/ocean food waste dumping is common.
Some families gather food wastes to feed pigs mostly in communities along the causeway as raising livestock is not permitted in Ebeye. One practice expressed by the team involves the common practice of just throwing their wastes on the ground expecting the refuse crew to gather and load their garbage manually onto the garbage truck. The crew believes that one reason behind this practice is that some families have either lost their garbage bins or their bins are no longer usable due to wear and tear. In either case, the local government is not able to replace old or lost receptacles because there are none available at the moment. The quantity of electric meters that were hooked up to various households throughout Ebeye and communities by the causeway was used to determine the quantity of bins to order. As such, 1,500 small bins and around 10 large size bins were distributed to businesses, schools, and government organizations. Commenting on the conditions of existing bins, the team observed that most are in pretty bad shape and needs to be replaced. If this is to be part of the plan moving forward, the team suggested that the ESWMP team may want to consider a slight modification on bin specifications to allow the next batch of garbage bins to last in Ebeye’s harsh and corrosive environment.
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Pulling the 6-man refuse collection crew on their only day off to discuss garbage collection in Ebeye.
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