49345-002: Wind Power Generation Project

External Environmental Monitoring Report

Project No. 49345-002 Quarterly Report May 2020

Sri Lanka: Wind Power Generation Project

Prepared by the Ceylon Electricity Board, Government of Sri Lanka for the Asian

Development Bank.

This external environmental monitoring report is a document of the borrower. The views expressed herein do not necessarily represent those of ADB's Board of Directors, Management, or staff, and may be preliminary in nature. 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.

i

Environmental & Biodiversity Monitoring Report

Report: 03 Quarterly Report: Period: From October 01, 2019, to December 31, 2019

Project No. 49345-002

Sri Lanka: Wind Power Generation Project

Project No. 47037-005

SRI: Green Power Development and Energy Efficiency Improvement Investment Program – Tranche 2

Package 2: Lot A - Construction of Nadukuda 220/33 kV Grid Substation & Augmentation at Mannar 220/33 kV Grid Substation

Package 2: Lot B1 - Construction of Mannar - Nadukuda 220 kV, 30 km Transmission Line

Prepared by the Ceylon Electricity Board (CEB), Government of Sri Lanka for the Asian Development Bank

ii

CURRENCY EQUIVALENTS (as of 01 September 2019)

Currency Unit = Sri Lanka Rupees (SLR) SLR 1.00 = US $ 0.00571 US $1.00 = SLR 175.11

ABBREVIATIONS

ADB – Asian Development Bank AMSL – Above Mean Sea Level BMP – Biodiversity Management Plan CEA – Central Environmental Authority DS – Divisional Secretary DWLC – Department of Wildlife Conservation EA – Executing Agency EHS – Environment, Health & Safety EIA – Environmental Impact Assessment EMP – Environmental Management Plan EMoP – Environmental Monitoring Plan EPL – Environmental Protection License GPD&EEIIP – Green Power Development and Energy Efficiency Improvement

Investment Program GoSL – Government of Sri Lanka GRM – Grievance Redress Mechanism H&SP – Health and Safety Plan IFC – International Finance Corporation NEA – National Environmental Act O&M – Operation and Maintenance PAC – Project Appraisal Committee PD – Project Director PIU – Project Implementation Unit PMU – Project Management Unit PPE – Personal Protective Equipment RDA – Road Development Authority REA – Rapid Environmental Assessment RoW – Right of Way SPS – Safeguard Policy Statement

WEIGHTS AND MEASURES

km – kilometre km2 – square kilometre m2 – square metre mm – millimetre kV – Kilovolt kW – Kilowatt MW – Megawatt

iii

NOTES (i) In this report, "$" refers to US dollars. (ii) The fiscal year (FY) of the Government of Sri Lanka and its agencies is the Calendar Year

External Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily represent those of ADB's Board of Directors, Management, or staff, and may be preliminary in nature. 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.

iv

Contents

1.0 Introduction .................................................................................................................... 1

1.1 Project description ...................................................................................................... 1

1.2 Objectives of the project.............................................................................................. 1

1.3 Environmental category as per ADB Safeguard Policy Statement (2009) ................... 2

1.4 Monitoring requirement ............................................................................................... 2

1.5 Objectives of the Assignment ...................................................................................... 2

1.6 Objectives of this Report ............................................................................................. 2

1.7 External Monitoring of the implementation of the EMP ................................................ 3

2.0 Implementation of the EMP and the BMP ...................................................................... 4

2.1 Methodology ............................................................................................................... 4

2.2 Project EMP/BMP Readiness Assessment ................................................................. 5

2.3 Compliance Report ..................................................................................................... 6

2.3.1 Compliance with National/Local statutory environmental requirements ............ 7

2.3.1.1 Wind Power Generation Project ................................................................... 7

2.4 Project Progress ......................................................................................................... 8

2.4.1 Wind Power Generation Project ............................................................................ 8

2.4.2 Construction of the Transmission Line and the Grid Sub-Stations ....................... 11

2.4.2.1 Progress of Construction of Mannar – Nadukuda Transmission Line......... 11

2.4.2.2 Augmentation at Mannar 220/33kV Grid Substation ................................... 12

2.5 Implementation arrangement of the EMP /BMP ........................................................ 12

2.6 Implementation of the Environmental Management Plan .......................................... 14

2.6.1 Wind Power Generation Project ..................................................................... 14

2.6.2 Construction of the Transmission Line and the Grid Sub-Stations .................. 27

2.7 Implementation of the Biodiversity Management Plan ............................................... 38

3.0 Implementation of Monitoring Plans ............................................................................. 41

3.1 Implementation of the Environmental Monitoring Plan .............................................. 41


3.1.2 Construction of the Transmission Line and the Grid Sub-Stations .................. 45

3.2 Implementation of the Biodiversity Monitoring Plan (BMP) ........................................ 47


3.2.2 Construction of the Transmission Line ................................................................ 50

3.3 Marine Environmental Monitoring .............................................................................. 52

4.0 Summary ..................................................................................................................... 56

v

ANNEXES

1. Photographs taken during field visits2. Summary of consultations3.1 Summary of Environmental Safeguard Monitoring Reports Received3.2 Summary of Monitoring Reports of Environmental Quality Parameters

Received4.2a Monthly Environmental Monitoring Reports for the Wind Farm and Test

Reports for Water Quality and Air Quality 4.2b Quarterly Environmental Monitoring Reports for the Nadukuda GSS and

Transmission Line and the Soil Test Report 5. Comments on Environmental Safeguard Monitoring Report

LIST OF FIGURES Figure 2.1 Flow chart for the environmental monitoring process 4 Figure 2.2 Status of Project Implementation – Wind Farm 10 Figure 2.3 Status of Project Implementation – Transmission line 12

LIST OF TABLES

Table 2.1 Project EMP/BMP Readiness Assessment 5 Table 2.2 Compliance status with environmental loan covenants 6 Table 2.3 Approvals/Clearances/Permits obtained for the Wind Power

Generation Project 7

Table 2.4(a) Proposed Sequence for Project Implementation – Wind Farm 8 Table 2.4(b) Summary of the Project Implementation Schedule – Wind Farm 10 Table 2.4(c) Summary of Civil Works as on 31st December 2019 10 Table 2.5(a) Summary of Project Contracts - Transmission Line and Grid

Substation 11

Table 2.5(b) Project Progress Status and Implementation Schedule- Transmission Line

11

Table 2.5(c) Project Progress Status and Implementation Schedule – Grid Substation

12

Table 2.6 Project Implementation/safeguard team Table 2.7 Monitoring of implementation of Environmental mitigation

measures – Wind Farm (Environment Management Plan (EMP)

12

Table 2.8 Monitoring of the implementation of Environmental mitigation measures – Transmission Line and the Grid Sub-Stations

27

Table 2.9 Mitigating potential impacts to Marine biology- Wind Power Generation Project

39

Table 2.10 Monitoring mitigating of potential impacts to Marine biology- Transmission Line

40

Table 3.1 Environmental Parameters and Periodicity for Environmental Monitoring Plan- Wind Power Generation Project

41

Table 3.2 Environmental Parameters and Periodicity for Environmental Monitoring Plan- Transmission Line and the Grid Sub-Stations

45

Table 3.3 Monitoring of implementation of Biodiversity Monitoring Plan (BMP) for Wind Farm

47

Table 3.4 Monitoring of implementation of Biodiversity Monitoring Plan (BMP) for Transmission line (Vankalalai sanctuary)

49

Table 3.5 Monitoring of Marine Environment 51 Table 4.1 Overall Compliance with EMP/ EMoP 56

1

1.0 Introduction

1.1 Project description

The Ceylon Electricity Board (CEB) is planning to build and operate a semi-dispatchable wind farm of 100 MW capacity and associated 220 kV transmission line (29.1 km) in the Mannar region under the financial assistance of the Asian Development Bank (ADB) under (i) Wind Power Generation Project, and (ii) Green Power Development and Energy Efficiency Improvement Investment Program – Tranche 2. The wind energy conversion systems (WECS) would be selected for the proposed wind farm to generate clean electrical energy sustainably. The proposed Wind Power Park will be located in the southern part of Mannar Island from Thoddaveli for a length of about 12 km along the coast. A row of 30 (+3 locations set aside for the time being) turbines will be installed parallel to the shoreline. The proposed wind farm has excluded the areas belongs to Adam’s Bridge Marine National Park which has been declared in 2015. The nearest village is located about 800 m away from the second row of wind turbines. Also, several Navy camps/ Navy observation points, boat landing sites, Ma-del hauling sites, and fishermen vaadi/camps (seasonal) and a tourist hotel are found within the wind farm block.

1.2 Objectives of the project

The components of the project are as follows:

1. Sri Lanka: Wind Power Generation Project (Project No. 49345-002): Integrate the 100 MW power from the Mannar Wind Power Generation Project to National Grid network of Sri Lanka.

2. Green Power Development and Energy Efficiency Improvement Investment Program (GPD&EEIIP) - Tranche 2 (Project No. 47037-005)

- Package 2: Lot A - Construction of Nadukuda 220/33 kV Grid Substation & Augmentation at Mannar 220/33 kV Grid Substation

- Package 2: Lot B1 - Construction of 30 km long Mannar–Nadukuda 220 kV transmission line

The impact of the investment project will be increased access to clean and reliable power supply enhanced by 2025. The outcome will be clean power generation increased. The outputs of the investment project are:

(i) Wind power generation increased. This output consists of three subcomponents: (i) 100 MW wind farm constructed in Mannar Island in the Northern Province; (ii) wind park infrastructure developed that involves the construction of the wind park's internal medium voltage infrastructure, internal cabling, access roads, and other arrangements; and (iii) a renewable energy dispatch control centre established to forecast, control, and manage intermittent 100 MW wind power generation.

(ii) System reactive power management improved. This includes installation of 100 Mega Volt-Ampere reactive (MVAr) reactors at the 220-kilo Volt (kV) level at the Anuradhapura grid substation in the North Central Province and a 50 MVAr reactor at the 220 kV level at the Mannar grid substation in the Northern Province to manage voltage levels within the planning limits and practical operational requirements, and ensure reliable operation of the wind park.

(iii) The capacity of CEB in project engineering design review and supervision strengthened. Expert consultancy services will be procured to strengthen CEB's capacity in project engineering design, review, and supervision. These advisory consultancy services will assist CEB in ensuring engineering oversight of wind turbine installation, commissioning and testing activities, and technical certification of contractor's activities throughout the construction period.

2

1.3 Environmental category as per ADB Safeguard Policy Statement (2009)

ADB is extending loan assistance to Sri Lanka’s power sector for Green Power Development and Energy Efficiency Improvement Investment Program with a focus to identify the transmission and distribution projects for the evacuation of renewable energy (wind and solar) parks/ projects and overall improvement of network efficiency. The following are the Project Categorization based on the ADB SPS (2009):

Safeguard Categories

Environment A

Involuntary Resettlement B

Indigenous Peoples C

1.4 Monitoring requirement

The proposed project is located close to the three protected areas: viz., Vankalai Sanctuary, Adams Bridge Marine National Park and Vidathalathivu Nature Reserve. The transmission line passes through Vankalai Sanctuary (7.5 km) which is legally protected under the Fauna and Flora Protection Ordinance and is also designated as a wetland of international importance (Ramsar Sites) under the Ramsar Convention. Due to the location sensitivity of the proposed project, it is considered as a ‘Category A’ project under the ADB Environmental Safeguard project categorization (ADB SPS, 2009). Accordingly, an Environmental Impact Assessment (EIA) was carried out by the Ceylon Electricity Board (CEB), who is the project proponent. In the EIA report, applicable laws/legislation and policy framework have been reviewed, and environmental mitigation measures have been recommended for implementation during construction and operation stages of the project and its associated facilities. Accordingly, a comprehensive Environmental Management Plan (EMP), and Environmental Monitoring Plan (EMoP) were provided with guidelines for detailed construction method statement to be prepared by the Contractor (and sub-contractors). Also, a Biodiversity Management Plan (BMP) has been formulated to ensure no net loss of biodiversity. This Biodiversity Management Plan (BMP) falls under the EMP and is a part of the package of activities designed to meet the requirements of ADB’s Safeguards Policy Statement (SPS) 2009.

1.5 Objectives of the Assignment

The objective of this assignment is to monitor the implementation of relevant mitigation measures recommended by the EMPs/EMoPs and implementation of measures proposed in the BMP for three years during construction and further two years during the operations.

1.6 Objectives of this Report

The Environmental Specialist and the Biodiversity Specialist have now mobilized and commenced the work on External Monitoring of implementing the EMP, BMP and the EMoP by the Project Proponent, Contractors, and sub-contractors of the Mannar Wind Power Generation Project and Package 2 Lot A and Lot B1 of the GPD&EEIIP. The Consultants first met the officials of the Ceylon Electricity Board and collected the documents prepared which described the EMP, BMP and the EMoP for each of the main components of the project. Subsequently, they visited the project areas in Mannar on 19th and 20th October 2019 and then on 6th, 7th and 8th February 2020.

This report serves as the Quarterly Report No. 3 (covering the period of 1 October 2019 to 31 December 2019) of the External Monitoring of the implementation of the EMP, BMP and EMoP. The Quarterly report submitted for 1 April 2019 to 21 June 2019 mainly concerned

3

about the project readiness and compliance of project interventions with local environmental regulations, implementation of the EMP and the EMoP. However, Report No. 2 (July 01 - September 30, 2019) and the subsequent ones will mainly focus on the implementation of the EMP and the EMoP. However, any compliance requirements that arise during construction stage will also be included when and where they are pertinent.

1.7 External Monitoring of the implementation of the EMP

The scope of the work of the Environmental specialist / Biologist for external monitoring of the implementation of the EMP includes:

(i) Perform independent third-party monitoring on the implementation of mitigation and monitoring activities on the physical and ecological environmental components.

(ii) Development of the appropriate methodology and tools for monitoring process, design appropriate forms, formats, schedules and prepare other documents required for successful monitoring activities. Conduct field visits before construction, during project construction and operational period to monitor the implementation of relevant mitigation measures recommended by EMPs/EMoPs.

(iii) Review of mitigation measures and provide advice and guidance on improvements, corrective measures for any shortcomings.

(iv) Assist the implementing agency and Project Implementation Units (PIUs) in making sure the project development is in compliance with the environmental management plan (EMP) and environment protection requirements.

(v) Verify whether the set environmental targets are achieved and recommend remedial measures are adopted.

(vi) Conduct field investigation and monitoring on project environment protection and management regularly.

(vii) Submission of environmental monitoring reports to the CEB and ADB, quarterly during the construction phase and semi-annual reports during operational phase.

4

2.0 Implementation of the EMP and the BMP

2.1 Methodology

The general approach for external monitoring of the implementation of the EMP/BMP and the EMoP. The monitoring approach for environmental monitoring will comprise of the preparation phase, field phase, and desk phase. In the preparation phase, project EMP and BMP readiness will be carried out at the preparation phase by reviewing the EIA reports and the BMP Report, EMPs/EMoPs and provide a recommendation for improvements (Figure 2.1).

During the field phase, implementation of mitigation measures for physical environmental components will be monitored based on major project components which are identified as:

1. Sri Lanka: Wind Power Generation Project: 100 MW power from the Mannar Wind Power Generation Project

2. Green Power Development and Energy Efficiency Improvement Investment Program (GPD&EEIIP) - Tranche 2

• Package 2: Lot A - Construction of Nadukuda 220/33 kV Grid Substation & Augmentation at Mannar 220/33kV Grid Substation

• Package 2: Lot B1 - Construction of 29.1 km long Mannar–Nadukuda 220 kV transmission line

Figure 2.1: Flow chart for the environmental monitoring process (quarterly during the construction phase and semi-annually during the operational phase)

Desk Phase

Oversee implementation of necessary corrective actions and highlight good practice

Provide technical guidance/ feedback to improve and implementation of mitigation

measures in EMPs/ EMoPs.

Field Phase

Monitor the implementation of mitigation of physical and biological/ecological

environmental impacts

Assess the consistency and accuracy with site conditions and compliances.

Preperation Phase

Review the EIA reports, EMPs, BMP and EMoPs

Adequacy checking and provide recommendations for improvement

5

2.2 Project EMP/BMP Readiness Assessment

The Consultants have first assessed whether project proponent is ready to proceed with the proposed construction of the Mannar Wind Power Generation Project and construction of the Transmission Line and the Grid Sub-Station. The Indicators and Criteria are listed below (See Table 2.1).

Table 2.1: Project EMP/BMP Readiness Assessment

Indicator Criteria Assessment

Remarks

EMP - Mannar Wind Power Generation Project

EIA approval and disclosure The EIA was cleared by ADB and disclosed on ADB’s project website

Yes/No

Mitigation measures as described in the EMP adopted during detailed design and construction, preparation and implementation

Measures defined in EIA and EMP are included in detailed designs for each component.

Yes/No EMP and the EMoP have been included as part of Tender/Contract Documents

EMP update Whether the EMP is updated after detailed design and cleared by ADB.

Yes/No An update was not needed

Compliance with loan covenants

The borrower complies with loan covenants related to project design and environmental management planning.

Yes/No

Environmental Monitoring The monitoring parameters, locations, and methods for the ambient air, noise and surface water defined in the EMoP.

Yes/No

EMP - Construction of Nadukuda 220/33 kV Grid Substation & Augmentation at Mannar 220/33kV Grid Substation; Construction of 29.1 km long Mannar–Nadukuda 220 kV transmission line

EIA approval and disclosure The EIA was cleared by ADB and disclosed on ADB’s project website

Yes/No

Mitigation measures as described in the EMP adopted during detailed design and construction, preparation and implementation

Measures defined in EIA and EMP are included in detailed designs for each component.

Yes/No EMP and the EMoP have been included as part of Tender/Contract Documents

EMP update Whether the EMP is updated after detailed design and cleared by ADB.

Yes/No An update was not needed

Compliance with loan covenants

The borrower complies with loan covenants related to project design and environmental management planning.

Yes/No

Environmental Monitoring The monitoring parameters, locations, and methods for the ambient air, noise and surface water defined in the EMoP.

Yes/No

6

BMP

BMP approval and disclosure

The BMP was cleared by ADB and disclosed on ADB’s project website

Yes/No Updated BMP still not provided to the Contractors.

Measures during detailed design and construction, preparation and implementation

Measures defined in EIA and BMP are included in detailed designs for each component.

Yes/No Complied with the requirements and included to the updated BMP

BMP update Whether the BMP is updated after detailed design and cleared by ADB.

Yes/No Complied with the requirements and included to the updated BMP

Monitoring of implementation of the BMP

The monitoring parameters, locations, and methods defined in the BMP and/or EMoP.

Yes/No Fulfilled the requirements

2.3 Compliance Report

The compliance status of the project implementation has two aspects: Compliance status with environmental loan covenants (Table 2.2) Compliance status with National/State/Local statutory environmental requirements (Table 2.3) The purpose of compliance report is to check whether there are any deviations from conditions provided in loan covenants and environmental legislation. If there are any deviations, the action required will be described, in consultation with the PMU. All the consent, approvals, permits, and clearances that are needed for implementation of the project and its interventions have been reviewed and checked as outlined in Table 2.3.

Table 2.2: Compliance status with environmental loan covenants

Activity/Description Status of Compliance/Action Required

Additional Pre-construction (bird) survey A bird monitoring programme for the development should include continuation of pre-construction base-line surveys for a further year to provide more detailed information about bird activity within the wind farm site.

Hence, a pre-construction (bird) survey has been continued for one year until February 2019 to cover full migrating /breeding season by the National Consultant

Photographic Records of the Birds within Wind Farm

The PMU has continued the biweekly photographic records of the birds in the vicinity of the wind farm area. The records are being continued during the migration period and non-migration period.

Consultancy Procurement for Recruitment of a Local Consultancy firm to Monitor the implementation of BMP and EMP

A consultancy firm has been selected for Monitoring the Implementation of BMP and EMP.

This Monitoring Report has been prepared by the Team of External Monitoring Consultants thus selected (Environmental Specialist and Ecologist/Ornithologist)

7

Photographic records during the site clearance for the wind turbine

A complete surveillance photographic records have been kept during the land cleaning process

The Borrower shall ensure that the preparation, design, construction, implementation, operation and decommissioning of the Project and all Project facilities comply with (a) all applicable laws and regulations of the Guarantor relating to the environment, health, and safety; (b) the Environmental Safeguards; (c) the EARF; and (d) all measures and requirements outlined in the respective IEE or EIA, EMP and BMP, and any corrective or preventative actions outlined in a Safeguards Monitoring Report

The CEB has indicated that they are taking every effort to comply with the ADB requirement while NOT affecting the completion of the Project.

2.3.1 Compliance with National/Local statutory environmental requirements

2.3.1.1 Wind Power Generation Project

Table 2.3: Approvals/Clearances/Permits obtained for the Wind Power Generation Project

Clearance/ Permit Status

1 Provisional approval from Sri Lanka Sustainable Energy

Authority Obtained

2 Letter of Intent from CEB to develop the Project N/A

3 Approval from the Coast Conservation Department Obtained 4 Approval from the Divisional Secretary, Divisional Secretariat,

Mannar Obtained

5 National Water Supply and Drainage Board Approval Obtained 6 Irrigation Department Approval Obtained 7 Mannar District Coordination Committee approval N/A 8 District Land Utility Committee Approval N/A 9 District Environmental Committee Approval N/A 10 District Agricultural Committee approval N/A 11 Approval from the Mannar Pradeshiya Sabah To be obtained 12 Generating License To be obtained 13 Civil Aviation Authority Approval for Wind Mast Construction Obtained 14 Approval from Road Development Authority for transportation of

heavy vehicles and equipment N/A

15 Approval from Department of Agrarian Development, Mannar Obtained 16 Approval from Coconut Cultivation Board N/A 17 Approval from the Ministry of Tourism N/A 18 Approval from the Survey Department of Sri Lanka N/A N/A 19 Approval from the Department of Wildlife Conservation Obtained 20 Approval from the Forest Department N/A 21 Approval from the Ministry of Defense N/A

22 Approval from the Department of Archaeology N/A

23 Solid waste disposal arrangement with Mannar Pradeshiya

Sabha during the operational phase of the project SWM Plan will be implemented

with the consultation of the PS

8

2.4 Project Progress

2.4.1 Wind Power Generation Project

Table 2.4(a): Proposed Sequence for Project Implementation

Table 2.4(b): Summary of the Project Implementation Schedule – Wind Farm

9

Status of Project Implementation as of 31 December 2019

The Implementation period of the Mannar Wind Power Project is from May 2019 to November 2020. The major activity of this project includes the construction of access roads, rehabilitation of roads, construction of 30 nos. of wind towers, construction of buildings, bird collision detection system, community roads and sanitary facility for the fishing community.

The following table is giving the summary of the civil work status as of 31st December 2019.

Table 2.4(c): Summary of Civil Works as of 31st December 2019

Activity Unit Total Qty

Actual Qty

Culvert road – Main access road Nos 24 6

Access road1 – Subbase 1st layer m 100 70

Access road 1 - Embankment 1st layer m3 2250 240

Admin building screed concrete % 100 34

Accommodation building- sand filling % 100 17

Subgrade preparation - Accommodation m2 22,000 1,480

WTG foundation – Piling work Nos 451 213

Pile cap Foundation concreting Nos 30 7

On-going work

• Main access road works

• Accommodation building work

• Administration building work

• Piling work: ongoing-Tower 8

• Site clearing for yards and soil storage activities

10

Main access road works Administration building work

Ongoing piling work - Tower 8

Soil storage activities

Figure 2.2: Status of Project Implementation

11

2.4.2 Construction of the Transmission Line and the Grid Sub-Stations

The contract details, including the contract price of the following two lots under Package 2, are as follows.

Table 2.5(a): Summary of Project Contracts

Package 2: Lot B1 Package 2: Lot A

Scope Construction of Mannar – Nadukuda 220 kV Transmission Line

Construction of Nadukuda 220/33 kV Grid Substation & Augmentation at Mannar 220/33 kV Grid Substation.

Contractor KEC International Limited. Siemens Limited, India

Contract Price including change orders

Contract Amount

LKR 426,309,080.00 +USD 6,477,201.00

Change Order 01

LKR 8,240,000.00 +USD 88,638.00

Change Order 02

LKR 3,955,000.00 +USD 21,518.00

Contract Amount

LKR 932,903,081.57 + USD 11,901,167.32

Change Order 01

LKR 5,660,000.00 + USD 476,988.00

Contract Effective Date

October 04, 2017 March 16, 2018

Expected Completion Date

January 23, 2020 (with time extension)

March 16, 2020

2.4.2.1 Progress Status of the Package 2: Lot B1 Construction of Mannar – Nadukuda 220kV Transmission Line

The updated status of environment activities during the period of October 1, 2019, to December 31, 2019, is given below for the Transmission Line.

Table 2.5(b): Project Progress Status and Implementation Schedule

Description Status

Mannar - Nadukuda 220 kV, 30 km transmission line

1. Profile & Tower designs were completed.

2. 90% of Equipment Procurement is completed

3. Erection of towers are in progress – 76 completed

4. 80 foundations were completed

Source: ADB Loan No: 3483/3484 SRI Quarterly Progress Report, Q4, October - December 2019

12

Completed towers in the transmission line

Completed towers in the transmission line

Figure 2.3: Status of Project Implementation – Transmission line

2.4.2.2 Construction of Nadukuda 220/33 kV Grid Substation & Augmentation at Mannar 220/33kV Grid Substation

The updated status of environment activities during the period of October 1, 2019, to December 31, 2019, is given below for the Grid Substations.

Table 2.5(c): Project Progress Status and Implementation Schedule

Description Status

Construction of Nadukuda 220/33 kV Grid Substation & Augmentation at Mannar 220/33 kV Grid Substation

1. Design works are in progress up to 90%

2. Equipment procurement is in progress

3. Control room building is in progress.

4. Transformer foundation works are completed

Source: ADB Loan No: 3483/3484 SRI Quarterly Progress Report, Q4, October - December 2019

2.5 Implementation arrangement of the EMP /BMP

Table 2.6: Project Implementation/safeguard team

Name Designation/Office Email Address Contact Number

1. PMU (Transmission)

Eng. H.K.Illeperuma Project Director [email protected] 0714150724

Eng. Anuruddha Tilakaratne

Project Manager [email protected] 0714150634

Eng. K.Ramjee Project Engineer (Electrical)

[email protected] 0718740954

13

Eng. P.G.W.P.Manjula Project Engineer (Civil) [email protected] 0712309381

2. PMU (Wind Farm)

Eng. D.D.U. Dompage Project Director [email protected] 0714115587

Eng. Ajith Alwis Project Manager (WFS) [email protected] 0714150639

Eng. Thusitha Eranjeewa

Project Engineer (Electrical)


Eng. Randula Wijeratne

Project Engineer (Electrical)


V. Chandrasegaran ESSS [email protected] 0777253047

mailto:[email protected]

14

2.6 Implementation of the Environmental Management Plan


Table 2.7: Monitoring of implementation of Environmental mitigation measures – Wind Farm (Environmental Management Plan (EMP)

Project Activity Potential Environmental

Impact

Mitigation Action Monitoring Scope/Standard

Responsibility of Implementation

& schedule

Observations and Remarks

Pre-construction

Temporary use of lands

Impact on the existing environment

39 turbine locations are available for the EPC contractor to use provided they can demonstrate that the impact at receptors will be same or less than that presented in this EIA

Selection of lands adhering to local laws and regulations and in close consultation with LAs

Restrictions on location of temporary infrastructure: Tower foundations should be placed at least 140 m away from the coastline, 25 m from water channels, natural flow paths, important ecological habitats and residential areas.

Air, Water, Noise and Soil quality

The baseline for air pollution, water pollution levels (Air quality Standards, CEA water quality standards and Noise standards etc.)

CEB

Detailed design

This condition/mitigation measure has been complied with.

The locations for the wind turbines have been finalized, and all the locations are at least 140 m away from the coastline.

The selection has been made in compliance to and accordance with the local laws.

The contractor has already measured the baseline parameters on air quality, surface and groundwater and noise and vibration.

All these reports have been submitted (which have been included in the External Monitoring Report for July-September 2019)

- Air Quality (Baseline)

- Noise and vibration (Baseline)

- Water quality

- Soil investigation report

Wind turbine generator location and design

Noise generation Exposure to noise, Nuisance to neighbouring properties

EPC Contractor to develop a communications plan and appoint a fisheries liaison officer and community liaison officer

Undertake pre-construction noise monitoring following IOA and ETSU methodology and collate concurrent wind data at 10 m height for a minimum period of two weeks during the SW and NE monsoon in order that background

Expected noise emissions based on wind turbine generator design, noise levels

Turbine design and layout and

CEB

Detailed Design

EPC contractor has not yet developed the communications plan

Pre-construction noise monitoring has been completed.

Detailed designs are not available yet to confirm noise minimization.

Protocol for the operation of low noise mode

15

noise levels correlated to wind speed are available during both high and low wind speed seasons

Noise levels should first be minimized through design. Turbines to be sited to ensure noise limits (turbines + background) can be met and minimize the magnitude of change in noise level at adjacent properties Noise assessment following good international practice (assess octave frequencies as well as broadband sound) to be run for final turbine design and layout. The noise modelling assessment must demonstrate that during all months of the year (including the low wind speed season when low noise environment occurs) that the noise limits (B+T) can be met. Turbines must not have a tonal component unless this is included in the noise modelling assessment, and it is demonstrated that the noise limits can be met with it included.

accompanying noise assessment to be cleared by CEB and receive no objection from ADB before CEB can approve the Contractor’s design /

Noise control regulations in 1994 Noise levels to be specified in EIA

(shut down) has to be prepared for implementation during the operational phase

The contractor has already measured the baseline parameters on noise and vibration.

All these reports have been submitted (External Monitoring Report for July-September 2019)

However, it has to be noted that the Noise levels measurements have been carried out per the methods laid down In ISO 1996 Part 1, 2 and 3, and BS 4142:1990, as stipulated in National Environmental Noise Control Regulations of 1996.

As suggested in the EMP, the noise levels have to be measured following IOA (Institute of Acoustics) and ETSU-R-97 procedures.

This has been communicated to the Contractor.

The turbine design has yet to be finalized.

Cut and fill operations

Disturbance to the adjacent lands and the people due to cut and fill operations

Maintain clearance, construction of retaining structures, minimize cut and fill operations adjoining to the dwellings

Proximity to houses and other structures / Technical specification

CEB

Detailed Design

This is not applicable, as there are no structures adjoining land plots identified for wind turbines

There are no cuts and fill operations envisaged, other than excavations and trenching for foundations and footings

Location of Wind turbines and their alignment on coast and design

Exposure to safety-related risks

Turbines to be sited to achieve set back of 1.5 x turbine height. If 1.5 x turbine height cannot be achieved, RP to be updated to include for resettlement of the affected properties Turbines to be designed with vibration sensors that can react to any imbalance in the rotor blades and shut down the turbine.

Turbines to be designed with a lightning protection system.

Turbines selected to be subject to independent design verification/certification (IEC 61400-1)

Wind turbine location with respect to nearest dwellings / Setback distances to nearest houses

Review of turbine design and layout including updated blade throw assessment and operational protocol /

CEB

Part of detailed survey and design

These conditions have to be confirmed after designs are finalized. The following are needed from the Contractor:

• Turbines to be sited to achieve set back of 1.5 x turbine height.

• Turbines to be designed with vibration sensors that can react to any imbalance in the rotor blades and shut down the turbine.

• Turbines to be designed with a lightning

16

and surveillance of manufacturing quality.

No injury or loss of life as a result of blade throw (as per IFC-WB EHS Guidelines on Wind Energy)

protection system.

• Turbines selected to be subject to independent design verification/certification (IEC 61400-1) and surveillance of manufacturing quality.

Impact on water channels/land/ residences

Consideration of Wind turbine location where they could be located to avoid avian breeding areas, water channels by a minimum of 25 m. Follow IFC-WB EHS Guidelines for avoiding water pollution.

Site location selection (distance to dwelling, water channels and/or agricultural land)/

CEB

Part of detailed project sighting and survey and design

Wind turbine locations have been selected to comply with this provision

Encroachment into precious ecological areas

Loss of precious ecological values/ damage to precious species

Qualified Ecologist will be engaged by the EPC contractor.

The ecologist will mark out and record the location all endemic and locally EN plants as well as Palmyra and coconut in and adjacent the construction working area. Hard standing area and access roads to be pegged out to minimize loss of these species. If T3 and T36 used, then hard standing design to be given careful attention to see if fewer than five endemic Neralu trees can be lost.

At each turbine location, no more than 0.7 ha will be cleared permanently for the activities of construction of wind turbine and the vegetation (herbs, shrubs and trees) in the rest of the area (2.25ha-0.7ha) used for the hard standing area will be allowed to grow back.

The ecologist will record the baseline situation and monitor the continued presence of vegetation, especially the endemics and locally EN plants during the construction.

Floral and faunal habitats loss in coastal area / Flora and Fauna Protection Ordinance.

CEB

Detailed design

EPC contractor has already appointed a qualified Environmental Safeguard Officer. However, qualified Ecologist has not been appointed by the Contractor.

The mitigation measures stated in the EIA/EMP are being implemented.

Proper records have not been maintained for the turbine locations with regard to conservation status of flora.

Interference with drainage patterns/water channels

Temporally flooding hazards/loss of ecology in water channels

Siting of Wind turbines at least 5-10 m away from Thonas (water channels) to avoid disturbing habitats in water channels.

Site location Selection

Sri Lanka Land Reclamation and Development

CEB

Detailed alignment survey

This condition has been complied with.

17

Corporation (SLLRDC) recommended measures to avoid adverse effects on the natural drainage system within the area from project construction /

Irrigation Act, 1933. Consultation with local authorities and design engineers SLLRCD recommendation

and design

Explosions/Fire Hazards to life Provision of firefighting equipment to be located close to sub-transformers, power generation equipment.

Sub-transformer design compliance with fire prevention and control codes /

Tender document to mention detailed specifications

CEB

Part of detailed layout and design /drawings

The detailed design has been completed to verify this condition.

Wind Farm layout of its facilities

Temporary Jetty impact on marine flora and fauna

Collate daily and monthly fish catch data for 2-year prior for fishermen in the project area and a representative control site.

Survey and undertake a translocation of any trans-locatable marine flora and fauna located within the working area of the jetty to similar habitat away from the working area

Undertaken nightly survey the beach working area for at least 60-days prior construction (depending on the time of year in relation to nesting season) to identify any turtle nests and if found fence off the nest and buffer zone from construction working area to avoid disturbance

No bright or white lighting to be installed on turbines and the design of associated infrastructure to ensure no light spill onto the

Fish Catch Survey Visual Survey of beach for turtle nests Visual Survey of the jetty area to observe any marine flora/fauna /

None

CEB together with Department of Coastal Conservation


This is not applicable as the jetty will not be constructed.

18

beach

Healthy and Safety Environment (HSE)

Occupational and community health and safety

Turbines selected to be designed to international good practice standards (IEC 61400) and have means of working at height systems fitted to them.

EPC contractor to ensure all staff have received appropriate health and safety training and are competent for their role before the commencement of work, including working at height, working over water, and lifting operations. EPC contractor to develop a traffic management plan covering the import of materials and staff by road and use of local access roads for construction of the wind farm. Undertake a baseline survey to determine the condition of existing roads which will be used for importation.

No injury or loss of life to construction staff or members of the public (records of near-miss, minor, major and fatal health and safety incidents to be maintained and monitored during the construction phase)


Designers have to confirm that the turbine designs conform to good international practice.

EPC contractor has to provide details of the proposed training module on Health and Safety at work.

Construction

Construction at the wind farm

Adverse impacts to flora/fauna/receptors in the area

EPC contractor to develop detailed site-specific Construction Method Statement based on the outline construction management plan and measures set out in the general EHS Guidelines for construction and demolition and the sector IFC-WB EHS guidelines for Wind Energy.

Project area/

EIA document and all regulatory requirements of Sri Lanka and IFC-WB EHS guidelines

CEB and EPC Contractor

Prepare before the start of construction

EPC contractor has developed a detailed site-specific Construction Method Statement.

Acquisition of plantations and other lands

Loss of agricultural productivity

Avoid bird’s migration/breeding season wherever possible for the project activities.

Ensure existing water channels/ irrigation facilities are maintained in working condition

Protect /preserve topsoil and reinstate after construction completed

Repair /reinstate damaged areas etc. after construction completed

Compensation for loss in agricultural production

The land area of agriculture loss

Usage of existing Utilities

Implementation of compensation (amount paid, dates, etc.)

Agrarian Service Act. Regular monitoring compliance with regulations

CEB, Contractor through contract provisions

Throughout the construction period

The land plots identified for wind turbines are not agricultural land. Acquisition of plantations is not needed.

No loss of agricultural productivity is envisaged.

19

Wind turbine foundation construction

Dumping of excess soil

Excess soil from the foundations to be disposed of off-site after permission of local authorities. All construction material to be kept within the footprint of the area acquired. Loose construction material to be covered to avoid being carried into adjoining areas by the wind.

The volume of soil to be disposed of (area of the site in m2 and estimated volume in m3)

Laws and regulations of respective LAs


Construction period

A total of 213 (out of a total of 451) piles have been completed at December 31, 2019. Seven (07) pile caps foundations have been completed out of the total of 30 tower locations.

It was noted that:

(i) All the construction material have been kept within the footprint of the tower area

(ii) Excess soil has been levelled and compacted within the site

(iii) No soil piles (loose soil) were noted.

Water pollution Storage facilities for fuels, oil, chemicals and cement will be within secured areas on impermeable surfaces, provided with bunds of at least 110% volume with clean up equipment immediately available for use

All vehicles, machinery, and equipment maintenance and re-fuelling will be carried out on impermeable surfaces and in such a way that spilt materials do not seep into the adjacent soil. Fuel storage and refilling areas will be located at least 100 m from sea and water channels and will be protected by temporary drainage bunds of at least 110% volume to contain spills. Construction wastewater will not be discharged directly onto the surrounding soil or into the surface water system, all wastewater to be passed through silt traps or temporary sedimentation screens.

Oil-interceptors will be installed, and oil-containing wastewater will be intercepted, collected and transported to the central location for further treatment and disposal.

The contractor will provide sufficient garbage bins at each turbine location and ensure that they are (i) protected from birds and vermin; (ii) emptied regularly (using the nearest licensed solid waste landfill); and (iii) are not

Seasonal start and finish of major earthworks (pH, BOD/COD, Suspended solids, other)

Sri Lanka’s National Environment Act and IFC-WB EHS guidelines 2007 (under revision)

Timing of major disturbance activities - before starting of construction activities Construction period

The following were noted:

Storage facilities for fuels, oil, chemicals and cement have been provided as suggested.

All vehicles, machinery, and equipment maintenance and refuelling are carried out satisfactorily. No oil/fuel spills were noted.

Fuel storage and refilling areas are located well-away from the seacoast.

The contractor has provided garbage collection bins at each turbine construction site as described in the EMP. The garbage management procedure is satisfactory.

As of the end of December 2019, only foundation work has been undertaken. The contractor has assured that no heavy construction will be carried out during monsoons and no work will be carried out within 100 m of water bodies during the wet season

Stormwater management measures are in place at construction sites.

20

left to overflow.

Construction activities involving significant ground disturbance (i.e. foundation land forming) not undertaken during the monsoon season.

Do not undertake any works within 100 m of a water channel during the wet season

Arrangement for stormwater management during the construction period to be made to avoid sediment runoff from the site.

Construction schedules

Noise nuisance to neighbouring properties

Construction activities were undertaken during the day and local communities informed of the construction schedule. In the vicinity of Shell Coast Resort (cabanas are now exempt), no piling or other noisy construction works to be undertaken for more than 6 hours or at any time on the weekend or public holiday

Timing of construction (noise emissions, [dB (a)]) Daytime construction Only


Construction period

The only activities that are being carried out at the moment are pile foundation construction and access road construction. No significant noise levels were observed due to these activities.

A nuisance to birds from wind turbine construction

Restrict construction work during the known period of migration (Oct-January) by the birds. Construction period to be finalized in keeping with the construction method statement (CMS). Work must be undertaken from 1 hour after sunrise to 1 hour before sunset.

Timing of Construction/

Biodiversity Management Plan, Construction Timing - the period of migration of birds

CEB, Contractor

Construction period

This will be checked during wind turbine construction.

Provision of facilities for construction workers

Contamination of receptors (land, water, air)

Construction workforce facilities to include proper sanitation, water supply and waste disposal facilities following IFC-WB EHS Guidelines. Solid waste and hazardous waste to be disposed of offsite to a suitably licensed landfill. No waste to be disposed of to an unlicensed dumpsite. No water well will be located within minimum 100 m of a toilet facility and vice versa.

Contractor to prepare and implement pollution prevention and emergency response plan following IFCWB EHS Guidelines.

Amenities for Workforce facilities/

National Solid Waste Management Policy and IFCWB EHS guidelines 2007 (under revision)


Construction period

Only small teams of workers are engaged in piling and road construction work.

21

Surplus earthwork/soil

Runoff to cause water pollution, solid waste disposal

Any excess inert spoil material will only be used as fill material onsite or offsite after permission from local bodies. The disposal site restored in a manner that prevents erosion and does not block any drainage path. No solid or hazardous waste to be disposed of alongside excess inert spoil.

Location and amount (m3) of fill disposal. Soil disposal locations and volume (m3) /

Appropriate fill disposal and dispersal locations. Pollution Prevention as per International best practices133


Construction period

This was not observed at foundation construction sites. However, surface runoff along access road construction was observed to carry heavy loads of sediments.

The contractor was advised not to carry out earthworks during rainy days (periods).

Tree cutting/ vegetation harvesting, cut and fill operations

Loss of vegetation and deforestation

Construction workers prohibited from harvesting trees in the project area during their employment. Get approval for cutting female Palmyra trees from Divisional Secretary. During the construction, CEB/EPC contractor to record the exact number of trees/ shrubs removed from the hardstand, access roads and other areas cleared for building and other facilities etc. Replanting/ restoration programmes to compensate for the loss of trees/ shrubs and the habitat can be enriched once the project activities are completed.

Illegal tree/ vegetation harvesting (area in m2, number of incidents reported) Monitoring for all tree/shrubs to be cut by EPC contractor

Complaints by local people or other evidence of illegal harvesting

CEB, Contractor through Contract provisions External monitoring would be done by Forest Department and Dept. of Wildlife Conservation

Construction period

The sites for the proposed construction have cleared for wind turbine locations, access roads, yards and offices, etc. according to the guidelines and requirement as mentioned in the EIA/EMP.

Awareness programme on the conservation of flora, fauna and habitats is being continued by the contractor for the workforce.

The uprooting of endangered and endemic species of plants and vegetation

To ensure EPC contractor does not remove any locally EN or an endemic variety of flora/trees at any hard-standing area. The ecologist will be engaged by the EPC contractor to oversee the above. The ecologist will mark out and record the location all endemic and local EN plants in and adjacent the construction working area. EPC Contractor staff will be given guidance on their identification through toolbox talks and notices in site offices and instructed not to clear them. The ecologist will monitor the continued presence of the endemics and EN plants during the construction.

No more than five endemic Neralu trees, nine palmyra trees and 37 coconut trees will be

Hard standing Area

The ecologist will ensure endemic, and EN plants are not removed

EPC contractor through contract provisions

Construction period

Endemic and endangered plants were not recorded within the identified sites for construction prior to land clearing.

22

removed from the project area.

Effect on fauna Prevent workforce from disturbing to the flora, fauna including the hunting of fauna and fishing in water channels. No poaching allowed in the birds’ habitat area (Vankalai sanctuary, Adam’s Bridge National Park, Vedithalativu Nature Reserve.)

Proper awareness programme regarding the conservation of flora, fauna including ground vegetation to all drivers, operators and other workers

Habitat loss /

Fauna and flora protection Act.

CEB/ DWC/ CCD/DoF

Construction period

Awareness programme for conservation of flora, fauna and habitats is being continued by the contractor under instruction of CEB for the workforce. Workers that engage in construction activities are not permitted to enter the important ecological habitats located around the project sites.

Site clearance Vegetation removal Marking of vegetation to be removed before clearance, and strict control on clearing activities to ensure minimum clearance. The localized sprinkling of water at areas where vegetation is removed shall be undertaken for the entire duration of construction. Private trees/plantations will be compensated as per GoSL norms.

Vegetation marking and clearance control (area in m2) /

Felling of trees (Amendment Act. Nº 01 of 2000 and act of felling of trees control). Clearance strictly limited to target vegetation


Construction period Re-vegetation cost will have limited capital cost as seedlings can be obtained from Horticulture/ Forest Department

Clearing activities of all construction sites have been completed under instructions of CEB and Environmental Safeguard Officer of the Contractor. Clearing activates were restricted to the defined areas of each location.

Sprinkling of water in construction sites, roads and access to the turbine locations is continuing by the Contractor parallel to the construction activities.

The contractor will be advised to submit a tree planting programme within the wind farm areas and elsewhere as compensatory reforestation and as a CSR project.

Soil erosion and surface runoff

Construction in erosion-prone areas should be restricted to the dry season. Outline construction Method Statement shall be the basis for construction practice by the EPC contractor.

Treat clearing and filling areas against flow acceleration and foundation/road construction work should be carefully designed to minimize obstruction or destruction to natural drainage.

All earthwork disturbance areas shall be stabilized within 30 days after earthworks have ceased at the construction site

Soil erosion

Reengineering of drainage channels wit 25 m of the Wind turbine foundation as well as along access roads /

Visual inspection (Turbidity and sedimentation).

CEB, Contractor Through contract Provisions

Construction period

There are no erosion-prone areas. However, earthwork during heavy rains causes erosion of loose soil.

The contractor has been advised not to carry out earthworks during rainy days to minimize such erosion of loose soil.

Mechanized Noise, vibration and operator safety,

Construction equipment to be well maintained. Check for pollution prevention and oil dripping

Construction equipment -

CEB, Contractor through contract

The contractor has been advised to keep the

23

construction efficient operation, equipment wear and tear

etc. from vehicles while working in bird habitat and other areas. Adopt pollution prevention measures following IFC-WB EHS Guidelines.

Use of inherently quiet plant and equipment as far as reasonably practicable and regular maintenance to ensure noise emissions are maintained at design levels. Turning off the plant, not in use. Noise sources to be acoustically treated, for example with silencers, acoustic louvres and enclosures. Provision of rubber paddings/noise isolators at equipment/machinery used for construction.

estimated noise emissions and operating schedules /

Technical specifications, safety regulations, Noise control regulations (1994), Pollution Prevention as per International best practices

provisions

Construction period

construction equipment well-maintained.

The site supervisor has been advised to check for any oil dripping etc. from vehicles/ equipment/machinery

Noise emissions are to be monitored continuously by the contractor to be maintained below regulatory levels.

Construction of roads for accessibility

Increase in airborne dust particles Increased land requirement for temporary accessibility

Existing roads and tracks used for construction and maintenance access to the site wherever possible. New access ways restricted to 8m carriageway width. Access road shall be planned to cause minimal disturbance to the terrain topography.

Existing surface drainage pattern to be retained to the extent possible.

All equipment will be maintained to a high standard to ensure efficient running and fuel-burning. All vehicle emissions will comply with relevant Sri Lankan emission standards.

All vehicles carrying soil, sand, or other fine materials to and from the construction sites will be covered.

Access roads (length and width of new access roads to be constructed) /

Use of established roads wherever possible


Construction period

Most of the sites are accessed using existing roads. However, some sections of the access roads need extensive rehabilitation.

New access roads are being constructed, and others are being rehabilitated. The contractor had been advised to maintain existing surface drainage pattern be retained to the extent possible.

The Contractor has been advised to screen all the vehicles for Emission Certificates.

Although trucks must cover any material during transportation. Most of the trucks transporting soil are not covered properly. This has been brought to the attention of the contractor.

Transportation and storage of materials

A nuisance to the general public

Hazardous waste from machinery, generators etc. (lube oil, hydraulic oil, waste oil etc. from cranes etc.)

Transport loading and unloading of construction materials should not cause a nuisance to the people by way of noise, vibration and dust.

Avoid storage of construction materials beside the road, around water bodies, residential or public sensitive locations No storage of construction material near waterways and beach area. Construction materials should be stored in covered areas to ensure protection from dust, emissions and such materials

Soil, water and air quality Every three months after commencement of construction /

National Environment Act Laws and regulations of respective LAs National Emission Standards,

CEB/LAs

Construction period Storage: No additional cost is envisaged. Water quality monitoring cost – SLR 3,500 per sample Performance

The current practice of loading and unloading of construction materials cause certain amount nuisance to the people and noise and dust have posed inconvenience. Not much mitigation measures are adopted.

Storage of construction materials has avoided road-sides, water bodies/beach, residential or public sensitive locations

High levels of dust have been observed along the roads that are being constructed. The contractor has given strict instruction

24

should be bundled in environment-friendly and nuisance free manner. Random stocking of raw material, storage of debris, piling of loose soil etc. to be strictly controlled. Other wastes like wood packaging material, metal, etc. will be sold to scrap dealers. Housekeeping of the area to be maintained by deputing sweepers to remove dirt/debris from the sites daily in case of any accidental spill the soil to be cut and stored securely for disposal with hazardous waste. Hazardous waste will be stored at a secure location and only be sold to authorized vendors.

Hazardous waste laws and CEA water quality standards Weekly

parameters – Suspended Solids (SS), Total dissolved solids (TDS), oil, grease, Biological oxygen demand (BOD), Total coliforms, Fecal coliforms

to keep the dust emission to the minimum and to prevent wind-borne dust and emissions.

Monitoring of dust levels is not being done. The Contractor has been advised to record monitoring of dust levels and to take appropriate mitigation action: to sprinkle water and to limit speed limits to less than 30 km/h.

Soil, water and air quality test reports are available with the contractor (See Annex 4.1).

VEC of construction vehicles is not checked.

Impacts related to storage yards of soil and gravel are not monitored.

Trimming/cutting of trees


Felled trees and other cleared or pruned vegetation to be disposed of as authorized by the statutory bodies. Forest trees, if any, would be planted based on 1:1 replacement. Any trees that die within five years are to be replaced.

Species-specific tree retention as approved by statutory authorities (average and maximum tree height at maturity, in meters) Disposal of cleared vegetation as approved by the statutory authorities (area cleared in m2)

Felling of trees (Amendment Act. No 01, of 2000 and Act of felling of trees control) Presence of target species following vegetation clearance.


Construction period

The Contractor has completed removal of trees and other green cover vegetation based on the EIA/EMP requirements, local laws and regulations in an acceptable manner.

Health and safety Injury and sickness of workers and members of the public

EPC contractor to undertake a risk assessment (named person assigned for management of all medium and above risks) and develop detailed site-specific Occupational Health and Safety Plan (including emergency response plan) based on

Contract clauses (number of incidents and total lost-work days caused by injuries and sickness)

CEB (Contractor through contract provisions)

Construction period

The EPC contractor has prepared Occupational Health and Safety Plans as part of policies and procedures followed by Vestas.

The sub-contractor (Access) who carried out piling work is following their safety procedures,

25

measures set out in the IFC-WB general EHS Guidelines for occupational and community health and safety and the sector IFC-WB EHS guidelines for Wind Energy including procedures for eliminating and reducing working at height, working over water, and lifting operations and use of appropriate working methods and equipment where elimination is not possible. Construction site to have a well-stocked first aid box at each turbine location and be staffed by qualified first-aid trained personnel Construction site around each turbine to be securely fenced to prevent public access with 24-hour security when deep excavations are left open overnight Establish exclusion zone for all members of the public and workforce during working at height and lifting operations No construction staff to be exposed to a noise level greater than 85 dB(A) for more than 8 hours per day without hearing protection. No unprotected ear should be exposed to a peak sound pressure level (instantaneous) of more than 140 dB(C). Hearing protective devices provided should be capable of reducing sound levels at the ear to at least 85 dB(A).

Construction staff to be provided with a source of clean drinking water (groundwater not suitable due to saline intrusion) that is tested weekly to confirm meets Sri Lankan Drinking Water standards. Sufficient quantity of drinking water available to construction staff and toilet/sanitation facilities provided at the construction site following EHS general guidelines on occupational H&S Contract provisions specifying minimum requirements for construction of day-time camps including sanitation and welfare facilities following IFC-WB EHS Guidelines Contractor to prepare and implement a health and safety plan following IFC-WB EHS Guidelines.

Arrangement for fire control measures. Display

Health and safety regulations and IFC-WB EHS guidelines 2007 (under revision)

which are deemed satisfactory.

The rest of the safety procedures will be checked once the erection of each wind turbine is commenced.

Construction staff is provided with clean drinking water (bottled water) which is supplied by reputed companies, and the water meets Sri Lankan Drinking Water standards.

Sufficient amounts of water are available for washing and sanitation/toilets.

Arrangement for fire control measures is satisfactory. Phone numbers of the city/local fire services, etc. are displayed at the site.

Housekeeping at the construction sites is satisfactory.

The contractor is conducting regular health and safety awareness programmes.

26

of phone numbers of the city/local fire services, etc. at the site. Ensure good housekeeping at the construction site to avoid slips and falls. Contractor to arrange for health and safety awareness programmes.

Working at heights

Operation of heavy Machinery

Accidents leading to injuries fatalities

Occupational health hazards

All personal protective equipment like gloves, helmets, earmuffs, safety belts, etc.) for construction workers through the contractors.

Ensure effective work permit system for hot work, electrical work, working at height, working in confined space etc. Lifting /Dropping/lowering of construction material or tool to be restricted and undertaken only under strict supervision, if required.

Contract clauses (number of incidents and total lost-work days caused by injuries and sickness). Operation of Cranes to follow a Crane Safety Plan

Health and safety regulations and IFC-WB EHS guidelines 2007 (under revision)


Throughout the construction phase

Still, the piling construction is in progress.

This will be checked once the construction has commenced

A nuisance to nearby properties

Losses to neighbouring land uses/ values

Contract clauses specifying careful construction practices in accordance with IFC-WB EHS Guidelines. Incorporating good construction management, design engineering practices.

Productive land will be reinstated following completion of construction

Contract clauses Design basis and layout Reinstatement of land status (area affected, m2) Implementation of Tree/Crop compensation (amount paid)

Public Nuisance Ordinance No.: 15 of 1862. IFC-WB EHS guidelines 2007

CEB (Contractor through contract provisions) EPC Contractor

Construction period Consultation with affected parties immediately after completion of construction

This will be checked once the construction has commenced

There is no apparent impact on productive land.

Road infrastructure

The possible crossing of ecological and ornithologically habitat. Access to the local population to roads infrastructure

Ensure wind turbines and access roads are constructed to avoid any critical habitats

Villages will get access to all approach roads to the coast/shore built for accessing the project facilities.

Site Plan to minimize such occurrence and facilitate community convenience. /

IFC’s GN6 and incorporation of good construction management, design engineering practices


Construction period

The wind turbine locations have been selected so as not to disturb any critical habitats.

The access roads and village roads used by inhabitants are not obstructed.

27


Table 2.8: Monitoring of the implementation of Environmental mitigation measures – Transmission Line and the Grid Sub-Stations


Impact

Mitigation Action Monitoring Scope Standard Responsibility of Implementation &

schedule


Pre-construction

Temporary use of lands

Impact on the existing environment

Selection of lands adhering to local laws and regulations and in close consultation with LAs

Construction facilities should be placed at least 100 m away from water bodies, natural flow paths, important ecological habitats and residential areas. No temporary land use in Vankalai Sanctuary.

Water and air quality

Air Quality Standards and CEA water quality standards

CEB

Contractor

Detailed design

The Monitoring Report prepared by the CEB (Annex 4.1) stipulates water and air quality records measured on 19.09.2019 – which is not within the period of monitoring. However, for Nadukuda GSS, the report states that samples for water quality and Air Quality have been collected on 27.12.2019. However, the following reports have NOT been submitted:

- Air quality and Water quality reports have not been received for the samples collected on 27.12. 2019.

Substation location and design

Noise generation Exposure to noise, Nuisance to neighbouring properties

Disturbance to the adjacent lands and the people due to cut and fill operations

Substation designed to ensure noise will not be a nuisance (i.e. less than 55dBA LAeq daytime and less than 45dBA LAeq nighttime at nearest receptor).

Maintain adequate clearance, construction of retaining structures, minimize cut and fill operations adjoining to the dwellings

Expected noise emissions based on substation design, noise levels

Proximity to houses and other structures

Noise control regulations in 1994 Noise levels to be specified in tender documents

Technical specification

CEB

Detailed Design

Summary of existing noise levels are reported in the quarterly environmental monitoring (Annex 4.1). However, the test reports have not been submitted for the testing that has been carried out on 27.12.2019 at Nadukuda GSS.

Location of transmission towers and

Line traversing across environmentally

The setback of dwellings to transmission line route designed in accordance with the permitted

Tower location and line alignment selection to nearest

Setback distances to nearest houses -

CEB

Part of tower

The transmission line has been routed through areas with low-grown vegetation and

28


Impact


schedule


transmission line alignment and design

sensitive areas with possible impacts to biodiversity and excessive clearance of vegetation

Excessive requirements for clearance of way-leaves and land-use restrictions in areas of high population density

Exposure to safety-related risks

level of power frequency and the regulation of supervision at sites.

dwellings sighting survey and detailed alignment survey and design

agriculture, such as paddy and low grown vegetables

A detailed design, including tower type, location, profile already been submitted.

Trees have been removed, and compensation has been paid for the identified owners.

Impact on water bodies (Vankalai sanctuary wetland)/land/ residences

Consideration of tower location where they could be located to avoid avian breeding areas, water bodies or agricultural land as much as possible. Follow EHS Guidelines on avoiding water pollution.

Careful site selection to avoid existing avian/marine settlements and negative impacts to the sanctuary area.

Increase the height of towers, adopt measures to reduce possible collision with birds during flight.

EPC contractor to implement mitigation measures according to Biodiversity Management Plan and Construction Method statement outlining construction precautions in the Vankalai

Site location, line alignment selection (distance to dwelling, water and/or agricultural land)

Improve tower design and measures

Consultation with local authorities Biodiversity Management Plan, Dept of Wildlife Conservation

CEB

Part of detailed project sighting and survey and design


29


Impact


schedule


Sanctuary area.

Equipment specifications and design parameters

Release of chemicals and harmful gases in receptors (air, water, land)

Ensure equipment design must be sound to avoid emissions for oil, gases etc.

Compliance with setback distances (as-built” diagrams)

Setback distances to nearest houses

CEB

Detailed design

No significant amounts of emissions (release of chemicals and harmful gases) are envisaged.

Poly Chlorinated Biphenyls (PCBs) has not been used in substation transformers or any other equipment. Exclusion of PCBs in transformers stated in tender specifications.

Encroachment into precious ecological areas

Loss of precious ecological values/ damage to precious species

Minimize the need for tower base disturbance in sanctuary wherever possible

Floral and faunal habitats loss in the sanctuary area

Flora and fauna protection act. Biodiversity Management Plan

CEB

Detailed design

This condition has complied with mitigation actions. All the activities are restricted to the construction sites.

Interference with drainage patterns/water channels

Temporally flooding hazards/loss of agricultural production

Appropriate siting of towers (use longer spans) to avoid putting towers in the water channel to avoid disturbing aquatic habitats in the sanctuary area.

Site location and line alignment selection

Irrigation Act of 1933. Consultation with local authorities and design engineers

CEB

Detailed alignment survey and design

The contractor has selected tower locations in consultation with the CEB and other authorities. No loss of agricultural land and disturbances to aquatic habitats have been observed.

Explosions/Fire Hazards to life Design of substations to include modern fire control systems/firewalls.

Provision of firefighting equipment to be located close to transformers, power generation equipment.

Substation design compliance with fire prevention and control codes

Tender document to mention detailed specifications

CEB

Part of detailed substation layout and design /drawings

Provision of firefighting equipment has been planned. This has to be verified prior to commissioning.

Construction

Removal or disturbance to other public

Public inconvenience

Advance notice to the public about the time and the duration of the utility disruption.

Disruption of other commercial and public activities /

Technical specification

CEB/ PRDA / NWSDB/SLT

Throughout the

No public utilities have been disturbed as yet.

The contractor has employed

30


Impact


schedule


utilities Use of well trained and experienced machinery operators to reduce accidental damage to the public utilities and specifically any natural habitats in Vankalai Sanctuary. Restore the utilities immediately to overcome public inconvenient

Public complaints construction period well trained and experienced machinery operators.

Natural habitats in Vankalai Sanctuary have not been permanently damaged.

A temporary outage of the electricity

Loss of power supply to the local community when distribution lines crossing the new transmission line are switched off

Advance notice to the public about the time and the duration of the utility disruption

Restore the utilities immediately to overcome public inconvenience.

Houses and commercial premises of power disruption

Regular monitoring during the period of strengthening the conductors

Contractor CEB


Temporary outages of electricity should be monitored, especially during stringing.

4km of the line stringing completed. Temporary outages of 1 hr for ten days taken.

Acquisition of paddy fields and other lands

Loss of agricultural productivity

Avoid farming and bird’s migration/breeding season wherever possible for the project activities.

Ensure existing irrigation facilities are maintained in working condition

Protect /preserve topsoil and reinstate after construction completed Repair /reinstate damaged areas etc. after construction completed

Compensation for temporary loss in agricultural production

The land area of agriculture loss

Usage of existing Utilities

Status of facilities (earthwork in m3)

Implementation of crop compensation (amount paid, dates, etc.)

Agrarian Service Act.

Regular monitoring compliance

with regulations



No acquisition of lands required for tower foundation or line; Construction of transmission towers is in progress, and some towers have been completed. The contractor, in consultation with the CEB, has

avoided/minimized the cultivation seasons, and bird migratory seasons to the extent as possible.

The contractor has been able to satisfactorily reinstate the damaged construction areas to the satisfaction of all the parties concerned.

Payment of compensation for crop damages of paddy area is in progress.

31


Impact


schedule


Equipment layout and installation

Noise and vibrations

Selection of construction techniques and machinery to minimize ground disturbance

Construction techniques and machinery/

Minimal ground disturbance


Construction period

Disturbances have been kept to a minimum. No significant noise and vibration impacts recorded and no complaints.

Substation construction

Loss of soil Fill for the substation foundations obtained by creating or improving a local drain system.

Borrow area sighting (area of the site in m2 and estimated volume in m3)

Laws and regulations of respective LAs


Construction period

Filling of the site is complete. Road-side drains adjoining the site area and the access road have been maintained properly.

No local drainage problems have been observed so far.

Water pollution Construction activities involving significant ground disturbance (i.e. substation land forming) not undertaken during the monsoon season. No work in lagoon areas during high tide periods.

Seasonal start and finish of major earthworks (pH, BOD/COD, Suspended solids, other)

Sri Lanka’s National Environment Act and IFC’s EHS guidelines 2007 (under revision)

Timing of major disturbance activities - before starting of construction activities Construction period

Much of the earthwork and filling activities are completed now, and these works have been carried out during the dry season.

According to the contractor, no earthworks are planned during the forthcoming rainy season.

No surface water bodies found within or around the substation area.

Construction schedules

Noise nuisance to neighbouring properties

Construction activities only were undertaken during the day and local communities informed of the construction schedule.

Timing of construction (noise emissions, [dB (a)])

Daytime construction only


Construction period

There are no dwelling units located close to the grid station site.

Tower construction near dwelling units (e.g., close to the Mannar Railway Station) has now been completed

No significant noise and vibration impacts recorded and no complaints.

32


Impact


schedule


A nuisance to birds if the line construction crosses their migratory path

Restrict construction work during the known period of

migration/breeding period by the birds. Construction period in the sanctuary to be finalized in keeping with the CMS. Work inside the sanctuary must be undertaken from 1 hour after sunrise to 1 hour before sunset.

Timing of Construction

Biodiversity Management Plan, Construction Timing - the period of migration of birds

CEB, Contractor

Construction period

All construction activities are conducted during off migratory season; February 2019 to September 2019.

Provision of facilities for construction workers

Contamination of receptors (land, water, air)

Construction workforce facilities to include proper sanitation, water supply and waste disposal facilities at substation site following EHS Guidelines. No facilities to be set up within the Sanctuary. Solid waste and hazardous waste to be disposed of offsite to a suitably licensed landfill. No waste to be disposed of to an unlicensed dumpsite. Contractor to prepare and implement pollution prevention and emergency response plan following EHS Guidelines.

Amenities for Workforce facilities/

National Solid Waste Management Policy and IFC’s EHS guidelines 2007 (under revision)


Construction period

Construction workforce has been provided with proper facilities to include proper sanitation, water supply and waste disposal facilities (for both transmission tower workers and at substation site) in accordance with EHS Guidelines.

No labour camps have been set up within the Sanctuary.

It was not apparent whether the solid waste and hazardous waste is handed over to the Pradeshiya Sabha or not. There is solid waste dumped around the grid sub-station which should be avoided. The contractor has given repeated instruction to refrain from dumping solid waste into the nearby shrub areas.

Wood/ Vegetation harvesting, cut and fill operations


Effect on fauna

Construction workers prohibited from harvesting wood in the project area

Prevent workforce from disturbing to the flora, fauna

Illegal wood/ Vegetation harvesting (area in m2, number of incidents reported)

Complaints by local people or other evidence of illegal harvesting

Fauna and flora


CEB/ DWC/ DoF

Clearing for the transmission towers and the line is done with minimum impact to the vegetation. Existing roads are mainly used for transportation.

33


Impact


schedule


including the hunting of fauna and fishing in water bodies. No poaching allowed in Sanctuary or bird habitat area.

Proper awareness programme regarding the conservation of flora, fauna including ground vegetation to all drivers, operators and other workers

Habitat loss protection Act. Construction period Storage of material without clearing of vegetation.

Awareness program regarding the conservation of flora, fauna and habitats is being conducted by the contractor for the workforce.

Strict instructions have been given to construction workers prohibiting from harvesting wood in the project area, disturbing to the flora, fauna including hunting and fishing.

Poaching in the sanctuary or bird habitat areas has been strictly prohibited.

Site clearance Vegetation Marking of vegetation to be removed before clearance, and strict control on clearing activities to ensure minimum clearance. Minimum vegetation clearance to be done in the sanctuary area.

No tree felling in Sanctuary required. Private trees/plantations will be compensated as per GoSL norms.

Vegetation marking and clearance control (area in m2)

Felling of trees (Amendment Act. Nº 01 of 2000 and act of felling of trees control). Clearance strictly limited to target vegetation


Construction period

The sites clearing for the proposed construction have been completed, tower foundations and erection of number of towers have been completed according to the guidelines and requirement as mentioned in the EIA/EMP.

Awareness program regarding the conservation of flora, fauna and habitats is being continued by the contractor for the workforce.

The contractor will be advised to submit a tree planting program within the grid station area and elsewhere as compensatory reforestation, and also as a CSR project

34


Impact


schedule


Soil erosion and surface runoff

Construction in erosion-prone mudflats, lagoon areas should be restricted to the dry season. Outline construction Method Statement shall be the basis for construction practice in the Sanctuary area. Treat clearing and filling areas against flow acceleration and construction work should be carefully designed to minimize obstruction or destruction to natural drainage

Soil erosion

.

Visual inspection (Turbidity and sedimentation)

CEB, Contractor Through contract Provisions

Construction period

The contractor has been instructed to clear any construction debris, spoil, excavated soil from the site areas before commencement of the rainy season.

It has been noted that the contractor and sub-contractors have obliged with this condition.

Mechanized construction

Noise, vibration and operator safety, efficient operation, equipment wear and tear

Construction equipment to be well maintained.

Check for pollution prevention and oil dripping etc. from vehicles while working in bird habitat and other areas. Adopt pollution prevention measures in accordance with EHS Guidelines

Proper maintenance and turning off the plant, not in use.

Operating schedules

Noise control regulations (1994), Pollution Prevention as per International best practices43


Construction period

The contractor is maintaining records of the status of construction equipment and machinery.

No oil dripping has been observed during site visits

Construction of roads for accessibility

Increase in airborne dust particles

Increased land requirement for temporary accessibility

Existing roads and tracks used for construction and maintenance access to the site wherever possible.

New access ways restricted to a single carriageway width within the RoW. Avoid construction of permanent access routes in sanctuary area by use of mats etc.

Access roads, routes (length and width of new access roads to be constructed)

Use of established roads wherever possible

Access restricted to single carriageway width within RoW


Construction period

The contractor has been using existing roads for accessing tower locations. Some of the tower locations have been accessed, and material transportation has been done with the use of a railway carriage.

Increased air-borne dust was not observed at transmission tower locations during the site visit. Even though air-borne

35


Impact


schedule


dust occurs at the grid sub-station site frequent water spray along the road and construction site is observed.

Transportation and storage of materials

A nuisance to the general public

Transport loading and unloading of construction materials should not cause a nuisance to the people by way of noise, vibration and dust.

Avoid storage of construction materials beside the road, around water bodies, residential or public sensitive locations

No storage of construction material in the sanctuary area.

Construction materials should be stored in covered areas to ensure protection from dust, emissions and such materials should be bundled in environment-friendly and nuisance free manner.

Water and air quality

National Environment Act Laws and regulations of respective LAs National Emission Standards and CEA water quality standards

CEB/LAs

Construction period

There have been no complains related to the public nuisance caused by noise, vibration and dust due to transport loading and unloading of construction materials

The contractor has avoided storage of construction materials beside the road, around water bodies, residential or public sensitive locations such as the sanctuary area.

However, the contractor has failed to cover construction material at the grid substation site. Airborne dust emissions were observed during the site visit.

Trimming/ cutting of trees within RoW

Fire hazards


Trees allowed growing up to a height within the RoW by maintaining adequate clearance between the top of the tree and the conductor as per the regulations.

Trees that can survive pruning to comply should be pruned instead of cleared.

Felled trees and other cleared or pruned vegetation to be disposed of as authorized by the statutory bodies. Forest trees, if

Species-specific tree retention as approved by statutory authorities (average and maximum tree height at maturity, in meters)

Disposal of cleared vegetation as approved by the statutory authorities (area cleared in m2)

Felling of trees (Amendment Act. No 01, of 2000 and act of felling of trees control)

Presence of target species in RoW following vegetation clearance.


Construction period

Tower locations have been selected to minimize tree cutting. Selective tree cutting and trimming were adopted.

No trees were cut or trimmed within Vankalai sanctuary.

36


Impact


schedule


any, would be planted based on 1:1 replacement. Any trees that die within five years are to be replaced.

Health and safety Injury and sickness of workers and members of the public

Contract provisions specifying minimum requirements for day-time construction camps including sanitation and welfare facilities in accordance with EHS Guidelines

Contractor to prepare and implement a health and safety plan in accordance with EHS Guidelines.

Contractor to arrange for health and safety awareness programmes.

Contract clauses (number of incidents and total lost-work days caused by injuries and sickness)

Health and safety regulations and IFC’s EHS guidelines 2007 (under revision)


Construction period

Health and safety procedures are well-established. Health and Safety plans have been prepared and implemented by both the contractors: grid sub-station and the transmission tower.

H&S officers have been mobilized by both the contractors.

A nuisance to nearby properties

Losses to neighbouring land uses/ values

Contract clauses specifying careful construction practices in accordance with EHS Guidelines.

As much as possible, existing access ways will be used.

Productive land will be reinstated following completion of construction

Compensation will be paid for loss of production if any.

Contract clauses Design basis and layout Reinstatement of land status (area affected, m2) Implementation of Tree/Crop compensation (amount paid)

Public Nuisance Ordinance No.: 15 of 1862. And IFC’s EHS guidelines 2007 (under revision). Incorporating good construction management, design engineering practices


Construction Period

Consultation with affected parties immediately after completion of construction and after the first harvest


Avian Collision The possible collision of migrant birds with transmission line

Install Swan-Flight Divertor or Aerial Marker Spheres at the stated separations on the length of the transmission line that crosses through Vankalai sanctuary and Mannar island.

Installations on transmission lines

on Birdlife International (2012) and APLIC (2012) guidance


Construction period

Most of the construction work of transmission towers have been completed and stringing of transmission lines are ongoing and some sections have been completed.

37


Impact


schedule


After installation of transmission lines, monitoring of the possible collision of birds will be commenced by the Contractor during migration period.

Rail and road infrastructure

The possible crossing of ecological and ornithologically habitat

Ensure route avoids such habitats outside the sanctuary area

Route alignment to minimize such occurrence

IFC’s GN6 and incorporation of good construction management, design engineering practices


Construction period


38

2.7 Implementation of the Biodiversity Management Plan

The BMP falls under the Environment Management Plan (EMP) and is part of the package of activities designed to meet the requirements of ADB’s Safeguards Policy Statement (SPS) 2009 which sets out policy principles and outlines the delivery process for ADB’s safeguard policy concerning environmental safeguards. The main objective of the BMP is the reduction of impacts to Vankalai Sanctuary from the transmission line and Adam’s Bridge Marine National Park from wind park. The BMP adopts a ‘whole environment’ approach to safeguard the existing environment of the wind park and Vankalai Sanctuary from the construction of transmission line, maintain its biodiversity values and provide for its future management, as well as promoting actions to safeguard other critical habitats on Mannar Island and environs.

The request of approval for the implementation of BMP of Mannar–Nadukuda 220 kV transmission line project submitted by the CEB to the DWC and approval is given on 11th March 2019, under several concerns and recommendations.

The request of approval for the implementation of BMP of 100 MW Wind Park project submitted by the CEB to the DWC and approval is given on 20th August 2019, under several concerns and recommendations.

39

Table 2.9: Monitoring of mitigation of potential impacts on marine biology (Wind Power Generation Project)

Project Phase

Feature Mitigation Methods Benefit of mitigation Compliance with the requirements in the field

level

Construction Phase

Timing Constructing during the dry

period to minimize impacts to

wetland habitat and erosion.

Reduce turbidity due to loosening soil from water runoff (if any).

The ongoing construction schedule is followed by the Contractor as agreed with the Client/DWC and the Department of Coastal Conservation.

Construction activities within the wind park area restricted to the dry season.

Pier Construction Equipment

Reduce excessive impact on drilling in the Pier foundation to reduce soil vibration and rutting in sensitive soils and natural areas.

• Booms, which are floatingbarriers to oil.

• Sorbents, which are bigsponges used to absorb oil.

• Skimmers, which are boatsthat skim (scoop) spilt oilfrom the water surface.

Not applicable due to omission of pier construction

Erosion Control Installing and maintaining proper erosion controls during construction to minimize run-off of topsoil and disturbances to natural areas.

If some hatchery is found, the EPC Contractor will ensure the approach to the area is sealed off.

Construction activities in erosion-prone areas are restricted to the dry season. However, actions are taken to control erosion in construction sites of turbine footings.

Some issues not applicable due to omission of pier construction

Barge Operations Oil Spillage from Barge engines, lubes from gearboxes of cranes used for unloading etc.

Increase in invasive species in the water channels will damage the marine and avifauna sensitive ecosystem in the area.

Not applicable due to omission of pier construction

Habitats Hire services of Ecologist to ensure there are no nesting of turtles in the construction area.

To restore any natural habitat to original condition for avifauna and marine species

Periodic surveys have been done by the Client and the Contractor to identified nesting areas of the sea turtles. However, the Contractor has failed to provide reliable checklist or survey report regarding the above survey.

The Contractor has been instructed to preparation of checklist for periodic surveys. A qualified Ecologist has not been appointed for the project.

40

Table 2.10: Monitoring of mitigation of potential impacts on marine biology (Transmission line (Vankalalai Sanctuary)

Project Phase

Feature Mitigation Methods Benefit of mitigation Compliance with the requirements in the field

level

Construction Phase

Timing Constructing during the dry

period to minimize impacts

to wetland habitat and

erosion.

Reduction in disturbance to critical habitats

The ongoing construction schedule is followed by the Contractor as agreed with the Client/DWC and the Department of Coastal Conservation.

Construction activities within the Sanctuary area and other marine habitats restricted to the dry season as mentioned in the CMS.

All the excavation and foundation work completed. Specific Construction Equipment

Using low pressure wide- track vehicles and matting to reduce soil compaction and rutting in sensitive soils and natural areas.

Reduce damage to seagrass meadows and soil

All machinery and equipment used within the sanctuary and other sensitive locations are carried out to mitigate anticipated impacts.

Currently construction activities within the sanctuary area are restricted to erection of towers and installation of transmission lines.

Erosion Control Installing and maintaining proper erosion controls during construction to minimize run-off of topsoil and disturbances to natural areas.

Reduce turbidity due to loosening soil from water runoff (if any).

Actions are taken to control erosion in construction sites depending on ground and the severity of the erosion. Most of the locations construction debris already removed.

The contractor has been instructed to clear all the construction sites prior to commencement of the rainy season.

41

3.0 Implementation of Monitoring Plans

3.1 Implementation of the Environmental Monitoring Plan


Table 3.1: Environmental Parameters and Periodicity for Environmental Monitoring Plan

Environmental component

Project stage Parameters to be monitored Location Frequency Comments/Remarks

1. Air Quality Preconstruction stage (The project after assigning to the contractor)

CO, PM10, PM2.5, SPM Inside and outside (0.5 km) of the proposed wind farm

A single time Air Quality (Baseline) has been submitted (See External Monitoring Report for July-September 2019)

Construction Stage CO, Pb, PM10, TSPM Inside and outside (0.5 km) of the proposed wind farm

Daily visual inspections, overall monthly monitoring

Records of daily visual inspection have not been recorded.

Environmental impacts related to activities of the sub-contractor (Access Engineering) have not been monitored, either by the contractor or the CEB.

Format for monthly monitoring has been given to the contractor. The contractor has submitted monthly monitoring reports (Annex 4.1)

2. Surface Water Quality

Preconstruction stage (The project after assigning to the contractor)

EC, TSS (turbidity & suspended sediment), DO, BOD, COD, pH Oil and grease, E Coli (faecal coliforms), hydrocarbon

All water channels within 100 m of the working area

A single time Water quality (Baseline) has been submitted (See External Monitoring Report for July-September 2019)

42



Construction Stage EC, TSS (turbidity & suspended sediment), DO, BOD, COD, pH, Oil and grease, E Coli (faecal Coliforms), hydrocarbon

One each from water channels inside the wind farm.

One time/3 months

The contractor agreed to carry out water quality testing towards the end of the year.

Water quality reports have been submitted (See Annex 4.1).

3. Ground Water Quality


EC, TSS (turbidity & suspended sediment), DO, BOD, COD, pH Oil and grease, E Coli (faecal Coliforms), hydrocarbon

All wells within 100m of the working area

A single time Baseline groundwater quality report has not been submitted.

Construction Stage EC, TSS (turbidity & suspended sediment), DO, BOD, COD, pH Oil and grease, E Coli (faecal Coliforms), hydrocarbon

One from nearest well around the wind farm and one from well near the coast

1 time/ 3 months

The contractor agreed to carry out water quality testing towards the end of the year. However, groundwater quality reports have not been submitted.

4. Noise/ Vibration


Noise level (dB level) Inside park and at the nearest receptor of the wind farm

The single time during NE and one single time during SW monsoon

Noise and vibration (Baseline) - has been submitted (See External Monitoring Report for July-September 2019)

Construction Stage Noise level (dB level) Inside and outside (0.5 km) of the proposed wind farm

Every month for construction noise

Weekly during Piling for temporary pier

Format for weekly monitoring has been given to the contractor. However, weekly monitoring records during piling are not available.

However, monthly monitoring records during construction are not available. The report observed once during the quarter has been submitted (See Annex 4.1)

Environmental impacts related to activities of the sub-contractor

43



(Access Engineering) have not been monitored, either by the contractor or the CEB.

5. Soil Preconstruction stage (The project after assigning to the contractor)

pH, Sulfate (SO3), Chloride, ORP, Salinity, Resistively, Organic Matter, Moisture Content

Inside and outside (just close to the proposed site, 2 locations) of the proposed wind farm

A single time Soil investigation report - has been submitted (See External Monitoring Report for July-September 2019)

Construction Stage pH, Sulfate (SO3), Chloride, ORP, Salinity, Resistively, Organic Matter, Moisture Content

Inside and outside (just close to the proposed site, 2 locations) of the proposed wind farm

1 time/ 3 months

This is needed during construction.

However, monitoring reports have not been submitted.

7. Bird and bat collision’s


Bird and bat monitoring survey Near wind farm boundary as per Collision Risk Assessment Report (adopt the same methodology for bats and birds)

Once Complied with

Preconstruction survey has been completed up to February 2019

8. EMI Preconstruction stage (The project after assigning to the contractor)

Electric Field (kV/m), Magnetic Field (μT) and Antenna Field Electric strength dBμV/m

TV/radio signal at the property on the boundary in line of sight of the wind farm

Once Not Applicable at this stage.

9. Fish catch Preconstruction, construction,

Collate daily (for fish catch data (amount of catch, no fishers, no of boats, the value of catch etc.) and monthly fish catch data for 2-year prior for fishermen in the project area and a representative control site and continue through

Madels in front of the wind farm

Daily data The contractor agreed to carry out the survey, during previous monitoring sessions. But they have not conducted as they agreed.

The contractor is reluctant to collect the fish catch data due to omission of pier construction.

44



construction and three years of operation

10. Health and Safety

Construction, operation

Monitoring of accidents to workers and community in construction and operation

Wind turbine locations, access roads, staff quarters

Weekly The H&S Plans are available. Risk assessment has been done; Monthly field visits, HAS committee has been established;

Note:

GRM has been established. Awareness to be conducted shortly for GRC. The GN has agreed to make the communities and the villagers aware of the project and project-related activities.

No complaints have been received by the GRC so far.

45


Table 3.2: Environmental Parameters and Periodicity for Environmental Monitoring Plan


Project stage Parameters to be monitored

Location Frequency Remarks/Comments

1. Air Quality Preconstruction stage (The project after assigning to the contractor)

CO, Pb, PM10, TSPM

Inside and outside (0.5 km) of the proposed substation

A single time

Reports yet to be received.

Construction Stage

CO, Pb, PM10, TSPM


1 time/ 3 months

Air Quality measurement report received for the period from July 01, 2019, to September 30, 2019, For Grid Substation (GSS);

(Measured parameters are CO, PM10, PM2.5, Pb); TSPM has not been measured.

According to the report, data was measured on 18th & 19th Sep 2019, but the results table in the same report depicts CO was measured on 10/04/2019 and analyzed on 10/04/2019 whereas PM 10, PM 2.S, Pb were measured on 09-10/04/2019 and analyzed on 12/04/2019. Therefore, these dates are

contradicting.

Air quality reports for the measurements done on 27 and 28 December 2019 is still pending.

2. Water Quality


EC, TSS (turbidity & suspended sediment), DO, BOD, COD, pH, Oil and grease, Pb, E Coli (faecal Coliforms), hydrocarbon

One from nearest well and one from surface water source around the substation

A single time


Construction Stage

EC, TSS (turbidity & suspended

One from nearest well

1 time/ 3 months

Water quality reports have not been received for this quarter.

Water Quality Reports for the measurements done on 27

46

sediment), DO, BOD, COD, pH, Oil and grease, Pb, E Coli (faecal Coliforms), hydrocarbon

and one from surface water source around the substation

December 2019 is still pending.

3. Noise/ Vibration


Noise level (dB level)


A single time


Construction Stage

Noise level (dB level)


1 time/ 3 months

Noise report has been received. Noise measurement was taken on 19th Sep 2019 at four locations identified by the client.

(Continuous time-integrated noise level was taken at 15 sec time intervals for 15 min every hour and then averaged for 24hours)

Noise measurements were done on 27 December 2019 is still pending.

Vibration levels have not been measured.

4. Soil Preconstruction stage (The project after assigning to the contractor)

pH, Sulfate (SO3), Chloride, ORP, Salinity, Resistively, Organic Matter, Moisture Content155

Inside and outside (just close to the proposed site, 2 locations) of the proposed substation

A single time

The sample for Soil testing has been collected on 10th April at Grid Sub Station site.

Location 1: Inside GSS Location 2: Outside GSS The sample was collected on 10/04/2019 but tested on 02/10/2019 according to the report.

Construction Stage

PH, Sulfate (SO3), Chloride, ORP, Salinity, Resistively, Organic Matter, Moisture Content

Inside and outside (just close to the proposed site, 2 locations) of the proposed substation

1 time/ 3 months

The sample for Soil testing has been collected on 14.11.2019 at Grid Sub Station site.

Location 1: Inside GSS Location 2: Outside GSS The sample was collected on 14/11/2019 but tested on 02/12/2019.

47

3.2 Implementation of the Biodiversity Monitoring Plan (BMP)


Table 3.3: Monitoring of implementation of Biodiversity Monitoring Plan (BMP) for 100m Wind Farm

Project activity Potential impact

Locations Time Responsibility of Implementation

Parameters Observations and Remarks

Pre-Construction

Pre-construction bird monitoring surveys

Impact on birds

Within 100m of turbine locations

Before construction commencing

Consultant, Contractor

Block counts by sector Monthly birds monitoring surveys to undertake impact on birds within 1,000 m of turbine locations including block counts & vantage point counts have been conducted.

Vantage point count

Broad-scale flight counts

Fine-scale flight counts

Monitoring of surface and groundwater

Impact on surface and groundwater

All thonas within the wind park, groundwater from well nearest to wind park and from one near to cost.

Once prior to construction


Water quality parameters; DO, BOD/, COD, PH, turbidity, TSS, oil content, E. coli

Ground and surface water quality monitoring survey of thonas and well nearest to wind park and from one near to cost has not been conducted.

Monitoring on aquatic fauna in thonas

Impact on aquatic fauna in thonas

All thonas within the wind park



Fish and invertebrate surveys

Aquatic fauna survey within proposed thonas for the establishment of baseline condition has been conducted during IEE and EIA Studies.

Invasive species survey

The impact of invasive species

All turbine footings,

either side of roads



Presence of any invasive species; 100m radius around each turbine footings and either side of temporary and permanent roads

Invasive species survey was conducted by the contractor and no invasive species recorded from the 25 turbine locations.

Invasive species survey beside the rods was not conducted by the contractor.

48




Construction

Bird monitoring surveys

Impact on birds

Within 100m of turbine locations

Monthly during the construction stage


Block counts by sector Still not started.

Vantage point count



Bird collision monitoring

Impact on bird collision

The whole area of the wind park

Monthly during the construction stage


Carcasses searching

Construction of turbine footings are in the latter stage and installations will be completed within next few months. After installation of wind turbines, this study can be started. The contractor agreed to carry out the study.

Radar monitoring Impact on bird activity

The whole area of the wind park

Daily and seasonal


Radar and field observations

Field inspection for the installation of radar was carried out by the experts with the help of the engineers of the CEB and currently in the design stage.

The radar is still not installed, and therefore this study has been deferred until the radar is installed and properly calibrated by the experts from the company that will be supplying the radar. No updated information.

49




Monitoring of surface and groundwater

Impact on surface and groundwater

All thonas within the wind park, groundwater from the well nearest to the wind park and from one near the coast

Quarterly during the construction period


Water quality parameters; DO, BOD/, COD, PH, turbidity, TSS, oil content, E. coli

Ground and surface water quality monitoring survey have been conducted by the Contractor during this quarter, including surface water bodies and water wells.


Monitoring of aquatic fauna

Impact on aquatic fauna

Survey of all nine thonas within the wind park

Quarterly during the construction period


Fish and invertebrate surveys

Monitoring of aquatic fauna fish and invertebrate survey has not been started.

50

3.2.2 Construction of the Transmission Line

Table 3.4: Monitoring of implementation of Biodiversity Monitoring Plan (BMP) for Transmission line (Vankalalai sanctuary)




Pre-Construction

Pre-construction bird monitoring surveys

Impact on birds

Throughout the Vankalai sanctuary

Up to January 2019


Block counts by sector A survey has been conducted throughout the Vankalai Sanctuary from March 2018 to March 2019. This survey included block counts throughout the Vankalai Sanctuary and along the area identified for installation of wind turbines (twice a month), vantage point (VP) surveys including four VPs to cover the area that will be used for the establishment of wind turbines and three VPs to cover the section of the transmission line that traverses through the Vankalai Sanctuary using broad-scale flight counts and fine-scale flight mapping. The survey was completed, and the data were sent to Dr Steven Percival to carry out the Collision modelling, and the report was to be submitted to the ADB directly by Dr Percival.

Vantage point count



Invasive species The impact of invasive species

100m radius around each tower footing

Up to January 2019


Existing population and distribution of species

Invasive species survey has been conducted by the contractor and some invasive species recorded.

Construction

Brid monitoring surveys

Impact on birds

Throughout the Vankalai sanctuary

Monthly Consultant, Contractor

Block counts by sector Not yet started,

Vantage Broad-scale

51




point count flight counts


Bird collision monitoring

Impact on bird collision

The whole length of Transmission line Vankalai sanctuary

The wet and dry season


Carcasses searching

Construction of tower footings and erection of transmission towers except few locations have been completed within the sanctuary area. Stringing of transmission lines within the sanctuary and outside the sanctuary are also ongoing.

Therefore, collision monitoring study can be undertaken just after the transmission line completed within short time period.

52

3.3 Marine Environmental Monitoring

Table 3.5: Monitoring of Marine Environment

Potential Impact Proposed Mitigation measures

Monitoring Means and frequency

Responsibility Performance Indicator

Compliance with the requirements in the field level

Construction Phase

Sedimentation in sensitive coastal environments due to dredging and disposal of excavated material

Any disposal of excavated material should be done outside of the sanctuary away from sensitive fisheries or breeding grounds. Disposal should be timed to be outside of the upwelling period.

Scientific investigation should be undertaken downstream delineate the area impacted by the plume.

Once before, regularly during and once after construction

EPC Contractor

Siltation of soil in the lagoon, salt marshes from construction activities.

No significant impact due to omission of pier construction. All type of unwanted disposal materials disposes to the approved site by the LAs.

Soils excavated for the erection of towers should be used for refilling and should not be left exposed to wind or water for long periods. Sediment control measures such as retention weirs will be used, as necessary, to minimize sediment transport offsite. Silt fencing must also be implemented to minimize erosion of soil stockpiles.

Inspection, Routine monitoring


EPC Contractor

Physical Water Quality (TSS, soil texture)

Erosion control measures are well-established in construction sites. All most all the excavated soil use to refiling and leveling of the sites.

53





Soil erosion due to loss of vegetation

Mangrove vegetation should be minimally disturbed during the construction phase to reduce soil erosion and safeguard waterbody protection

Inspection Once before, regularly during and once after construction

EPC Contractor

Status of ground cover in constructed areas

Complied with necessary mitigation measures. No impact to Mangrove vegetation due to ongoing construction activities.

Re-plant degraded areas with local species common in the area to Complement natural vegetation regeneration to improve ground cover.

Routine Maintenance Supervising engineer

Revegetation per sq. m)- Costing will be done by ecologist

Will be complied with the proposed tree planting process.

Water Pollution Maintenance of construction vehicles should be carried out in the Contractor's day-time camp.

Routine inspection, Maintenance records

Consultant Supervising Engineer and Contractor

Water quality parameters

DO, BOD, COD, Water transparency, oil content, coliforms

Complied with proposed mitigation actions.

Impact on aquatic fauna Strict measures should be taken to minimize the impact on aquatic life

Scientific investigation should be undertaken downstream delineate the area impacted by the plume.


Consultant Contractor

• Ichthyo-plankton surveys

• Zooplankton and phytoplankton surveys

Not applicable due to omission of pier construction.

54





Impact on aquatic resources

A survey should be carried out to assess any impact on marine resources. Changes in fish Catch in particular. Complaints may likely to be received from local fishermen regarding decreasing catches after the project.



Records of fish and shellfish impingement:

• number and weight

by species • fish catch data

Not applicable due to omission of pier construction. No records regarding the impact on marine resources.

Impact on seagrass meadows

A survey should be carried out to assess any impact on seagrass meadows.



Underwater survey for diversity and extent of seagrasses within direct Impact Zone

Not applicable due to omission of pier construction.

Invasive species

A survey should be carried out to assess any invasion of invasive species.



Surveying for new populations of invasive species resulted from Construction.

Investigations are carried out within construction area, roads witch use for the transportation of materials and storage yards.

Management of Solid Waste

The contractor must dispose of solid wastes away from the site to an approved licensed waste disposal site.

Routine Maintenance Contractor, Supervising Engineer

Complied with proposed actions.

Solid soil Waste and stone debris

Transportation of waste from site & safe disposal

Project Duration Contractor Supervising Engineer

All type of disposal materials disposes to the approved site by the LAs.

55





Drainage construction Of pylons may interfere with the natural drainage systems and modify the flow of surface water

In sections along watercourses, earth and construction waste will be properly disposed of so as not to block waterways, resulting in an adverse impact on water quality

Properly disposed waste Contractor Supervising Engineer

Complied with proposed actions.

All necessary measures will be taken to prevent earthworks from Impeding cross drainage at rivers/ streams, canal/existing irrigation and drainage systems

56

4.0 Summary

The overall evaluation of the Environmental Monitoring Programme will be assessed based on Table 3.1 and 3.2.

Sub-Project Name Environm- ental screening is carried out? (Yes or No)

Environment category of the project / subproject (A/B/C/FI)

EIA/IEE/ DDR with EMP is prepared (Yes/No)

ADB approved EIA/IEE with EMP (Yes / Under Review/ Not Yet Due/Overdue)

Government approved EIA/IEE with EMP (Yes / Under Review / Not Yet Submitted)

Safeguard monitoring and coordination mechanism established (Yes/No)

GRC is established (Yes /No)

Automated safeguard monitoring system customized (Yes/No)

EMP cost in approved document is included in BOQ as an individual item (Yes/No)

Wind Power Generation Project (Project No. 49345-002):

Integrate the 100 MW power from the Mannar Wind Power Generation Project to National Grid network of Sri Lanka.

Yes A Yes Yes Yes Yes Yes Yes Yes

Green Power Development and Energy Efficiency Improvement Investment Program (GPD&EEIIP) - Tranche 2 (Project No. 47037-005)

Package 2: Lot A - Construction of Nadukuda 220/33 kV Grid Substation & Augmentation at Mannar 220/33kV Grid Substation

Yes A

Yes Yes Yes Yes Yes Yes Yes

Package 2: Lot B1 - Construction of 30 km long Mannar–Nadukuda 220 kV transmission line

Yes Yes Yes Yes Yes Yes Yes Yes

57

Table 4.1: Overall Compliance with EMP/ EMoP

No. Sub-Project Name

EMP/ CEMP Part of

Contract Documents

(Y/N)

CEMP/ EMP Being

Implemented (Y/N)

Status of Implementation

(Excellent/ Satisfactory/ Partially Satisfactory/ Below Satisfactory)

Action Proposed and Additional Measures Required

1. Wind Power Generation Project (Project No. 49345-002):

Integrate the 100 MW power from the Mannar Wind Power Generation Project to National Grid network of Sri Lanka.

Y Y Partially Satisfactory (Quarterly) Monitoring Reports by the CEB have not been submitted for Q1, Q2, Q3 and Q4 of 2019. The reminders in previous external monitoring reports have not been taken into consideration by the CEB.

Environmental quality measurement reports (water quality, air quality, noise levels, vibration) are available. Soil testing report is not available.

Records of daily visual inspections for air quality have not been recorded. A summary of monthly monitoring reports is available, which are too summarily prepared. Dust control is very poor, hover, no mitigation is practised, and no records are kept by the contractor/sub-contractors and monitoring by the CEB is poor.

Environmental impacts related to activities of the sub-contractors (especially that of Access Engineering) have not been monitored, either by the contractor or the CEB.

Gravel borrow sites, material procurement (gravel, sand and soil) are not monitored by the Contractor/Sub-contractor. Records of transport vehicles, storage yards, parking areas, etc. are not available and are not monitored. Records of land clearing for material stockyards are not available. VEC of construction machinery and vehicles are not monitored.

No environmental monitoring is done at the concrete batching plant, and related activities.

58

2. Green Power Development and Energy Efficiency Improvement Investment Program (GPD&EEIIP) - Tranche 2 (Project No. 47037-005)

Package 2: Lot A - Construction of Nadukuda 220/33 kV Grid Substation & Augmentation at Mannar 220/33kV Grid Substation

Y Y Satisfactory Construction of the grid sub-station is in progress. Measures for dust control should be improved. Solid waste should be collected and disposed of properly.

The CEB has submitted Quarterly Monitoring Reports for Construction of Nadukuda GSS and Transmission Line. The External Monitoring Team has provided comments for revision of the Quarterly Reports. However, to date, no revised version of the Quarterly Reports have been submitted to the External Monitoring Team for review.

Package 2: Lot B1 - Construction of 30 km long Mannar–Nadukuda 220 kV transmission line

Y Y Satisfactory More than 90% of the towers have been erected. Others have been partially erected. No particular additional measures are required.

59

Annex 1: Photographs taken during field visits

Wind turbine transport vehicles Wind turbine yard

Site office built at the yard area Access road to Grid sub-stations

Safety and warning signs erected at appropriate locations

Material waste/soil piles inside the Grid sub-stations site

60

Boundary walls (partially constructed) Poor storage of Formwork

Garbage disposed at nearby lands Site clearing at Grid sub-stations

Administration building Soil erosion at Administration building site

61

Main access road to wind towers Ongoing constructions at Main access road

Shoulder construction at Main access road Culvert construction at Main access road

Construction progress (Tower 33) Construction progress (Tower 16)

62

Construction progress (Tower 22) Garbage disposed at site (Tower 22)

Construction progress (Tower 26) Transporting the parts of Wind tower base

Construction progress (Tower 12) Construction progress (Tower 12)

63

Construction progress (Tower 09) Bentonite collection

Pile construction in progress (tower 08) Transmission Tower base

Stringing in progress Stringing (Completed)

64

Annex 2: Summary of consultations

Date Venue Description

20.03.2019 Wind Farm, Transmission line, Grid Substation, Mannar

Reconnaissance surveys, field visits, discussions with field personnel

28.03.2109 Asian Development Bank Discussions with the ABD staff and the CEB staff

29.06.2019 Wind Farm, Grid Substation, Mannar

Detailed surveys, field visits, discussions with field personnel

30.06.2019 Transmission Line, Mannar Detailed surveys, field visits, discussions with field personnel







65

Annex 3.1: Summary of Environmental Safeguard Monitoring Reports Received

Component Report Status and comments

ADB Loan 3483/3484 SRI: Green Power Development and Energy Efficiency Improvement Investment Programme (Tranche 2)

Package 2: Lot B1 Construction of Mannar – Nadukuda 220kV Transmission Line

Package 2: Lot A Construction of Nadukuda 220/33 kV Grid Substation & Augmentation at Mannar 220/33kV Grid Substation

Q1 (January 1 – March 31, 2019)

Environmental Safeguard Monitoring Report Received.

Comments submitted to the CEB.

Response matrix pending

Q2 (April 1 – June 30, 2019) Environmental Safeguard Monitoring Report NOT Received.

Q3 (July 1 – September 30, 2019)


Comments are submitted to the CEB as part of this External Monitoring Report

Two weekly checklists (#21 and #25) have been forwarded by the Contractor

Q4 (October 1 – December 31, 2019)


Comments are submitted to the CEB as part of this External Monitoring Report (See Annex 5 of this report)

Wind Power Generation Project (Project No. 49345-002)

No quarterly Environmental Safeguard Monitoring Reports have been received so far for 2019 from the CEB.

Monthly Environmental Monitoring Reports submitted by Vestas have been forwarded.

(for October, November and December 2019) – See Annex 4.1 of this report.

66

Annex 3.2: Summary of Monitoring Reports of Environmental Quality Parameters Received

Parameter Wind Farm Transmission Line Nadukuda GSS

Baseline Reports

Monitoring Reports

Baseline Reports

Monitoring Reports

Baseline Reports

Monitoring Reports

Water Quality

Sept 24, 2019 NBRO

20.01.2020

NBRO -

21.05.2018 19.09.2019

Awaiting: 27.12.2019

June 06, 2019 MBRO

Air Quality Sept 10, 2019 NBRO

16.12.2019

NBRO -

14&15 Jan 2019

18 and 19.09.2019

Awaiting: 27 and 28.12.2019

May 10, 2019 NBRO

Noise Sept 10, 2019 NBRO

16.12.2019

NBRO -

14.01.2019 19.09.2019

Awaiting: 27.12.2019

May 10, 2019 NBRO

Vibration Sept 10, 2019 NBRO

16.12.2019

NBRO - - - -

Soil testing - - - - 10.04.2019 14.11.2019

Geotechnical June 6, 2019 UoM, Access

- - - - -

MWPP-VAPC-HSE-MPR-0001 1 November 2019

Environmental Monitoring Report - October 2019 1

Environmental Monitoring Report - November 2019

Reporting Period October 1st to 31st October 2019

Date 1st November 2019

Mannar Wind Power Project

Construction of 100MW Semi Dispatchable Wind Farm in Mannar Island

Ceylon Electricity Board

Prepared by Vestas for the Ceylon Electricity Board

Annex 4.1: Monthly Environmental Monitoring Reports for the Wind Farm and Test Reports for Water Quality and Air Quality



Version History

Revision Date Changes Overview Remarks

A 01/11/2019 First Issue

This version,

Main Contractor

(Vestas Asia Pacific

A/S)

Prepared By: V. Ravi Environmental & Social

Safeguard Officer

Approved By: Sivaprakash

Mohan Assistant Project Manager

Paper Size (for printing)

Main Document (Page 1 to 10) A4

Document Type Monthly Progress Report

Discipline HSE

Area Project Wide

Document Classification Restricted



Contents Executive Summary ................................................................................................................................. 4

1.0 Introduction ................................................................................................................................ 5

1.1 Brief Project Description ......................................................................................................... 5

1.2 Project Progress Status and Implementation Schedule .......................................................... 5

Implementation Schedule ............................................................................................................... 5

2.0 Compliance to National Regulations ........................................................................................... 6

2.1 Applicable National Laws, regulation and policies ....................................................................... 6

3.0 Compliance to Environmental Covenants from the ADB Loan Agreement ................................ 7

4.0 Compliance to Environmental Management Plan ...................................................................... 8

4.0 Safeguards Monitoring Results and Unanticipated Impacts ...................................................... 8

6.0 Implementation of Grievance Redress Mechanism and Complaints Received from

Stakeholders ......................................................................................................................................... 10

7.0 Conclusion and Recommendations........................................................................................... 11

Annex 1; Photo sheet ............................................................................................................................ 11



Executive Summary

The Environmental Impact Assessment (EIA) of this project has carefully reviewed by the Vestas. As

first step to comply the EIA recommendations, the Construction Method Statement (CMS) has

prepared and submitted to the CEB. Further, the SEMP submitted to CEB.

This monthly report is prepared as per the request and outline provided by the contractor for civil

activities for the month of October 2019. An environmental and social safeguard officer with the HSE

team has established to perform this task. Around eight site induction and 117 tool box meetings

have conducted to the staffs during this period.

Preparatory works of main access road, access road 1, accommodation building column work, piling

works and admin building foundation and soil stock works are the main civil activities during October

2019.

Environmental parameter testing for second quarter will be conducted by end of November 2019.

No any exceedance of environmental standards was identified.



1.0 Introduction

1.1 Brief Project Description

Ceylon Electricity Board is implementing a semi-dispatchable 100 MW wind power project in Mannar

with the loan assistance of Asian Development Bank. The main benefit from the project is electricity

generation from wind power of about 345 gigawatt hours (GWh) per year, which will be avoiding

electricity generation from conventional power plants such as thermal power.

The project is comprised the construction of the following major components:

1. A total of 30 wind turbines with a turbine specification and layout to comply with

environmental and social aspects;

2. A collector substation and control building;

3. The collector cables, step-up transformers and switchgears and accessories;

4. Supporting infrastructure will consist of access roads, temporary storage facilities, building

and staff accommodation facilities, etc.

The proposed wind power farm is in the southern part of Mannar Island from Thoddaveli to Pesalai

South, with a length of about 12.5 kilometers (km) along the coast. A row of 30 turbines will be

placed about 150 meters (m) to 160 m from the shoreline. The proposed wind farm has excluded the

areas coming under the Adam’s Bridge Marine National Park (by approximately 1 km) declared in

2015 by the Government of Sri Lanka (GoSL). Several Navy camps and Navy observation points, boat

landing sites, ma-del hauling sites, and fishermen vaadi/camps (seasonal), two investment cabanas,

and a tourist hotel are found within the wind farm block. Access roads to the Navy camps, fishermen

camps and fish landing sites from Mannar- Thalaimannar highway, and roads parallel to the coastline

are also found within the wind farm.

VESTAS ASIA PACIFIC A/S as a main contractor has awarded to construct the wind farm in Mannar by

the CEB during November 2018.

1.2 Project Progress Status and Implementation Schedule

Implementation Schedule

The Implementation period of the MWPP is from May 2019 to November 2020. The major activity of

this project includes, construction of access roads, rehabilitation of roads, construction of 30 nos. of

wind towers, construction of buildings, bird collision detection system, community roads and

sanitary facility for fishing community.

During the reporting period, mainly three activities are in-progress. Those are test bore hole works,

surveying of access roads and batching plant construction. The following table is giving the summary

of the civil work status as on 31st July 2019.



Activity Unit Total

Qty Act Qty

Sub base 1st layer Preparation - Main Access

Road m 12500 820

Culvert road – Main access road Nos 24 0.5

Access road1 – soil laying m 2250 60

Access road 1 - Excavation M3 2250 100

Admin building screed concrete M3 180 180

Admin building RR work M3 103 80

Construction columns & 1st floor slab – Admin

building M3 180 30

Accommodation building- sand filling M3 1540 1400

Subgrade preparation - Accommodation M2 22000 2276

Accommodation - Brick work M2 1249 172

Boundary wall – RR work - Accommodation M3 275 59


WTG access road Nos 30 5

Foundation excavation Nos 30 1

Table 1 Summary of work progress as on 31st October 2019

Man Power

In addition, an Environmental and Social safeguard officer, HSE manager, HSE officers are appointed

by Vestas and one HSE manager, three safety officers are appointed by two sub-contractors. This

team is executing the environmental and social related matters in addition to the health and safety

aspects.

2.0 Compliance to National Regulations

2.1 Applicable National Laws, regulation and policies

Following national Laws, regulations and policies are identified as applicable to the MWPP in the EIA

report.



• National Environmental Act (NEA) No 47 of 1980, and its amendment Act No. 56 of 1988

and Act No. 53 of 2000

• Flora and fauna Protection Ordinance (FFPO) amended by Act No. 38 of 1949Agrarian

Services Act No. 58 of 1979

• Forest Act No. 34 of 1951Control of Pesticide Act No. 33 of 1980

• PradeshiyaSabha Act No. 15 of 1987Crown Land Ordinance (Chapter 454)

• Sri Lanka Electricity Act No. 20/2009 and 2013 (as amended)

• Felling of trees Act No. 9 of 1951

• The Ma-del (beach seine) Regulations of 1984

• Fisheries and Aquatic Resources Act No. 2 of 1996 (and subsequent amendments, No 22 of

2006, 35 of 2013)

• Coast Conservation Act No 57, of 1981, amended by Act no 4 of 1996

• Marine Pollution Prevention Act No 35 of 2008

• Soil Conservation Act No 25 of 1951 subsequent amendments:

• Land Acquisition Act No 9 of 1950 and Local Authority Regulations of 2008

• Explosive Act No. 34 of 1976

• Felling of Trees Control Act No. 09 of 1951 as amended through Act No. 30 of 1953

• Public Utilities Commission of Sri Lanka Act No 35 of 2002.

• Sri Lanka Sustainable Energy Authority Act No. 35, 2007

• Agrarian Services Act (N0 58 of 1979)

• Flood Act N0 22 of 1955

• Monuments and Archaeological Sites and remains Act, 1958. Act No24 of 1958

• Motor Traffic Act No 60 of 1979

• National Involuntary Resettlement Policy

• National Institute of Occupational 1 Safety and Health Act, No. 38 Of 2009

• Geological Survey and Mines Bureau (GSMB) Act no. 33 of 1992

• Irrigation Act No. 1 of 1951

• Land Acquisition Act No. 9 of 1950

• National water Supply and Drainage Board (NWS&DB) Act No. 2 of 1974

• State Land (Recovery Possession) Act No 7 of 1979

• Urban Development Authority (UDA) Act No. 7 of 1978

3.0 Compliance to Environmental Covenants from the ADB Loan

Agreement

ADB loan agreement of schedule 5 para 2 stated as, ‘The burrower shall ensure that (a) all applicable laws and regulations of the Guarantor relating to environment, health, and safety; (b) the

Environmental Safeguards; (c) the Environmental Assessment Results Framework (EARF); and (d) all

measures and requirements set forth in the respective IEE or EIA, EMP and BMP, and any corrective

or preventative actions set forth in a safeguards monitoring report.

In addition to this Vestas will ensure that the preparation, design, construction, implementation and

operation and commissioning of the project and all project facilities pertaining to the tender

document will comply with;



a. All applicable laws and regulations of the country relating to environment, health and safety,

b. Environmental safeguards,

c. Requirements outlined in the EIA, EMP, EMoP, BMP and any corrective or preventive actions

mentioned in this monitoring report.

4.0 Compliance to Environmental Management Plan

Construction Environmental Management Plana and Site-Specific Environmental Management Plan

had developed and submitted to CEB.

In addition, three ways of approach has developed to implement the EMP;

1. A daily progress review meeting organized with the civil work sub-contractor it includes the

discussion of environmental issues based on the previous day observation.

2. Independent inspection – The Environmental & Social Safeguard Officer of Vestas will inspect

the work sites regularly.

3. Monthly Environmental & Safety committee – Collective inspection with CEB, Vestas and sub-

contractor has organized by Vestas and the monthly inspection and discussion is in progress.

4. Independent safeguard monitoring team has visited on 19th October 2019 to the project area

as their routine second quarter visit.

5. ADB has visited with CEB on 28th October 2019 and inspected our project area.

5.0 Safeguards Monitoring Results and Unanticipated Impacts

Environmental parameter testing carried out by NBRO, the result report is received the same is

submitted to the CEB. The following table outlined the quality rank for the environmental and social

safeguard effort during the reporting period.



No Activity / Task Excellent Very Good Good Poor Very Poor Remarks

1 Land Survey & Clearance Completed

2 Geotechnical Investigation Completed

3 Pile Foundation √4 Excavation for WTG Foundation NA

5 Excavation of UG Cable Trench & Cable Laying NA

6 WTG Components Shifting / Transportation NA

7 PCC NA

8 Anchor Cage Assembly & Installation NA

9 Steel Reinforcement NA

10 UG Cable Laying NA

11 Trans Mixer Movement √12 Tower Sections Installation NA

13 Nacelle Assembly & Installation NA

14 Blade Assembly & Installation NA

15 Main Access Road Development & Construction √16 Access Road 1 Development & Construction √17 Access Road 2 Development & Construction NA

18 Access Road 3 Development & Construction NA

19 Development of Culverts in Access Roads √20 Accommodation Building Construction √21 Admin Building Construction √ NA

22 Storage Yard Development √23 Crane Pad & Hard Stand Development NA

24 Loading & Unloading of Components √25 Commissioning of Feeder NA

26 Commissioning of Switch Gears NA

27 Batching Plant Development, Construction & Operation √28 Labor Camp facilities at Construction site √29 Driving in Windfarm Roads √30 Working at Night √31 Social safeguard activites (5.13) NA

The following CMS checklist attached accordance with the contract requirement.



SNo. Procedure to be followed Yes/No Impact Action Taken

A

1 Site induction for each workman prior to commencing activities on site. Penalties of violating any EMP/regulatory

requirements must be explained and agreed. Y

Every workers have inducted and it is

continuing with the intensive monitoring

Weekly mass tool box meeting and

monthly safety committee meetings are in

progress

B Pre-Construction & Site Preparation

1

Mark work areas, exclusion areas that are situated in the coastal/private areas. Make arrangement as per design and

location finalized by CEB/CCD for toilets at site. No water well will be located within minimum 100 m of a toilet facility

or vice versa. Y

Work area is marked, sign boards are in

place Continuous monitoring & reporting

2 Designate and fence using sheets all laydown areas, material storage area, personnel area Y

Storage yards and workers

accommodations are arranged accordingly Continuous monitoring & reporting

3

Provide orientation training to construction staff on working methods that relate to air, water, noise and soil pollution,

avian, avifauna and mammal life in the area. Instructions on not to damage any property of local fishermen should

also be given. Fishing is not allowed by construction staff within project area. Y

Awareness program and safety induction

included the aspects and related notice

boards were displayed Continuous monitoring & reporting

4Designated area can only be used for storage of water, oil, construction material etc. with marked area for

construction. Park equipment within the same area specified by CEB as per design. Y

Related areas were selected with the

clients concurrence Continuous monitoring & reporting

C Access Road to each Wind turbine site in the coastal area

1 Ensure minimal disturbance to flora and fauna during construction of access route to Wind turbine footing Y Site specific safeguard plan is in place Some works are started

2 Ensure water channels are not blocked. Make use of culverts as required Y

Appropriate bypass has constructed with

the concurrence of client

3 Remove extra sand/soil from site and store it in areas of depression. Do not throw any waste into the waterways to

pollute ecosystemY

Strict measures has implemented. An

Environmental rules sheet prepared and

read out at every TBM Tracking the TBM sheets

D Laydown areas next to each Wind turbine site in the coastal area

1 Ensure minimal disturbance to flora and fauna during construction of laydown area next to Wind turbine footing Y Only the hardstand area shrub cleared

2 Make arrangements to reroute water channels near the construction areas if avoidance is not possible in consultation

with the project Ecologist. Y Channel diversion. Only one location identified

3 Remove extra sand/soil from site and store it in areas of depression until it is disposed of at locations specified by local

authorities offsite. Y

Removed extra sand used for backfilling

purpose of farm

E Wind turbine Foundation construction

1 Excavator must not disturb flora and fauna while working on Wind turbine foundation site NA

2 Planning for stacking of dugout sand/soil from foundation. Sheet piles to be used to avoid caving in of the sand sides

into the wind turbine foundation before concreting. NA

3 Dewatering of the area excavated for Wind turbine foundation erection into a pit for sedimentation and any oil

removal before letting of to the sea- prevention of pollution and damage to marine flora and fauna NA

4 Pre-cut/bent steel to be brought to Wind turbine site for fixing in the dugout foundation NA

5 Usage of premix concrete lorry with long boom to fill concrete. NA

6 Backfilling and compaction at foundation to be followed by removal of excess soil to designated offsite location while

ensuring no marine flora or fauna is damaged/killed NA

F Wind turbine, Nacelle and Blades Erection

1 Crane should not traverse directly over water course – use culverts NA

2 Carefully position heavy cranes and structures inside hard standing area for Wind turbine to ensure no damage NA

G Construction/Decommissioning of Pier for equipment

1 Noise for digging of piles to be monitored. Construction only during prescribed working timing of the area. Night time

working not allowed. NA

2 Decommissioned pier to be removed entirely from the project site and the piles will be cut at least 1 m below the

coast sand to ensure that the fishing nets do not entangle into its protruding edges NA

H Digging/Construction of Cable Trenches

1 To ensure minimum water course crossing in the coastal area. Trenches to run along the access roads and be covered

to avoid soil erosion. NA

2 Construct sheet piles at corners of waterways areas to avoid damage to waterways NA

I Removal of construction waste material

1 Remove all waste material from coastal area including excess soil preventing water flow to designated waste

containment areas specified by the local body. Y

All site wastes are segregated and collected

at site. The final disposal is according to

the recommendation of EMP.SWM plan is

prepared

2 Remove all liquid waste material from coastal area NA

CONSTRUCTION METHOD STATEMENT CHECKLIST - October 2019

General Procedures

(The EPC contractor shall comply with Annexure 4 on Construction Method Statement for compliance with ADB SPS 2009.)

The EMP (Annexure 3), the EMoP (Annexure 5), and the Construction method statement (Annexure 4) shall be read together for environmental safeguards compliance for working within the wind farm project area by the EPC contractor. The following

checklist will be reviewed by CEB and more details may be added as deemed suitable.

6.0 Implementation of Grievance Redress Mechanism and

Complaints Received from Stakeholders

Complaint boxes prepared with record books at the following locations are identified to install the

compliant boxes, will be checked daily and keep recording if any by the safety officers and by Vestas.

➢ Sub-contractors site office & Laboratory - Puthukudiyiruppu

➢ Sub-contractor’s storage yard - Thoddavely

➢ Batching plant – Periya Karisal

➢ Vestas office/ Storage area – Nadukkuda

➢ Admin building area - Nadukuda

➢ Accommodation building area - Thoddavely

So far, no grievances were received from public or any agencies. GRM committee formulated at

divisional secretariat office this month by CEB.



7.0 Conclusion and Recommendations

During the reporting period, Main access road works, accommodation building column work, admin

area column works, piling works, access road 1 and soil storage activities were carried out. Most of

the period of this month received precipitation. All works are strictly following the recommendation

of EMP, CMS and SEMP.

Onsite tool box meeting at accommodation

Worker with full PPE Condition of WTG 22 after piling work

Short tree planting at WTG 22 site

ADB visit to Vestas office

MWPP-VAPC-HSE-MPR-0001 1 December 2019


Environmental Monitoring Report - November 2019

Reporting Period November 1st to 31st November 2019

Date 1st December 2019







Version History



This version,

Main Contractor


A/S)


Safeguard Officer






Discipline HSE

Area Project Wide





1.0 Introduction ................................................................................................................................ 5










Stakeholders ........................................................................................................................................... 9





Executive Summary




This monthly report is prepared as per the request and outline provided by the contractor for civil

activities for the month of November 2019. An environmental and social safeguard officer with the

HSE team has established to perform this task. Around thirteen induction and 126 tool box meetings

have conducted to the staffs during this period.

Preparatory works of main access road, access road 1, accommodation building column work, piling

works, foundation work, admin building construction, components unloading, and soil & metal stock

works are the main civil activities during November 2019.

Environmental parameter testing for second quarter has collected by NBRO during last week of

November. No any exceedance of environmental standards was identified.



1.0 Introduction














South, with a length of about 12.5 kilometers (km) along the coast. A row of 30 turbines will be

placed about 150 meters (m) to 160 m from the shoreline. The proposed wind farm has excluded the

areas coming under the Adam’s Bridge Marine National Park (by approximately 1 km) declared in


landing sites, ma-del hauling sites, and fishermen vaadi /camps (seasonal), two investment cabanas,












The following table is giving the summary of the civil work status as on 30th November 2019.

Activity Unit Total

Qty Act Qty

Sub base 1st layer Preparation - Main Access

Road m 12500 12060

Culvert road – Main access road Nos 24 0.75




Access road 1 - Embankment 1st layer M3 2250 240

Admin building screed concrete M3 180 180

Admin building RR work M3 103 80

Construction columns & 1st floor slab – Admin

building M3 180 30

Accommodation building- sand filling M3 1540 1500


Accommodation - Brick work M2 960 260

Boundary wall – RR work - Accommodation M3 275 160


WTG access road leveling Nos 30 24

Foundation excavation Nos 30 2

Table 1 Summary of work progress as on 30th November 2019

Man Power


by Vestas and one HSE manager, three safety officers are appointed by two sub-contractors. This

team is executing the environmental and social related matters in addition to the health and safety

aspects.




report.






• Pradeshiya Sabha Act No. 15 of 1987Crown Land Ordinance (Chapter 454)







2006, 35 of 2013)



• Soil Conservation Act No 25 of 1951 subsequent amendments



















Agreement

ADB loan agreement of schedule 5 para 2 stated as, ‘The burrower shall ensure that (a) all applicable

laws and regulations of the Guarantor relating to environment, health, and safety; (b) the














Construction Environmental Management Plana and Site-Specific Environmental Management Plan








contractor has organized by Vestas and the monthly inspection and discussion is in progress.








3 Pile Foundation √4 Excavation for WTG Foundation √5 Excavation of UG Cable Trench & Cable Laying NA


7 PCC √8 Anchor Cage Assembly & Installation √9 Steel Reinforcement √







19 Development of Culverts in Access Roads √20 Accommodation Building Construction √21 Admin Building Construction √22 Storage Yard Development √23 Crane Pad & Hard Stand Development NA








A



Every workers have inducted and it is

continuing with the intensive monitoring



progress. No accidents were reported


1



or vice versa. Y


place Continuous monitoring & reporting



accommodations are arranged accordingly Continuous monitoring & reporting

3

















pollute ecosystemY


Environmental rules sheet prepared and

read out at every TBM Tracking the TBM sheets


1 Ensure minimal disturbance to flora and fauna during construction of laydown area next to Wind turbine footing Y Only the hardstand area shrub cleared


with the project Ecologist. Y Dewatering from culvert location

Strict measures implemented to reduce

the siltation effect.




purpose of farm


1 Excavator must not disturb flora and fauna while working on Wind turbine foundation site Y Exhavated soil is keeping at site

All area get barigated and soil erosion

and clopse measures at place


into the wind turbine foundation before concreting. NA


removal before letting of to the sea- prevention of pollution and damage to marine flora and fauna Y

Mud misxed water generatin while

dewatering

Cattch pirs or sediments earthen pits

have developed to prevent to mix with

water body


5 Usage of premix concrete lorry with long boom to fill concrete. NA


ensuring no marine flora or fauna is damaged/killed NA



















prepared


CONSTRUCTION METHOD STATEMENT CHECKLIST - November 2019

General Procedures



















During the reporting period, Main access road works, accommodation building column work, admin

area column works, piling works, foundation works, access road 1 and soil stock activities were

carried out. Most of the period of this month has received rainfall. All works are strictly following the

recommendation of EMP, CMS and SEMP.

Noise & Vibration measurement Site induction training

Condition of a truck mixture Sanitory facility at WTG site

MWPP-VAPC-HSE-MPR-0001 1 January 2020


Environmental Monitoring Report - December 2019

Reporting Period December 1st to 31st December 2019

Date 1st January 2019







Version History



This version,

Main Contractor


A/S)


Safeguard Officer






Discipline HSE

Area Project Wide





1.0 Introduction ................................................................................................................................ 5










Stakeholders ........................................................................................................................................... 9





Executive Summary




This monthly report is prepared as per the request and the report outline provided by the contractor

for civil activities for the month of December 2019. An environmental and social safeguard officer

with the HSE team has established to perform this task. 43 induction and 194 tool box meetings have

conducted to the staffs during this period.

Culvert works of main access road, accommodation building side wall constructions, piling works,

pile cap foundation concrete work, admin building construction, components unloading, and soil &

metal stock works are the main civil activities during December 2019.

Environmental parameter testing for second quarter has done collected by NBRO. No any

exceedance of environmental standards was identified.



1.0 Introduction














South, with a length of about 12.5 kilometers (km) along the south coast. A row of 30 turbines will

be placed about 150 meters (m) to 160 m from the shoreline. The proposed wind farm has excluded

the areas coming under the Adam’s Bridge Marine National Park (by approximately 1 km) declared in


landing sites, ma-del hauling sites, and fishermen Vaadi /camps (seasonal), two investment cabanas,












The following table is giving the summary of the civil work status as on 31st December 2019.

Activity Unit Total

Qty Act Qty

Culvert road – Main access road Nos 24 6


Access road 1 - Embankment 1st layer M3 2250 240



Admin building screed concrete % 100 34

Accommodation building- sand filling % 100 17



Pile cap Foundation concreting Nos 30 7

Table 1 Summary of work progress as on 31st December 2019

Man Power


by Vestas and three safety officers are appointed by two sub-contractors. This team is executing the

environmental and social related matters in addition to the health and safety aspects.




report.






• Pradeshiya Sabha Act No. 15 of 1987Crown Land Ordinance (Chapter 454)





2006, 35 of 2013)



• Soil Conservation Act No 25 of 1951 subsequent amendments





















Agreement

ADB loan agreement of schedule 5 para 2 stated, ‘The burrower shall ensure that (a) all applicable laws and regulations of the Guarantor relating to environment, health, and safety; (b) the












Construction Environmental Management Plan and Site-Specific Environmental Management Plan










contractor has organized by Vestas and the monthly inspection and discussions are in

progress.







A



Sub-contractor has a system to induct all

employees and Vestas has on its own

including visitors induction.



progress. No accidents were reported


1



or vice versa. Y


place. No wells excavated Continuous monitoring & reporting



accommodations are in designated Continuous monitoring & reporting

3

















pollute ecosystemY


Environmental rules sheet has prepared to

execute during TBT Tracking the TBM sheets


1 Ensure minimal disturbance to flora and fauna during construction of laydown area next to Wind turbine footing Y no clearing activity during the reporting periodOnly the hardstand area shrub cleared


with the project Ecologist. Y

No rerouting of water channes has found.

Only temporary bypass.

Strict measures implemented to reduce

the siltation effect.




purpose of farm


1

Excavator must not disturb flora and fauna while working on Wind turbine foundation site Y

All exhavators are working with in the

confied area. Parked away from sensitive

locations

All area get barigated and soil erosion

and clopse measures at place


into the wind turbine foundation before concreting. Y

All dugouts has kept in a designated area

with the concurrence of CEB


removal before letting of to the sea- prevention of pollution and damage to marine flora and fauna Y

Mud mixed water generatin while

dewatering

Catch pits or sediments earthen pits have

developed to prevent to mix with water

body


5 Usage of premix concrete lorry with long boom to fill concrete. Y All washing activity set out side of the farm


ensuring no marine flora or fauna is damaged/killed Y It is measured as per the guidence of CEB



















prepared


CONSTRUCTION METHOD STATEMENT CHECKLIST - December 2019

General Procedures




A quality rank matrix has prepared based on the routine visit during the reporting month. The results

are as follows.






3 Pile Foundation √4 Excavation for WTG Foundation √5 Excavation of UG Cable Trench & Cable Laying NA


7 PCC √8 Anchor Cage Assembly & Installation √ √9 Steel Reinforcement √







19 Development of Culverts in Access Roads √20 Accommodation Building Construction √21 Admin Building Construction √22 Storage Yard Development √23 Crane Pad & Hard Stand Development NA



















During the reporting period, culvert works of Main access road, brick work of accommodation

building & admin building, piling works, pile cap foundation works, and soil stock activities were

carried out. Most of the period of this month has received rainfall. All works are strictly following the

recommendation of EMP, CMS and SEMP.

Noise & Vibration measurement Condition of piling site

Sanitory facility at WTG location Condition of admin building site

Environmental Safeguard Monitoring Report

ADB Loan 3483/3484 SRI

Reporting Period Date

{ From October 01,2019 to December 31, 2019} { January 30,2020}

Green Power Development and Energy Efficiency Improvement Investment

Programme (Tranche 2)

Package 2: Lot B1 Construction of Mannar – Nadukuda 220kV Transmission Line

Package 2: Lot A Construction of Nadukuda 220/33 kV Grid Substation & Augmentation at Mannar 220/33kV Grid

Substation

Prepared by the Ceylon Electricity Board for the Asian Development Bank

Annex 4.2: Quarterly Environmental Monitoring Reports for the Nadukuda GSS and Transmission Line and the Soil Test Report

GPDEEIIP Tr 2 P1&P2 P a g e | 1

TABLE OF CONTENTS

Page

Abbreviations 2

Executive Summary

• Brief status of environmental compliance during the coverage period 3

1.0 Introduction 3

2.0 Compliance to National Regulations 7

3.0 Compliance to Environmental Covenants from the ADB Loan Agreement 8

4.0 Compliance to Environmental Management Plan 8

5.0 Safeguards Monitoring Results and Unanticipated Impacts 25

6.0 Implementation of Grievance Redress Mechanism and Complaints Received from Stakeholders 28

7.0 Conclusion and Recommendations 28


Abbreviations ADB – Asian Development Bank CCD – Coast Conservation Department CEA – Central Environment Authority, Government of Sri Lanka CEB – Ceylon Electricity Board DC or D/C – Double Circuit DPR – Detailed Project Report DSD – Divisional Secretariat Divisions EA – Executing Agency EARF – Environmental Assessment and Review Framework EIA – Environmental Impact Assessment EMoP – Environmental Monitoring Plan EMP – Environmental Management Plan EHV – Extra High Voltage GHG – Green House Gas GND – Gram Niladhari Divisions GoSL – Government of Sri Lanka GRC – Grievance Redress Committee GRM – Grievance Redress Mechanism IA – Implementing Agency IEE – Initial Environmental Examination LILO – Line – in- Line- out MFF – Multi-tranche Financing Facility MOPE – Ministry of Power and Energy. Government of Sri Lanka PAA – Project Approving Authority PCB – Poly Chlorinated Biphenyl PMU – Project Management Unit REA – Rapid Environment Assessment ROW – Right of Way RP – Resettlement Plan SC or S/C – Single Circuit SF6 – Sulphur Hexafluoride SPS

GPD&EEIIP1-2 – –

Safeguard Policy Statement Green Power Development & Energy Efficiency Improvement Investment Programme (Tranche 1) Part 2

WEIGHTS AND MEASURES

ha (hectare) – Unit of area

km (kilometer) – 1,000 meters

kV – kilovolt (1,000 volts)

kW – kilowatt (1,000 watts)

MW – Mega Watt

NOTE{S}

In this report, "$" refers to US Dollars.

“LKR” refers to Sri Lankan Rupees


EXECUTIVE SUMMARY

In the efforts to harness renewable energy in the country, wind has been identified as a source of significant

potential to generate electricity. Studies carried out by both local and international experts envisaged that 375

MW of wind capacity with 35~45% plant factor could easily be developed in the Mannar island. Accordingly,

CEB has planned to set up a 220/33kV GSS at Nadukuda in the Mannar island and a 220kV transmission line

from Nadukuda to Mannar in order to evacuate the wind power generation in the Mannar island under the

Green Power Development and Energy Efficiency Improvement Program (Tranche II) which will be funded by

ADB.

Under this project component, it is proposed; (1) to construct 220/33kV Grid Substation (GSS) at Nadukuda in

Mannar island and the augmentation of Mannar GSS. This GSS will able to absorb entire 375 MW of wind power

at this stage only 2 X 63MVA capacity transformers will be installed with the provision to install further 4 X

63MVA transformers in the future. (2) to construct a 30km of 220kV transmission line from Nadukuda GSS to

the Mannar GSS. The Nadukuda GSS will interconnect the clusters of wind plants at 33kV level and transmit the

power & energy to Mannar Grid Substation via the 30km long 220kV transmission Line.

Green Power Development and Energy Efficiency Improvement Investment Program (Tranche II) has been

launched with a focus to develop transmission and distribution projects for evacuation of renewable energy

(wind) parks/ projects and overall improvement of energy efficiency and capacity development.

Green Power Development and Energy Efficiency Improvement Investment Program is

intended to finance a series of investments in Sri Lanka. It includes generation capacity enhancement,

transmission capacity addition and distribution system strengthening installation energy efficiency measures.

The Investment Program will also finance a number of “softer” activities, including operational capacity

building and implementation supervision. The objective of the investment is to achieve increased adequacy

and efficiency of power system, including renewable energy in Sri Lanka.

1.0 Introduction


The Green Power Development & Energy Efficiency Improvement Investment Programme (Tranche 2)

Package 1 & 2 Transmission Infrastructure Capacity Enhancement Project, consists of following Lots

with the estimated costs:

Package Lot Project Total

(MUSD)

1 Lot A Hambantota Grid Substation 220kV development 15.5

Lot B New Polpitiya-Hambantota 220kV, 150km transmission line 57.3


The contract details including the contract price of the following two lots under Package 2 are as follows.

Package 2: Lot B1 Package 2: Lot A

Scope Construction of Mannar – Nadukuda

220kV Transmission Line

Construction of Nadukuda 220/33 kV Grid

Substation & Augmentation at Mannar

220/33kV Grid Substation.

Contractor KEC International Limited Siemens Limited, India.

Contract Price

including change

orders

Contract Amount

LKR 426,309,080.00 +USD 6,477,201.00

Change Order 01

LKR 8,240,000.00 +USD 88,638.00

Change Order 02

LKR 3,955,000.00 +USD 21,518.00

Contract Amount

LKR 932,903,081.57 + USD 11,901,167.32

Change Order 01

LKR 5,660,000.00 + USD 476,988.00

Contract Effective

Date October 04, 2017 March 16, 2018

Expected Completion

Date

May 04, 2020

{ extension of time have been granted as

per the Change Orders No 01 & No 02}

March 16, 2020


A. Progress Status of the Package 2: Lot B1 Construction of Mannar – Nadukuda 220kV Transmission

Line

The updated status of environment activities during the period of October 2018 to December 2018

is given below for the Transmission Line.

Description Status

2B1

Mannar - Nadukuda 220kV, 30km

transmission line

1. Profile & Tower designs were completed.

2. 90% of Equipment Procurement is completed

3. 76 Erection of towers were completed

4. 80 foundations were completed

Site Photos of Construction of Mannar – Nadukuda 220kV Transmission Line


Note: Completion of foundation in most of the locations acquired more time than estimated due

to heavy rainfall in the northern region. Hence the work progress is slightly low during this

quarter.

Construction in vankalai bird sanctuary

The work has been started in the Vankalai from Febreuary 2019 onwards. The Progress was slow and

Contractor unsuccessful to finnish the all construction activities due to collapsible soil, more time taken

to manual excavation process ( removal of existing foundation at N1 & O0 locations taken additional

time) and delay in obtaining the transport facilities from Sri Lanka Railways as schedule to transfort the

Materials inside the Vankalai. All construction activities are under strict supervission of CEB as per the

BMP.


B. Progress Status of Package 2: Lot A Construction of Nadukuda 220/33 kV Grid Substation &

Augmentation at Mannar 220/33kV Grid Substation

The updated status of environment activities during the period of October 2018 to December 2018

is given below for the Grid Substation.

Description Status

2A

Construction of Nadukuda 220/33 kV

Grid Substation & Augmentation at

Mannar 220/33kV Grid Substation

1. Designs works were completed up to 90% .

2. Equipment Procurement are in progress

3. Control room building works are in progress

4. Transformer foundation works are completed

Site Photos of Construction of Nadukuda 220/33 kV Grid Substation & Augmentation at Mannar

220/33kV Grid Substation


The relevant Acts and Legislations to the project is given in the Table No. 2.0 Table No. 2.0: Applicable Acts and Legislations to the Project

Act/Rule/Notification Year Objective Compliance

Schedule Agrarian Services Act (Nº 58 of 1979)

Agrarian Development Act Nº 46 of 2000 1979 &

2000 To provide secure background to

farmers and their agricultural premises

Being complied.

Electricity Act 2009 2009 To provide reliable and affordable

electrical energy Being complied.

Fauna and Flora Protection (Amendment) Act

1993 (Nº 49 of 1993) 1993 To provide greatest protection to fauna

and flora Being complied.

Felling of Trees (Amendment Act Nº 01 of

2000 and Act to Amend felling oanuaryf trees

control)

2000 The control removal of trees. Trees have been

removed in the

GSS area.

Act/Rule/Notification Year Objective Compliance

Schedule

Fisheries and Aquatic Resources Act 1996 1996 To provide for the management,

regulation, conservation and

development of fisheries and aquatic

resources in the main land.

Being complied.

http://www.commonlii.org/lk/legis/num_act/asa58o1979220/


Flood Act Nº 22 of 1955 1955 Protection of areas subject to flood Being complied.

Forest Ordinance Act Nº 13 of 1966

Forest (Amendment) Act Nº 65 of 2009 1966 &

2009 Conservation, protection and

management of forest and forest

resources for control of felling and

transport of timber.

Being complied.

Irrigation Clauses Act 1973 1973 To provide regulations for the

construction of structures across the

irrigation canals and water resources.

Being complied.

Land Acquisition (Amendment) Act, Nº 13 of

1986 1986 Establishes the procedure to be

followed by the competent authorities

for the acquisition of land for public

purpose.

Being complied.

Monuments and Archaeological Sites and

remains Act, 1958. Act Nº24 of 1958.

Antiques Ordinance, 1960

1958

&1960 An Act to provide for the preservation of

ancient and historical monuments and

archaeological sites and remains of

national importance.

Being complied.

Motor Traffic Act Nº 60 of 1979 1979 To provide sustainable approach for

vehicle traffic. Being complied.

National Environmental Act Nº 47 of 1980,

amendment Nº 56 of 1988, and other

amendments.

1980 To provide protection, management,

enhancement of the environment with

prevention and control of pollution.

Being complied.

National Environmental (Protection &

Quality) Regulations, No 01 1990. 1990 To provide for the prevention and

control of water pollution and

enhancing the quality of water.

Being complied.

National Environmental (Ambient Air Quality)

Regulations, 1994. 1994. To provide for the prevention and

control of air pollution. Being complied.

National Environmental (Noise Control)

Regulations Nº1 1996. 1996. To provide maximum allowable noise

levels. Being complied.

National Involuntary Resettlement Policy. Land Acquisition Act does not deal with

the broader social and economic

impacts of the project. Thus, this policy

was established to overcome these

impacts.

Being complied.


3.0 Compliance to Environmental Covenants from ADB Loan Agreement

The applicable Environmental Covenants from the ADB Loan Agreement

Public Utilities Commission of Sri Lanka Act ,

Nº 35 of 2002. 2002 To create an environment for all

inhabitants of Sri Lanka and the

contributors to its development, to have

access to essential infrastructure and

utility services in the most economical

manner within the boundaries of the

sustainable development agenda.

Being complied.

Soil Conservation (Amendment) Act Nº 24 of

1996. 1996 Act for conservation of soil resources

and productive capacity of land. Being complied.

Product Description Remarks/Issues

ADB Loan

3483/3484 SRI

The Borrower shall ensure that the

preparation, design, construction,

implementation, operation and

decommissioning of the Project and all

Project facilities

comply with (a) all applicable laws and

regulations of the Guarantor relating to

environment,

health, and safety; (b) the Environmental

Safeguards; (c) the EARF; and (d) all measures

and requirements set for the in the

respective IEE or EIA, EMP and BMP, and any

corrective or

preventative actions set forth in a Safeguards

Monitoring Report.

CEB is taking every effort to

comply ADB requirement.


The Environmental Management Plan (EMP) has been prepared for the sub-project that

discusses the anticipated impacts, monitoring requirements, and development of mitigation

measures with respect to the following stages: (i) pre-construction, (ii) construction, and (iii)

operation and maintenance. Detailed, site-specific mitigation measures and monitoring plans

were developed and are being implemented during the project implementation phase.

GPD&EEIIP1-2 P a g e | 11

Monitoring of the implementation of Environmental mitigation measures – Transmission Line and the Grid Sub-Stations

Project Activity Potential

Environmental

Impact

Mitigation Action Monitoring Scope Standard Responsibility of

Implementation &

schedule


Pre-construction

Temporary use

of lands

Impact to the

existing

environment

Selection of lands adhering to

local laws and regulations and

in close consultation with LAs

Construction facilities should

be placed at least 100 m away

from water bodies, natural flow

paths, important ecological

habitats and residential areas.

No temporary land use in

Vankalai Sanctuary.

Water and air

quality

Air quality

Standards and CEA

water quality

standards

CEB

Contractor

Detailed design

summary of Ambient air quality, water

quality reports enclosed

Substation

location and

design

Noise generation

Exposure to noise,

Nuisance to

neighboring

properties

Disturbance to the

adjacent lands and

the people due to

cut and fill

operations

Substation designed to ensure

noise will not be a nuisance

(i.e. less than 55dBA LAeq

daytime and less than 45dBA

LAeq nighttime at nearest

receptor).

Maintain adequate clearance,

construction of retaining

structures, minimize cut and fill

operations adjoining to the

dwellings

Expected noise

emissions based on

substation design,

noise levels

Proximity to houses

and other structures

Noise control

regulations in 1994

Noise levels to be

specified in tender

documents

Technical

specification

CEB

Detailed Design

summary of existing noise level reports

enclosed

Location of

transmission

towers and

transmission line

alignment and

design

Line traversing

across

environmentally

sensitive areas with

possible impacts to

biodiversity and

excessive clearance

of vegetation

Excessive

requirements for

Setback of dwellings to

transmission line route

designed in accordance with

permitted level of power

frequency and the regulation of

supervision at sites.

Tower location and

line alignment

selection with

respect to nearest

dwellings

Setback distances

to nearest houses -

CEB

Part of tower

sighting survey and

detailed alignment

survey and design

The transmission line has been routed

through areas with low-grown

vegetation and agriculture, such as

paddy and low grown vegetables

A detailed design including tower type,

location, profile already been submitted.

Trees have been removed and

compensation has been paid for the

identified owners.



Environmental

Impact


Implementation &

schedule


clearance of way-

leaves and land use

restrictions in areas

of high population

density

Exposure to safety

related risks

Impact on water

bodies (Vankalai

sanctuary

wetland)/land/

residences

Consideration of tower location

where they could be located to

avoid avian breeding areas,

water bodies or agricultural

land as much as possible.

Follow EHS Guidelines on

avoiding water pollution.

Careful site selection to avoid

existing avian/marine

settlements and negative

impacts to sanctuary area.

Increase the height of towers,

adopt measures to reduce

possible collision with birds

during flight.

EPC contractor to implement

mitigation measures according

to Biodiversity Management

Plan and Construction Method

statement outlining

construction precautions in the

Vankalai Sanctuary area.

Site location, line

alignment selection

(distance to

dwelling, water

and/or agricultural

land)

Improve tower

design and

measures

Consultation with

local authorities

Biodiversity

Management Plan,

Dept of Wildlife

Conservation

CEB

Part of detailed

project sighting

and survey and

design

complied

Equipment

specifications

and design

parameters

Release of

chemicals and

harmful gases in

receptors (air,

water, land)

Ensure equipment design must

be sound to avoid emissions for

oil, gases etc.

Compliance with

setback distances

(as-built” diagrams)

Setback distances

to nearest houses

CEB

Detailed design

No significant amounts of emissions

(release of chemicals and harmful gases)

are envisaged.

Poly Chlorinated Biphenyls (PCBs) will

not be used in substation transformers



Environmental

Impact


Implementation &

schedule


or any other equipment. Exclusion of

PCBs in transformers stated in tender

specifications.

Encroachment

into precious

ecological areas

Loss of precious

ecological values/

damage to precious

species

Minimize the need for tower

base disturbance in sanctuary

wherever possible

Floral and faunal

habitats loss in

sanctuary area

Flora and fauna

protection act.

Biodiversity

Management Plan

CEB

Detailed design

complied

Interference

with drainage

patterns/water

channels

Temporally flooding

hazards/loss of

agricultural

production

Appropriate siting of towers

(use longer spans) to avoid

putting towers in water

channel to avoid disturbing

aquatic habitats in sanctuary

area.

Site location and

line alignment

selection

Irrigation Act 1933.

Consultation with

local authorities

and design

engineers

CEB

Detailed alignment

survey and design

The contractor has selected tower

locations in consultation with the CEB

and other authorities. No loss of

agricultural land and disturbances to

aquatic habitats have been observed.

Explosions/Fire Hazards to life Design of substations to include

modern fire control

systems/firewalls.

Provision of firefighting

equipment to be located close

to transformers, power

generation equipment.

Substation design

compliance with fire

prevention and

control codes

Tender document

to mention detailed

specifications

CEB

Part of detailed

substation layout

and design

/drawings

Provision of firefighting equipment has

been planned. This has to be verified

prior to commissioning.

Construction

Removal or

disturbance to

other public

utilities

Public

inconvenience

Advance notice to the public

about the time and the

duration of the utility

disruption.

Use of well trained and

experienced machinery

operators to reduce accidental

damage to the public utilities

and specifically any natural

habitats in Vankalai Sanctuary.

Restore the utilities

immediately to overcome

public inconvenient

Disruption of other

commercial and

public activities /

Public complaints

Technical

specification

CEB/ PRDA /

NWSDB/SLT

Throughout the

construction

period

No public utilities have been disturbed

as yet.

He contractor has employed well trained

and experienced machinery operators.

Natural habitats in Vankalai Sanctuary

have not been permanently damaged.



Environmental

Impact


Implementation &

schedule


Temporary

outage of the

electricity

Loss of power

supply to the local

community when

distribution lines

crossing the new

transmission line

are switched off

Advance notice to the public

about the time and the

duration of the utility

disruption

Restore the utilities

immediately to overcome

public inconvenience.

Houses and

commercial

premises of power

disruption

Regular monitoring

during the period of

strengthening the

conductors

Contractor CEB

Throughout the

construction

period

4km of the line stringing completed.

Temporary outages of 1hr for 10 days

taken.

Acquisition of

paddy fields and

other lands

Loss of agricultural

productivity

Avoid farming and bird’s migration/breeding season

wherever possible for the

project activities.

Ensure existing irrigation

facilities are maintained in

working condition

Protect /preserve topsoil and

reinstate after construction

completed Repair /reinstate

damaged areas etc. after

construction completed

Compensation for temporary

loss in agricultural production

Land area of

agriculture loss

Usage of existing

Utilities

Status of facilities

(earthwork in m3)

Implementation of

crop compensation

(amount paid,

dates, etc.)

Agrarian Service

Act.

Regular monitoring

compliance

with regulations

CEB, Contractor

through contract

provisions

Throughout the

construction

period

No acquisition of lands required for

tower foundation or line; Construction

of transmission towers is in progress,

and most of the tower erection have

been completed. The contractor, in

consultation with the CEB, has

avoided/minimized the cultivation

seasons, and bird migratory seasons to

the extent as possible.

The contractor has been able to

satisfactorily reinstate the damaged

construction areas to the satisfaction of

all the parties concerned.

Payment of compensation for crop

damages of paddy area are in progress.

Equipment

layout and

installation

Noise and

vibrations

Selection of construction

techniques and machinery to

minimize ground disturbance

Construction

techniques and

machinery/

Minimal ground

disturbance

CEB, Contractor

through contract

provisions

Construction

period

Disturbances have been kept to a

minimum. No significant noise and

vibration impacts recorded and no

complaints.

Substation

construction

Loss of soil Fill for the substation

foundations obtained by

creating or improving local

drain system.

Borrow area

sighting (area of site

in m2 and estimated

volume in m3)

Laws and

regulations of

respective LAs

CEB, Contractor

through contract

provisions

Construction

period

Filling of the site is complete. Road-side

drains adjoining the site area and the

access road have been maintained

properly.

No local drainage problems have been

observed so far.



Environmental

Impact


Implementation &

schedule


Water pollution Construction activities involving

significant ground disturbance

(i.e. substation land forming)

not undertaken during the

monsoon season. No work in

lagoon areas during high tide

periods.

Seasonal start and

finish of major

earthworks (pH,

BOD/COD,

Suspended solids,

other)

Sri Lanka’s National Environment Act

and IFC’s EHS guidelines 2007

(under revision)

Timing of major

disturbance

activities - prior to

start of

construction

activities

Construction

period

Much of the earthwork and filling

activities are completed now, and these

works have been carried out during the

dry season.

According to the contractor, no

earthworks are planned during the

forthcoming rainy season.

No surface water bodies found within or

around the substation area.

Construction

schedules

Noise nuisance to

neighboring

properties

Construction activities only

undertaken during the day and

local communities informed of

the construction schedule.

Timing of

construction (noise

emissions, [dB (a)])

Daytime

construction only

CEB, Contractor

through contract

provisions

Construction

period

There are no dwelling units located close

to the grid station site.

Tower construction near dwelling units

(e.g., close to the Mannar Railway

Station) has now been completed

No significant noise and vibration

impacts recorded and no complaints.

Nuisance to birds if

the line

construction

crosses their

migratory path

Restrict construction work

during the known period of

migration/breeding period by

the birds. Construction period

in the sanctuary to be finalized

in keeping with the CMS. Work

inside the sanctuary must be

undertaken from 1 hour after

sunrise to 1 hour before

sunset.

Timing of

Construction

Biodiversity

Management Plan,

Construction Timing

- period of

migration of birds

CEB, Contractor

Construction

period

All construction activities are conducted

during off migratory season; February

2019 to September 2019.

Note: Contractor not finished the all

construction activities by Sept 2019 due

to collapsible soil, more time taken to

manual excavation process ( removal of

existing foundation at N1 & O0 locations

taken additional time) and delay in

obtaining the transport facilities from Sri

Lanka Railways as schedule to transfort

the Materials inside the Vankalai.

Provision of

facilities for

construction

workers

Contamination of

receptors (land,

water, air)

Construction workforce

facilities to include proper

sanitation, water supply and

waste disposal facilities at

Amenities for

Workforce facilities/

National Solid

Waste

Management Policy

and IFC’s EHS

CEB, Contractor

through contract

provisions

Construction workforce has been

provided with proper facilities to include

proper sanitation, water supply and

waste disposal facilities (for both



Environmental

Impact


Implementation &

schedule


substation site in accordance

with EHS Guidelines. No

facilities to be setup within the

Sanctuary. Solid waste and

hazardous waste to be

disposed of offsite to a suitably

licensed landfill. No waste to be

disposed of to an unlicensed

dump site. Contractor to

prepare and implement a

pollution prevention and

emergency response plan in

accordance with EHS

Guidelines.

guidelines 2007

(under revision)

Construction

period

transmission tower workers and at

substation site) in accordance with EHS

Guidelines.

No labor camps have been setup within

the Sanctuary.

Solid waste and hazardous waste is

handed over to the Pradeshiya Sabha.

Wood/

Vegetation

harvesting, cut

and fill

operations

Loss of vegetation

and deforestation

Effect on fauna

Construction workers

prohibited from harvesting

wood in the project area

Prevent work force from

disturbing to the flora, fauna

including hunting of fauna and

fishing in water bodies. No

poaching allowed in Sanctuary

or bird habitat area.

Proper awareness programme

regarding conservation of flora,

fauna including ground

vegetation to all drivers,

operators and other workers

Illegal wood/

Vegetation

harvesting (area in

m2, number of

incidents reported)

Habitat loss

Complaints by local

people or other

evidence of illegal

harvesting

Fauna and flora

protection Act.

CEB, Contractor

through contract

provisions

CEB/ DWC/ DoF

Construction

period

Strict instructions have been given to

construction workers prohibiting from

harvesting wood in the project area,

disturbing to the flora, fauna including

hunting and fishing.

Poaching in the sanctuary or bird habitat

areas has been strictly prohibited.

Monthly awareness programme for

contractor carried out on conservation

of flora, fauna including ground

vegetation

Site clearance Vegetation Marking of vegetation to be

removed prior to clearance,

and strict control on clearing

activities to ensure minimal

clearance. Minimum vegetation

Vegetation marking

and clearance

control (area in m2)

Felling of trees

(Amendment Act.

Nº 01 of 2000 and

act of felling of

trees control).

Clearance strictly

CEB, Contractor

through contract

provisions

Construction

period

Vegetation has been removed in some

sites already. The contractor has been

instructed to record any tree species

prior to clearance and to exercise strict

control on clearing activities to ensure

minimal clearance.



Environmental

Impact


Implementation &

schedule


clearance to be done in the

sanctuary area.

No tree felling in Sanctuary

required. Private

trees/plantations will be

compensated as per GoSL

norms.

limited to target

vegetation

The contractor will be advised to submit

a tree planting programme within the

grid station area and elsewhere as

compensatory reforestation, and also as

a CSR project

Soil erosion and

surface runoff

Construction in erosion prone

mudflats, lagoon areas should

be restricted to the dry season.

Outline construction Method

Statement shall be the basis for

construction practice in

Sanctuary area. Treat clearing

and filling areas against flow

acceleration and construction

work should be carefully

designed to minimize

obstruction or destruction to

natural drainage

Soil erosion

.

Visual inspection

(Turbidity and

sedimentation)

CEB, Contractor

Through contract

Provisions

Construction

period

Construction of towers will be over prior

to the rainy season of 2019.

The contractor has been instructed to

clear any construction debris, spoil,

excavated soil from the site areas prior

to commencement of the rainy season.

Mechanized

construction

Noise, vibration and

operator safety,

efficient operation,

equipment wear

and tear

Construction equipment to be

well maintained.

Check for pollution prevention

and oil dripping etc. from

vehicles while working in bird

habitat and other area. Adopt

pollution prevention measures

in accordance with EHS

Guidelines

Proper maintenance and

turning off plant not in use.

Operating schedules

Noise control

regulations (1994),

Pollution

Prevention as per

International best

practices43

CEB, Contractor

through contract

provisions

Construction

period

The contractor is maintaining records of

the status of construction equipment

and machinery.

NO oil dripping has been observed

during site visits

Construction of

roads for

accessibility

Increase in airborne

dust particles

Existing roads and tracks used

for construction and

Access roads, routes

(length and width of

Use of established

roads wherever

possible

CEB, Contractor

through contract

provisions

The contractor has been using existing

roads for accessing tower locations.

Some of the tower locations have ben



Environmental

Impact


Implementation &

schedule


Increased land

requirement for

temporary

accessibility

maintenance access to the site

wherever possible.

New access ways restricted to a

single carriageway width within

the RoW. Avoid construction of

permanent access routes in

sanctuary area by use of mats

etc.

new access roads to

be constructed)

Access restricted to

single carriageway

width within RoW

Construction

period

accessed, and material transportation

has been done with the use of a railway

carriage.

Increased air-borne dust was not

observed at transmission tower

locations during the site visit.

Eventhough air-borne dust occur at the

grid sub-station site frequent water

spray along the road and construction

site is observed.

Transportation

and storage of

materials

Nuisance to the

general public

Transport loading and

unloading of construction

materials should not to cause

nuisance to the people by way

of noise, vibration and dust.

Avoid storage of construction

materials beside the road,

around water bodies,

residential or public sensitive

locations

No storage of construction

material in the sanctuary area.

Construction materials should

be stored in covered areas to

ensure protection from dust,

emissions and such materials

should be bundled in

environment friendly and

nuisance free manner.

Water and air

quality

National

Environment Act

Laws and

regulations of

respective LAs

National Emission

Standards and CEA

water quality

standards

CEB/LAs

Construction

period

There have been no complains related

to the public nuisance caused by noise,

vibration and dust due to transport

loading and unloading of construction

materials

The contractor has avoided storage of

construction materials beside the road,

around water bodies, residential or

public sensitive locations such as the

sanctuary area.

However, the contractor has failed to

cover construction material at the grid

substation site. Air borne dust emissions

were observed during the site visit.

Trimming/

cutting of trees

within RoW

Fire hazards

Loss of vegetation

and deforestation

Trees allowed growing up to a

height within the RoW by

maintaining adequate

clearance between the top of

Species-specific tree

retention as

approved by

statutory

Felling of trees

(Amendment Act.

No 01, of 2000 and

CEB, Contractor

through contract

provisions

Selective tree cutting and trimming was

adopted, however within vankalai no

trees were cut or trimmed other than the

tower location; further tower locations



Environmental

Impact


Implementation &

schedule


tree and the conductor as per

the regulations.

Trees that can survive pruning

to comply should be pruned

instead of cleared.

Felled trees and other cleared

or pruned vegetation to be

disposed of as authorized by

the statutory bodies. Forest

trees, if any, would be planted

on basis of 1:1 replacement.

Any trees that die within 5

years are to be replaced.

authorities (average

and maximum tree

height at maturity,

in meters)

Disposal of cleared

vegetation as

approved by the

statutory

authorities (area

cleared in m2)

act of felling of

trees control)

Presence of target

species in RoW

following

vegetation

clearance.

Construction

period

have been selected to minimize the tree

cutting.

Health and

safety

Injury and sickness

of workers and

members of the

public

Contract provisions specifying

minimum requirements for

construction day-time camps

including sanitation and

welfare facilities in accordance

with EHS Guidelines

Contractor to prepare and

implement a health and safety

plan in accordance with EHS

Guidelines.

Contractor to arrange for

health and safety awareness

programmes.

Contract clauses

(number of

incidents and total

lost-work days

caused by injuries

and sickness)

Health and safety

regulations and

IFC’s EHS guidelines 2007 (under

revision)

CEB (Contractor

through contract

provisions)

Construction

period

Health and safety procedures are well-

established. Health and Safety plans

have been prepared and implemented

by both the contractors: grid sub-station

and the transmission tower.

H&S officers have been mobilized by

both the contractors.

Nuisance to

nearby

properties

Losses to

neighboring land

uses/ values

Contract clauses specifying

careful construction practices

in accordance with EHS

Guidelines.

As much as possible existing

access ways will be used.

Contract clauses

Design basis and

layout

Reinstatement of

land status (area

affected, m2)

Implementation of

Tree/Crop

Public Nuisance

Ordinance No.: 15

of 1862. And IFC’s EHS guidelines 2007

(under revision).

Incorporating good

construction

management,

CEB (Contractor

through contract

provisions)

Construction

Period

Consultation with

affected parties

immediately after

Being complied



Environmental

Impact


Implementation &

schedule


Productive land will be

reinstated following

completion of construction

Compensation will be paid for

loss of production, if any.

compensation

(amount paid)

design engineering

practices

completion of

construction and

after the first

harvest

Avian Collision Possible collision of

migrant birds with

transmission line

Install Swan-Flight Divertor or

Aerial Marker Spheres at the

stated separations on the

length of the transmission line

that crosses through Vankalai

sanctuary and Mannar island.

Installations on

transmission lines

on Birdlife

International (2012)

and APLIC (2012)

guidance

CEB and EPC

Contractor

Construction

period

Construction work of the transmission

line is too early to consider the proposed

activities

Rail and road

infrastructure

Possible crossing of

ecological and

ornithologically

habitat

Ensure route avoids such

habitats outside the sanctuary

area

Route alignment to

minimize such

occurrence

IFC’s GN6 and incorporation of

good construction

management,

design engineering

practices

CEB and EPC

Contractor

Construction

period


Environmental Parameters and Periodicity for Environmental Monitoring Plan

Environmental

component

Project stage Parameters to

be monitored

Location Frequency Remarks/Comments

1. Air Quality Preconstruction

stage (The

project after

assigning to

contractor)

CO, Pb, PM10,

TSPM

Inside and

outside (0.5

km) of the

proposed

substation

A single time Complied

Construction

Stage

CO, Pb, PM10,

TSPM

Inside and

outside (0.5

km) of the

proposed

substation

1 time/ 3 months Samples for Air Quality Testing have been

collected on 18th & 19th Sep 2019 within the

Grid Sub Station

2. Water Quality Preconstruction

stage (The

project after

assigning to

contractor)

EC, TSS

(turbidity &

suspended

sediment), DO,

BOD, COD, pH,

Oil and grease,

Pb, E Coli (fecal

Coliforms), ,

hydrocarbon

One from

nearest well

and one from

surface water

source

around

substation


Construction

Stage

EC, TSS

(turbidity &

suspended

sediment), DO,

BOD, COD, pH,

Oil and grease,

Pb, E Coli (fecal

Coliforms), ,

hydrocarbon

One from

nearest well

and one from

surface water

source

around

substation

1 time/ 3 months Water Samples have been collected on 19 th Sep

2019 from within the Grid Sub Station

Water Samples have been collected within the

Proposed Tower Location


3. Noise/

Vibration

Preconstruction

stage (The

project after

assigning to

contractor)

Noise level (dB

level)

Inside and

outside (0.5

km) of the

proposed

substation


Construction

Stage

Noise level (dB

level)

Inside and

outside (0.5

km) of the

proposed

substation

1 time/ 3 months Noise levels have been measured on 19th Sep

2019 at all the 4 boundaries of the Grid Sub

Station

(Continuous time integrated noise level taken at

1 sec time intervals for 15 min every hour and

then averaged for 24hours)

Noise levels have been measured on 14th Jan

2019 at the Vankalai Area

(Continuous time integrated noise level was

taken at 15 sec time intervals for 15 min every

hour and then averaged for 24hours)

4. Soil Preconstruction

stage (The

project after

assigning to

contractor)

pH, Sulfate

(SO3),

Chloride, ORP,

Salinity,

Resistively,

Organic

Matter,

Moisture

Content155

Inside and

outside (just

close to the

proposed site,

2 locations) of

the proposed

substation

A single time The sample for Soil testing has been collected on

10thApril at Grid Sub Station site.

Construction

Stage

PH, Sulfate

(SO3),

Chloride, ORP,

Salinity,

Resistively,

Organic

Matter,

Moisture

Content

Inside and

outside (just

close to the

proposed site,

2 locations) of

the proposed

substation

1 time/ 3 months Complied


Note: Refer the Annex -II for the Vankalai Sanctuary design details.

Environmental Safeguard Measures

Project activity

Potential impact Mitigation measure Location Duration Institutional responsibility

Implementation schedule

Taken Action To Mitigate

Construction

Design of Tr Line

in Vankalai

Sanctuary

Impact to the

Environment

• Tower heights

increased to protect

the trees (CEB will

not cut any Trees in

Vankalai Sanctuary .

• Tower Location is

selected to avoid the

foundation in water

logged area.

• Any pile foundation

will not be

encountered.

Location

of Towers

in

Vankalai

Sanctuary

During the

Design &

construction

stage

CEB and

Contractor

Construction

period

Complied.



5.1 Water Quality at Mannar-Nadukuda TL – During construction stage

Water Samples were collected on 21th May 2018 by boring within the Proposed Tower Location

Parameter Method Unit Result Maximum Limit

pH at 26.1 ºC ASTM D 1293-

99 - 7.3 ≥ 4

Turbidity USEPA 180.1 NTU NT (8 Jackson Turbidity units as per

SLS (No value as per WHO)

Chloride (Cl) Content ASTM D 512-04 mg/L 3696 (1200 as per SLS (No value as per

WHO)

Sulphate (SO3) Content ASTM D 516-07 mg/L 510 2000 (400 as per SLS (No value as

per WHO)

Humic matter BS EN

1008:2002 -

Colour is

lighter

than

Yellowish

brown

Total Dissolved Solid

(TDS) APHA-2540-C mg/L NT

2000 (500 as per SLS, 1000 as per

WHO)

5.2 Air Quality at Mannar- Nadukuda TL – Pre construction stage

Samples for Air Quality Testing were collected over a period 14th & 15th Jan 2019 within the Proposed

Vankalai Area

Sr No Parameter Method

Recorded

Values

(μg/m3)

Permissible level (μg/m3)

(as per Min of

Environment, Govt of SL)

1 Particulate Matter (PM10) ASTM D 4096-82 82 100

(24 hr Average)

2 Particulate Matter (PM2.5) ASTM D 4096-82 43 50

(24 hr Average)

3 Carbon Monoxide (CO) ASTM D 3162-78 2679 30000

(1 hr Average)

5.3 Noise Level at Mannar-Nadukuda TL – Pre construction stage

Noise Samples were collected on 14th Jan 2019 At the Vankalai Area

Continuous time integrated noise level was taken at 15 sec time intervals for 15 min every hour and

then averaged for 24hours.


Sr No Parameter Method Corrected

Noise

Level dB

(A)

Permissible Noise Level dB (A) (As

per Central Environmental

Authority, SL)

1 Noise Level Sound level meter

(RION NL-52)

57 75 (during day time)

5.4 Test on Soil at Mannar-Nadukuda TL – Pre construction stage

Layer description Average

SPT

Shear strength

parameters

Ultimate bearing

capacity (kN/m2)

Elastic Modulus

E (kN/m2)

Medium dense sand 14 c' = 0 kPa, φ' = 30 250 1800

0 Very dense sand > 50 c' = 0 kPa, φ' = 43 2000 2500

0 Dense sand 30 c' = 0 kPa, φ' = 35 750 2200

0

Completely weathered

rock

> 50

c' = 10 kPa, φ' = 38

1500

2500

5.5 Water Quality at Nadukuda GSS – Pre-construction stage

Water sample was collected on 27th Dec 2019 and the results are awaited. The results of the earlier

Water Samples were collected on 19th Sep 2019 from within the Grid Sub Station and the results are

given below.

Parameter Method Unit Result Maximum Limit

pH at 26.1 ºC ASTM D 1293-99 - 7.0 ≥ 4

Turbidity USEPA 180.1 NTU 0.4 (8 Jackson Turbidity units as per

SLS

Chloride (Cl) Content ASTM D 512-04 mg/L 90.22 (1200 as per SLS

Sulphate (SO3) Content ASTM D 516-07 mg/L 92.4 (400 as per SLS

Humic matter BS EN 1008:2002 - Colour is

Clear


5.6 Air Quality at Nadukuda GSS – Construction stage

Samples for Air Quality Testing were collected on 27th & 28th Dec 2019 and the results are awaited.

Samples for Air Quality Testing collected earlier over a period 18th & 19th Sep 2019 within the Proposed

Grid Sub Station are as follows

Sr No Parameter Method

Recorded

Values

(μg/m3)

Permissible level (μg/m3)

(as per Min of

Environment , Govt of SL)

1 Particulate Matter (PM10) ASTM D 4096-82 13 100

(24 hr Average)

2 Particulate Matter (PM2.5) ASTM D 4096-82 21 50

(24 hr Average)

3 Carbon Monoxide (CO) ASTM D 3162-78 2900 10000

(8 hr Average)

5.7 Noise Level at Nadukuda GSS – Construction stage

Noise sample was collected on 27th Dec 2019 and the results are awaited. Noise Samples collected

earlier on 19th Sep 2019 at all the 4 boundaries of the Grid Sub Station

Continuous time integrated noise level were taken at 1 sec time intervals for 15 min every hour and

then averaged for 24hours.

Sr

No

Parameter Method Corrected

Noise Level

dB (A)

Permissible Noise Level

dB (A) (As per Central

Environmental

Authority, SL)

1 Noise Level – Boundary 1 Sound level meter (RION NL-52) 54 75 (during day time)




5.8 Test on Soil at Nadukuda GSS – Pre construction stage

Soil Samples were collected from Inside and outside the Substation area on 14th November 2019 and

the results are as follows


PARAMETERS

RESULTS

LOCATION 1

(INSIDE GSS)

LOCATION 2

(OUTSIDE GSS)

pH 6.9 6.8

Moisture Content 5.60% 5.80%

Sulphate Content (SO3) 2900 ppm 3000 ppm

Chloride Content (Cl) 125 ppm 142 ppm

Organic Matter 22% 24%


Stakeholders

No any Grievance Redress Mechanism have been implemented during the reporting period.

7.0 Conclusions and Recommendations.

The Green Power Development and Energy Efficiency Improvement Investment Programme

(Tranche 2) Package 2 which consists of two major projects components namely Lot B1

Construction of Mannar – Nadukuda 220kV Transmission Line and: Lot A Construction of

Nadukuda 220/33 kV Grid Substation & Augmentation at Mannar 220/33kV Grid Substation

are already commenced. It has been identified the project activities associated with the

environment during implementation phase as clearing of trees along the route alignment,

excavation for installation of towers, erection of towers, civil works related to transmission

line and line stringing, excavation for building and equipment foundations in substations, civil

works and erection of equipment especially in the Vankalai sanctuary.

The impacts on the environment from aforesaid activities of the project can be categorised

as follows:

• Impact on Physical Resources (Impact on Topography, Impact on Climate)

• Impact on Environmental Resources (Impact on Air Quality, Impact on Noise Levels,

Impact on Surface Water Quality, Impact on Ground Water Quality, Impact on Soils and

Geology)

• Impact on Ecological Resources (Terrestrial Ecology, Aquatic Ecology, Ornithology)

• Impact on Human Environment (Health and Safety, Agriculture, Socio-economics,

Resettlement and Rehabilitation Cultural sites, Traffic and Transport, Interference with

other utilises and traffic)

• Waste Disposal (Solid waste disposal, Liquid waste disposal)

Environmental Safeguard Measures are being adopted to mitigate the aforementioned

impacts during the construction period in compliance with the applicable acts and the

legislation to this Project.

Annex 5

ADB Loan 3483/3484 SRI: Green Power Development and Energy Efficiency Improvement Investment Programme (Tranche 2)

₋ Package 2: Lot B1 Construction of Mannar – Nadukuda 220kV Transmission

Line

₋ Package 2: Lot A Construction of Nadukuda 220/33 kV Grid Substation &

Augmentation at Mannar 220/33kV Grid Substation

Comments on Environmental Safeguard Monitoring Report

Reporting Period: Q3 of 2019 (From October 01, 2019, to December 31, 2019)

1. Section 1.2: The progress status of the project is given for October 2018 –December 2018. It is more appropriate to provide the progress at the end of theperiod that is reported in the Environmental Safeguard Monitoring Report, i.e.,end of Q4 of 2019.

2. Site Photos of Construction of Mannar – Nadukuda 220kV Transmission Line: Itis always good to provide a short description for each photograph (location, tower

number, what is the main feature that is intended to be highlighted, etc.), and thedate the photo was taken.

3. Indicate the number of days lost due to inclement weather, and the implication of

such incidents on the environment (e.g., flooding of the footings, trenches,

drainage problems, erosion of topsoil, etc.). Then describe what the contractshave done to mitigate such environmental incidents.

4. Page 6 (top): Progress status of the GS: the comment (#1) that has been givenabove for Section 1.2 applies here, too.

5. Site photos of the construction of the Nadukuda GS: comment #2 given aboveapplies here.

6. Table 2.0: Applicable Acts and Legislations to the Project:

₋ The Compliance Schedule to be corrected as the Compliance Status.

₋ It had been indicated that the Act/Rule/Notification has ‘being complied’ for all

the entries (other than for felling of trees). More explanation is required for each entry as to how each Regulation has being complied with.

7. Section 4.0: Compliance to Environmental Management Plan

Check whether all the Project Activities and Potential Impacts for both Pre-construction and Construction Periods match with the EMP given in the EIA Reportapproved by the ADB.

If they do not match, please add all other entries given in the EMP proposed in theEIA Report.

8. EMP and EMoP – Pre-construction

The following are missing (baseline monitoring reports):

• Water Quality

• Air Quality

• Noise and Vibration Levels

• Soil testing results

Include the following:

₋ The location where the samples were taken

₋ The third-party who collected, and who tested the samples

₋ Test Reports to be attached to the Report.

9. Explosions/Fire as included in the EMP

Check whether the following statement needs any updating:

‘Provision of firefighting equipment has been planned. This has to be verified priorto commissioning.’

10. Equipment layout and installation, Noise and vibrations included in the EMP

Check whether the following statement needs any updating:

‘Disturbances have been kept to a minimum. No significant noise and vibrationimpacts recorded and no complaints.’

11. Transportation and storage of materials: Nuisance to the general public asincluded in the EMP

It has been stated that:

“The contractor has failed to cover construction material at the grid substation site.Airborne dust emissions were observed during the site visit.”

It is advisable to provide proper guidance and directions for the contractor tomitigate this impact.

Subsequent monitoring is also needed.

12. Avian Collision as included in the EMP.

It has been stated that:

“Construction work of the transmission line is too early to consider the proposedactivities.”

It has to be noted that the stringing is now in progress. Therefore, bird collisionsmonitoring should be commenced without any further delay.

13. Check whether the Safeguard Monitoring is followed according to the EMoPproposed in the EIA Report. Check the locations, frequency, parameters, etc.

14. EMoP – Monitoring Reports for Nadukuda Grid Sub-station

(i) Air Quality monitoring report conducted by the NBRO

Update the report with the air quality testing results for samples collected in27.12.2019 and 28.12.2019.

(ii) Water Quality report not received

Update the report with the water quality testing results for samples collected in 27.12.2019.

(iii) Noise measurement report received

Noise report has been received. Noise measurement was taken on 27.12.2019 at four locations identified by the client.

Vibration levels have not been measured.

(iv) Soil report received.

Location 1: Inside GSS

Location 2: Outside GSS

The sample was collected on 14/11/2019.

15. EMoP – Monitoring Reports for Mannar - Nadukuda Transmission Line

(i) Water Quality monitoring: the results are for samples collected in 21.05.2019,which are not applicable for the quarter that is reported in this report.

(ii) Air quality monitoring: the results are for samples collected in 14 and 15.01.2019,which are not applicable for the quarter that is reported in this report.

(iii) Noise Level monitoring: the results are for samples collected in 14.01.2019,which are not applicable for the quarter that is reported in this report.

16. Add a short write-up on any deviations from the EMP, and the EMoP as suggested inthe EIA Report.

17. Add a section on Unanticipated Impacts

18. Add a section on any ‘Lessons Learnt.’

19. It is not clear how you have received any Environmental Reports from the Contractor.

It is suggested that the Contractors are advised to maintain environmental monitoringrecords to comply with the procedures using a standard template.

49345-002: Wind Power Generation Project

Documents

Transcript of 49345-002: Wind Power Generation Project