Annual Environmental and Social Compliance Audit Report Project No. 40517-013 Annual Report April 2015
2454-BAN: Public-Private Infrastructure
Development Facility
Prepared by Infrastructure Development Company Limited for the Asian Development Bank.
This environmental audit 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.
Loan No. 2454-BAN-OCR
Public-Private Infrastructure Development Facility
ANNUAL ENVIRONMENTAL AND SOCIAL COMPLIANCE AUDIT REPORT
108 MW Power Project at Kolagaon, Chittagong, Bangladesh
ECPV Chittagong Limited
April, 2015
Prepared by
INFRASTRUCTURE DEVELOPMENT COMPANY LIMITED
2
TABLE OF CONTENTS
Executive Summary…..………………………….…………………………………..……………..6
1. Introduction………..………….………………….……...………………………………………..8
1.1 Project proponent.…….…..……………….…….…….……………...………………………………8
1.2 Area and location of the project…………..…….…………………………………….………..…….8
1.3 Brief description of the project……………..…………….………………………….…….……..…10
1.4 Objectives of environmental and social compliance audit……..…….………….……………….11
1.5 Methodology ….………………………..……………………………………….………...………….11
1.6 Reporting period………………………..……………..………………………….…………………..12
1.7 Changes in project scope……………..……………………………………….………..…………..12
1.8 Environmental monitoring ……………..………………………………….…….…………………..12
2. Regulatory Requirements………………………………………………………….………….…………13
2.1 ECR, 1997 of Bangladesh Government………………………………………………………..… 13
2.3 SPS, 2009 of Asian Development Bank……………...……………….….……………….………13
2.4 ESSF of IDCOL………………………………………………………………….……………………13
3. Status of Project Implementation….....………………..…………...................................................14
3.1 Implementation of electro-mechanical and civil components….…….……….…………….……14
4. Implementation of Environmental Safeguards………………………….……………………………15
4.1 Compliance with ECR, 1997…………………………..…………..…………………….…….……15
4.2 Compliance with EMP……………………………………………………………………….……….15
4.3 Compliance with ADB requirement……………….…………………………………….………..…24
5. Implementation of Social Safeguards…………………………………………………..…………..…26
5.1 Impact on resettlement and livelihood ….…………………………………………………….……26
5.2 Institutional arrangement for social safeguards ………………………………………….……….26
5.2 Impact on indigenous people………………….. ………………………………………….……….27
5.3 Child labour…………………………………..………………………………...………….….………27
5.4 Public consultation and disclosure of information …………...……………...……………………28
6. Corrective Action Plan ………………...……….……………………...…….………………………….29
7. Conclusion…………………………………….…………………………………………………….…..…30
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Annexure
Annex-1: Environmental Clearance Certificate………...………………………….……..………………...31
Annex-2: Location of the project site……...……………………….…………….…….…….………………32
Annex-3: Project risk rating checklist of ESSF, IDCOL……….………….………….………………….…34
Annex-4: Arrangement of workers’ shed..…….………………….………….………….………………..…35
Annex-5: PPE arrangement and medical check up.…………….………….………….………………..…35
Annex-6: Dust management………….………………….………….………………………….….…………36
Annex-7: Construction of fuel storage tank…………….……………………………………..….…………37
Annex-8: Consultation with local community during construction phase.…….…………..….… ………38
Annex-9: List of some participants in consultation…….……………………………………..….…………39
Annex-10: Fuel treatment process………….…………….……………………………………..…..….……40
Annex-11: Stack….………..………………………………………………………………….…………….…40
Annex-12: Closed oil transportation process.……………………………………………………………….41
Annex-13: PPE arrangement….………………………………………………………………..……….……41
Annex-14: Fire fighting arrangement ….…………………………………………………………….………42
Annex-15: Application of signage….. ….………………………………………………………….…………42
Annex-16: Current status of project (external view)….……………………………………….……………43
Annex-17: Current status of project (internal view)….……………………………………….……….……44
Annex-18: Housekeeping …………………………………………………………………….………………45
Annex-19: List of male respondents during consultation in operation phase……… ……...……………46
Annex-20: Boundary wall……………………………………………………………….… …….……………47
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List of Abbreviations
ADB Asian Development Bank
CCC Chittagong City Corporation
DOE Department of Environment
ECR Environment Conservation Rules
ECPVCL Energypac-Confidence Power Venture Chittagong Limited
EHS Environmental and Health Safety
EMP Environmental Management Plan
ERP Emergency Response Plan
FGD Focus Group Discussion
IDCOL Infrastructure Development Company Limited
IEE Initial Environmental Examination
PPE Personal Protective Equipment
SPS Safeguards Policy Statement
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List of Tables
Table 1.1: Project related basic information…………...………….……………….….…..………………...8
Table 1.2: Geographic location of project site……………….…………..…….……..….….………………9
Table 1.3: Distance of project site from major infrastructures.………..…….……..…..….………………9
Table 1.4: List of major equipment……...……………………….…………….….……..….……….………10
Table 1.5: Engine specifications..…….………………….………….……………….….………………...…10
Table 1.6: Generator specifications.…………….………….………….……………….……………..…..…11
Table 3.1: Project progress………….………………….………….…………………….…….….…….……14
Table 4.1: Compliance with ECR, 1997.…….…………..….… ……………………….………………...…15
Table 4.2: Response of ECPVCL on major project activities (construction phase)….…..….……….…16
Table 4.3: Major environmental and social issues and implementation of corrective action plan….…18
Table 4.4: Monitoring parameters and frequency (trial run)…………………….………….….……….…18
Table 4.5: Ambient air quality ……………………………………………………..…….……………..….…19
Table 4.6: Response of ECPVCL on major project activities (operation phase)……..….………...……21
Table 4.7: Monitoring parameters and frequency (operation phase)……..….…………………………..23
Table 4.8: Compliance status on major E&S issues during construction and operation phases…..…24
Table 6.1: Gap between E&S compliance and corrective actions…………………….……………….…29
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EXECUTIVE SUMMARY
Background
Considering the importance of electricity, the Government of Bangladesh (GOB) has adopted a number of initiatives including implementation of power plant through independent power producer (IPP) modality by private sector. The 108 MW HFO based project of Energypac Confidence Power Venture Chittagong Limited (ECPVCL) is an example of this initiative of Government of Bangladesh.
Through a competitive bidding process Bangladesh Power Development Board (BPDB) has selected ECPVCL to establish and operate an HFO based power plant by using Julda or Shikalbaha sub-station, Chittagong under a 15-year Power Purchase Agreement (PPA). Accordingly ECPVCL has purchased required land at Kolagoan Union of Patiya Thana, Chittagong. The generated electricity will be sold to BPDB.
For financial assistance ECPVCL has approached Infrastructure Development Company
Limited (IDCOL), along with other lenders. Considering the importance of the Project to meet
the national power demand, IDCOL has provided a term loan facility of USD 30 million in
favour of the Project. IDCOL has sourced the required financing from the fund allocated as
ordinary capital resources (OCR) for large infrastructure projects under Public-Private
Infrastructure Development Facility (PPIDF) of Asian Development Bank (ADB).
The project has been classified as B under Safeguards Policy Statement, 2009 of Asian
Development Bank (ADB) in regard of environmental compliance. But in consideration of
Indigenous People (IP) and Involuntary Resettlement (IR) aspects the project has been
classified as C. According to the Environmental Conservation Rules (ECR), 1997 of the
Department of Environment (DOE), Bangladesh the project belongs to Red category. In
addition, the Environmental and Social Safeguards Framework (ESSF) of Infrastructure
Development Company Limited (IDCOL) has categorized the project as High Risk project.
So, a comprehensive Initial Environmental Examination (IEE) Report has been prepared for
the project by Bangladesh Centre of Advanced Studies (BCAS) as ‘Environmental
Consultant’ appointed by ECPVCL.
To assess the actual implementation of environmental management plan and social
safeguards, respective IDCOL official visited the project site during construction and
operation phases. According to the IEE, there is requirement of IDCOL to submit annual
Environmental and Social Compliance Audit Report of this project to ADB. Accordingly, this
audit report has been prepared by IDCOL.
Audit overview and findings
The respective IDCOL official has visited the project during the audit period (July 2014 to
April 2015). He has also reviewed the available relevant documents and clearances. In
addition, there was consultation with senior representatives of adjacent neighborhood. The
audit period encompasses two phases viz. construction (upto December 2014) and
operation (from January 2015). During construction phase, ECPVCL had been found to be
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satisfactorily responsive in regard of environmental and social safeguards. But during
operation phase they need to consider the following issues with due importance:
Monitoring of air, water and noise quality and adopt required mitigation measures
based on the monitoring data (if required);
Introduce comprehensive EHS guidelines, which will describe the detail procedure
about complying with Environmental Management Plan (EMP);
Develop a competent EHS team with required competence;
Arrange emergency response facility including training on fire-fighting, earthquake
hazard management;
Adopt well-structured Grievance Redress Mechanism.
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1.0 INTRODUCTION
1.1 PROJECT PROPONENT
Energypac is a reputed name in electro-mechanical sector in Bangladesh. Confidence
Group is a trusted name in cement and ready mixed concrete, lead-acid battery and
electro-mechanical products. The captioned project is a joint initiative of these two well
acknowledged entrepreneurs. As special purpose vehicle, the project proponent has been
jointly named as Energypac Confidence Power Venture Chittagong Limited (ECPV
Chittagong Limited). The project related major information are as follows:
Table 1.1: Project related basic information
Project Company ECPV Chittagong Limited
Date of Incorporation 21 August 2011
Registration Number C-94987/11
Registered Address 79 Shahid Tajuddin Ahmed Sharani, Tejgaon I/A, Dhaka
1208
Trade License Number & Issuer No: 0948634; Dhaka City Corporation
TIN Number 211-202-3847/C 20
Type of Business Power Generation
Project Location Kolagaon, Chittagong
Capacity 108 MW
Fuel Type HFO
GenSet Supplier Rolls-Royce
Off-taker BPDB
Project Tenure 15 Years from the COD
Project Type (Operational) HFO fired Power Plant to be developed on BOO basis
Project Type (Awarding) IPP1
1.2 AREA AND LOCATION OF THE PROJECT
It The project site is located at Kolagoan Union of Patiya Thana under the jurisdiction of
Chittagong City Corporation (CCC). The area of CCC is about 157 sq. kilometres. The land
having an area of about 6 acres has been purchased by ECPVCL. The site is about 9
kilometres away from Shah Amanat International Airport, Chittagong and about 5
kilometres away from the Chittagong Port. The site is about 270 kilometres away from the
capital Dhaka. The location of the project in respect of Chittagong city Corporation area
and adjacent area is presented in Annex-2.
1 IPP means Independent Power Producer
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A B
D C
Table 1.2: Geographic location of the project site with schematic lay out
Point Latitude Longitude
A 22o20.064/N 91 o 52.510/ E
B 22 o20.013/ N 91 o52.448/ E
C 22 o19.975/ N 91 o52.614/ E
D 22 o20.030/ N 91 o52.625/ E
Source: GPS survey by IDCOL
Along the BC, AB, DA and CD are access road& vacant land, neighborhood, vacant land &
Western Marine Shipyard, and Karnaphuly River respectively.
Table 1.3: Distance of project site from major infrastructures
Major Infrastructure Approx. areal Distance from site
(kilometer)
Julda 132VV Sub-Station 4
Shah Mirpur 132KV sub-Station 9.5
Bangladesh Navy Bases/Jetty 6.5
Chittagong Port 5.5
Shah Amanat Bridge on Karnaphuli River 1.5
Bangladesh Naval Academy 10
Eastern Refinery, & BPC Chittagong Oil Depots 8.5
KAFCO 10
Shah Amanat International Airport 9
Marine Academy 7.5
Shikolbaha 120MW Power Plant 4
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1.3 BRIEF DESCRIPTION OF THE PROJECT
The technology involves for power generation of ECPVCL108 MW power is mainly based
on reciprocating engines. The primary fuel is HFO. There are 16 (sixteen) reciprocating
engines of 7.2 MW each to be coupled with alternator to generate electricity. The following
Table 1.4 shows list of major equipment as have been used in this power plant.
Table 1.4: List of major equipment
The engine model B32:40V16A manufactured by Rolls-Royce for the 108 MW HFO based
power plant is 4-stroke, turbocharged, inter-cooled. The following Table 1.5 shows detail
technical specifications of the engines.
Table 1.5: Engine specifications
Equipment Unit Country of Origin
Rolls-Royce B32:40V16A 16 Norway
Generator (AvK make DIG 167/d8) 16 Germany
11/132 kV Step-Up Power Transformer 2 Bangladesh
11/ 0.415kV Distribution Transformer 2 Bangladesh
Indoor and outdoor switchgear 21 Bangladesh
Power Transformer Control Panel 2 Bangladesh
Current Transformer (132KV) 2 Bangladesh
Particular Specification
Model B32:40V16A
Number of cylinders 16
Engine speed (rpm) 750
Maximum Continuous Alternator Rating 6984 kW
Cylinder bore 320 mm
Piston stroke 400mm
Mean effective pressure (BMEP) Bar 24.9
Altitude above sea level (max) 100m
Turbocharger air suction temperature (max) +35oC (25oC)
Charge air cooling water inlet temp +42oC (25oC)
Relative humidity 70%@35oC
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The generators are synchronous, three-phase, brushless, salient pole and marine types. The
generators are designed to operate together with B32:40V16A engines. The following Table
1.6 shows technical specifications of the generators.
Table 1.6: Generator specifications
1.4 OBJECTIVES OF THE ENVIRONMENTAL AND SOCIAL COMPLIANCE AUDIT
The audit has been conducted with the aim to assess the project’s compliance with-
(i) Environment Conservation Rules (ECR)1997 of GOB;
(ii) Environmental and social safeguards according to the Environmental and Social
Safeguard Framework (ESSF) of IDCOL;
(iii) Environmental and social safeguards according the Safeguards Policy Statement
(SPS), 2009 and other relevant standards and guidelines of the ADB;
(iv) Proposed mitigation measures and monitoring procedures according to the
committed environmental management plan (EMP), resettlement action plan (RAP)
as are applicable.
1.5 METHODOLOGY
The audit includes the following steps:
(i) visits the project site and consult with stakeholders especially local people;
(ii) review the environmental and social safeguards documents including environmental impact assessment report, EMP and Resettlement Action Plan (as are relevant) ;
(iii) assess actual implementation of the guidelines/action plan of the safeguard related
documents.
Parameters Description
Make CGT ( AvK)
Type DIG
Construction IM 1101 (B20), Two bearings
Output 6984 kW(e) 8730 kVA
Power Factor 0.80
Voltage 11 kV
Frequency 50Hz
Generator speed 750 rpm
Insulation Class F
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1.6 REPORTING PERIOD
The reporting period of this Environmental and Social Compliance Audit Report is
July 2014 to April 2015. During this reporting period upto December 2014 was
Construction phase and from January 2015 has been considered as Operation
phase.
1.7 CHANGES IN PROJECT SCOPE
There is no change in the technology and operational process as have been declared
by the respective government and accepted by ECPVCL. So, it can be said that the
Environmental Management Plan of ADB approved Initial Environmental Examination
(IEE) is fully applicable during the reporting period as well.
1.8 ENVIRONMENTAL MONITORING
The parameter, frequency and methodology of environmental monitoring are in
accordance with EMP of ADB approved IEE, as has been detailed in chapter 4 of this
audit report.
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2.0 REGULATORY REQUIREMENTS
2.1 ENVIRONMENT CONSERVATION RULES, 1997 OF BANGLADESH
The project has to comply with the Environment Conservation Rules (ECR), 1997. According
to the categorization of ECR, 1997, the project has been categorised as Red2 meaning that
it has significant adverse environmental impacts, which are to be mitigated with proper
mitigation measures.
2.2 ENVIRONMENTAL AND SOCIAL COMPLIANCE RELATED STANDARDS AND
GUIDELINES OF ASIAN DEVELOPMENT BANK
The project has to be complied with Safeguards Policy Statement (SPS), 2009 of ADB in
regard of environmental and social (E&S) compliances. Considering the adversity of
environmental impacts, it has been categorized as B from environmental safeguard point of
view. Accordingly an IEE has been prepared, which is already approved by the ADB. As no
record of any indigenous habitat has been found in Kolagaon, the project has been
categorised as C in respect of Indigenous People (IP). In addition, as there was neither any
issue of involuntary resettlement (IR) nor adversely affecting any income generating activity,
the project has been categorised as C from IR perspective.
2.3 ENVIRONMENTAL AND SOCIAL SAFEGUARDS FRAMEWORK OF IDCOL
IDCOL has adopted an Environmental and Social Safeguards Framework (ESSF) in 2011,
which is to be complied with all infrastructure projects as are to be funded IDCOL. According
to the environmental categorization of ESSF, the project has been categorised as High
Risk3 project requiring significant compliance safeguards including comprehensive
environmental impact assessment and regular monitoring. In consideration of social
categorization, the project has been categorised as Low Risk project both for Indigenous
People (IP) and Involuntary Resettlement (IR) perspectives.
2 Schedule-1 of ECR (project no. 6 of Red category), 1997
3 The project risk screening checklist of ESSF, IDCOL is provided in Annex-3
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3.0 STATUS OF PROJECT IMPLEMENTATION
3.1 STATUS OF IMPLEMENTATION OF VARIOUS ELECTRO-MECHANICAL
COMPONENTS
The status of progress of implementation of major electro-mechanical and civil components upto 15 April 2015 are as follows:
Table 3.1: Progress of implementation of electro-mechanical and civil components
Type of
component
Component Percentage of
accomplishment
Ele
ctr
o-m
ec
ha
nic
al c
om
po
ne
nt
Generator 100
Exhaust gas system 100
Ventilation system 100
Intake air system 100
Lube oil system 100
Cooling water system 100
Electrical works 100
11KV/230 KV sub-station 100
11/0.4 KV auxiliary transformer 100
Gen-set control panel/MCC panel/VCB panel (switch gear) 100
Testing & Commissioning 100
230 KV HT cable terminations and Transmission Towers 100
TBS and RMS 100
Fire Fighting System4 95
Civ
il c
om
po
nen
t
Power house and warehouse 100
Internal and external drainage 100
Road surface 100
Administrative Building 100
Septic tank and soak pit 100
Water reservoir of fire hydrant 100
The photographs of current status of various project components are provided as Annex-15
and 16.
4 The firefighting system is already installed (Annex-14). It is now under the process of testing
15
4.0 IMPLEMENTATION OF ENVIRONMENTAL SAFEGUARDS
4.1 COMPLIANCE WITH ENVIRONMENT CONSERVATION RULES, 1997
ECPVCL has to comply with the requirement of ECR, 1997 of the DOE. In the following
Table 4.1, the compliance status of ECPVCL, in regard of major milestones of ECR, 1997 is
depicted.
Table 4.1: Compliance with the requirement of ECR, 1997
Basic Requirement Compliance Status
Approve IEE Fully complied
Approve EIA Fully complied
Award Site Clearance Certificate Fully complied
Award EIA approval Fully complied
Award Environmental Clearance Certificate Fully complied
4.2 COMPLIANCE WITH ENVIRONMENTAL MANAGEMENT PLAN
4.2.1 COMPLIANCE WITH EMP DURING CONSTRUCTION PHASE
a. Institutional arrangement
ECPVCL had formed an Environmental and Health Safety (EHS) Team comprising three full-
time personnel, to look after the environmental, social and occupational health safety
aspects. The EHS team is led by Mr. Khan Mohammad Mehbub Hossain. He is a graduate
Electrical Engineer having basic orientation on EHS aspect. He was assisted by two diploma
engineers. The overall EHS implementation at Project site was monitored by Mr. Md.
Ashekus Salam. He is a graduate Electrical Engineer having about 15 years’ experience in power sector. He was involved in a number of power projects including 100 MW power
project of Energypac at Gopalganj.
At the corporate level, the EHS aspect was monitored by Mr. Md. Mainuddin. He is an
experienced Mechanical Engineer. He has completed the Lead Auditor Course of ISO
14001:2005 (Environmental Management System).
b. Compliance status
In the IEE, a number of activities having potential adverse environment impacts and
occupational health safety aspects have been identified. In the following Table 4.2, suitable
mitigation measures to address these impacts according to the EMP and responses by
ECPVCL have been given.
Table 4.2: Response of ECPVCL on major activities and potential impacts (construction phase)
Project activity Potential Impacts Proposed mitigation measures as per EMP Actual Implementation Status of
compliance
Influx of workers
Generation of
sewage and solid
waste
Construction of sanitary latrines and septic tank system
Erecting “no litter” sign, provision of waste bins/cans, where appropriate
Proper disposal of solid waste
Sanitary latrines were provided
To ensure proper solid waste disposal, various types of waste bins were found to be practiced.
Fully complied
Possible spread of
disease from
workers
Clean bill of health a condition for employment
Regular medical monitoring of workers
There was a dedicated doctor to conduct weekly medical monitoring of workers (Annex-5)
Fully complied
Transportation of
equipment,
materials `and
personnel; storage
of materials
Deterioration of air
quality from
increased vehicular
movement, affecting
people in the
surrounding areas
Keeping vehicles under good condition, with regular
checking of vehicle condition to ensure compliance with
national standards and EHS guidelines (as applicable)
The available vehicles were found mostly of satisfactory condition, based on visual observation
Partially complied
Wind-blown dust
from material (e.g.
fine aggregate)
storage areas
Watering the access road
Sprinkling and covering stock piles
Covering top of trucks carrying materials to the site and
carrying construction debris away from the site
Access road was found to be watered
Stock piled had been found to be
covered (Annex-6)
Partially complied
HFO Oil storage
tank
Soil contamination Oil storage tank should be well protected against
leakage.
The construction of oil storage tank
has been found as satisfactory
(Annex-7)
Fully complied
Site clearance Topographic change
by cutting existing
trees, shrubs, herbs,
and filling land
Adopt such type design as is required minimum cutting
of trees, shrubs, herbs, and low-land filling
Use waste shrubs, herbs as organic fertilizers
Adopt required measures to prevent waste shrubs,
herbs as fuel to cook or for any localized burning
purpose.
Basic design of the project has been
found as land efficient i.e. ensuring
optimum use of land.
As the project site was a low lying
land having irregular terrain, there
was neither significant shrubs nor
trees.
Partially complied
17
Project activity Potential Impacts Proposed mitigation measures as per EMP Actual Implementation Status of
compliance
Noise from
construction
equipment
operations and
maintenance
Noise could exceed
the allowable limit
and result in hearing
loss
Use of noise suppressors and mufflers in heavy
equipment
Avoiding, as much as possible, construction equipment
producing excessive noise
Avoiding prolonged exposure to noise by workers
Creating a buffer zone by introducing green belt around
the Project site
Follow construction scheduling to avoid evening and
nighttime disruption
Workers were found to be equipped
with required PPE.
Most of the noise intensive work had
been reported to be accomplished
during day time
Partially complied
Dust during
construction and
exhaust gases from
construction
machinery and
vehicles (particulate
matter, NOx, SO2)
Increased SPM,
NOx, SOx levels at
construction sites,
and surrounding
areas
Avoiding equipment usage such as stone crushers at
site, which produces significant amount of particulate
matter
Immediate use of construction spoils as filling materials
Immediate disposal/sale of excavated materials
Continuous watering of bare areas
Ready-made stone chips were used
The evidence of using construction
spoils as filling materials was
observed
Watering was observed in bare areas
(Annex-6)
Partially complied
Fires, explosion and
other occupational
health safety related
issues
Risk of human
health and property
damage
Use of personal protective equipment during construction and maintenance.
Prepare and implement safety and emergency manual.
Regular inspection of lines for faults prone to accidents.
Provision of fire protection equipment.
Provision of Lightening arrestors
Fire extinguishers were found in the site.
Evidence of regular inspection of lines for faults prone to accidents, had been observed.
Partially complied
ECPVCL has been found responsive about satisfactory complying with EMP requirement.
While visit in July 2014, IDCOL had identified some areas requiring corrective actions.
ECPVCL’s response in regard of this proposed corrective actions are documented in Table 4.3.
Table 4.3: Major environmental and social issues and action plan
Issue Required corrective action Status of implementation
of corrective action
House keeping The standard of house-keeping at project site needs to be
improved to minimize the risk of accidents and associated
pollution.
Fully complied
Availability of
PPE
There is scope to increase the number and quality of PPE, in
respect of actual demand.
Fully complied
Documentation The induction training and other relevant issues need to be
more structured. In addition, social safeguards especially
grievances need to be properly documented and duly
resolved.
Partially complied
C. Environmental monitoring
I. Technical approach of environmental monitoring
According to the IEE, no environmental monitoring has been required in the EMP during
construction phase except during trial run. Because usually trial run phase is considered as
the final milestone of construction phase. According to the EMP, the monitoring requirement
during trail run is as follows (Table 4.4):
Table 4.4: Monitoring parameters and frequency of monitoring during trial run
Key parameters to be monitored: (1) Ambient Air Quality
location frequency parameter
At Project site, residential/institutional/commercial
areas within 500m outside from plant boundary
(4 locations)
Once during trial run SOx, NOx and CO
Key parameters to be monitored: (2) Noise
location frequency parameter
At four corners of Project boundary,
residential/institutional /commercial areas within 100m
and 300m outside from plant boundary
Hourly basis for 24
hours during trial run
Limits in dBA
19
Table 4.5: Ambient air quality at project site dated on 4 August 20125 (baseline condition)
Location PM2.5
(µg/m3)
PM10
(µg/m3)
SOx
(µg/m3)
NOx
(µg/m3)
CO
(ug/m3)
At project site from the
Karnaphuli River side
11 18.24 0.85 1.64 0
Standard of DOE 65 150 365 150 10
Figure 4.1: Ambient hourly noise of project site from Karnaphuli River side (4 August 2012)
II. Result of environmental monitoring
There was no air and noise quality monitoring during trial run.
III. Disclosure of environmental monitoring
As disclosure of environmental monitoring, ECPVCL is required to keep monitoring result available at
project site. But neither air nor noise quality was monitored during trial run, no result has been made
available for disclosure purpose.
IV. Monitoring adjustment measure
As there was no monitoring, the requirement of monitoring adjustment was not determined.
5 During IEE preparation phase, the ambient air and noise quality were assessed on 4 August 2012.
20
4.2.2 COMPLIANCE WITH EMP DURING OPERATION PHASE
a. Institutional arrangement
ECPVCL is in the process to form an Environmental and Health Safety (EHS) Team, which
would be headed by Mr. Mostafizur Rahman. Mr. Rahman is serving as Plant Manager. He
is a retired Marine Engineer having orientation on EHS aspect of power project. He is well
conversant with Integrated Management System (ISO 14001, OHSAS 18001, and ISO
9001). Before joining ECPVCL, he was involved with Orion Group for power projects. He is
expected to be assisted by a team of engineers. But the activities has been found as
informal as there is yet any comprehensive EHS implementation plan and systematic
practice of EHS implementation.
At the corporate level, the EHS aspect is expected to be monitored by Mr. Mainuddin. In the
earlier section, his qualification and competence in regard of environment and social (E&S)
safeguards has already been discussed. It is expected that like construction phase, he will
play the leading role in EHS implementation during operation phase as well.
b. Compliance status
In the IEE, a number of activities having potential adverse environment impacts and
occupational health safety aspects during operation phase have been identified. In the
following Table 4.6, suitable mitigation measures to address these impacts according to the
EMP and actual responses by ECPVCL has been given.
Table 4.6: Response of ECPVCL on project activities and mitigation measures during operation phase
Project Activity Potential Impacts Proposed mitigation measures in EMP Actual implementation Compliance
status
Transportation of
HFO oil to the plant
Possible spillage and leakage of oil
during storage
Oil should be stored through close piping system Oil has been found to be
stored through closed piping
system (Annex-12)
Fully complied
Emission from the power plant Using 27 meter tall stack
Installation of stack emission monitoring equipment for major pollutants
Planting of indigenous trees around the Project site
27 meter tall stacks have been installed
Partially complied
Generation of noise from
generators and associated sub-
stations , which could exceed 70
dB(A) at site boundary
Locate facility 70–100 m from nearest receptor;
Use walls, fencing, and/or greenbelt to provide partial noise barrier
Provision of silencers or generators an turbines (if need arises)
Use of ear-muffs and ear-plugs by plant personnel working in the generator and turbine facilities of the plant
The project is about 100 m away from nearest settlement.
Walls are being installed as noise barrier (Annex-20)
Ear plugs were being used as noise barrier.
Partially complied
SO2 generation from the engine,
which has adverse health impact
Use low sulfur (0.5 %) content fuel.
Distillate fuel oil to control SO2;
If the SO2 emission is more than standards, desulfurization measure is to be adopted
ECPVCL has installed fuel treatment plant. So, it can be said that the sulfur content in the fuel is within the limit of acceptable standard (Annex-10)
Fully complied
Suspended particulate matter
(SPM) and PM2.5, PM10 generation
from the engine, which can
adversely affect health
Use fabric bag filter to reduce particulate matter before discharging the emission.
Good combustion control, required stack height
should also be maintained properly
Fabric bag has been introduced.
Partially complied
22
Project Activity Potential Impacts Proposed mitigation measures in EMP Actual implementation Compliance
status
Power generation Electro-magnetic wave or electrical
interference, which may result in
occupational health risk.
All equipment should be grounded earthing with mesh system.
Power plant to sub-station should be connected by HT cable.
Power plant & substation site is away from the settlement.
No house is located in the immediate vicinity of the site.
Relevant equipment have been grounded.
Power plant to sub-station has been connected by HT cable.
Power plant & substation site are away from the settlement.
No house is located in the immediate vicinity of the site.
Fully complied
Heath safety during
operation
Risk of human health and property
damage
All necessary safety equipment should be ready at the plant.
Regular training on safety needs to provide.
PPE were found to be practiced.
Partially complied
Fires, explosion and
other accidents
Risk of human health and property
damage
Use of personal protective equipment during operation and maintenance.
Prepare and implement safety and emergency manual.
Regular inspection of lines for faults prone to accidents.
Provision of fire protection equipment.
Provision of Lightening arrestors
There are fire extinguishers
Automated firefighting system is in the final stage to install (Annex-14).
Partially complied
Domestic wastewater
and sewage
BOD, fecal coliform contamination
in groundwater and surface water
Need to provide septic tank with soak pit for
treatment of sewage.
Septic tank with soak pit for treatment of sewage.
Fully complied
Wastes oil from Plant
(scrap metal, waste,
lube oils, spill oil etc)
Potential soil and groundwater
contamination
Secure on-site storage, waste sell to the DOE authorized vendor for discharge in a safe place.
Used lube oil is being sold to DOE designated vendor.
Fully complied
c. Environmental monitoring
I. Technical approach of environmental monitoring
In the EMP of the IEE, environmental monitoring has been required during operation phase.
The air, water and noise quality monitoring schedule are depicted in Table 4.7.
Table 4.7: Monitoring parameters and frequency of monitoring during operation phase
Key parameters to be monitored: (1) Ambient Air Quality
location frequency parameter
At Project site, residential /institutional
/commercial areas within 500m outside from
plant boundary.
Quarterly (routine) analysis SPM, SOx, NOx
Key parameters to be monitored: (2a) Surface Water
location frequency parameter
Project site at Kolagaon Bi-annual basis in each year (pre-
monsoon and post-monsoon)
pH, Temperature, DO,
BOD, COD, TDS, Oil
and grease
Key parameters to be monitored: (2b) Ground Water
location frequency parameter
Project site at Kolagaon Bi-annual basis in every year (pre-
monsoon and post-monsoon)
pH, Temperature, DO,
BOD, COD, TDS, Oil
and grease
Key parameters to be monitored: (3) Noise
location frequency parameter
At four corners of Project boundary,
residential/institutional /commercial areas
within 100m and 300m outside from plant
Quarterly (routine) analysis (four
times in each year)
Limits in dBA
II. Result of environmental monitoring
ECPVCL is yet to conduct air, water and noise quality monitoring.
III. Disclosure of environmental monitoring
As disclosure of environmental monitoring, ECPVCL is required to keep monitoring result
available at project site. But as there is yet any monitoring result, no result has been made
available for disclosure purpose.
IV. Monitoring adjustment measure
Based on the monitoring result of the project during operation phase, it will be determined
whether there is necessity of any adjustment or mitigation measures.
24
4.3 COMPLIANCE WITH SAFEGUARDS POLICY STATEMENT, 2009 OF ADB
It is already said that the ECPVCL project has to comply with the requirement of SPS, 2009
of ADB. Accordingly, the compliance of this project in regard of major EHS related
requirement are mentioned in Table 4.8, where the gray colored portion represents the
construction phase and colorless portion represents the operation phase.
Table 4.8: Compliance with important EHS aspects during construction and operation phase
ADB
Requirements
Issue and Description of
Observation
Status of
compliance
Recommendation
Environment
Assessment
requirements for
various financing
modalities
The IEE of the project comprehensively
describes the potential environmental,
social and occupational impacts in
compliance with SPS 2009 of ADB, and
IFC EHS guidelines (General and
power plant).
To ensure the implementation of EMP
during construction phase (upto
December 2014) ECPVCL has been
found to adopt specific EHS
Implementation Guidelines, where
induction training and other relevant
issues need to be more structured.
Partially
complied
To revise the EHS
Implementation Guidelines with
focus on induction training and
other relevant issues need to be
more structured.
But during operation phase (from
January 2015), ECPVCL is yet to adopt
any comprehensive EHS
Implementation Guidelines, which
clearly specify the EHS Policy and
Procedure to address the ADB’s Environment Safeguard, EHS
guidelines of IFC (general and power
plant).
Late
complied
ECPVCL has to ensure the
availability of a comprehensive
EHS Implementation Guidelines
for operation phase.
Occupational and
Community
Health and safety
During construction phase the
Occupational and community health
safety measures have been found
satisfactory. Because there were
application of PPE and arrangement of
weekly doctor at plant level. Regular
consultation with community
representative had ensure the
community participation.
Fully
complied
No additional measures were
recommended.
During operation phase, ECPVCL has
to emphasize application of PPE. In
addition, they have to adopt required
mitigation measures to limit the higher
noise level issue.
Partially
complied
ECPVCL has already started to
increase the height of eastern
side boundary wall to serve as
noise barrier. Based on the
noise monitoring result, they
need to go for further
mechanical measures (if
required).
25
ADB
Requirements
Issue and Description of
Observation
Status of
compliance
Recommendation
No documented evidence of any fire or
emergency hazard drill have been
found during operation phase.
Late
complied
To arrange the fire and
associated emergency hazard
drill with proper documentation.
Biodiversity
conservation and
Sustainable
natural resource
Management
The scale and complexity of
construction activities were too limited
to adversely affect local biodiversity and
to appear as detrimental in respect
natural resource management.
Fully
complied
No action was required
The activities in relevant to operation
phase seems to be inadequate to
adversely affect the biodiversity and
natural resource
Fully
complied No action seems to be required
Pollution
prevention and
abatement
During construction phase, the pollution
prevention and abatement process has
been found as satisfactory.
Fully
complied No action was required
To assess the impact of the project to
the ambient air and water quality, there
is necessity to conduct air and water
quality monitoring during operation
phase.
Late
complied To monitor and water quality
During operation phase, the noise level
seems to be higher than the acceptable
limit. So, there is necessity of noise
monitoring to have the actual data and
respond accordingly.
Late
complied
To monitor the noise quality.
There is scope to improve the present
spillage management process.
Partially
complied
ECPVCL should be adequately
careful about satisfactory
spillage management.
Physical Cultural
resources
Kolagaon is a rural area having
dominating agricultural trend. In
addition, it is significantly deprived with
adequate educational and cultural
facility. So, there is no significant
physical cultural resources in close
proximity to this project. So, to affect
the physical cultural resources during
construction phase seemed to be
irrelevant.
Fully
complied
No action was required.
Due to the unavailability of physical
cultural resources within the range of
close distance, the issue of adversely
affecting the physical cultural property
seems not to be relevant with the
project.
Fully
complied
No action is required
26
5.0 IMPLEMENTATION OF SOCIAL SAFEGUARDS
5.1 IMPACT ON RESETTLEMENT OF THE PROJECT AFFECTED PEOPLE AND
LIVELIHOOD
As the project site is a purchased land of ECPVCL from private land-owners through willing
seller-willing buyer arrangement, there is no issue of resettlement. In addition, as the project
site was of a low lying land with dominating water logging trend, there was no significant
economic activity. So, the project is not associated with adversely affecting the livelihood of
any local household.
Photographs 5.1 and 5.2: View of a portion of project site
5.2 INSTITUTIONAL ARRANGEMENT ON SOCIAL SAFEGUARD
Institutional arrangement
During construction phase, although there was no dedicated structural arrangement to
comprehensively look after social safeguards issue, there were several comprehensive
consultations with local people and their views were given due attention. For example, there
were demand for drinking water and job opportunity for local people, which has been
successfully resolved by ECPVCL. In addition, due to initiative of ECPVCL, the local
infrastructures including road has been developed.
But as operation phase comprises a long term period, ECPVCL has to emphasize the social
safeguards issue with due priority and has to designate official with specific responsibility to
ensure social safeguards.
Grievance Redress Mechanism
Although there is no IP and IR issues associated with the project, the project involves
numerous stakeholders resulting the concern of potential grievances. So, there should be
well structured grievance redress mechanism. In this regard, ECPVCL has to make sure the
27
availability of Grievance Box and Grievance Log Book. So, that who does not prefer to put
his grievance in written in Grievance Log Book may prefer Grievance Box. In addition, there
should be a designated cell phone number and e-mail ID facility, where victim can raise his
grievance comprehensively and confidentially.
5.3 IMPACT ON INDIGENOUS PEOPLE
Based on the primary observation during site visit and secondary sources including
Chittagong City Corporation and Chittagong Development Authority, no habitat of any
indigenous community has been reported at Kolagaon. So, the project has been categorized
as C for Indigenous Peoples (IP) safeguards concluding that there is no issue about
adversely affecting IP neither in construction phase nor in operation phase.
ECPVCL has conveyed that they are gender and caste neutral. So, any qualified person
coming from the indigenous community will be equally treated during the recruitment
process, and will be given the same benefits as like as other personnel.
5.4 CHILD LABOUR
The Bangladesh Labour Act 2006 (Act XLII of 2006) also defines the “child” and the “adolescent” on the basis of age. As per section 2(8) of the Act, a person who has attained the age of 14 but below the age of 18 is considered to be an „adolescent‟ and as per section
2(63), a person not attaining the age of 14 is defined as a “child‟.
According to The National Child Labour Elimination Policy 2010, following rights are to be
complied with, in regard of addressing child labour Issue
Employing children according to the age determined by the Acts and not to employ children below 14 years as a regular employee;
Ensuring the children at domestic work not to perform any hazardous work and providing them with proper food and accommodation, education, recreation since they work full time; and
Refraining child workers from physical, mental, sexual persecution and abuse.
ECPVCL has been found to be careful about the child labour issue. So, neither in
construction phase nor in operation phase, no child has been found to be engaged in the
project activities.
28
5.5 PUBLIC CONSULTATION AND DISCLOSURE OF INFORMATION
i. Consultation
From the beginning of the construction phase, IDCOL officials have tried to ensure the
project as socially compliant. In this regard, there were a number of formal consultation
including consultation of 5 May 2014 are worth mentioning (Annex-8). However, four senior
persons were informally consulted on 19 April 2015 to share their views about the potential
environmental and social impacts of the project (Annex-19). They are-
Md. Foujul Haq, son of Md. Badrul Haq
Md. Osman Ali, son of Late. Yakub
Md. Ayub Ali, son of Late. Shamir Ali
Md. Abul Mia, son of Late. Sador Ali
ii. Major findings
They have said that the project is advantageous to them for many reason but also there are few issue to requiring due attention from ECPVCL.
The advantages of the project are:
The project has given them a social identity. Because initially Kolagaon was considered as a backward area struggling with basic infrastructures. But now Kolagaon is informally considered as industrial area.
The land price has increased
There is employment opportunity for the local people.
ECPVCL has provided drinking water facility through connection with its deep tubewell.
The quality of road has been improved.
ECPVCL has made financial contribution in social infrastructure like mosque.
The dis-advantages of the project are:
The noise level of the project has appeared as a concern, especially at night.
iii. Response from ECPVCL
In response, the ECPVCL official has ensured that they are considering the noise issue with
due importance and accordingly they are erecting brick wall on the eastern side of the plant
as is shown in Annex 20.
iv. Disclosure
ECPVCL has to adopt structured approach to disclose the grievance redress aspects,
results of environmental monitoring and any other issue (as seems relevant during operation
phase).
29
6.0 CORRECTIVE ACTION PLAN
6.1 CORRECTIVE ACTION PLAN IN REGARD OF ENVIRONMENTAL AND SOCIAL
SAFEGUARDS
Based on the discussion in earlier chapters, it assumes that the ECPVCL had been found to
be satisfactorily E&S compliant during construction phase. But they are required to focus on
some specific issue to make the project satisfactorily E&S compliant during operation phase
as well. In this regard, the specific E&S issues with potential corrective measures are
depicted in the following Table 6.1.
Table 6.1: Gap between E&S compliances and proposed corrective actions
Aspect Issues Reason of inadequacy Corrective measure Required committed time period
Environmental
EHS
guidelines
Without a documented EHS
guidelines, it seems to be
inconvenient to ensure proper
implementation of EMP.
Adopt an EHS guideline which clearly describes the process of EMP implementation during operation phase.
30 June, 2015
EHS training The officials and workers
have been found to require
comprehensive training on
disaster management
including fire and earth quake
hazard.
Arrangement of firefighting
and earthquake safety drill.
31 July, 2015
Emergency
Response Plan
There is yet any Emergency
Response Plan (ERP) is
required to ensure the proper
management of emergency
condition
Prepare an ERP by detailing out the all relevant hazards, risks and near misses and suitable way to address them.
31 July, 2015
Arrangement
of
Environmental
Monitoring
There is no environmental
monitoring (air, water and
noise) report based on the
current situation.
Conduct environmental
monitoring (air, water and
noise) according to the EMP
30 June, 2015
Noise
The local people raised the
issue of higher noise level
Erection of boundary wall and adopt required mechanical measures to limit noise level.
30 September,
20156
Social Institutional
arrangement
and Grievance
Redress
Mechanism
(GRM)
Due to the close proximity to neighborhood, the project requires structured institutional arrangement to look after social safeguards issues including GRM.
Develop a team to look after social safeguards and adopt GRM in a structured manner.
31 July, 2015
6 To address the noise issue, erection of boundary wall has already been started, which may require upto 30 September 2015.
But ECPVCL has instructed to EPC contractor to accomplish the erection work ever earlier, if possible.
30
7.0 CONCLUSION
Based on the findings of E&S compliance audit, it can be concluded that ECPVCL had been
found adequately responsive in regard of complying with environmental and social
safeguards during construction phase. It is expected that they will show similar type of
commitment during operation phase as well and will ensure the proper implementation of
corrective action plan (Table 6.1).
31
Annex 1: Environmental Clearance Certificate issued by the DOE
32
Annex 2: Location of the project site
Figure : Satellite image of ECPVCL Project site in respect of Chittagong City
Figure : Satellite image of ECPVCL Project site in respect of distant surrounding area
33
Figure : Satellite image of ECPVCL project site in respect of close surrounding area
Figure : Satellite image of a close view of ECPVCL Project site
34
Annex 3: Project risk screening checklist of ESSF, IDCOL
Sl.
no
Env. and scl. risks rating criteria Response Remarks
Yes No
01
For new projects, does the project have any pending compliance such as
Location and Environmental Clearance based on its category (Red,
Orange-A, Orange-B and Green), from the DOE?
02
Is the project located in the immediate vicinity (likely to adverse impact) of
environmentally critical areas (national wetlands, wildlife habitats, important
bird areas, and protected areas)
03 Does the project construction and/or operation lead to environmental
impacts that are diverse, irreversible and/or unprecedented in nature?
04 Does the project require involuntary resettlement that results in loss of land
or livelihoods or physically displaces more than 200 persons?
05
Is the project site on or in immediate vicinity of socially vulnerable or
Indigenous People IP) owned or occupied land and has the potential to
cause an adverse impact on their culture and identity?
06 Is the project vulnerable to climate change related impacts?
07 Does the Borrower have a documented Policy on E&S Performance?
08
Does the Borrower have dedicated human resources to address E&S
performance?
09
Has the Borrower established and implemented Environmental, Health &
Safety Management Systems and Social Accountability Systems for the
Project SPV or in the parent company?
35
Annex 4: Arrangement of workers’ shed and storage shed (construction phase)
Photograph: A view of an storage shed Photograph: A view of an workers’ shed
Annex 5: PPE arrangement and medical check-up (construction phase)
Photograph: Treatment provided by doctor Photograph: Workers with PPE
Photograph: Accident record arrangement
36
Annex 6: Dust management (construction phase)
Photograph: Watering in access road Photograph: Covering of stock piles
Photograph: Watering in bare areas
37
Annex 7: Construction of fuel storage tank (construction phase)
Photograph: Secondary layer of fuel storage tank Photograph: Base piling of fuel storage tank
38
Annex 8: Consultation with local community (construction phase)
Photograph: Representatives of ECPVCL, IDCOL and
Kolagaon Union Parishad at consultation
Photograph: A view of the participants at consultation
39
Annex 9: List of some participants in the consultations (construction phase)
40
Annex 10: Fuel treatment process (operation phase)
Photographs: Fuel Treatment Plant
Annex 11: Stack (operation phase)
Photograph: 27 m tall stack
41
Annex 12: Closed oil transportation process (operation phase)
Photographs: Closed oil transportation system
Annex 13: PPE arrangement (operation phase)
Photograph: Application of PPE
42
Annex 14: Fire-fighting arrangement (operation phase)
Photographs: Firefighting pumps and internal and external fire fighting arrangement
Annex 15: Application of signage
Photographs: Bengali and English signage at project
43
Annex 16: Current status of project (external view)
Photograph: External view of the Plant (partial)
Photograph: Riverside view of the plant
Photograph: Transformer
44
Annex 17: Current status of project (internal view)
Photograph: Internal view of the Plant (production record and gen sets)
45
Annex 18: Housekeeping
Photograph: Status of internal housekeeping
Photograph: Application of different types of dustbin
46
Annex 19: List of male respondents during consultation in operation phase
Photographs: Participants in the consultation process
47
Annex 20: Boundary wall
Photograph: Construction of boundary wall at eastern side
Photograph: Boundary wall at western (river) side
