While all Performance Standards are applicable to this investment, IFCs environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with the following Performance Standards. If IFCs investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

PS 1 – Assessment and Management of Environmental and Social Risks and Impacts
PS 2 - Labor and working conditions
PS 3 - Resource Efficiency and Pollution Prevention
PS 4 – Community Health, Safety and Security
PS 5 – Land Acquisition and Involuntary Resettlement
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards
While all Performance Standards (PSs) are applicable to this Project, IFC’s project due diligence did not identify issues related to PS 6 ‘Biodiversity Conservation and Sustainable Management of Living Natural Resources’, PS 7 ‘Indigenous Peoples’ or PS8 Cultural Heritage. PS 6: Biodiversity Conservation and Sustainable Management of Living Natural Resources is not applicable as the Project site primarily comprises agricultural land and is a modified habitat and further, no adverse impacts on biodiversity and natural resources are expected. PS7: Indigenous Peoples is not applicable as no tribal land is being acquired for the development of the Project and its associated facilities and no diversions, material degradation or adverse impact is expected on indigenous peoples and their land resources. PS8: Cultural Heritage is not applicable as the Project is not located in areas of known historical or cultural significance.

The Project has been categorized as A given that there are significant adverse environmental and social risks and impacts that are diverse and irreversible which are associated with various applicable Performance Standards. More specifically, these relate to; i) land acquisition (land acquisition means permanent acquisition) of approximately 72 acres and requisition (land requisition means temporary acquisition) of 29.7 acres with the resulting physical displacement of 15 households, partial acquisition of homestead land from 12 households and economic impact upon 361 households (including 53 share cropper households) as well as 138 agricultural laborers; (ii) potential impacts on ambient conditions (air, soil and water) and communities immediately neighboring the Project site due to an increase in traffic, influx of labor and emissions including noise during construction and operations; (iii) impacts from associated facilities (T-Line, switchyard, access road and gas supply line); and (iv) cumulative impacts from the proposed construction and operation of two more CCGT power plants adjoining the Project.

IFC's appraisal considered the environmental and social management planning process and documentation for the project and gaps, if any, between these and IFCs requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and (if applicable) in an agreed Environmental and Social Action Plan (ESAP). Through the implementation of these measures, the project is expected to be designed and operated in accordance with Performance Standards objectives.

Policy



Summit Group (the “Sponsor”) has a formal Environment, Health, Safety and Security (EHSS) Plan and Manual, which defines the scope for EHSS management during the construction and operation phases of the Project. Further, SBPCLII has an Environmental Policy and a Health & Safety Policy for the Project which defines the environment, health and safety objectives of the Company. The Company, however, does not have a social policy. The Company shall develop a social policy and ensure that all three, environment, health & safety, and social policies, are consistent with the principles of IFC Performance Standards. Further, the Company shall ensure that the policies are prominently displayed within the Project site and communicated to the staff. The EPC contractor has EHS management systems certified to ISO 14001 and OHSAS 18001 standards, has EHS policy and objectives, which are displayed at the site.



Identification of Risks and Impacts



The Company undertook an Initial Environmental Examination (IEE) for the Project in March- April 2011 to comply with the national requirements for such Projects, and to obtain from the regulators, a site clearance and terms of reference for an environmental and social impact assessment (ESIA). Prior to commencement of operations, the Company will obtain applicable clearances, permits, consents, authorization and all regulatory approvals under all the relevant legislation and will submit copies of the same to IFC as and when these are obtained. Further, the Company will comply with all applicable host country labor laws and demonstrate this compliance to IFC.



Further, the Company commissioned a third party to undertake an ESIA in accordance with national regulatory requirements and international good practice standards including IFC Performance Standards (PSs). Baseline surveys were carried out in 2008 and 2009 and subsequently during March and April 2011 as part of the IEE. Further, primary data for the ESIA were generated during the period from February to October 2011. While no fresh baseline data were collected for the current ESIA (2014), baseline data collected in the past have been validated through fresh sample surveys. Accordingly, validation surveys were undertaken in September 2013 to March 2014 with a view to update the findings of the baseline study carried out in 2011. The ESIA has been prepared on the basis of all survey data collected from 2011 - 2014.



The ESIA assesses the impact of flooding and climate change, based on the historical data of water level and meteorology on the Project. Quantitative impact assessments have been provided for air quality, noise, greenhouse gases in the ESIA report.



A large part of the Project site is situated at an elevation of 7.8 m above sea level. The elevation of the highest recorded flood is 10.15 m above sea level and, consequently, the Project site has been designed to be 11.2 m above sea level (i.e. 1 m above the highest recorded flood).
In order to raise Project site levels by 3.4 m, approximately 300,000 m3 of sand was excavated from six sites. The E&S impacts from sand mining have been covered in the ESIA. Land filling work was completed at the Project site in 2012. While raising the site is expected to mitigate any increase in flood levels, the Company will develop a climate change adaptation policy including monitoring, measurement and corrective actions for: (i) Flood mitigation (safe access /egress during flood events / use of evacuation shelters); (ii) Surface water quality monitoring to include ambient river temperature, where ambient water temperature is consistently (i.e. over 6 months) within 1.5°C of the temperature design limit of the SBPCL II power plant then adaptation measures should be actioned, including use of areas already allocated for potential adaptation plan; and (iii) Monitor the banks of the Kushiyara River and address any significant increased erosion of the banks adjacent to or opposite to the Project site by stabilization methods.

While Kushiyara river is host to 32 fish species, none of these are IUCN red list critically endangered, endangered or vulnerable species. The makeup water requirement to be abstracted from Kushiyara river is expected to be 0.124 m3/s (about 450 m3/hr). The velocity at the inlet point will be within the WBG EHS Guideline limit to prevent entrapment of fish. Further, to prevent impingement and entrainment of fish, barrier screens will be installed and the intake structure will be located towards the center of the river. The assessment indicates that material adverse impact on ecosystem services may not be expected. One fish sanctuary, one river dolphin habitat and one densely populated area were located close to three of the 9 sand mining sites approved for the Project. However, sand mining from these three sites was avoided in accordance with the regulatory requirements. Baer’s Pochard (Aythya baeri), an endangered (EN) species as per IUCN red list, is present in Hail Haor and Hakaluki Haor, which are located approximately 20 km south and 30 km east of the Project site respectively. Whilst there is a wider risk to this species from collisions with the transmission line, in light of the fact that the transmission line associated with the Project is 70 m, this risk on account of the Project is expected to be limited. The Company will as part of its monitoring program continue to monitor bird species within the project area of influence.



The Project site primarily comprises agricultural land and is a modified habitat. The following macro ecosystem types have been identified within the Project are: (i) cultivated land; (ii) roadside vegetation; (iii) exotic wood plantation; (iv) local species; (v) homestead vegetation; and (vi) wetland areas. The ESMMP includes measures for protection of terrestrial and aquatic habitat. Further the Company will conduct six monthly construction phase monitoring of terrestrial and aquatic or
ganisms of the area. The Project site does not have any statutory designations or ecological protection status. There are no areas declared as ecologically critical area within the Project area of influence. ESMMP requires that the greenbelt should be developed by using native species and invasive species are not present at site



Alternatives analysis covered fuel, combined or open cycle, the no-development option and sand mining locations. However, the alternative analysis did not include site selection and alignment of gas pipeline and access road as these were identified by BPDB and JGTDSL outside the scope of the ESIA. The ESIA report also provides an assessment of key cumulative impacts due to the proposed Bibiyana South and III power Projects to be built in the future and covers impacts on air quality, ambient noise levels and on Kushiyara river. While salient risks and impacts due to associated facilities like switchyard, T-Line and gas pipeline have been identified in the ESIA, there is limited assessment of these impacts in light of the fact that these facilities are being developed separately by state utilities.



In view of the fact that construction has commenced before finalization of the ESIA, the Company has commissioned a third party to undertake an environment, health, safety and social audit of the Project in October 2014. The Company has agreed a corrective action plan based on the audit findings to ensure that the Project is constructed and operated in accordance with the national requirements and the Performance Standards.



Management Programs



The ESIA includes an Environmental and Social Management and Monitoring Plan (ESMMP) for the Project, covering pre-construction, construction, operation and decommissioning phases of the Project. Mitigation and monitoring measures include those related to: emissions to air; ambient noise; water consumption and risk of contamination; wastewater treatment and disposal; thermal discharge into marine environment; land take; hazardous material and waste handling, storage and disposal; socio-economic impacts; avoidance and minimization of impacts on culturally significant features; construction workers; community health, safety and security; traffic and transport management; and decommissioning. The aforesaid identified mitigation and monitoring measures will be developed into full management plans that have been delineated in the ESIA as per the timeline proposed in the E&S Action Plan (ESAP) and will include: defined action items, responsibilities, monitoring indicators and review/ audit mechanisms and also additional management plans identified as part of the third party audit.



The Company has contractually required the Project’s engineering, procurement and construction (EPC) contractors to adhere to applicable social and environmental legal/ national requirements and fully implement environmental and occupational health and safety (“EHS”) measures defined in Project ESIA, th
e Project specific EHS Plan. The EPC Contractor has prepared an EHS management plan which broadly covers: EHS policy and objectives; Project specific information; roles and responsibilities; site EHS management; contractor site EHS activities; and Project EHS guidelines. The EPC contractor will develop and implement the plans that have been delineated in the ESIA and are relevant to construction stage of the Project.



The agencies responsible for the development of associated facilities are large utilities and government agencies like Bangladesh Power Development Board (construction lay down area and access road), Power Grid Company of Bangladesh (switchyard and T-line) and Jalalabad Gas Transmission and Distribution System Limited (gas pipeline). Accordingly, the Company will share IFC PSs and relevant EHS Guidelines with each of these agencies respectively and make efforts to encourage them to construct and operate these facilities in accordance with GIIP. However, the Company will implement livelihood restoration activities consistent with IFC Performance Standards for all households impacted by the associated facilities.



The Company will put in place within, 18 months from the disclosure of this ESRS, an Environment, Occupational Health and Safety (EHS) Management System (EHSMS) certified to ISO 14001 and OHSAS 18001 standards with IFC Performance Standards appropriately incorporated. The EHSMS will include: (a) an Environment, Occupational Health and Safety Policy aligned with the PSs; (b) procedures for screening, scoping, assessment and management of environment, health, safety and social risks and impacts; (c) stakeholder mapping and consultation process; (d) organization structure; (e) roles and responsibility allocation; (f) procedures for environment, occupational health and safety (EHS) training of employees and contract workers; (g) internal and external communication procedures; (h) procedures for recording, investigation, reporting and corrective action in relation to EHS incidents including those involving contractors’ workers; (i) emergency preparedness and response plan; (j) periodic monitoring of EHS performance; (k) periodic internal and external EHS audit process; and (l) procedure for management review of EHSMS effectiveness and implementation of measures for system upgrade.



Organizational Capacity and Competency



There is provision for Construction Management Team (CMT) in the Sponsor’s EHSS plan. The Company will put in place an appropriate EHS organization for both construction and operation phases, with clearly defined roles and responsibilities including a CMT. The Company’s EHS organization will be supported by EHS staff of the owner’s engineer as well. The Company has appointed a community development officer and is in the process of appointing an EHS Manager for the Project site. The EPC contractor has a detailed organizational structure with roles and responsibilities delineated including: site manager, c
onstruction manager, site HSE manager and 9 safety officers for different locations. While some level of health and safety training is being provided by the EPC contractor, the Company will develop and implement a comprehensive training program in line with the requirement outlined in the ESIA.



Emergency Preparedness and Response



The EPC contractor has prepared Emergency Preparation and Response measures and it covers emergencies such as fire, electrical shock, personal injury, food poisoning, large mechanical accident, drowning accident, radiation accident, and other environmental pollution accident. The Company will upgrade its emergency preparation and response to cover specific emergencies related to natural disaster such as earthquake, floods and heavy rain and heavy winds. The Company will require the EPC contractor to prepare and implement an updated Emergency Response Plan covering all emergencies, appoint a suitably qualified emergency coordinator, and undertake awareness training including drills for building awareness on emergency response. Further, prior to commencement of operation and as part of the OHSAS 18001 certification process, the Company will undertake HAZOP studies, risk assessments and draw upon risk assessments already completed as part of the ESIA to develop, communicate and implement preparedness and response plan both for onsite and offsite emergencies.



Monitoring and Review



The ESIA report provides an environmental and social monitoring plan for the Project during different phases of the Project with institution level roles and responsibilities and frequency of monitoring. At present, internal reporting of the EHS management is being done by the EPC contractor. The records are being maintained in the Chinese language. SBPCL II will set up a system of regular review of EHS performance of the EPC contractor and shall ensure that copies of all monitoring records are available in local language and English. All external reporting on EHS&S aspects will be undertaken by SBPCL II.



Going forward, the Company will put in place detailed procedures, including reporting requirements for the EPC contractor, site audits jointly with EPC contractor’s staff and periodic meetings with EPC contractor as also their subcontractors, to review and document EPC contractor compliance with national, ESIA requirements and EHSS audit recommendations. Further, the Company will put in place procedures to ensure that corrective actions based on the findings of the EHSS audit are implemented in a timely manner. In addition, Summit [has engaged] an owner’s engineer, whose EHS and social specialists will undertake monthly audits during the construction period, recommend corrective actions as required, and follow up on close out of the corrective actions. A detailed monitoring and review program for the operations phase will be developed as part of the ISO 14001 and OHSAS 18001 certified EHSMS.

Working Conditions and Management of Worker Relationship



There are currently 1650 staff and workers deployed at site, of which approximately 1300 are contract workers. However, it is expected that on an average 1200 workers will be employed during the 36 month construction period. There are 7 contractors presently hired by NEPC. The currently deployed workforce at site includes local workers as well as expatriate staff for specialized work from China. Upto 40 skilled and unskilled persons will be employed during the operation and maintenance (O&M) phase of the Project. Most of the employees will be deployed on the O&M service provider’s rolls.



Human Resources (HR) Policies and Procedures



While the Sponsor Company, Summit Industrial & Mercantile Corporation Limited (SIMCL), has HR policies and procedures in place. The Company shall put in place HR policies and procedures that meet national laws and PS2 provisions, before Commercial Operation Date (COD). In developing its HR Policies, the Company will draw upon the HR policies of SIMCL. In addition to SIMCL’s policies, to address PS2, SBPCL II will develop and implement additional policies and procedures including among others on equal opportunity and non-discrimination, employee and contract worker grievance redress, prevention of child labor and forced labor, prevention of sexual harassment. Further, as part of its HR Policies, the Company will require the EPC and O&M service provider to implement HR policies and procedures that address the national laws and IFC PS2.



Working Conditions and Terms of Employment



Working conditions and terms of employment for SBPCL II staff are laid out in their respective employment letters. NEPC staff are employed on terms as per NEPC’s HR policies. However, working conditions and terms of employment for other contract and subcontract workers shall be improved in line with national legal and PS2 the requirements particularly with respect to issuance of employment letters, payment of overtime wages, provision of weekly off and insurance. Further, the Company will undertake a labor audit covering its own staff, NEPC staff and contract workers engaged at the Project site to assess compliance with the national laws and IFC PS 2 requirements, and implement corrective actions based on findings of the audit.



Going forward and for the remaining construction period, the Company will require the EPC contractor to: identify all compliance requirements under the national labor and employment laws and PS2 covering its employees and sub contractors’ workers including on minimum age, non-discrimination and equal opportunity, freedom of association, worker accommodation and occupational health and safety; put in place a grievance mechanism for its employees and sub contractors’ workers; and implement procedures to demonstrate its and its sub contractors’ compliance with the national laws and its labor standards.



The subcontractors have arranged rented acc
ommodation for migrant workers (around 150 in number) in the nearby areas. Accommodation for the NEPC’s Chinese employees and workers is in a separate accommodation camp inside the Project boundary. The accommodation is in line with IFC’s requirements on Worker Accommodation. However, NEPC and their sub-contractors have set up labor accommodation for NEPC hired direct local workers. There are several gaps with respect to PS2 provisions including inadequate living space, poor drainage, no fire extinguisher, lack of storage space, no recreation facilities are available; etc. The Company shall ensure that the EPC contractor develops and implements construction labor camp guidelines in accordance with PS2 provisions on workers’ accommodation.



Workers’ Organizations



There is no collective bargaining agreement or any worker union at the site presently. However, the Company is committed to complying with national laws in relation to collective bargaining and formation of lawful workers unions.



Non-discrimination and Equal Opportunity



SBPCL II shall ensure that the principles of non-discrimination and equal opportunity are included in its HR Policy and that the EPC Contractor abides by the same while engaging local subcontractor or contract workers.



Grievance Mechanism



The Company shall develop, communicate and establish formal grievance mechanisms in line with PS2 provisions which will be accessible and a channel for management and workers to communicate and for the workers to place their concerns as well as suggestions. The grievance process will be made accessible for construction workforce (both Company and contract workers), enable workers to raise anonymous complaints and will have provisions for protection of confidentiality and non retribution. The Company will maintain grievance records and shall monitor redressal of grievances.



Protecting the Work Force



There are some procedures like checking of national ID card of all workers for verification of age to prevent child labor. However, the Company will, cover these aspects under the proposed labor audit and strengthen procedures based on the audit findings to protect the workforce.



Occupational Health and Safety



During the construction phase, occupational health and safety of staff and workers is coordinated by the EPC Contractor’s EHS Department. There are at present a total of 15 EHS personal available at site. The EPC Contractor is certified with GB/T 28001-2011 and OHSAS 18001 Occupational Health and Safety Management System from QAC. There is a First Aid Centre, an ambulance tie up with local hospital in Sylhet which is about 40 km from site. However, the Company shall engage a full time doctor and para medical staff at site to respond to emergencies. NEPC has procedures in place for safety induction trainings for contractor employees; Weekly site safety inspections, Monday tool box talks (TBT) and Fire drills. However, documentation and their implementation
leave room for significant improvement. The Company shall also ensure that procedures for reporting, recording, investigation, analysis of accidents and incidents, and follow up corrective action are put in place immediately.



The current OHS practices shall be strengthened through task specific hazard identification and safety analysis/ risk assessment, provision of appropriate engineering controls to physical hazards, and provision of mandatory and job specific PPEs at the site. The Company will require the EPC contractor to develop and implement an Occupational Health and Safety Management Plan (OHSMP) that is based on GIIP. The OHSMP will detail procedures for: hazard identification and risk assessment; provision of personal protective equipment and ensuring their use; training in the relevant hazards, safe working procedures and emergency response; provision of medical care, first aid, health monitoring, measures for prevention of disease spread; accident/ incident monitoring, investigation, reporting and corrective action; fire prevention and fighting system; and periodic joint audits and corrective action. Further, the Company will deploy site specific EHS staff for effective supervision of compliance with the contractual provisions relating to labor working conditions and occupational health and safety.



SBPCL II will in the O&M phase address occupational health and safety (OHS) under the OHSAS 18001 certified OHS management system it proposes to implement, which will also incorporate GIIP on occupational health and safety.



Workers Engaged by Third Parties



Presently, there are approximately 1300 contract workers engaged at the construction site through 7 contractors hired by NEPC. With respect to contractors’ management, the Company shall put in place a formal contractor management system to audit its contractors as well as those of the EPC contractor. The management system shall include: (i) compliance checklist against the applicable standards; (ii) criterion on contractor selection to minimize HSE or labor related risks and issues at the time of engagement; (iii) monitoring and audit procedures; and (v) further, the sub-contractor shall be made responsible for the insurance of the workers mobilized at the site.



The Company will ensure that the proposed labor audit covers among other aspects, the following: compliance of the EPC contractor and its subcontractors with applicable statutory requirements, PS2 and IFC’s labor and OHS standards; consistency of worker accommodation with IFC Guidance on Worker Accommodation; implementation of grievance mechanism; and migrant workers, if any, are engaged on substantially equivalent terms as non-migrant workers performing same work, all in accordance with PS 2 provisions.

The potential environmental aspects and impacts from construction activities for the Project and its associated facilities include: fugitive dust; noise; water consumption; hazardous materials and waste handling, storage and transport; sewage and domestic garbage treatment & disposal; surface runoff and sediment load management; and vehicle traffic. The EPC contractor and subcontractors are expected to control these to acceptable levels through application of standard construction environmental controls. The relevant recommendations and mitigation measures suggested in the ESMP and the EHSS compliance audit will be incorporated into the construction contract documents and the same will be revised, if necessary.



Resource Efficiency



The Project uses natural gas, a cleaner fuel and higher efficiency combined cycle technology. The electrical efficiency of CCGT is 50-62% at lower heating value (LHV) compared with 35-40% LHV for Open Cycle Gas Turbine (OCGT) power plants. The CO2 emissions are lower with CCGT (340-400 kg/MWh) compared with OCGT (480-575 kg/MWh). The project efficiency is expected to be about 55% and GhG emission is expected to be about 375 gCO2/kWh. Further, a cycle of concentration (COC) of 6 has been envisaged for cooling water, which will reduce the cooling tower make-up requirement.



Energy and Material Efficiency



The EPC contractor is ensuring use of efficient construction equipment and machines during the construction phase and meeting the emission standards applicable in Bangladesh. The records of energy efficiencies of construction equipment will be reviewed by the Company’s EHS Manager. During the O&M phase, the Company will set energy and material efficiency goals as part of its ISO 14001 certified management system.



Water



Baseline surface water quality monitoring results of Kushiyara River indicates that during the monsoon season Total Suspended Solids (TSS) and Turbidity of the river water increases significantly, relative to pre-monsoon concentrations. Further, ground water quality monitoring results indicate that arsenic is present in the ground water above the WHO and Bangaldesh national standards. Furthermore, the results indicate exceedance of phosphorous, iron in some samples and exceedence of oil and grease concentrations in the ground water compared to Bangladesh national standards. The Company will ensure that drinking water made available on project premises and in the workers accommodation meets Government of Bangladesh potable water standards or WHO Drinking Water norms.



The water consumption during the construction phase is expected to be about 80 m3/day, which is sourced from the Kushiyara River and from a deep tubewell at site. The EPC contractor maintains a log of water level of deep tubewell. The SBPCL II power plant will operate a closed-loop cooling water system; make-up water from the Kushiyara river is expected to be about 10,500 m3/day. This is approximately 0.058% of the mean
low flow during the dry season. The cumulative water requirement taking into account Bibiyana South and III has been assessed at about 31,500 m3/day, which is not expected to exceed 0.35% of the dry season mean river flow. The Company will implement a program to monitor water consumption, and identify and harness conservation and efficiency opportunities.



GHG Emissions



The Company will ensure that all air conditioning equipment and fire safety equipment comply with the Ozone Depleting Substances phase-out plan of Government of Bangladesh and Montreal Protocol. Total direct annual greenhouse gas emission (GhG) from the Project will be 1.012 million tCO2e.



Air Emissions and Ambient Air Quality



The Project is a gas based power project. Hence, oxides of nitrogen (NOx) are the key emission to air. Ambient air quality baseline data indicates that the baseline concentrations of NO2, SO2 and CO are all within the Bangladesh National Ambient Air Quality Standards. However, baseline concentrations of PM10, PM2.5 and SPM in the vicinity of the Project site exceed the national standards. Accordingly, the airshed while non-degraded for NOx and SO2 has been considered degraded for particulate matter. Dispersion modeling for PM, NOx and CO has been undertaken taking into account cumulative air quality impacts from two other gas based thermal power plants that are proposed to be built adjoining the Project. The current modeling indicates that the Project related and cumulative incremental ground level concentration of NOx, CO and PM will not be significant. The Project’s predicted contribution to incremental ground level concentration (GLC) of PM10 is negligibly small at 0.04 μg/m3. The maximum predicted incremental ground level concentrations of NOx and CO from the Project is 1.58 μg/m3 and 1.81 μg/m3, respectively. The modelling results further indicate that the cumulative incremental GLCs of PM, NOx and CO due to the three plants will be 0.08, 7.85 and 5.73 μg/m3 respectively. However, ambient NOx and CO levels will remain within national standards.



The Company is designing the Project to meet the WBG EHS Guideline NOx limits through use of dry low NOx combustors and is committed to meet the WBG EHS Guideline particulate matter emission limit for degraded airshed.



Further, to minimize impact on air quality during construction: equipment will be maintained in good condition; the number of trips of transport vehicles will be minimized; stockpile management undertaken to minimize fugitive dust; covered transport of earth or other friable/dust generating construction material will be undertaken; drop heights will be minimized in unloading friable construction material; wheel washing and other measures are proposed.



The air quality dispersion modelling study was performed considering main stack height as 50 m and stack diameter as 3.0 m, which has now been modified to 70 m and 7.0 m, respectively. It has further been noted that the ESIA repo
rt has considered exit velocity as 25 m/s as against the design exit velocity of 20 m/s.



In light of the increase in the stack height and diameter and reduction in the exit velocity of the flue gas, the Company will perform the air quality dispersion modelling study with updated stack characteristics.



Wastewater Treatment



Effluents from thermal power plants include thermal discharges, wastewater effluents, and sanitary wastewater. All the treated effluent water during operation will be collected at central monitoring basin (600 m3 capacity). About 120 m3/day of treated water will be utilized within the Project premise for green area, whereas remaining 1,395 m3/day of treated water will be discharged back to the Kushiyara River. The treated wastewater discharge from the plant will be at a temperature which is less than 3 degree C above the ambient temperature of the Kushiyara river (the receiving water body). The Company will also ensure that the residual chlorine in this water remains below 0.2 mg/l. The DM plant waste water shall be neutralized and mixed in the condenser cooling water for disposal. The neutralization sump/ tank will be provided with appropriate corrosion resistant lining. Compressor cleaning water will be generated periodically and will be tankered off to a hazardous waste treatment and disposal site. The Company will put in place a sewage treatment plant. Treated sewage will meet WBG guideline norms and may be used on premises. Boiler blow down will also be mixed with the condenser cooling water and disposed to the Kushiyara river. The storm water drainage system will comprise oil/ water interceptors and all drainage in the vicinity of designated hazardous materials storage areas will discharge to the effluent treatment system. Storm water/ surface runoff water, from areas not likely to be contaminated, will be collected through the gulleys and surface drains into underground drainage, including any rain water collected from building roofs that does not risk being contaminated. This underground drainage will be discharged into the Kushiyara river. Surface runoff from areas that have potential for contamination including from the area within the transformer secondary containment will be treated through an oil-water separator and discharged into the effluent discharge system. Wastewater during construction is primarily sanitary wastewater, which is being stored onsite and collected by a tanker vehicle for offsite treatment. The Company will ensure that the wastewater is being disposed of in line with WBG EHS guidelines. The Company will commence monitoring and implement measures to minimize dust emissions and noise from the batching plant, and treat wastewater in accordance with GIIP, prior to discharge.



Noise



Baseline noise levels during day at sensitive receptors is below the 55 dB(A) norm but night time baseline noise levels exceed the 45 dB(A) norm. However, noise modeling for the plant as designed predicts
that noise increment due to the Project at sensitive receptors will be below 3 dB(A). Further, cumulative noise impact modeling also indicates that the incremental noise levels due to the three plants together is predicted to be below 3dB(A) and is expected to meet the WBG EHS Guideline norms.



Solid Waste Management



For the construction phase, the EPC contractor has engaged a waste management Company approved by regulatory authorities for collection and disposal of kitchen and food wastes; hazardous wastes (including waste batteries. waste fluorescent lights, waste medicines, etc.); other wastes (including any waste tiles, waste ceramics. soils, washroom waste and any other wastes which is difficult to recycling). All the waste collected is being segregated prior to the collection by the waste management contractor. Other wastes generated during construction include: plastics, paper, food, packaging, office equipment, cables, scrap metal, paint cans, packaging, tin cans, glass, and small amounts of other substances.



Sanitary waste water is collected in septic tank and the waste management contractor periodically collects the sewage and disposes it off to the treatment facility located in Sylhet. The bio-medical waste is being collected and stored separately near site clinic and being disposed off by the approved waste management Company that has been engaged by the EPC contractor.



At the end of construction, a post-construction survey of the construction area will be conducted to confirm that all debris and wastes have been removed and appropriately disposed at the end of the construction phase. During operation phase, the nature of sanitary and biomedical waste generated will largely be similar to the waste generated in construction phase. The Company will develop a detailed Waste Management Plan prior to the start of operations for proper storage and disposal of all wastes generated during operations.



Hazardous Materials



Hazardous materials that are stored at site during construction include: gas cylinders, diesel, hydrochloric acid, sulfuric acid, caustic soda, sodium hypochlorite, solvents, lubricating oils, transformer oil and other chemicals. A steel fuel storage tank having a capacity of 1,000-liters has been built within the Project site for storing diesel to operate the temporary diesel generator which is required during the construction phase. Diesel spills were noticed in the storage shed. The Company will require the EPC contractor to improve hazardous materials storage, management at site especially containments to avoid any accidental spillages, documentation and record keeping of hazardous materials and wastes, which will be periodically reviewed by the Company’s EHS Manager.



The primary hazardous waste during operations include: the oil collected from oil water separators; sludge and residual solids from oil and grit separator tank; waste water treatment plant sludge; compressor cleaning waste; oil fil
ters; batteries; oil and grease contaminated maintenance waste; used oil/paint/chemical drums and carbuoys; oil contaminated water or spills from oil storage areas; used oil generated in maintenance; oily rags/oil contaminated scrap from maintenance activity; and transformer oil from oil water separator.



The ESMMP provides the mitigation and monitoring measures for waste management during the construction and operation phases of the Project and it has recommended that a comprehensive waste management plan be developed. The Company will store all waste duly segregated, in a designated area and as required with containment. The waste management entity will collect the waste periodically from the plant and dispose of it in line with the national laws and World Bank Group EHS guidelines. Some of the reusable waste/scrap may be sold/ handed over by the Company to scrap dealers. Further, the Company will implement procedures to assure itself that the hazardous waste treatment and disposal facilities remain compliant with the national laws and good international industry practices.

Community Health and Safety



While most construction activities will be within the Project site, a significant amount of work is envisaged in areas open to public particularly work on gas pipeline and transmission line. The gas pipeline is being constructed by JGTDSL. The impacts of gas pipeline construction are expected to be of temporary nature. The ESIA report confirms that most E&S impacts associated with gas pipeline construction and relevant mitigation measures have been identified in the gas pipeline. The T-line will be constructed by PGCB and associated impacts will be temporary and insignificant. Both PGCB and JGTDSL are large utilities and government agencies with which the Company will share IFC PSs and relevant EHS Guidelines with each of these agencies and encourage them to adopt those.



Due to the proximity of Kushiyara River, the bulk of the construction material, heavy machinery and equipment required for the Project will be transported via the waterways. An increase in road traffic is expected due to movement of labor and transportation of some construction material during construction phase. The ESIA recommends measures to minimize community health and safety risk due to movement of vehicles and traffic during construction and operation. The Company will prepare, as recommended in the ESIA, a detailed transport and traffic management plan including procedures to ensure that EPC contractors adopt good EHS practices for the remaining construction period including: training of equipment operators and drivers in safe driving techniques; implementation of a personnel and materials movement plan to ensure that vehicle movement during construction takes into account the daily life and traffic patterns; speed controls; alarms; posting traffic marshals at high risk locations; undertaking appropriate measures to reduce fugitive emissions from storage and transport of construction and waste material; periodically monitor noise levels in potentially affected communities/villages; and undertaking community awareness programs etc.



Community Exposure to Disease



While no significant influx of labor has occurred, the EPC contractor has adequate provisions within the site for wastewater, garbage collection and disposal in order to minimize the workers and community exposure to water-borne, water-based and vector-borne diseases. Health check-up of workers is conducted at the time of induction and further medical assistance is being provided by the on-site medical facility.



Emergency Preparedness and Response



The EPC contractor has prepared Emergency Preparation and Response measures and it covers emergencies such as fire, electrical shock, personal injury, food poising, large mechanical accident, drowning accident, radiation accident, other environmental pollution accident. The Company will require the EPC contractor to prepare and implement an updated Emergency Response Plan covering all emergencies, appoint a suitably qualified
emergency coordinator, and undertake awareness training including drills for building awareness on emergency response. Further, prior to commencement of operation and as part of the OHSAS 18001 certification process, the Company will undertake HAZOP studies, risk assessments and draw upon risk assessments already completed as part of the ESIA to develop, communicate with workers and surrounding community and implement preparedness and response plan both for onsite and offsite emergencies.



Security Personnel



Security services at the construction site are provided by two private security companies. The security staff is unarmed and community consultations did not indicate any issues regarding the existing security arrangements. The security arrangements for operation phase of the Project are currently not known. However, the Company will put in place procedures to review past records of private security personnel deployed and develop and implement procedures for ensuring that: security personnel have clear objectives and permissible actions laid out; security personnel are trained in avoidance of abusive conduct and handling various situations with clear procedures; security incidents are recorded, investigated and corrective action implemented; bona fide complaints against security personnel are investigated/disciplinary actions implemented; and there is a grievance mechanism for aggrieved members of the community or employees in the event of a violation of the code for security personnel.

Stakeholder mapping / analysis

The SIA report includes a preliminary mapping of stakeholders. The key stakeholders identified are the district government agencies, project affected people, utilities implementing the associated facilities and local community leaders & influential people. The company is in the process of preparing a detailed Stakeholder Engagement Plan (SEP) with stakeholder analysis, key concerns, expectations, impact and influence, and risk rating of various stakeholder groups. It will include details on engagement strategy, information disclosure, monitoring (including participatory monitoring where appropriate), stakeholder feedback mechanism, reporting, etc. and guidance on maintaining records of stakeholder consultations.

Stakeholder Engagement Plan

The company has proposed a draft SEP as part of its SIA and LRF but the same is being developed further to ensure ongoing community engagement during construction and operation phases of the Project. The detailed SEP, as described above, will include detailed stakeholder analysis, key concerns, expectations, impact and influence, and risk rating of various stakeholder groups.

Information Disclosure

During the course of consultations, information has been shared informally with key stakeholders on the Project and its impacts. Formally, the draft SIA report was disclosed in September 2013 in English and Bangla (local language) to obtain feedback/ information from all stakeholders including PAHs. Subsequently, in 2015, the company has locally disclosed the LRF, summary of the SIA & ESIA and the CDP at in local language and these have been widely disseminated to the PAHs. Further, as part of the SEP, the company shall develop a plan for ongoing and timely disclosure of information to the affected communities and key stakeholder groups.

Consultation

Stakeholder consultation covering a wide range of stakeholders including regulatory agencies, governance institutions, and PAHs (including women) was undertaken during the preparation of the ESIA and SIA & LRF between 2011-14. First public notice was served by the Government on March 10, 2008 to inform landowners and land users about the scope of proposed land acquisition for the main plant and access road. Second public notice was served specifying the average land value on July 6, 2008. Following this notice, the land owners conducted several meetings at the DC office with the Upazilla Chairman, local Chairman (the elected chairman of the Union Parishad- the local government administration), members of the Union Parishad, Thana Nirbahi Officer (the Government Officer responsible for overall administrative duties on the Upazilla level), District Land Acquisition Officer (LAO) and other Government officials. At these meetings, the land compensation was negotiated. Third notice to the land owners was served on January 18, 2009 stating the negotiated land price and providing necessary legal documents for land acquisition, including copies of the Gazette Notification and other Government notices.
For land acquisition and requisition for the gas pipeline, the first notice was served on January 5, 2010 followed by second notice on March 28 2011 providing necessary legal documents. For the switchyard, the first and second notices were served and land prices were negotiated between the government and the land owners.

Stakeholder consultations were undertaken throughout the ESIA process by the consultants. The consultants held a series of stakeholder engagement activities including household surveys, focus group discussions, large consultations / public meetings, and informal meetings with affected communities to inform them about the project and identify project impacts and community development needs. These consultations were conducted in the pre-project situation in 2008, during the ESIA in 2011 and after completion of the draft ESIA. A series of public discussion activities were undertaken by the ESIA consultant as part of designing the compensation package/ LRF. Altogether around 25 consultations were organized between 2008- 2013. These consultations were conducted in the local language in different villages. The consultant conducted some of these meetings in the presence of company representatives. Furthermore, after preparation of the draft ESIA and SIA a large consultation meeting was held by the ESIA consultant in September 2013 to disclose the draft ESIA, SIA and LRF report and to obtain feedback / information from all stakeholders including PAHs. In addition and subsequent to the local disclosure of social and environmental documents, the company has engaged, consulted with, and raised the awareness of the affected communities about the project’s impacts, mitigation measures and benefits. The company’s representatives continue to undertake additional consultations with the affected communities; document the consultation; and implement measures to address concerns and expectations expressed in the engagement process.

The consultations involved: providing information on and discussing the project and its E&S impacts such as noise, air pollution, water pollution, etc.; identifying any issues or concerns for action; managing community expectations; and informing the stakeholders of further stakeholder engagement in the context of project implementation. IFC''s Project team has reviewed documentation of the stakeholder engagement activities, records of village and stakeholder meetings, met with key stakeholders including a sample of the affected community and government authorities, and observed village meetings after the local disclosure of ESIA, SIA, LRF and CDP. In the various community consultations held during the course of EIA, SIA and post disclosure of E&S documents, the various stakeholders and communities have put forward their concerns and expectations including those related to a) employment and livelihood opportunities and training; b) support for community investments such as the provision of infrastructure such as sanitation and drainage facilities in the resettlement site, a high school in the village, and a village hospital; c) provision of electricity and cooking gas; d) impacts on river fish population from project related sand mining; and (e) environmental pollution. The company has implemented (and in some instances, is in the process of implementing) measures to address these community expectations, recognizing also the need to proactively manage some of the community expectations related to the number of available direct jobs and electricity provision. For more proactive engagement with the community, the company has appointed a Community Development Manager (CDM). The CDM is actively engaged in dissemination of information and providing detailed responses to community expectations including clarifying, where relevant, the regulatory constraints on it; for example related to running of a school and provision of electricity to the community.

External Communications and Grievance Mechanisms

The SIA includes a grievance mechanism which is being further strengthened by the company. The current grievance mechanism includes plant and corporate level grievance committees and a Joint Committee for Community Relations (JCCR) to receive and address grievances. The JCCR has been formed and recently the company strengthened it by ensuring representation of all affected communities including women and resettled households. The company is working on strengthening the JCCR further by more clearly defining its role, the process of member selection, tenure of members, frequency of meetings, etc. In addition, the upgraded grievance mechanism will include a detailed grievance receiving and handling process. In recent consultations, the company has started explaining the grievance mechanism to the affected communities. The company is also considering implementing a corporate social responsibility program / CDP for the community. Some of the activities that are proposed under the CDP include: i) construction a hospital building/ clinic in the local area; ii) setting up 5 tube wells in and around the project area; and iii) book donations to a local school and library.

Ongoing Reporting to Affected Communities

Ongoing consultation during the remaining construction and operation period will be carried out by the CDM. For ongoing information disclosure, the company will continue to share information through printed information brochures, press releases, fliers, etc. The SEP, under finalization, will include a stakeholder feedback mechanism to provide formal responses to community enquiries and concerns.

Mr. S. M. Noor Uddin
Chief Executive Officer
Summit Bibiyana II Power Company Limited
SUMMIT CENTRE
18 Karwan Bazar Commercial Area
Dhaka 1215
Bangladesh
Tel: +880-2-9130845 (8 lines)
Fax: +880-2-9130853-54

Approach to ICP and/or BCS

As described in the Stakeholder Engagement section above, the company has enhanced its engagement with the community. Furthermore, it has completed various stakeholder engagement activities as part of the SIA process and following the disclosure of E&S documents. The IFC has reviewed documentation of the stakeholder engagement activities; records of village and stakeholder meetings; met with key stakeholders including a sample of the affected community and government authorities; and observed a number of stakeholder meetings. The IFC has assessed overall project engagement activities in the context of the support they provided for the Informed Consultation and Participation (ICP) of the project-affected communities, leading to BCS for the project.

Based on the review of project documentation, assessment of the Informed Consultation and Participation (ICP) process, and observations of meetings organized by the company with affected communities, IFC has determined that Broad Community Support exists for the project. In general, the affected community views the project as a development opportunity for economic progress in the area. *ICP - Information Consultation and Participation **BCS - Broad Community Support

Bibiyana II(30542) Supervision Disclosure Snapshot – Version 3
Description	Anticipated Completion Date	Status	Comments	Completion Date
Upgrade the existing EHS Policy, EHS Management Procedures and EHSS Plan in accordance with the provisions of IFC PSs, the ESMMP and findings of EHSS Audit, and implement the EHS management procedures	31-Mar-2015	Completed	Completed	11/3/2014
Obtain an Environmental, Occupational Health and Safety (EHS) Management System (EHSMS) certified to ISO 14001 and OHSAS 18001 standards with IFC Performance Standards appropriately incorporated	31-Jan-2018	Completed	Completed	12/31/2017
Development and implementation of SBPL II Human Resource Policy, Environmental Policy, Social Responsibility Policy and Health & Safety Policy/ or statements	31-Mar-2015	Completed	Completed	11/3/2014
Formation of SBPCL II CMT and appointment of SBPCL II's EHS Manager, and CDO/ community liaison officer	15-Feb-2015	Completed	Completed	5/15/2015
Undertake labor audit covering own and subcontractor workers to assess compliance with the national laws and IFC PS2 requirements. This will cover review of all HR Policies and Practices. Complete implementation of mitigation measures based on labor audit findings including those relevant to EPC contractor's management of labor issues (May 30, 2015).	31-Mar-2015	Completed	Completed	5/15/2015
Develop, communicate and operationalize worker's grievance mechanism	31-Mar-2015	Completed	Completed	3/31/2015
Complete implementation of corrective actions based on First EHSS audit findings as per the audit action plan and submit an action taken report	31-Mar-2015	Completed	Completed	10/1/2015
O&M stage documentation for management of environment, health and safety performance appropriately incoprorating IFC Performance Standards and Good International Industry Practices	30-Nov-2015	Completed	Completed	11/30/2015
Duty of care procedures implemented in relation to hazardous waste treatment and disposal facility	28-Feb-2015	Completed	Completed	10/3/2015
The Company will as part of its monitoring program continue to monitor bird species within the project area of influence	31-Dec-2017	Completed	Completed	12/31/2017
Develop and implement livelihood restoration plan (LRP) based on the livelihood restoration framework	28-Feb-2015	Completed	Completed	6/30/2017
Develop and implement comprehensive stakeholder engagement plan and a detailed community grievance mechanism	15-Mar-2015	Completed	Completed	8/15/2015
Completion audit of the resettlement/ livelihood restoration activities demonstrating compliance with IFC PS5 or, if necessary, identifying remaining gaps and corresponding corrective actions	31-Dec-2016	Completed	Completed	3/31/2019