If IFC’s investment proceeds, IFC will periodically review the project’s ongoing compliance with the Performance Standards.

Policy:
The project sponsor is certified per ISO 9001:2015, ISO 14001:2015, ISO 17025:2005, ISO 9001:2015 standards. The Company has also identified E&S risks in its operations and has developed an Environmental and Social Management System (ESMS) and Environmental, Health and Safety policy that was institutionalized by APPC’s Chief Executive Officer (CEO). The policy contains a management statement that defines the environmental and social objectives and principles for achieving sound environmental and social performance, possesses an internal system with structured Social and Environment, Health and Safety (EHS) organization and responsibilities, an E&S policy, procedures, and supporting monitoring and reporting systems and training programs.

Identification of Risks and Impacts:

An Environmental and Social Impact Assessment (ESIA) for Mazar IPP was prepared by Green Tech Construction and Engineering Company following national standards and IFC guidelines. The ESIA was approved by NEPA in May 2018. The most significant environmental impact of the project during the operational phase is expected to be on the physical environment. An air quality model was set up to evaluate the project impacts on the air quality and this is discussed in the ESIA under air emissions and ambient air quality. The ESIA included baseline information which will be supplemented with monitoring measures (discussed further below).  At IFC’s request, supplemental air quality dispersion modelling was prepared by HBP. The ESIA also included an assessment of alternatives including alternatives to the project and alternative sites. The implementation of the ESIA and land acquisition for the transmission line is the responsibility of DABS. Nevertheless, as per the agreed the Environmental and Social Action Plan (ESAP), the Company will monitor the progress of the ESIA and land acquisition process for the identified associated facility by keeping close contact with DABS (ESAP #1).

Management Programs:

The ESIA provides a summary of an Environmental and Social Management System (ESMS) framework with programs and mitigation measures applicable to the construction and operation phases of the project.  To ensure compliance with Afghanistan legislation and IFC requirements the company shall require the EPC contractor to develop, implement and maintain a Construction Environmental and Social Management Plan (CESMP) and associated procedures as noted in ESAP item #2.  The CESMP will include a suite of mitigation plans: dust management plan; traffic and transportation  management plan; noise and vibration management plan; soil and waste management plan (for hazardous and non-hazardous waste); oil and chemical spill contingency management plan; emergency preparedness and  response plan for construction phase; community health management plan; workers’ accommodation management plan; local recruitment and procurement plan; influx management plan; cultural heritage chance find procedure; security plan for construction phase; environmental monitoring plan and contractor management plan.

As indicated in ESAP item #3 the O&M contractor will develop and implement an Operational Environmental and Social Management Plan (OESMP) consistent with the project updated ESIA, local regulation and IFC PS requirements. The OESMP shall include: Noise supplemental Management Plan; Waste Management Plan (Hazardous and non-Hazardous Waste); Emergency Preparedness and Response Plan (including Community Emergency Response Plan); Occupational Health and Safety Management Plan; Security Plan; Life and fire safety plan; Environmental monitoring plan for operational phase.

Organizational Capacity and Competency:

The project sponsor has a dedicated environmental, safety and social department to ensure the operations comply with local EHS requirements at a corporate level. The EHS management systems shall also be established at APPC as subsidiary company of The Ghazanfar Group. As per ESAP item #4, the sponsor shall establish an EHS&S Management Structure including an overall organizational chart detailing the Environmental, Social, Health and Safety teams, structure and relationship at the corporate and project site levels, including Contractors and sub-Contractors. Per ESAP item #4, the sponsor will designate the EHS manager responsible for preparing an EHS&S Manual incorporating all the relevant procedures and plans necessary for implementation of Environmental and Social Management Plan (ESMP) and EHS performance of the project, including activities undertaken by contractors and other third parties (supply vendors/service providers) as well as any on-site staff.  (The manual should include the plans and procedures of EPC and O&M contractors).

Emergency Preparedness and Response:

The project sponsor has a suite of emergency preparedness, response management and incident investigation procedures at a corporate level. As per ESAP items #2 and #3, the EPC Contractor and O&M Contractor shall develop Emergency Preparedness and Response Plans (including Community Emergency Response Plans) for the construction and operation periods that contains the following principles; identification of areas where accidents and emergency situations may occur; consideration of earthquake risks identification of communities and individuals that may be impacted; establishment of response procedures for fire and safety;  provision of equipment and resources; designation of responsibilities and communication with workers and the public.

Monitoring and Review:

As per ESAP item # 2 and #3 the project company will establish procedures to monitor the effectiveness of the mitigation measures in coordination with the EPC and O&M contractors. Monitoring will be done by EPC’s and APPC’s HSE Managers. APPC staff will request EHS monitoring data from those contractors and report to both external regulators as required and to the management team and lenders.

The project’s EHS performance will also be audited by an independent auditor that will review the effectiveness of the CESMP and OESMP as set out in ESAP item #5.

Working Conditions and Management of Worker Relationship:

During the project construction period, local workforce from the local region (primarily residents of Mazar-e-Sharif and nearby villages) shall be employed for the construction works. According to the ESIA study, at the peak of the construction phase, it is expected that the labor force will peak at about 180 workers, most of which will be in the employ of the EPC Contractor. APPC has committed to meeting with elders and stakeholders from the surrounding villages to identify eligible individuals from the immediately surrounding villages. The workforce requirement during full scale operations is anticipated to be approximately 45-50 people (excluding security) within the proposed facility. APPC recognizes the multi-faceted benefits of employing workers from surrounding villages in terms public acceptance, social inclusion and security.

The sponsor and its subsidiaries do not employ child or forced labor, and they comply with local labor laws related to protection of the workforce.

Human Resources Policies and Procedures:

The majority of workers during construction will be employed or contracted by the EPC Contractor. During operations most, workers will be employed by the GroupO&M Contractor.

Ghazanfar Group has a Human Resources (HR) Manual in place which will be adopted for use by APPC and applied to APPC staff. As described in ESAP item #6, APPC will develop project specific HR policy covering non-discrimination, equal employment opportunity, employee grievance mechanism, respectful treatment, performance appraisals, workers’ organization, OHS (Occupational Health and Safety), and training and development for its staff. APPC shall also the adopt Ghazanfar Group HR manual and update it to reflect the following: a) project specific terms and conditions of employment, working hours and rest time, weekly rest, minimum wages, termination of contract, decertification, social dialogue, and mechanism for resolution of collective and individual labor disputes; b) make employment contracts consistent with the local Labor Laws and IFC PS2 requirements; and d) reflect HR requirements applicability and binding on the contractors and third-party service providers. Last, APPC will require its contractors to put in place equivalent policies and procedures.

Worker Grievance Mechanism:

A worker grievance mechanism is included in the ESIA study and also a part of Ghazanfar Group’s Human Resource Manual. According to the ESIA, the EPC and O&M Contractors will be responsible for generating and instituting employee grievance redress mechanisms (GRM) for their employees and subcontractors. These GRMs will be explicitly outlined in their individual HR Policies that will be prior-approved by the APPC.

The functional procedures of the employee GRM will be posted on-site in the local languages and disseminated verbally at health and safety tailboard meetings on an ongoing basis throughout the project. APPC will periodically monitor the effectiveness of the Contractor GRM through interviews with employees and third parties. The EPC and O&M contractors will share a copy of the updated GRM and implement a grievance management system to enable their workers to raise reasonable workplace concerns.  The GMs shall provide a prompt, understandable and transparent process that provides timely feedback to those concerned, without any retribution.

Occupational Health and Safety (OHS):

According to information in the ESIA, the EPC and O&M contractors will develop site specific Health & Safety Plans (H&SP) for the construction phase and for the operation phase to ensure that all applicable health and safety legislation and IFC requirements set out in PS2 and relevant sub-sections of the World Bank Group General EHS Guidelines are met during the construction and operation phases of the project. These plans will be submitted to the APPC for approval prior to initiation of work. As per ESAP item #8, APPC will include monthly Health and Safety Implementation Status Report provision in its EPC & O&M contracts.

Workers Accommodation:

Workers will be housed in nearby towns and cities – there will be no on-site workers accommodations. Mazar-e Sharif which has a population of approximate 500,000 is about 12 km to the east and Balkh, with about 80,000 people, is a similar distance to the north. It can be expected that the relatively small number of expat workers and nationals from outside the region can be can be easily housed in the region.  During construction transfer of workers to and from the construction site shall be managed by the EPC Contractor.

Contractor Safety and Workers Engaged by Third Parties:

As outlined in ESAP item #6, APPC will i) develop and include EHS and labor provisions and compliance conditions in its EPC and O&M contracts which will provide contractors and third party service providers (including security agencies) with clear guidelines on labor performance; ii) develop and implement Contractor Management Plan to monitor and enforce contractors’, sub-contractors’ and service providers (including private security agencies) to compliance with APPC policy and procedures; iii) ensure children under the age of 18 are not employed in hazardous work by EPC and O&M Contractor;

As outlined in ESAP items #7 and #8,the EPC Contractor and O&M Contractor to develop an overarching Occupational Health and Safety (OHS) Management Plans  and also ensure workers are provided with personal protective equipment (PPE), and procedures are developed to ensure their use, in adherence to ensure that all applicable to applicable health and safety legislation and relevant sections of IFC PS2 are met both during the construction and operation phase. The EPC and O&M contractors will ensure workers are provided with personal protective equipment (PPE), and procedures are developed to ensure their use. They also will be properly trained in the relevant hazards, safety procedures, emergency procedure and response arrangements. Safety rules and guidelines will be established and regularly communicated to employees through internal circulars and training programs. All new employees will receive a basic safety and security presentation and regular training will be conducted for first aid and CPR (cardiopulmonary resuscitation), firefighting, and emergency response. EPC shall conduct regular safety inspections and track all incidents and loss time injuries during the construction phase.

Resource Efficiency:

The project will use 6 x Wartsila model 18V32 spark ignited, gas-fired reciprocating engines operating in simple cycle mode.  The technology and design of the plant were selected due to the need to provide a high partial load efficiency for fast and frequent startup and shutdown to rapidly adjust to small changes in the local market demand as needed for the region’s relatively small electrical grid. The multi-unit configuration allows for a part-load profile that enables the plant’s entire output range to be optimized. For any given total plant load, as many individuals generating sets as required are operated at their optimal efficiency. The power plant will have an overall efficiency rating of 45.3% “gross” on Lower Heating Value basis.

Another resource that the project is aiming at efficiently managing is water. The project has been designed with a “dry”, closed loop cooling system. While the dry cooling system results is a small reduction in overall plant efficiency, it also greatly reduces consumption of water compared to cooling towers and other “wet” cooling systems. Efficient use of water is especially important for this project as it in a water scarce area.

Greenhouse Gases:

During operations the primary source of greenhouse gas (GHG) emissions will be the exhaust gases from combustion of natural gas. The emissions of CO2 per unit of power generated will be approximately 446 g/kWh gross. This emission rate is comparable to typical GHG emissions for a gas-fired reciprocating engine power plant and much lower than the typical GHG emission rate of power plants fired by coal or oil.

At the planned 80% plant utilization per year, the estimated GHG from the facilities will be approximately 182600 tCO2/year. The project will not purchase energy from the grid.

As per ESAP item # 9, APPC will track and report GHG emissions on an annual basis. APPC will also develop as part of the ESAP item # 9: (i) a fugitive gas management plan following industry best practice to adequately manage and minimize any potential release of methane to the atmosphere; and (ii) a SF6 management plan, to manage and minimize the use and leaks of this greenhouse gas that has a significantly higher global warming potential than CO2.

Air Emissions and Ambient Air Quality:

During construction there will be emissions of dust and particulate matter from movement of vehicles, exposed soils, handling of friable material, and construction activities such as cutting and grinding which will be managed as part of the ESMPs defined under ESAP #2.

During operations there will be emissions of combustion gases from the 6 reciprocating engines as well as from a small black-start diesel generator set. The black-start engine will only run a small number of hours per year and therefore is not considered to be a significant emission source.

The emission of concern from the main engines is oxides of nitrogen (NOx) The NOx stack emission guarantee for the engines is 185 mg/Nm3 which is below IFC’s guideline value of 200 mg/Nm3 for natural-gas fueled, spark-ignition reciprocating engines. As per IFC’s guidelines stack emissions will be monitored using a continuous or indicative method and be tested annually.

The six individual stacks have been clustered into one stack bundle to improve plume dispersion compared to non-clustered stacks. The stack height used for modelling was 30 m and the model assumed that this height met Good Engineering Practice for stack heights. However, specific calculations were not available to confirm GEP is met.

Air dispersion modelling was completed for a conceptual design as part of the ESIA. Supplementary modelling was competed by HBP based on the project specific design.  The modelling was completed using the United States Environmental Protection Agency AERMOD modelling system to predict the effects of project emissions on ground level concentrations (GLCs) of nitrogen dioxide (NO2).

The modelling indicates that the contribution of the project to the annual average concentration of NO2 is less than 2 µg/m3. This meets IFC’s guideline that the project not contribute more than 10 µg/m3, which is 25% of the applicable reference value of 40 µg/m3.

South of the site the elevation rises, and there is a range of generally, east-west running hills and mountains. In this area the modelling predicts that GLCs of NO2 from the power plant will have greatest effect. The maximum predicted 1hr average concentration of NO2 is predicted to be 130 µg/m3 which is greater than 25% of the applicable reference values. The modelling report indicates that the area most impacted is relatively small and not populated. The frequency of occurrence was not calculated. Elsewhere, including the broad plain surrounding the site where settlements are located, the contribution of the power plant to 1hr NO2 GLCs will be lower than 25% of the applicable reference values.

No background NO2 levels are available to determine if the additive effect of background levels plus contribution from the plant will be lower that the applicable reference values. However, HBP did complete model runs including emission parameters from the nearby Jade Glass plant. The modelling used estimated emissions factors for the glass plant. The results indicate that the emissions from the glass plant may exceed guideline values. However, the effect does not appear to be additive as the maximum ground level concentrations are the same when modelling the glass plant alone and the glass plant plus the project.

As per ESAP Item #10, APPC will commission further analyses and modelling to confirm the stack height meets good engineering practice, determine the frequency that the 25% threshold value is exceeded, assess the benefits of taller stacks, and as well as assess potential cumulative effects of future expansion of the power plant, and will develop an air quality monitoring program.

Noise:

The ESIA included an assessment of potential impacts due to construction and operational noise. A key consideration for assessment of noise impacts is the location of the power plant. The ESIA indicates that the closest residences are located more than 1 km away towards the west and north. In the case of the northward residences there is an existing fertilizer plant located between the power plant site and the residences. There are no close by residences to the south or east.

With respect to construction phase noise impacts, the ESIA indicated that the most significant noise emissions would occur during activities involving operation of heavy equipment such as clearing, earthworks, trucking, installation of foundations, and so on. With respect to clearing and earthworks, The Lenders Technical Advisory report indicates that the site is clear of obstacles and relatively flat and therefore clearing and earthmoving will be minor. The ESIA concluded that given the separation distance between the site and residences, existing noise from the fertilizer plant, and application of a mitigation measure limiting noisy activities to daytime hours, that impacts at the nearest residences would be minor. As described in the ESAP item #11, going forward, the sponsor will require the EPC contractor to develop and implement a construction phase noise management plan which incorporates monitoring, a public complaints procedure, and direct noise mitigation such as noise barriers.

For operations the ESIA identified and assessed as the main source of noise the exhaust stacks but did not consider other significant sources of noise including the cooling radiators, the charge-air intakes, and the power house. In order to fully assess the potential for noise impacts APCC will complete a detailed noise assessment as set out in ESAP Action Item #11.

Water Consumption:

During construction modest volumes of water will be needed for mixing concrete, pressure testing vessels and pipes, applying to loose-surfaced roads as a dust suppressant, and other low-volume uses. Possible sources of water during construction include local surface water for non-potable water and municipal water utility for potable water.

The Water Balance provided by the EPC Contractor indicates that during operation the facilities will require an average flow of .87 m3/hr or 7,621 m3/yr. This relatively low rate of water use, comparable to the continuous flow from two kitchen faucets, is made possible by use of a dry, closed-loop cooling system. The ESIA indicates that a water supply line will be constructed to deliver water from the local municipal water supply system. A water supply contract will be entered into with the water supply utility. No additional measures to are considered necessary to mitigate water use.

Liquid Effluents:

The Water Balance provided by the EPC Contractor indicates that all process water, water potential contaminated with oils and sediments, and sanitary wastes water will be treated prior to release to the environment. All internal service and floor drains, and any stormwater potentially contaminated by oils and greases, will be passed through an oil - water lamelar type separator that will be able to reduce the oil content of the water down to 8 ppm, which meets IFC’s guidelines for direct discharge to surface waters. The treated drains water will flow to a waste water collection pit.

Wastewater from toilets, showers and similar drains will be treated in a wastewater treatment plant. The effluent from the wastewater treatment plant, estimated average flow .31 m3/h, will flow to a wastewater collection pit.

According to the water balance all treated effluent in wastewater collection pits will be evacuated by a licensed handler for offsite disposal. Similarly, sludge and oil collected by the oil - water separators will be evacuated by authorized handler. Storm water collected in outdoor areas potentially contaminated by oil shall be routed to the oil - water separator for oil removal; Waste water evacuation from waste water collection pit by authorized handler. However, the ESIA indicates that there may not be suitable capacity to accept and safely treat and dispose liquid effluents in the region and recommended liquid effluents be treated to a level of quality suitable for horticultural irrigation. As noted in ESAP item #12 the sponsor will confirm the licenses and evaluate the capacity of authorized handlers to safety transport and dispose of wastewater in compliance with IFC Guidelines or develop an on-site system that may include use of treated wastewater for horticultural irrigation.

Solid and Hazardous Waste Management

The ESIA indicates that the likely receiver for solid and hazardous wastes from the power plant is the “new”

Mazar-e Sharif municipal land disposal site located approximately 15 km west of the city center. The ESIA indicates that the landfill is unlined, and therefor there is a risk hazardous wastes may contaminate soils and groundwater under landfill.

As set out in ESAP Action #12 the sponsor will prepare a comprehensive waste management plans for construction and for operations that address the guidance provided in Section 1.6 “Waste Management” of the General EHS Guidelines. The plans will include an assessment of in-country capacity to manage the various wastes streams in an environmentally acceptable manner. Where acceptable solutions are not available the sponsor will devise in-house capacity for treatment and disposal (e.g., incineration of oily wastes).

Community Health and Safety:

Project construction activities will include civil works and transport of construction material for the power plant site. Construction activities may generate dust, noise pollution and vibration from additional traffic and operation of construction equipment. Other potential adverse public health issues that may arise during the construction phase include improperly managed solid wastes or releases of hazardous materials. As outlined in ESAP item #2, the EPC contractor will develop a Traffic Management Plan including elements such as: speed limits, haulage routes and maintenance of vehicle and construction equipment to minimize emissions. For management of solid waste and accidentals release of hazardous material during construction and operation phase, the EPC and O&M contractor will develop and implement Waste Management Plan as well as Spill Prevention, Control and Countermeasure plan as outlined in ESAP items #2 and #12.

Emergency Preparedness and Response:

The sponsor will require the EPC and O&M contractors to have in place emergency preparedness and response plans (“ERPPs”) as noted in ESAP item #2 and #3. The EPC contractor will closely coordinate its emergency procedures with the potentially affected communities and local government agencies in their preparation to respond effectively to emergency situations. The EPC and O&M contractors will ensure that critical components of the emergency plans are tested on a regular basis, including full scale emergency training exercises at least every year including jointly with authorities. The EPC and O&M contractors will be required to undertake mock drills as per a schedule.

Security Management:

As stated in ESIA study: The APPC will take the lead role for the project regarding security management. APPC, through the Ghazanfar Group, will facilitate a dedicated Security Manager and has generated a Security Management Plan that will govern site security for staff, contractors and visitors as well as transport to and from the site. As outlined in ESAP items 14., APPC shall update a Security Management Plan in line with IFC Performance Standard 4, i.e. to ensure that APPC and/or the EPC and O&M contractors implement a Security Management Plan, based on the outcomes of the security risk assessment undertaken. The plan will include the company’s code for security personnel and will ensure that past records of security personnel employed are screened; security personnel have clear objectives and permissible actions laid out; security personnel are trained in avoidance of human rights violations and handling various situations with clear procedures; security incidents are recorded, investigated and corrective action implemented; complaints against security personnel are investigated and disciplinary actions implemented; rules of engagement with public forces are clearly defined and shall be guided by principles of proportionality, good international practice and applicable law, and include training of security personnel regarding the use of force and conduct towards the community.; and there is a grievance mechanism for members of community or employees, in the event of a violation of the code by security personnel.