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
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards
IFC’s project due diligence determined that the project construction and operation is not expected to result in risks and impacts contemplated under PS 5- Land Acquisition and Involuntary Resettlement. The land required for the project (including those for utilities like water, gas and fuel pipeline, sub-station and transmission lines) is under the possession of the company. This land was acquired back in 1995 and due compensation was paid to land owners in accordance with the provisions of the existing laws. There are currently no encumbrances on the land and neither physical nor economic displacement will result on account of use of this land or on account of impacts on ecosystem services.

PS 6: Biodiversity Conservation and Sustainable Management of Living Natural Resources is not applicable for the project as the project site is located within an existing power complex and no material adverse impacts on biodiversity and natural resources are expected. The study area does not include any protected areas. None of the species falling within the transportation route were identified as species of conservational significance as per IUCN. The Jamuna river has two turtle species (Ganges Soft Shell Turtle (Nilssonia gangetica) and Striped Roof Turtle (Kachuga dhongoka) which are listed as Vulnerable and Endangered respectively as per IUCN) and one river terrapin (Batagur baska) which is listed as Critically Endangered as per IUCN. Habitat mapping for the above mentioned species was undertaken as part of the ESIA in order to understand the sensitivities related to their nesting/egg laying sites near the temporary jetty area and water intake location. Further consultations were held with IUCN Dhaka officials to validate the presence/absence of these species in the study area. The above species were not observed during field assessment/reported during stakeholder consultations. The analysis undertaken in the ESIA and other stakeholder consultation including those with the IUCN suggest that the study area is not a habitat for the above mentioned species.

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 the potential for significant adverse environmental and social risks and impacts, specifically, those related to i) cumulative impacts on physical, biological and socio-economic environment linked to the existing 225 MW power plant and planned development of another two 225 MW projects within the same complex as well as GOB’s future plans to set up an economic zone in an area of about 1000 acres in the southern part of the Sirajganj Power generation complex; ii) potential impacts on ambient conditions (air, soil and water) and communities neighboring the project site due to an increase in traffic, influx of construction labor (expected to be in the range of 1500-2000) and emissions including noise during construction (spanning 24-30 months) and operations; and iii) risks and impacts from associated infrastructure like fuel, gas and water pipelines, HSD storage at site, the transmission line and switchyard.

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



SCI (the parent company of the sponsor) has a corporate sustainability policy and a health, safety and environmental (HSE) policy, which defines the scope for HSE management during the construction and operation phases of the project under planning, development and implementation/operations. This policy will also apply to the project company. In accordance with the requirements of this policy, (the company will establish, implement and maintain an environment, health and safety and social management system that would integrate HSE considerations aimed at a) preventing accidents, injuries, occupational illnesses; b) reducing pollution and increasing resource efficiencies and c) ensuring conservation of natural resources. In addition to this, the company will also develop and implement a social policy aimed at protecting human life and ensuring social wellbeing of communities. Further, the company shall ensure that the policies are prominently displayed within the project site (including in local language) and are communicated to the staff.



Identification of Risks and Impacts



The sponsor commissioned a third party consultancy, Environmental Resources Management (ERM), to undertake an ESIA in accordance with international standards including IFC Performance Standards (PS, 2012) requirements. As a part of the process, baseline studies and data collection as well as detailed stakeholder consultations have been carried out and documented in the ESIA. This ESIA will also be used for obtaining regulatory clearances for the project. The company will ensure that all applicable clearances, permits, consents, authorization and all regulatory approvals under all the relevant legislation have been obtained prior to commencement of operations. The company will ensure that its operations, comply with applicable Bangladeshi laws/legislations and IFC Performance Standards.



The ESIA assesses the risks of flooding and climate change, based on the historical data of water levels and meteorology. The project site (within Saidabad power generation complex) is located within the flood plain of Jamuna River and has been raised by about 4m. This has ensured that the current ground level is around 1 m above the 200-year high water level return period. The project specification indicates that this is in addition to concrete placed at the perimeter of the site to prevent water ingress. Raising the ground level of the site is expected to mitigate any increase in flood levels, the company will, going forward evaluate options for developing a climate change adaptation policy, jointly with NWPGCL, including monitoring for flood mitigation (safe access /ingress during flood events / use of evacuation shelters



A consequence analysis in case of loss of containment of hazardous materials from the fuel storage facility and pipeline has been carried out (covering scenarios like fire and explosion due to leakage from the diesel storage tank, diesel pipeline and
natural gas pipeline and toxic release due to leakage from the hydrochloric acid tank and sulphuric acid tank). The pool fire effect zone for full bore rupture of natural gas pipeline, HSD pipeline near unloading zone and storage tanks, leakage in storage tank, and hydrochloric acid tank was covered by the assessment and it is expected that impact will be restricted to the plant boundary and risk reduction measures for handling of HSD and natural gas have been suggested.



Alternatives analysis done in the ESIA covers site location, design, alternative fuel and technology options - combined or open cycle and the no-development option. The ESIA report also provides an assessment of key cumulative impacts due to the proposed S4 project, the existing S1 project, soon to be commissioned S2 project and the probable S3 project and covers impacts on air quality and ambient noise levels.



Management Program



The ESIA includes an Environmental and Social Management and Monitoring Plan (ESMMP) for the project, covering pre-construction, construction and operation phases. This ESMMP takes into account the requirements of the corporate HSE management system. Environmental and social impacts during decommissioning phase have not been considered in the impact assessment, as these will depend on the options available at the time of expiry of the Power Purchase Agreement.



Key roles and responsibilities of the company and EPC contractor have been defined for implementation and monitoring of environmental and social impacts. For environmental monitoring, physical, biological, social and environmental management components of particular significance have been identified as performance indicators. Mitigation and monitoring measures include those related to emissions to air; ambient noise; water consumption; wastewater treatment and disposal; hazardous material and waste handling, storage and disposal; socio-economic impacts; construction workers and community health and safety. The aforesaid identified mitigation and monitoring measures will be developed into full management plans as per the timeline proposed in the agreed E&S Action Plan (ESAP) and will include: defined action items, responsibilities, monitoring indicators and review/ audit mechanisms and also additional management plans (refer ESAP items#2&3).



The company will ensure that the project’s Engineering, Procurement and Construction (EPC) contractors adhere to applicable social and environmental legal/national requirements and fully implement Environmental and Occupational Health and Safety (EHS) measures defined in project ESIA and ESMMP.



The company will put in place within, 18 months from the disclosure of this ESRS, an EHS Management System (EHSMS) aligned to ISO 14001 and OHSAS 18001 standards with IFC Performance Standards appropriately incorporated (refer ESAP item#2). The EHSMS will: (a) align the project HSE policy with the PSs; (b) using the ESMMP, further detail procedures f
or screening, scoping, assessment and management of environment, health, safety and social risks and impacts; (c) clearly define the project EHS organizational structure including roles and responsibilities for E&S management; (d) detail and implement the stakeholder engagement process; (e) put in place procedures for management of contract workers; (g) detail and implement internal and external communication procedures; (h) implement the emergency preparedness and response plan; and (h) have internal as well as external systems for periodic monitoring of EHS and social performance including procedure for management review of EHSMS effectiveness and implementation of measures for system upgrade.



Organizational Capacity and Competency



In accordance with the requirements of the EHSMS, the company will, prior to start of construction, put in place an appropriate EHS organization (ESAP item#1), with clearly defined roles and responsibilities. Further, the company will require the contractors to deploy appropriately qualified EHS staff, to manage EHS aspects on an ongoing basis. The company will as a part of the EHSMS develop and implement a comprehensive employee training program covering both permanent as well as contract employees.



During the operation phase of the project, the operations manager and EHS personnel will monitor the effectiveness of the ESMP implementation. The project administration and Human Resources (HR) manager will have additional responsibility of monitoring the implementation of social components of the ESMP. He/ she will also responsible for implementation of Corporate Social responsibility (CSR) activities to be conducted by the company. Both the operations manager and HR manager will report to the plant manager, who will be overall in-charge of the plant operations and management and who will in turn report to the senior management including the Board of the company.



Emergency Preparedness and Response



The company has prepared the draft outline of the Emergency Preparedness and Response Plan (EPRP). The company will ensure that the contractor has undertaken Hazard and Operability (HAZOP) studies within 12 months from issuance of notice to proceed. Based on the HAZOP study and taking into account other emergencies (like fire/explosion, chemical spill, electrical shock, failure & collapse of heavy machinery/equipment, sabotage) and natural disasters (like floods, earthquakes, cyclones), the contractor will develop and implement an updated EPRP, appoint a suitably qualified emergency coordinator and undertake awareness training including mock drills for building awareness on emergency response (refer ESAP item#7).



Monitoring and Review



The ESIA report provides an ESMMP for the project during different phases of the project with institution level roles and responsibilities and frequency of monitoring. As part of the ESMMP, the company will put in place detailed procedures, including: reporting requiremen
ts for the construction and O&M contractor; periodic site audits jointly with the contractors; review and documentation of the contractor’s compliance with national and lender requirements, and periodic EHSS audit recommendations. 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. These procedures will be eventually incorporated into the monitoring and review program that will be developed as part of the EHSMS. Quarterly independent audits during construction phase have been proposed to ensure compliance to ESAP and ESMMP requirements (ESAP Action #5)

Human Resources Policies and Procedures



The parent company of the sponsor (SCI) has a HR manual laying down the policies and procedures of the group company. The company will put in place before start of construction a company-specific HR policy and procedures that will meet national laws and PS2 provisions (refer ESAP item#4). This will include (but not be limited to): a) a clear policy on non-discrimination and equal opportunity; b) child and forced labour; c) prevention of sexual harassment; d) contract labor management; e) security; f) training and employee welfare; g) collective bargaining; and h) worker grievance mechanism. The company’s HR policies and procedures will be made available/accessible to all employees (including contract employees) and communicated at the time of employee induction. 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 applicable IFC PS2 requirements.



The company plans to engage around 1500-2000 people (around 80-100 will be on the company’s payroll) in the construction phase and around 70-80 people (around 30-40 directly) in the operations phase. The construction phase of the project is expected to last around 24-30 months during which a significant amount (around 50-60 percent of the total workforce) will be local laborers (mostly unskilled and semi-skilled). Construction workers from outside the area/region will be provided accommodation in the labour camp area identified by the company.



Working Conditions



The company will require its contractors and sub-contractors that engage migrant workers to make available living conditions with basic amenities and electricity; potable water; mess facilities for food; where workers desire self-cooking, provision of fuel and arrangement for cooking; provision of toilets and bath including separate toilets and baths for women family members of workers; appropriate sewage disposal facilities and/or septic tank and soak pit; and primary medical care for all workers engaged at site. A labour camp management plan (aligned to IFC-EBRD requirements on worker accommodation) will be developed by the company (prior to start of construction) and implemented by the contractors. These labour related requirements (like safety, camp management etc) will be incorporated in the contracts of the EPC and O&M contractors. Third party quarterly audits proposed during the construction phase will assess compliance to the labour camp management guidelines and procedures (refer ESAP item#5).



The contract labour management process developed as a part of the ESMP will be implemented for the project. As a part of the contractor oversight procedures, the company will review the contractors’ HR policies and procedures and communicate to them specific provisions of its own HR policy and PS 2 requirements that are applicable to contractors. It will put in place detailed r
equirements including audit procedures to ensure that: contractors comply with applicable statutory requirements; worker accommodation is consistent with IFC-EBRD guidance on worker accommodation; workers have access to an appropriate grievance mechanism; and migrant workers are engaged on substantially equivalent terms as non-migrant workers performing same work, all in accordance with PS 2 provisions. The company will provide training and capacity building support to the contractors to understand and meet the aforesaid requirements.



Occupational Health and Safety



The company will implement the Occupational Health and Safety (OHS) plan (part of the EHSMS) for the project and ensure that the contractors’ fulfills its environment, health & safety and labour related obligations/requirements. The company will require contractors and sub-contractors to ensure use of relevant personal protective equipment, implement work permit and tag out/lock out system (for working at height, confined space, electrical works etc) and implement incident/accident recording/reporting systems. It will periodically review the OHS performance of the EPC contractor and its sub-contractors during construction and operation phases. The company will contractually require the contractors to report on OHS, ESMP implementation and grievance related issues. The company will, in the O&M phase, address OHS under the OHSAS 18001 certified OHS management system it proposes to implement, which will also incorporate PS 2 and GIIP on OHS.



Grievance Mechanism



The company shall develop, communicate and establish a formal worker grievance mechanism 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 to the 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 worker grievance records and shall monitor resolution of grievances. The company will allow the workers to join unions and respect their rights of collective bargaining.

The potential environmental aspects and impacts from construction activities for the project and its associated facilities include: fugitive dust and noise emissions; water consumption and wastewater generation; hazardous materials and waste handling, surface runoff and vehicle traffic generation. 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 ESMMP will be incorporated into the construction contract documents and the same will be revised, if necessary. The EPC contractor will be required to ensure 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 in alignment with ISO 14001 standards.



Resource Efficiency and GHG Emissions



The project will use natural gas, a cleaner fuel and higher efficiency combined cycle technology. HSD will be used only as a back-up fuel. With respect to GHGs emissions, the project would emit 1,404,790 tons (CO2 equivalent) per year. The cumulative assessment of GHG emissions based on overall capacity of the all four power plants has been estimated as 3,624,541 tons of CO2 equivalent per year. The company will strive to reduce consumption of primary resources and emissions of pollutants by applying adequate control measures and enhance operating performance and efficiency. Additionally all the power plants need to monitor GHG emission continuously and to ensure annual reporting of the emissions. The water system is a close circuit system and water will be reused in the cooling with a cycle of concentration (COC) value of about 5. This will help in reducing the total water consumption as against a once-through system, which requires a lot more water. The company will ensure that all air conditioning equipment and fire safety equipment comply with the Ozone Depleting Substances (ODS) phase-out plan of Government of Bangladesh and the Montreal Protocol.



Water and Wastewater



The water consumption during the construction phase is expected to be about 100 m3/day, which will be met from the nearby Jamuna River. Analysis of water samples collected from project site as well as Jamuna River indicated the quality of water is suitable to be used in the construction phase of the project. The potable water requirement during the construction phase will be provided by the EPC contractor.



During the construction phase, wastewater will be generated from washing of equipment and machinery on site. This wastewater may contain suspended solids and traces of hydrocarbon. The contractor will be responsible for ensuring that any wastewater discharged meets the applicable stan
dards prior to discharge of such wastewater. Sanitary facilities including toilets will be provided for the use of the construction workforce both on-site and at the workers’ accommodation.



During the operations phase, the project will operate a closed-loop cooling water system and make-up water will be drawn from the Jamuna River located on the eastern side about 1.2 km from the project site. The raw water system will consist of an intake structure on the river Jamuna and vertical raw water pumps. Water requirements during the operations phase of the project will be approximately 600 m3/hr, which will be drawn from the Jamuna River via a 4 km long pipeline. Based on the last 15 years data of water flow in the river Jamuna as recorded by BWDB, minimum flow of the river was measured as 7,332,552 m3/hr on 5th March 2013 whereas the proposed water requirement of the Sirajganj 4 project is about 600 m3/hr amounting to 0.008% of the lean season flow of the Jamuna River in Sirajganj. The company will implement a program to monitor water consumption, and identify and harness conservation and efficiency opportunities.



Cooling water and other treated effluent discharge from the project will be about 74.4 m3/hr which will be discharged on land outside the southern boundary of the project in the upstream of adjacent channel which is about 200 – 400 m away from the discharge point during non-flooding season and about 1.2 km from river Jamuna. The channel is dried most of the time and gets water only during the monsoon season. Since the land where treated effluent will be discharged is a part of the power generation complex and does not house any habitation/includes agricultural land, no flooding impact or impact on crop land is envisaged. Further, the soil profile is porous in nature with soil permeability coefficient in the range of 10 to 15 m/day, representing “very rapid” soil permeability class (i.e. > 6 m/day) and which would enable percolation of treated wastewater into the ground. In the unlikely event that water percolation does not occur as expected, the company will provide temporary solutions such as to engage a sub-contractor to use the portable pumps & hoses to evacuate this water to the river or dry canal, thereby allowing a larger surface area for the water to percolate. The company will further monitor the wastewater discharge and if water stagnation is observed to persist continuously over an extended period of months, then permanent solutions will be worked out to resolve the issue. This discharge will be having about <3°C of intake water temperature at the outlet of condenser. Dispersants and algaecides will have to be added in the cooling water to prevent fouling of the heat exchangers and piping. The project will not have any direct discharge into the Jamuna River.



Treated effluent generated from sewage treatment plant (~ 3 m3/hr) will be used within the site for greenbelt development. No untreated sewage will be directly dis
charged into Jamuna River/channel or disposed of on land through the project life cycle. As back up of water supply, ground water may be considered, which is subject to the local authority approval.



Air Emissions and Ambient Air Quality



Ambient air quality baseline data indicates that the baseline concentrations of gaseous pollutants and fine particulate matter (PM2.5) are within the permissible limits. However, SPM and PM10 are slightly higher with respect to the National Ambient Air Quality Standard (NAAQS) of Bangladesh due to the site conditions and large open and agricultural areas, with scattered anthropogenic activities and traffic movement. Industrial activity in the area is currently limited to the existing 225 MW CCPP of NWPGCL and small scale handlooms at household level at nearby villages including Khas Bara Shimul (0.5 km), Radhunibari (3 km) and Makimpur (3 km).



The operation of the plant with natural gas as fuel in simple/ combined cycle will generate flue gas emissions containing NOx and CO. Emissions of SO2 and particulate matter are likely to be negligible, as natural gas typically has a very low sulphur level (as per the natural gas specifications for the project). However, operation of the plant with HSD as fuel in simple/ combined cycle would generate flue gas emissions containing NOx, SO2, PM and CO.



The gas turbine will have dry low NOx (DLN) combustors. The gas turbine and the steam turbine will be housed within a turbine building. A vertical configuration HRSG with a 60 m high stack is proposed. The project will connect to GTCL’s common point of delivery of gas, located near to the highway, about 1.5 km from the project site. A Regulating and Metering Station (RMS) will be installed by the company to control the gas flow to the plant.



Use of HSD as fuel for power generation in the project will be only in case of interruption in natural gas supply. As per the fuel supply agreement (draft), three days of HSD supply will be stored in two tanks with capacity equivalent to 15 days operation at 80% output on HSD, while the plant is running on gas. Total storage capacity at site will be 19,000 m3. HSD will be delivered via rail from BPC Depot in Chittagong/Daulatpur/Khulna up to the nearest rail head at Saidabad (i.e. Bangabandhu Bridge West railway station), which is located approximately 3 km from the project site. NWPGCL has constructed an HSD unloading and pumping station at the railway station and an HSD supply pipeline has been constructed up to the Saidabad Power Generation Complex by NWPGCL.



Impacts due to the operation of the plant were assessed by emissions modelling. On the basis of the modelling results, maximum ground level the study area will be well within the applicable standards for air quality with usage of natural gas and impact on air quality has been predicted to be negligible. Further to ensure compliance with the air emission criteria for flue gas stacks, Continuous Emission Monito
ring (CEM) equipment for the measurement of NOx emission levels in the exhaust stack of HRSG will be installed. The cumulative impact on ambient air quality due to the Sirajganj 4 project (gas/HSD), proposed Sirajganj 2, 3 and 1 projects was also evaluated by using air dispersion modelling. The modelling outcome revealed that maximum ground level concentrations of oxides of nitrogen, sulphur di oxide and particulate matter in the project area with natural gas will be well within the applicable standards. It is also noted that the project contribution for all the pollutants considered in the modelling study is < 25% of the applicable air quality standard.



Noise



The major noise sources include the air-cooled condenser (ACC) or cooling tower, steam turbine generator (STG), combustion inlet filter house, and the exhaust stack or heat recovery steam generator (HRSG). Noise and vibration from the project will be mitigated through engineering controls and wherever possible high noise equipment will be enclosed in noise-proofed buildings. Impact on ambient noise levels due to the operation of S4 plant as well as cumulative impact due to operation of all four plants was evaluated using a noise prediction model. The predicted results show that the noise levels will remain within the acceptable limits at the plant boundary during the operation phase for both scenarios.



Solid Waste Management



During the construction phase of the project, 100 – 150 m3 of concrete waste and bitumen will be generated. The inert wastes will be stored in the lay down area near the batching plant and will be reused under floors or under road to increase the California Bearing Ratio (CBR) value. Bitumen or any hazardous wastes will be disposed to licensed contractors. Domestic wastes consisting of food waste, plastic, glass, aluminum cans and waste packages will also be generated by the construction workforce.



The type and approximate volume of non-hazardous solid waste anticipated from operational activities will be as follows: 1) Office and kitchen, 5,000 kg/year; 2) Dewatered STP sludge from the WTP, ETP and STP sludge, 50 - 70 kg/year; and 3) Air filters from the gas turbines, 300 kg/year. The solid and non-hazardous wastes generated from the various areas during operations will be collected and segregated at the point of generation and stored in proper designated areas and disposed of through waste disposal contractors or authorized recyclers. The company will develop a detailed Waste Management Plan (WMP) prior to the start of constriction for proper storage and disposal of all wastes generated during operations.



Hazardous Materials



Hazardous materials during construction would include: used paint, engine oils, hydraulic fluids and waste fuel, spent solvents from equipment cleaning activities and spent batteries or spent acid/alkali from the maintenance of machinery on site, quantity of which will be less than 100 litres per month. The company will requ
ire the EPC contractor to have proper system for 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: chemical waste - 500 m3/year; chemical cleaning waste from the CT compressor - 300 l/year; waste/used oil from the power house and workshop - 2 m3/year; dewatered sludge from the WTP and ETP - 200 - 230 kg/year; and Oil/dust contaminated cloths and rags from the lube oil system and spill kit waste - 600 kg/year. The hazardous wastes generated from the project will be collected and stored in designated roofed-areas and/or barrels with concrete flooring and secondary containment and disposed of/ sold through contractors or treated prior to discharge.



The ESMMP provides the mitigation and monitoring measures for waste management during the construction and operation phases. 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, the fabrication work is planned offsite. In addition to the fabrication, work on gas and water pipeline is expected in open areas outside the project site boundary. These works are expected to be of temporary nature. The existing main road network to the project site is in fairly good condition; however these will require strengthening in some stretches for transportation of equipment and machinery. During the construction phase, materials will be transported to site primarily by river (utilizing the jetty) or using the railway lines. An increase in road traffic is expected due to movement of labor and transportation of some construction material during the construction phase. A detailed transport and traffic management plan will be developed and implemented by the contractor (refer ESAP item#3) including procedures to ensure that EPC contractors adopt good EHS practices for the 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



The construction phase of the project will engage around 1500-2000 workers in different construction activities. Where possible, the project will give preference and priority to local workers. However, it is envisaged that about 50-60% of the workers would be sourced from other parts of the country. The migrating labour population will primarily consist of semi-skilled and skilled workforce while unskilled workforce would be mostly procured locally through local contractors. There is a likelihood of overlapping in the construction schedule of Sirajganj 4 and Sirajganj 2 projects within the power generation complex and this will lead to unavailability of land within the complex for construction workers camp. Therefore, the labour camp will be located outside the power generation complex. The area identified for the construction workers camp is located between the main highway and Punorbason village fence line. Available land area for this purpose is about 8.37 acres. This influx of workers to the community may cause impacts to public health, especially an increase in prevalence of diseases. Measures such as proper collection, storage and disposal of wastes, construction of septic tanks to prevent contamination of water resources from sanitary effluents generated from labour camps, restrictions on labour movement and community interactions (including a c
ode of conduct for construction workers living in labour camps) etc will be implemented.



Security Personnel



The Sirajganj power complex has a central security committee in place to supervise security of the site, and a security manual has been prepared. This security manual lays down operational protocols for security management of the complex including emergency communication and response. NWPGCL is responsible for overall security of the complex. The power complex is raised approximately 4 m above the surrounding area and is fully fenced, with one gate to access the complex, and a second internal gate to access the plant site. Both gates have security guards to control access. Security guards at the site are a combination of contractors directly engaged by NWPGCL and unarmed paramilitary troops assigned by the government. Though the government is ultimately responsible for management and training of paramilitary security forces stationed at the site, while on site, the security personnel are also required to respond to directions from the NWPGCL site manager. The security staff is unarmed and community consultations did not indicate any issues regarding the existing security arrangements.



The company will review the security manual and further strengthen it with a) procedures to ensure mandatory security check of past records of all security personnel deployed; b) procedures for ensuring that security personnel have clear objectives and permissible actions laid out; c) training of security personnel in avoidance of abusive conduct and handling various situations with clear procedures; d) system to record, investigate and implement corrective measures for security incidents e) mechanism for investigative/disciplinary actions against bona fide complaints against security personnel; and f) a grievance mechanism for aggrieved members of the community or employees in the event of a violation of the code for security personnel (ESAP action #6).

Broad Community Support is not applicable for this project

Sirajganj 4 IPP(36050) Supervision Disclosure Snapshot – Version 3
Description	Anticipated Completion Date	Status	Comments	Completion Date
Put in place an appropriate EHS organization, with clearly defined roles and responsibilities for management of EHS and Social/labour aspects. Deploy appropriately qualified EHS and Social/labour personnel (including those for contractors), to manage EHS and social/labour aspects on an ongoing basis	01-Jul-2016	Completed	Completed	7/1/2016
Develop an environment, health and safety management system (EHSMS) in line with ISO 14001 and OHSAS 18001 standards, and incorporating IFC Performance Standards. Ensure that the company and the O&M contractor, implements and adheres to this EHSMS.	01-Jan-2020	Completed	Completed	4/30/2020
Develop and implement a project specific EHSMS for construction phases covering impacts and mitigation measures delineated in the ESIA and ESRS.	01-Jul-2016	Completed	Completed	7/13/2016
Detail out (with the help of contractors) implementation plans for risks and impacts identified in the ESIA including those for a) Health & Safety; b) Waste management; c) Traffic management; d) Emergency response; e) Stakeholder Engagement; f) Labour camp management; g) Contractor oversight	01-Jul-2016	Completed	Completed	7/13/2016
Develop and implement a project specific Human Resource (HR) policies and practices, especially elements linked to contractor management and worker grievance management, to comply with statutory as well as PS2 requirements	01-Jul-2016	Completed	Completed	10/18/2016
Undertake third party EHS audit during construction phase on quarterly basis to assess satisfactory compliance to statutory, PS 2 and ESMS requirements -during the construction phase. Complete implementation of mitigation measures based on audit findings including those relevant to EPC contractor’s management of labor issues	01-Jan-2017	Completed	Completed	12/30/2016
Implement a) the community/stakeholder engagement and grievance redress plan/ process in consultation with the community/stakeholders	01-Jan-2017	Completed	Completed	11/1/2016
Develop and implement Emergency Preparedness and Response Plan based on HAZOP and risk assessment studies and covering both onsite and offsite emergencies	01-Jan-2017	Completed	Completed	8/30/2017