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
PS 6 is not considered applicable as the project and ancillary facilities will be built on modified habitat consisting of land formerly or currently used for intensive agriculture or grazing as well as the right of way of existing utilities; PS 7 is not considered applicable as no Indigenous Peoples or ethnic minorities reside in the project area; and PS 8 is not applicable because the ESIA has not identified potential impacts on cultural heritage within the project’s footprint or its ancillary facilities.

The investment has been classified as Category A according to IFC’s environmental and social review procedure due to concerns about expansion of industrial activities in this rural area including cumulative impacts to air quality; influx of migrant construction labor, and the related community health and safety risks; and potential relocation of approximately 5 to 10 families of settlers without land titles or legal claims along the river water pipeline right of way.

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

The sponsor has in place a publicly disclosed Sustainability Policy which describes the company’s global commitment to international standards in the areas of business conduct; health, safety and environment; labor management; and corporate citizenship (http://www.sembcorp.com/en/esg-sustainability.aspx). This group level policy is applicable to this project. Additionally, the sponsor has a publicly disclosed Group Health, Safety, and Environment (HSE) Policy with the stated objective of managing health, safety and environment responsibilities as a first priority and in adherence to the principle of continuous improvement. The HSE Policy expresses the sponsor’s specific commitment to responsibility and accountability of employees and contractors; training on awareness of safety risks and health hazards; policy disclosure; environmentally sound design, construction, operation and maintenance; compliance with HSE laws and regulations and other HSE requirements applicable to Sembcorp's activities, products and services; influence of suppliers, contractors and other interested parties to improve their HSE performance; periodic system audits and management reviews to evaluate performance; and emergency preparedness (http://www.sembcorp.com/en/esg-health-safety-and-environment.aspx).



Identification of Risks and Impacts



The sponsor commissioned the preparation of an Environmental and Social Impact Assessment (ESIA) which was completed on September 15, 2015 and Revision 2 completed on August 2016. The ESIA included a comprehensive analysis of baseline environmental and social aspects including, for example: Background ambient air quality; background noise; surface water quality and quantity at the proposed cooling water intake point in the Ayeyarwady River; soils quality and condition at the project site; groundwater quality and at the project site; existing landscape and visual condition; existing waste practices and infrastructure in the Myingyan region; and terrestrial and aquatic biodiversity based on field surveys. The socio-economic baseline studies included a review of the conditions in the communities that may be impacted or influenced by the project due to their proximity to the project site and/ or project associated facilities including: Sa Khar village, Hnan Ywa village, Hpet Taw village, Nyaung Kan village, Gyoke Pin village, Thien Ywa, and Tha Pyay Thar village. Survey work included interviews with village leaders, focus groups with key sectors within each of the villages, and household surveys (total of 301 household surveys out of a total 2,557 households) to evaluate such aspects as: demography (including ethnic origin); community health statistics and indicators; economic activities and sources of livelihood; community infrastructure and public services; and cultural heritage.



The ESIA comprehensively identified key environmental and social impacts, and the corresponding mitigation measures, associated with the project’s construction including, for e
xample: air quality impacts during site clearance, site formation and levelling, as well as construction of substructure and superstructure of the power plant facilities; surface water quality from domestic wastewater discharge, inappropriate waste storage and disposal, contaminated surface water runoff, and sedimentation; noise during site preparation, pile driving and foundation works, as well as increased traffic in access roads; incremental change in the landscape and visual character of the area; soil and groundwater from potential leaks and spills of oil, lubricants, or fuel from heavy equipment; construction waste management; and community health and safety impacts due to increased traffic and influx of construction workers.



Mitigation and management measures corresponding to each of the identified impacts will be incorporated into the project’s design and construction phase environmental and social management plans, as well as in the EPC contractor’s contracts.



The ESIA comprehensively identified key environmental and social (E&S) impacts likely to be generated during the project’s operation including, for example: impacts to air quality due to stack emissions from the combustion of natural gas during combined cycle and simple cycle operation (mainly NOx emissions); surface water quality due from domestic wastewater discharge; noise associated with the operation of the power plant; landscape and visual due to the addition of an industrial component into the Industrial Complex area; generation of various types of non-hazardous and hazardous wastes from plant O&M activities; and community health and safety mainly associated with the unlikely event of a natural gas leak. Some of the social impacts (positive and negative) predicted due to the operations of the project are employment generation and in-migration of skilled workforce; demand for lodging, housing and civic services, resulting in increase in the cost of living; and risks of industrial accidents among others.



Mitigation and management measures corresponding to each impact have been proposed as part of environmental and social management plans to be developed prior to the operational phase.



The ESIA included an analysis of project alternatives for the following aspects: alternatives of the project location; alternatives of configuration on site; alternatives of technological options; and alternatives of temporary landing for heavy cargo. The analysis consisted mainly of a retrospective review of MOEP’s decisions with regards to main design criteria, plant technology, configuration and project type, prior to the issuance of a competitive concession bidding process. A key reason for MOEP’s site selection is its location adjacent to the steel mill, which is already in operation, and therefore the proposed project is in keeping with the existing industrial use. There are additional advantages in relation to land availability, gas supply pipeline and connection to the
national grid. The availability of cooling water is also an important factor, with the selected site being the closest of the siting options to the Ayeyarwady River.



The ESIA included an evaluation of cumulative impacts which considered existing activities, on-going expansions, and other planned developments within the immediate project area, including: existing No (4) Steel Plant Myingyan which produces billets and slabs from recycled material such as scrapped metals and cars; Aggreko temporary gas fired power plant on the north of the project site boundary; the MOGE gas receiving station on the east of the project site; and an expansion of the No (4) Steel Plant Myingyan, which based upon existing information is presently under construction. Valued Environmental Components (VECs) were identified based on the environmental, social and economic components assessed during the ESIA including topics raised during the ESIA consultation process and issues raised by stakeholders. VECs included: air quality; noise; surface water; soils and groundwater; and socio-economic impacts, divided into economic development (being those classified as positive impacts), physical and economic displacement, and influx. The sponsor is planning to implement a range of measures to comprehensively address its own environmental and social impacts. Additionally, and in order to manage cumulative impacts, the sponsor will endeavor to collaborate with the adjoining steel mill, and the Government of Myanmar (GOM) on a commercially reasonable effort basis in order to address cumulative impacts during the construction and operational phases.



Management Program



The ESIA provides a detailed summary of mitigation measures applicable to the construction and operation phases of the project. Some of the mitigation measures suggested during the construction phase of the project are associated with good construction and housekeeping practices while some mitigation measures for the operation phase of the project (such as those for air emissions and noise generation) are already incorporated into the project design specifications. The sponsor is also planning to include health, safety, and environment (HSE) requirements in the EPC contract specifications during the construction phase. A review of the draft EPC HSE requirements indicates that these are focused on the management of occupational health and safety risks and cover such aspects as: identification of safety risks; safety training; safety rules and regulations; incident investigations; selection of sub-contractors; and emergency procedures, among others.



Going forward, as described in the ESAP, the sponsor will further ensure that the mitigation measures in the ESMP are implemented during the construction and operational phases through the development and implementation of the following detailed set of Environmental, Social, Health, and Safety (ESHS) management plans and associated procedures:

Dust Management Plan;

Traffic Management Plan;

Noise and Vibration Management Plan;

Surface Water Management Plan;

Soil and Groundwater Management Plan;

Waste Management Plan (Hazardous and non-Hazardous Waste);

Oil and Chemical Spill Contingency Management Plan;

Emergency Response Plan (including Community Emergency Response Plan);

Stakeholder Engagement Plan (including Grievance Management Plan);

Community Development Plan (CDP);

Community Health Management Plan;

Workers’ Accommodation Management Plan;

Local Recruitment and Procurement Plan;

Influx Management Plan;

Cultural Heritage Chance Find Procedure;

Security Plan; and

Contractor Management Plan.



Going forward, as described in the ESAP, the sponsor will complement the EPC HSE construction requirements to include the aforementioned aspects. The sponsor will further review and approve the EPC HSE management plans and procedures to ensure compliance with sponsor and IFC PS requirements as per ESAP.



Going forward, as described in the ESAP, the sponsor will further develop and implement a full set of Operational Phase ESHS Management Programs that are consistent with the local legal requirement and the Lender’s ESHS standards including IFC PS requirements.



Organizational Capacity and Competency



The sponsor has a Group Governance Policy, part of the Group HSE Management System, which defines and assigns roles and responsibilities for HSE performance at the corporate and project levels. The project will be managed as an independent business unit from the sponsor, supported as needed by the sponsor’s corporate organization based in Singapore. The EPC contract currently stipulates that the EPC contractor will nominate and appoint, subject to the sponsor’s review and approval, a qualified HSE team for the construction phase consisting of a Construction Manager and HSE Officer supported by one HSE supervisor for every 50 workers. While the contractor or a particular party is responsible for physical implementation of the mitigating measures, the whole implementation process requires supervision, checking, documentation and verification so that problems are identified and properly addressed timely.



Going forward, as described in the ESAP, the sponsor will ensure proper execution of the ESMP by assigning dedicated technically qualified construction phase ESHS management team comprised of a Head and supported by environmental, OHS, and social (community affairs) coordinators either directly hired by the sponsor or through the construction oversight function of the owner’s engineer. Prior to the start of the operational phase, the sponsor will define an ESHS organizational structure comprised of a Head of ESHS with supporting OHS and community affairs coordinators who will be fully responsible for implementation of the ESMP.



Emergency Preparedness and Response



Consistent with one of the objectives of the sponsor’s Group HSE Policy, the sponsor plans to develop and imp
lement construction and operational phase emergency preparedness and response (EPR) plans. For the construction phase, the EPC contract terms stipulate that the EPC contractor in consultation with the sponsor shall develop and implement a site Emergency Response Plan covering such aspects as fire; explosions; releases of toxic substances; collapse due to structural failure of civil works or heavy machinery/equipment; or other emergencies. The EPC contract includes requirements for regular emergency drills to test the effectiveness and robustness of the EPR Plan.



Going forward, as described in the ESAP, the scope of the EPR mentioned in the EPC contract will be expanded to include preparedness and response for all emergency scenarios including but not limited to emergencies arising from occupational accidents or accidents involving members of the public or health related emergencies (including emergency treatment and emergency evacuation to treatment centres), emergencies related to natural hazards such as floods.



Additionally, as described in the ESAP, the sponsor will develop an operational phase EPR Plan prior to commencing of testing and operational activities based on the outcome of the detailed quantitative risk assessment of the project after finalisation of project design. The operational Phase EPR Plan will define protocols to be followed in the event of emergencies or disasters in order to limit the impact on the employees and the local community. The plan will address both on-site and off-site emergency situations due to the operation of the project. The plan will disclose potential disasters and potential risks from the plant to the local community as well as the plan of action on emergency protocol in the event of any such eventuality. This will also include awareness programs for the Plant personnel, local community and local administration.



Monitoring and Review



The sponsor’s HSE Management System has Group HSE Monitoring and Reporting Requirements applicable to all of its subsidiary operations. The objective of these procedures is to provide reporting principles to report internally to the sponsor’s corporate management and then externally, as applicable, in aggregate through a format following the Global Reporting Initiative (GRI). The HSE reporting requirements include detailed instructions applicable to occupational health and safety (OHS) activities for both employees and contractors including work related accidents Environmental compliance performance monitoring requirements cover electricity generation, wastewater treatment, water consumption, waste treatment, GHG emissions as applicable. Reporting frequency includes monthly performance reports covering the following: monthly man-hours worked for employees and contractors; number of near miss and dangerous occurrence incidents reported; number of recordable work incidents (fatality case, medical treatment cases, occupational diseases cases, lost workday
cases – including number of days lost and date of last workday case, restricted work cases); number of accidental discharges of substances from a storage or process into the environment that directly affects human health, land, vegetation, water bodies and ground water; number of material property damage lost; incidents; number of incidents of non-compliance with regulations and voluntary codes concerning the HSE, including any notification and cases pending investigation from the authority: incidents of non-compliance with regulations resulting in a fine or penalty; incidents of non-compliance with regulations resulting in warning; and incidents of non-compliance with voluntary codes. The above information is compiled into semi-annual and annual reports that are presented to the sponsor’s corporate line management.



The ESMP prepared as part of the project ESIA includes a detailed list of E&S indicators that will guide the preparation of detailed E&S monitoring program applicable to construction and operation activities. The ESIA includes a summary of the physical, biological and social environmental management components of particular significance including the tentative parameters to be measured, methods to be utilised, sampling locations, frequency of measurements, detection limits, cost and responsibilities for implementation and supervision.



Going forward, as described in the ESAP, the sponsor will develop and implement a detailed, project specific monitoring and reporting program with monitoring measures applicable to each of the relevant management plans. Monitoring and reporting activities will be reviewed by an independent E&S consultant on a semi-annual basis during the construction phase and annually thereafter for the first year of operation. A summary monitoring report will be disclosed to local communities semi-annually during construction and annually during the first year of operational phase containing the methods and results of environmental and social monitoring covering the indicators of potential relevance to local communities (i.e. dust, air emissions, noise, social impacts due to worker influx, etc). The public disclosure summaries will be prepared in Burmese and English.

Human Resources (HR) Policies and Procedures



The construction workforce for this project is expected to average 600 persons per day, reaching a peak of 900 person per day at the height of construction activities. During the project’s operational phase, headcount is expected to be 48 and all employees will be direct hires of the Company. There are no plans for any major upcoming reduction of the workforce given the greenfield nature of this project. As stated above, the company has developed a HSE Plan for this project, dated August 2015. The project HSE Plan contains details on contractor HSE management including a section discussing requirements on the quality of housing accommodation provided to contractor workers.



The Company will in due course develop human resource policies and procedures specific to this project, to comply with requirements of the Myanmar Labor Laws and Social Security Act. Terms of employment and benefits will include provisions such as in-patient (hospitalization and surgical) and out-patient medical benefits, Group life insurance coverage, Group accident insurance coverage, as per the Sembcorp Group Insurance plan, Maternity, Annual Leave and all other Leave scheme will be granted in accordance to the Labor Law. Where appropriate, these will be specified in employment contracts signed with all workers. The Company will hire a HR manager which will form a team to oversee the HR policy and procedure development and implementation.



Human resource policies to be developed for this project will include an employee grievance policy, consistent with the sponsor’s grievance policy at the Group level where unresolved grievances will be escalated to the Head of the Business Unit. The Company will also develop mechanisms for regular communications with and between staff e.g. staff meetings, forums, staff communication sessions etc.



The Company will ensure that relevant parts of the project’s human resource policies and procedures (including worker grievance policy – so that contractor/sub-contractor workers have a channel to directly lodge grievances with the Company where needed), will be extended to cover the labor practices of construction contractors and their sub-contractors e.g. provisions to ensure timely payment of remuneration; non-use of child and forced labor; ensuring occupational health and safety, etc. During construction, the Company will regularly monitor the labor practices of contractors and sub-contractors against a checklist to ensure compliance with national labor related laws and regulations (e.g. verifying the age of contractor workers through spot checking of IDs and the worker roster list). Refer to the ESAP for details.

Construction contractors and sub-contractors will provide accommodation to their workers. The Company will ensure that the housing provided meets standards as specified in the project HSE Plan and also specified in IFC PS2, and are also consistent with principles of non-discrim
ination and equal opportunity. Refer to the ESAP for details.



Equal Opportunity and Protecting the Workforce



The sponsor states that it fully supports principles of fairness and opportunity as well as dignity, respect and non-discrimination in relation to human resource management. Being a company based in Singapore, at the group level, it abides by the approach to human rights taken by the Singapore government, and endorse the Employers' Pledge of Fair Employment Practices under Singapore's Tripartite Alliance for Fair and Progressive Employment Practices. Globally it does not hire forced or child labor in any operations, and complies with local regulations restricting forced or child labor where the company operates. The Company will ensure non-use of child and forced labor by construction contractors and sub-contractors – refer to the earlier text and ESAP for details.



Workers’ Organizations



The Labor Organization Law of Myanmar (The Pyidaungsu Hluttaw Law No. 7 / 2011) came into effect in March 2012, which describes the rights of workers in Myanmar to form and join labor unions, and the right of labor unions to collective bargaining with employers. The Company confirms that should employees wish to set up a worker union or enter into a collective bargaining agreement, their right to do so will be ensured, as has been the case at the Group’s operations in other global locations. It will also ensure compliance with the Pyidaungsu Hluttaw Law No. 7 / 2011.



Occupational Health and Safety



The sponsor has a Corporate Occupational Health and Safety (OHS) Management Policy which defines the sponsor’s objectives, supported by project-specific OHS requirements to be incorporated into the EPC contract. EPC OHS requirements include procedures for: assignment of roles and responsibilities; hazard identification and risk assessment; permit to work requirements; safety training provisions; content and frequency of HSE meetings; incident investigation and analysis; safety rules and regulations (including use of personal protective equipment; lifesaving rules (LSRs); safety violation disciplinary procedures; worker welfare facilities; authority to stop work; etc); evaluation, selection and control of subcontractors; project owner audits of all high risk activities; lifting equipment safety; control of hazardous materials; and emergency response; among others. The project-level OHS requirements include quantitative objectives such as no fatalities, no lost time injuries or illnesses, no fire or explosion, no reportable environmental and compliance incidents, and no vehicle accidents and application and enforcement of fall prevention policy 100% of the time. It also requires contractors to report immediately to the sponsor all accidents, incidents and near miss incidents.



Going forward, and as previously noted in the ESAP (see Management Program), the sponsor will review the EPC contractor’s HSE (including OHS) plans and procedures to
ensure that they comply with sponsor and IFC requirements. Also as previously noted in the ESAP, the sponsor will develop and implement and project-specific OHS management plans and procedures prior to initiation of operations.

Resource Efficiency and GHG Emissions



The release of Green House Gas (GHG) emissions during construction phase is estimated to be 27,803.65 tonnes CO2-Equivalent (CO2-eq) based on certain assumptions about the use of earth moving and construction equipment in the construction areas (such as crawler crane, hydraulic crane, excavators, and trucks) as well as transport logistics for delivery of the project equipment (such as trucks and barges). Construction phase GHG emissions are not considered significant and can be managed through routine preventive maintenance of machines and engines to ensure combustion efficiency.



The project design consists of combined cycle gas turbine (CCGT) technology which is considered the most efficient option in terms of fossil fuel energy conversion efficiency due to the lower carbon intensity of natural gas (when compared with other fossil fuels) as well as the use of waste heat to generate additional power in the combined cycle mode. The overall approximate efficiency rating is expected to be about 54.5% net of the fuel’s Lower Heating Value (LHV). The greenhouse gas (“GHG”) emissions are expected to be approximately 350 g CO2-eq /kWh with a total direct annual GHG emission of approximately 731,000 tonnes CO2-eq. Based on the high efficiency of the selected technology, no additional GHG reduction measures are required during the operational phase.



Air Emissions and Ambient Air Quality



The ESIA includes an evaluation of potential impacts to air quality during the construction and operating phases. The most significant construction activities with potential air quality impact is fugitive dust emissions from the power plant site including excavation and filling, materials handling, vehicle movement on the haul roads and wind erosion of open stockpile area or open bare ground as well as combustion source emissions from vehicle movement and non-road machineries. The most significant operational phase air quality impact is power plant stack emissions due to combustion of natural gas during the operation of the project. The assessment of the potential construction air quality impacts focussed within the Area of Influence (AoI) which is generally defined as 500m area from the project site boundary as the impact is localized. For the impact assessment of stack emission, the AoI was extended to 10km area from the project site boundary.



The ESIA included a detailed evaluation of background air quality, particularly due to the presence of an operating steel mill, which is also presently undergoing expansion construction activities, as well as an operating 95MW natural gas fired reciprocating engine power plant, both of which are located adjacent to the proposed project site. Background air quality was measured for nitrogen dioxide (NO2), sulphur dioxide (SO2), and particulate matters (PM) including respirable suspended particulates (PM10) and fine suspended particulates (PM2.5) at five selected baseline
air sampling locations for seven consecutive days each month from July 2014 to June 2015 using portable testing equipment. Average background concentrations are consistent with those of a degraded airshed due to the presence of annual average NO2 levels of 54 µg/m3, considered to be significantly above the World Health Organization (WHO) Ambient Air Quality Guidelines (AAQG) of 40µg/m3. Background levels of PM10 and PM2.5 were also high at approximately 43µg/m3 and 26µg/m3 respectively, or about 60% and 70% of the ambient air quality headroom for these parameters. Construction activities will temporarily contribute to increased levels of dust.



The project consists of two sets of gas turbine generating units, two sets of heat recovery steam generator (HRSG) and one steam turbine generating unit with associated auxiliary equipment. The project will be designed to operate continuously throughout the year in either simple cycle or combine cycle mode. Each gas turbine is equipped with one bypass stack for simple cycle mode and one main stack for combined cycle mode. Potential incremental impacts from operating activities were evaluated through the use of predictive models (AERMOD). Modeling results indicate that under both operating modes the project will have a small additional contribution to background NO2 during the operational phase. The highest project contribution at the air sensitive receivers (ASRs) is about 1.56% (1-hour averaged NO2) under simple cycle mode and 11.07% (1-hr averaged NO2) and 4.35% (annual averaged NO2) under combined cycle operation. The project will minimize its contribution to background air quality through the use of dry low-NOx burners and by maintaining NOx emission levels of 25ppm at the stack, consistent with WBG EHS Guidelines for Thermal Power Plants (2008).



Going forward, as described in the ESAP, the sponsor will require the EPC contractor to implement a construction phase dust management plan, including dust suppression measures and good site practices at the construction worksites.



Wastewater Discharges and Runoff



According to the ESIA, anticipated sources of wastewater during the construction phase include workers’ accommodation camps (i.e. sanitary wastewater, effluents from canteen kitchens, including that from basins, sinks and floor drains), effluents from washing of equipment, machinery, and the concrete batching plant, and storm water runoff from storage of equipment, lubricating oils, and fuel. Of these streams the most significant by volume is considered to be sanitary wastewater which will be generated at an estimated rate of 48,000 liter/day (assuming an conservative average construction worker camp population of 600).



Wastewater discharge options described in the ESIA include wastewater treatment systems and/or properly designed and maintained septic systems for sanitary wastewater; settlement tanks and oil/water separators to remove solids and oil from storm water run
off from bunded areas; erosion prevention and control for construction site runoff including for openly stored construction materials or construction wastes; and use of grease traps for wastewater from canteen kitchens prior to discharge to sanitary treatment or reuse as greywater, among others.



The ESIA indicates that during the operational phase the most significant source of emissions will be the power plant’s closed circuit cooling systems blowdown which will generate approximately 70.5 m3/hr of cooling water discharge, followed by sanitary wastewater from operations (from an estimated workforce of 48 employees). According to the updated ESIA, cooling tower blowdown water will be disposed into the Ayeyarwady River instead of a nearby agricultural irrigation canals as initially planned. As part of the decision to change the discharge point, a supplemental study conducted by an independent environmental consultant concluded that this discharge into the Ayeyarwady River would have a negligible impact on water quality as the Ayeyarwady River has an estimated dry season low flow of 64 m3/s while the volume of cooling water discharge is about 0.02 m3/s, or less than 0.5% of the volume of the river during the dry season. Water quality will be monitored upstream and downstream of the discharge point in the Ayeyarwady River at Seik-Nyan every quarter for the life of the project. For these reasons, IFC considers this change in design acceptable from an environmental and social point of view. Prior to discharge, effluents will be treated according to the applicable WBG EHS Guidelines for Thermal Power Plants (2008), for temperature, residual chlorine, suspended solids, and other applicable parameters. Sanitary wastes will treated with properly designed and maintained package sanitary waste treatment system.



Going forward, as noted in the ESAP, the sponsor will ensure that wastewater discharge from construction and operational activities meets applicable World Bank Group (WBG) General EHS Guideline values including those applicable to sanitary wastewater, oily runoff, and cooling water blowdown.



Noise



The ESIA included an assessment of potential impacts due to construction and operational phase noise. The ESIA identified the main sources of noise during construction to include use of powered mechanical equipment; site preparation, pile driving and foundation works; installation of equipment; and construction of the infrastructure such as internal access roads, storm water drains and security fence. The sources of noise associated with the operation of the power plant are expected to include the heat recovery steam generators (HRSG), gas turbines, steam turbine and cooling tower. The key assumption for the noise assessment is that construction activities will take place during daytime hours while operation of the power plant will be generally 24 hours per day throughout the year.



The assessment identified the nearest noise sensitive receivers (NSRs) which included a permanent steel mill construction worker (EPC) accommodation in Taung Tha Township (approximately 1890 m to the south of the project site); a monastery and pagoda in Taung Tha Township (approximately 2400 m to the south); Hnan Ywa Village in Taung Tha Township (approximately 1960 m to the south-east); and Sa Ka Village in Myingyan Township (approximately 980 m to the north-east). Baseline noise monitoring was conducted continuously at the four NSRs from July to September 2014 and from February to June 2015. Hourly A-weighted equivalent continuous sound pressure levels (LAeq, 1 hour) were recorded continuously over 24 hours at each location during both weekday and weekend periods. Average background noise levels were found to be already near or above the W
BG EHS Guidelines values for daytime noise levels (between 54 and 59dB(A), above the 55dB(A) guideline applicable from 0700 hrs to 2200 hrs) and above night-time guideline levels (between 50 and 55dB(A), above the 45db(A) guideline applicable from 2200 hrs to 0700 hrs).



Potential impacts from incremental noise during construction and operation were evaluated with a noise propagation model (SoundPLAN) which generates noise contours based on assumed noise emissions levels of construction equipment and activities and operating equipment to provide an overall view of the predicted noise levels around the project Site. Increased noise at the nearest NSR during construction activities was estimated to be above the applicable daytime guideline of 55dB(A) and between 1 and 6dB(A) above background. Operational phase noise levels are estimated not to result in increased background noise at three of the four nearest NSR, with a 1dB(A) increase in one of the NSRs. Based on these results, the ESIA recommends the use of active noise mitigation measures during the construction phase, in order to address the maximum increase of 3dB(A) in background levels at the identified representative NSRs (WBG EHS Guidelines) but not during the operational phase.



Going forward, as described in the ESAP, the sponsor will required the EPC contractor to develop and implement a construction phase noise management plan which incorporates direct noise mitigation such as movable noise barriers.



Hazardous and Non-Hazardous Waste Management



The ESIA describes a range of waste materials that will be generated during the construction phase during daily activities of the construction workforce (e.g. generation of putrescible waste) as well as a range of general construction waste such as concrete, steel pipes, plastic pipes, steel plates, structural steel and wooden crates during the civil works phase of construction. While most of these are likely to be non-hazardous, some of these may be hazardous include used paint, engine oils, hydraulic fluids, spent solvents, spent batteries, and other potentially hazardous materials generated from construction equipment maintenance and repair. Similar types of hazardous and non-hazardous wastes will be generated during the operational phase.



Going forward, as described in the ESAP, the sponsor will require the EPC contractors to develop and implement a construction phase hazardous and non-hazardous solid waste management program that is consistent with local and IFC requirements. All the hazardous wastes will be segregated prior to the collection by an accredited treatment, storage, and disposal facility in Myanmar or externally. The primary hazardous waste during operations will 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 filters; 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. Separated waste oils, separated transformer oil and sludge will all be collected in dedicated sumps for recycling disposal through an authorized entity. The Company will undertake duty of care procedures to assess the adequacy of the hazardous waste treatment and disposal facility.



Hazardous Materials



Hazardous materials that are stored at site during construction and operation include: liquid fuel (diesel), gas cylinders, hydrochloric acid, sulfuric acid, caustic soda, sodium hypochlorite/chlorine, solvents, lubricating oils, transformer oil and other chemicals. The sponsor will require the EPC contractor to put in place procedures for appropriate storage of hazardous materials, including appropriate segregation, labeling, storage based on compatibility assessment, where required provision of secondary containment, corrosion resistant lining as required and access control.

Community Health and Safety



Project construction activities will include civil works for the power plant site as well as short term construction of the cooling water intake systems and electricity transmission line components. The EPC Contractor will mitigate the risk of accidents for the general public during construction through measures such as: access control, barricading, reflectors, signage, community safety awareness programs, posting of traffic marshal, equipment back up alarms, proper securing of material while moving them from one place to another, planning material movement to cause minimum disruption, 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, implementing driver safety management and training requirements for the transport of people and materials.



The Company will also require the EPC contractor to prepare a detailed traffic and transport management plan including such elements as: implementation of a personnel and materials movement plan which takes daily life and traffic patterns into account; periodical monitoring of noise levels at community sensitive receptor points.



Ecosystem Services



The project will require raw water intake from the Ayeyarwady River for several processes during the operational phase including make up water for cooling towers, demineralized water system, service water system, and potable water system. The ESIA evaluated potential impacts from this water withdrawal on uses and users of the Ayeyarwady River primarily on upstream and downstream agricultural water users (irrigation intakes) and on downstream fishing activities. Water demand during the operational phase will be on average approximately 0.12 m3/s (405 m3/hr, with a maximum requirement 0.13 m3/s and a minimum of 0.028 m3/s). The Ayeyarwady River has an estimated dry season low flow of 64 m3/s, and thus maximum project water demand is less than 1% of the lowest dry season flow in the southern channel of the river. Additionally, the cooling water intake system with will be designed with a maximum through-screen velocity of 0.15 m/s. Therefore the ESIA concluded that the risk to water uses and users is negligible.



Community Exposure to Disease



Since significant influx of labor is expected during the construction phase and a labor camp is proposed at the site, the project will require the EPC contractor to implement a management plan that will include: ensuring that appropriate medical facilities are available for all labor; a periodic health checkup program is in place; an awareness program on STI and HIV/AIDS; and measures to control disease vectors. Refer to the ESAP.



Emergency Preparedness and Response



The sponsor will require the EPC contractor have in place an Emergency Preparedness and Response plan (“ERP”) as previously described in this summary. Additionally, the s
ponsor is presently undertaking a quantitative risk assessment (“QRA”) to evaluate worst case effects in case of fire or explosion due to the use of natural gas at the proposed project site. Based on the QRA findings, the Company will implement measures to ensure that societal risk meets applicable norms. The Company will also expand the emergency response plan for operations phase to cover offsite emergencies. The Company will coordinate its emergency procedures also with emergency plans of neighboring facilities during operations. The EPC contractor and O&M contractor will be required to undertake mock drills as per a schedule. The Company will ensure that critical components of the emergency plan are tested on a regular basis including full scale emergency training exercises at least every year including jointly with authorities.



Security Personnel



The sponsor plans to deploy unarmed security personnel at its facilities in the future as well as required EPC contractors to do the same. Should armed security be deemed necessary either by the sponsor or the EPC contractor, the decision to arm will be based on a prior evaluation of security risks. Additionally, the sponsor will be required to develop and implement security management systems including formal procedures for reporting, responding to and documenting security incidents; training requirements; review of security record of potential security contractors including: review past records of private security personnel deployed; training on objectives and permissible actions for security personnel; training of security personnel in avoidance of abusive conduct and handling various situations with clear procedures. In the event that armed security is deemed necessary, the Company will put in place procedures such that bona fide complaints against security personnel are investigated and disciplinary actions implemented.

Community Engagement

Stakeholder Engagement Plan, Information Disclosure, and Consultation

The project’s community engagement activities have materialized mainly during three rounds of local stakeholder consultation activities during the period June to September 2015 as part of the project’s ESIA process. These activities included identification of key stakeholders, communication of key anticipated project E&S impacts and planned mitigations to identified stakeholders, discussing key facets of the community grievance mechanisms to be implemented, and collection of participants’ feedback on such disclosed information. At these consultative sessions, community members expressed overall support for the project, and inquired about employment opportunities, plans to improve local infrastructure, and potential project impacts such as those related to air quality and noise.

Grievance Mechanisms

The Group Community Grievance Management Policy policy document of Sembcorp refers to the establishment of facility outreach programs with a goal of assessing community concerns, and (as a means) for a continuing dialogue with the local community to respond to concerns about safety, health, and environmental issues. The company has also developed the following policies at the group level: Community grievance management policy; and Stakeholder and community engagement policy.

Ongoing Reporting to Affected Communities

The Company states that it seeks to promote local development and license to operate in the project area and is thus committed to working with members of local communities identified as project stakeholders to improve their livelihoods and facilitate access to project-related employment opportunities for them where possible (prioritizing affected households to the extent feasible). To this end, it will put in place a community development and outreach program, which will include clearly defined objectives, result measurement indicators, activities, resource allocation, and assigned personnel responsible for its implementation. The outreach component of the program will include: (i) accessible mechanisms for local stakeholders to provide feedback and voice concerns (if any) to the Company over the life of the project; and (ii) mechanisms to appropriately disclose project related information to communities on an ongoing basis (e.g. a summary of quarterly project monitoring results) during construction and operation. The entire program will be communicated to project affected local communities, so that they are well aware of its existence and content, and can also easily access the grievance mechanisms built into the program as well as the ongoing public reporting component. Refer to the ESAP for details.

The project ESIA will be available in English and the Executive Summary to the ESIA, which includes details about potential E&S impacts and mitigation measures, will be available in English and Burmese for public review at:

No. 10 Bo Yar Zar Street, Kyaukkone
Yankin Township
Yangon, Myanmar

Inquiries and comments about the project may be directed to:

Contact Details:

Name: Aung Lwin Oo
Email Address: mailto:alo.mdy70@gmail.com

Broad Community Support is not applicable for this project

Title	Anticipated completion Date
Develop and implement construction phase E&S Management Program (ESMP) consistent with ESIA recommendation and IFC requirements and which includes: • Dust Management Plan; • Traffic Safety Management Plan; • Noise and Vibration Management Plan; • Surface Water Management Plan; • Soil and Groundwater Management Plan; • Waste Management Plan (Hazardous and non-Hazardous Waste); • Oil and Chemical Spill Contingency Management Plan; • Emergency Response Plan (including Community Emergency Response Plan); • Stakeholder Engagement Plan (including Grievance Management Plan); • Community Development Plan (CDP); • Community Health Management Plan; • Occupational Health and Safety Management Plan; • Workers’ Accommodation Management Plan; • Local Recruitment and Procurement Plan; • Influx Management Plan; • Cultural Heritage Chance Find Procedure; • Security Plan; and • Contractor Management Plan	03/15/2016
The sponsor will also complement the EPC HSE construction requirements to include the aforementioned aspects.	03/15/2016
Develop and implement Operational Phase E&S Management Program (ESMP) consistent with the outcomes of the ESIA, local legal requirements, and IFC PS requirements. The ESMP will cover applicable environmental, occupational health and safety, community health and safety, and social management aspects.	09/15/2018
Assign a dedicated technically qualified construction phase ESHS management team comprised of a Head and supported by its own ESHS coordinators.	03/15/2016
Prior to the start of operations, define an ESHS organizational structure comprised of a Head of ESHS with supporting OHS and community affairs coordinators who will be fully responsible for implementation of the operational phase ESMP.	09/15/2018
Expand scope of construction phase Emergency Preparedness & Response (EPR) plans mentioned in the EPC contract to include all emergency scenarios including but not limited to emergencies arising from occupational accidents, accidents involving the public, health related emergencies, and from natural hazards.	03/15/2016
Develop and implement an operational phase EPR Plan prior to commencing of testing and operational activities based on the outcome of the detailed quantitative risk assessment and after finalization of project design. The EPR Plan will define protocols to be followed in the event of emergencies or disasters; address both on-site and off-site emergency situations; disclose potential disasters/risks from the plant to the local community as well as the plan of action on emergency protocol in the event of any such eventuality. It will also include awareness programs for the Plant personnel, local community and local administration.	09/15/2018
Develop and implement a detailed, project specific monitoring and reporting program with monitoring measures applicable to each of the relevant management plans.	03/15/2016
Monitoring and reporting activities will be reviewed by an independent E&S consultant on a semi-annual basis during construction and annually thereafter for the first year of operation. A summary monitoring report will be disclosed to local communities semi-annually during construction and annually during first year of operation.	09/15/2019
Develop and implement a community development and stakeholder engagement program - to include clearly defined objectives, stakeholder identification and analysis, performance indicators, activities, resource allocation, assigned implementation personnel, grievance mechanisms for local stakeholders, and mechanisms to appropriately disclose project related information to communities on an ongoing basis. The program will be communicated to project affected local communities on an ongoing basis, so that they are well aware of its existence and can also easily access the grievance mechanisms.	03/15/2016
Ensure relevant parts of project HR policies and procedures cover labor practices of contractors and sub-contractors.	03/15/2016
During construction, regularly monitor the labor practices of contractors and sub-contractors (e.g. non-use of child/forced labor) against a checklist to ensure compliance with national labor laws and regulations.	03/15/2017
Ensure that the housing provided by contractors/sub-contractors to their workers meets standards required by the company as specified in the project HSE Plan and in IFC PS2, and are also consistent with principles of non-discrimination and equal opportunity.	03/15/2016
Ensure that wastewater discharge from construction and operational activities meets applicable World Bank Group (WBG) General EHS Guideline values including those applicable to sanitary wastewater, oily runoff, and cooling water blowdown. c	03/15/2017
Mitigate traffic related accident risks during construction through measures such as: access control, barricading, reflectors, signage, community safety awareness programs, posting of traffic marshal, equipment back up alarms, proper securing of material while moving them from one place to another, planning material movement to cause minimum disruption, 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, implementing driver safety management and training requirements for the transport of people and materials. Require the EPC contractor to prepare a detailed traffic and transport management plan including such elements as: implementation of a personnel and materials movement plan which takes daily life and traffic patterns into account; periodical monitoring of noise levels at community sensitive receptor points.	03/15/2016
Require EPC contractor to implement a management plan that will include: ensuring that appropriate medical facilities are available for all labor; a periodic health checkup program is in place; an awareness program on STI and HIV/AIDS; and measures to control disease vectors.	03/15/2016
Develop a resettlement framework with a set of project-level PS5 compliant procedures on land acquisition and involuntary resettlement which will be applied to all ongoing, and future land acquisition related activities should they occur.	03/15/2016
Proactively work with MEPE during the river water supply pipeline and T-line RoW land acquisition process.	03/15/2016
Demonstrate that the outcome and process of land acquisition are consistent with PS5 requirements.	09/15/2018