While all Performance Standards are applicable to this investment, IFC’s 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

 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

 Land required for the power plant is under the possession of the Company and was acquired by BPDB back in 1997-98. 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 access to ecosystem services.  Necessary land for supporting infrastructure such as access road, transmission line, natural gas pipeline, fuel unloading facility, fuel storage tank farm is already within the existing power hub. Additional temporary land requirements during construction stage will include laydown areas and construction camps will be met through leasing from BPDB and which will not result in any physical or economic displacement. PS5: Land Acquisition and Involuntary Resettlement will therefore be not applicable to the Project. 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 which consists of historically modified habitat with no biodiversity values nor adverse impacts on biodiversity and natural resources. The Project and its activities will not impact indigenous people (IP) or community as no tribal land is being taken for the development of the Project and its associated utilities and no IPs inhabit the project area. PS7: Indigenous Peoples is therefore not considered applicable to the Project. PS8: Cultural Heritage is not applicable as the Project is not located in areas of known historical or cultural significance.

 The Project has been classified a Category A as defined in IFC’s Policy on Environmental and Social (E&S) Sustainability.  Key E&S risks and impacts include: (i) permanent cumulative impacts on ambient air quality, noise, and water discharges levels due to existing power plants  and proposed power projects as well as a number of operational industrial units within Meghnaghat north and Meghnaghat south industrial areas; (ii) potential impacts  on nearby communities due to influx of construction labor (expected to be in the range of 800); and (iii) operational occupational health and safety issues, risks due to transport, storage and handling of highly flammable chemicals as well as toxic chemicals.

IFC’s appraisal considered the environmental and social management planning process and documentation for the Project and gaps, if any, between these and IFC’s 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 implementation of these measures, the Project is expected to be designed and operated in accordance with Performance Standards objectives.

IFC’s appraisal considered the environmental and social management planning process and documentation for the Project and gaps, if any, between these and IFC’s 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 implementation of these measures, the Project is expected to be designed and operated in accordance with Performance Standards objectives.

Environmental and Social Assessment and Management System

Management System: 

SCL has in place a board approved formal documented environmental and social management system (ESMS) at the corporate level which would also be applicable for the proposed project. The corporate ESMS includes procedures for all project phases such as: project conceptualization, planning & design, construction, operation and decommissioning and has been developed in accordance with the requirements of national E&S regulations; IFC PSs; and the applicable provisions of the World Bank Group (WBG) Environment, Health and Safety (EHS) General Guidelines 2007 as also the Thermal Power Plant EHS Guidelines, 2008. The ESMS includes detailed procedures for: (i) project planning and design; (ii) site selection and analysis of alternatives; (iii) identification and assessment of E&S risks and impacts through PS compliant third party ESIAs; (iv) development of E&S mitigation measures and management plans in compliance with IFC PS; (v) ongoing monitoring, reporting and management review of E&S performance; (vi) construction worker accommodation guidelines; (vii) onsite and offsite emergency response procedures; and (viii) stakeholder engagement and a community grievance mechanism. 

The Company plans to obtain certification for ISO 9001: 2008 - Quality Management System; ISO 14001: 2004 - Environmental Management System and OHSAS18001: 2007 – Occupational Health and Safety.

Policy:

SCL has in place an Environment, Health, Safety and Social (EHSS) Policy consistent with the IFC PSs and the policy framework covers among other aspects: compliance with local laws; resource efficiency and adherence to good international practices; occupational health and safety for employees and contract workers; addressing impacts on affected communities; and assessing and managing adverse environmental and social impacts. This group level policy will also apply to the project company. 

Assessment: 

The Company commissioned a third-party consultancy, Environmental Resources Management (ERM), to undertake an Environmental and Social Impact Assessment (ESIA) (including risk assessment) in accordance with international standards including IFC Performance Standards (PS, 2012) requirements. As a part of ESIA, baseline studies and data collection as well as stakeholder consultations have been carried out and documented. The ESIA has identified key environmental and social impacts, and the corresponding mitigation measures, associated with the Project’s construction and operation phase. 

As part of the ESIA. baseline surveys covering ambient air quality, soil and sediment quality, water quality (surface and ground), noise quality, traffic (road and river), ecological and aquatic ecology was carried out between November 2017 to January 2018. Aquatic ecological study was conducted by sampling at six locations (upstream and downstream of intake and outfall points). It was observed that most of the fresh water species reported in the Meghna River are resident species and spawning grounds of fresh water prawns and other small indigenous fishes in the study area are located upstream of Meghna River. None of the fish species reported are IUCN red list critically endangered, endangered or vulnerable species. 

The ESIA identified key E&S impacts likely to be generated during the project construction including, for example: generation of noise and dust from construction activities and from operation of machinery, increased traffic on access roads, surface runoff, generation of sanitary waste and solid waste, occupational health and safety risks, and community health and safety impacts due to increased traffic, dust, noise, 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 E&S management plans, as well as in the EPC contractors’ contracts (refer ESAP action#3).

The ESIA also identified key E&S impacts likely to be generated during the project operation including, for example: impacts to air quality due to stack emissions from the combustion of RLNG during combined cycle operation (mainly NOx emissions); effluent discharge; noise associated with the operation of the power plant;; generation of various types of non-hazardous and hazardous wastes from plant O&M activities; community health and safety mainly associated with the unlikely event of a natural gas leak; among others.  The ESIA includes an assessment of cumulative impacts on ambient air quality and noise levels and which considered existing projects and other planned developments within the immediate project area (details as provided in project description section). 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 (refer ESAP item#4).

This ESIA will also be used for obtaining regulatory clearances for the Project. The Company plans to obtain applicable clearances, permits, consents, authorization and regulatory approvals under the relevant legislation prior to commencement of operations. The Company will ensure that its operations, comply with applicable Bangladeshi laws/legislations and IFC Performance Standards (PS). 

Organizational Capacity and Competency:

The corporate EHS department of SCL is staffed with four (4) full time personnel covering aspects of EHS and social/community relations.  This team is supported by local E&S consultants for non-routine activities such as for undertaking assessments specifically required by regulatory authorities or for meeting the E&S requirements of lenders. In addition to the corporate EHS capacity, all individual power companies under SCL have their own EHS staff for management of E&S issues on an ongoing basis. In accordance with the requirements of the corporate ESMS, the project company will ensure proper execution of the ESMP by assigning dedicated technically qualified construction phase EHSS management team and putting in place an appropriate EHS organization (ESAP item#1), with clearly defined roles and responsibilities for both construction and operation phases. Further, as per the requirement laid out in the ESMS, the Company will require the Engineering, Procurement and Construction (EPC) contractors to deploy appropriately qualified EHS staff to manage EHS aspects on an ongoing basis and require the EPC contractor to report on EHS performance periodically. The EPC contract will include E&S clauses as recommended in the corporate ESMS. 

Management Programs:

The Company will contractually require that the EPC contractor  develop a HSE plan (in line with the corporate ESMS) prior to start of construction and implement the same (ESAP item#2). The HSE plan will include the following amongst others: (i) management system for HSE implementation; (ii) organisation structure for HSE implementation; (iii) training and capacity building of its own staff and sub-contractor staff; (iv) emergency preparedness and response system; (v) monitoring and review of the HSE implementation system; (v) reporting; (vi) stakeholder engagement; and (vii) grievance redressal mechanism. 

The ESIA includes an Environmental and Social Management and Monitoring Plan (ESMMP) for the Project, covering pre-construction, construction and operation phases and also includes framework management plans for the construction phase, including on: a) Occupational Health and Safety; b) traffic management; c) waste management; d) pollution prevention; e) construction labour management; f) emergency preparedness and response (both onsite and offsite emergencies); g) stakeholder engagement; and h) grievance redressal plan. As included in ESAP item#3, the Company will contractually ensure that the EPC contractor develops detail management plans using framework management plans as reference (included as part of the ESIA) prior to start of construction. 

As per the corporate ESMS and is being followed by the Sponsor, the Company will contractually require the EPC contractor to abide with the HSE requirements and to adhere to applicable social and environmental legal/national requirements and fully implement EHS measures defined in the project ESIA and ESMMP.

Key roles and responsibilities of the Company and EPC contractor have been defined in the ESMMP for implementation and monitoring of environmental and social impacts. 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. 

Going forward, the Company will further develop and implement a full set of operational phase EHSS management plans prior to start of commercial operations that are consistent with the local legal requirement and IFC PS requirements (ESAP item#4).

Emergency Preparedness and Response:

As described in the ESAP (ESAP item#2), the Company will contractually require that the EPC contractor establishes and maintains an emergency preparedness and response (ERP) plan prior to start of construction and as per the format provided in the corporate ESMS so that they will be prepared to respond to accidental and emergency situations associated with the Project in a manner appropriate to prevent and mitigate any harm to people and/or the environment.

Additionally, as part of ESAP item#4, the Company will develop an operational phase EPR Plan prior to commencing of testing and operational activities. 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 ESMMP 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 and includes details on sampling locations, frequency of measurements and responsibilities for implementation. During the construction phase, the EPC contractor will undertake internal reporting of the EHS management. 

SCL’s corporate ESMS recommends internal monitoring and audits of all its projects. The corporate EHS team undertakes quarterly audits and develops a corrective action plan based on the audit findings. As included in ESAP item#5, the Company will undertake quarterly third party audits during construction phase and bi-annual third party audits for the first two years of operations against local permit conditions and regulatory requirements and against applicable aspects of IFC Performance Standards and WBG EHS Guidelines.  During the construction phase, the audits will monitor and verify EPC contractor and subcontractor compliance with EPC contract provisions covering aspects of construction phase environmental mitigation measures, compliance with labor laws, working conditions and terms of employment, occupational health and safety prevention and control, and other applicable project E&S requirements (ESAP item#5). 

Environmental monitoring during the operation phase will be aligned with the permit requirements and will be undertaken for ambient air quality, stack emissions, ambient noise levels and wastewater quality. In addition, there will be reporting on standard safety related key performance indicators (KPIs) such as (lost time accidents, recordable injury, first aid cases, etc.) and safety inspections will be done on a monthly basis. 

As per the Company protocol, there will be a monitoring mechanism which would include submission of monthly report on performance to the corporate office (including a section on EHS covering aspects on emergency preparedness, housekeeping, OHS and EMS, other safety information (including safety statistics), ambient air quality (SPM, SOx and NOx) and stack emissions). Quarterly management review meetings during construction phase will be conducted at corporate level to track progress of the plant and monitor whether the QHSE targets/ objectives are being met or not.

The construction workforce for this Project is expected to average 600 persons per day, reaching a peak of 800 person per day at the height of construction activities. During the Project’s operational phase, headcount is expected to be between 60-75.

Human Resources Policies and Procedures:

SCL has in place an employment policy which is applicable to all its probationary and full time employees. The policy covers general terms and conditions of services including appointment procedure, probation period, confirmation of service, promotion, retirement, employee’s code of conduct, pay scale, other financial benefits, transfer and change of designation. SCL has also developed documents pertaining to job categorization, leave policy, bonus policy, office timings, policy on non-employment of adolescent & child at work, anti-discrimination policy, anti- harassment & abuse at work policy, performance appraisal policy, anti-bribery & corruption policy, whistle blower policy. This HR policy is adopted by all group companies and will be adopted by the project company. The HR hand book is provided to all the direct employees at the time of their joining while the contractors and vendors are managed through their respective HR policies. In addition, SCL has developed additional policies and procedures on equal opportunity and non-discrimination, prevention of forced labor and prevention of sexual harassment. As included in ESAP item#6, the Company will ensure that its EPC and Operation and Maintenance (O&M) contractors have HR policies and procedures that meet the requirements of relevant national laws and IFC PS2. The Company will monitor the labor practices of contractors and sub-contractors through quarterly third party audits for ensuring 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) as part of ESAP item#5. 

Working Conditions and Terms of Employment:

The construction phase of the Project is expected to last around 30 months during which a significant amount (around 30-40 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 accommodations camp area identified by the EPC contractor. As included in ESAP item#7, the Company will contractually ensure that the EPC contractor provides accommodation, transportation, and basic services including water, cooking fuel, sanitation, and medical care for the workers working at site, in accordance with PS 2 requirements and as has been included in the corporate ESMS under requirements for labour accommodation and which will be further verified as part of EHSS audit to be carried out (ESAP item#5).

The employment policy of SCL defines employee pay scales and the gross salary which includes house rent allowances, conveyance allowances, medical allowance, special allowance, and festival bonus. Employees are entitled to paid sick leave, casual leave and annual leave. The HR department reviews these allowances once a year to check adequacy and suitability and adjusts/ implements review updates accordingly. The direct employees are provided with appointment letter describing the terms of employment. 

As included in ESAP item#1, the Company will put in place an appropriate EHS organization with clearly defined roles and responsibilities for management of EHS and social/labour aspects. The EHS team will also be responsible to review and monitor the performance of EPC contractor  especially with respect to working conditions, workers’ accommodation, OHS and protection of work force (as has been included as part of the corporate ESMS). 

Workers’ Organization:

The Bangladesh Labour Act, 2006 describes the rights of workers to form and join labor unions, and the right of labor unions to collective bargaining with employers.  The corporate HR policy of Sponsor however has no mention of right of worker to form union and collective bargaining system. There is no existing workers’ union at any of the assets of SCL although the site management has at plant level, neither formally nor informally, restricted formation of labor unions. As included in ESAP item#8, the Company will update its HR policy and include the provision for right of workers to form and join labor unions and right of labor unions for collective bargaining.  

Non-discrimination and Equal Opportunity:

SCL has developed an anti-discrimination policy as the part of their HR policy which clearly states the company’s commitment against discrimination based on sex, gender, parental status, age, race, religion etc. SCL has also adopted a policy on anti-harassment and abuse at work which states that any reports of unfair discrimination or harassment will be treated seriously and appropriate actions will be taken. The Company shall ensure that the principles of non-discrimination and equal opportunity are followed by the EPC contractor as well while engaging local subcontractor or contract workers (as included in ESAP item# 6) and including the requirement to develop detailed Code of Conduct for construction workers to avoid or minimize risks and negative impacts that may be a consequence of interaction with the local population in the Project’s area of influence including code of conduct related to prevention of gender based violence and child abuse. 

Grievance Mechanism:

At the corporate level, there is a formal three-tier grievance redress mechanism (GRM) to address employee grievances. Employees are required to report their grievances verbally or in writing to their immediate managers, which is the first level where action is required to be taken within five working days of receiving the complaint. In case of unresolved grievances, the employee can escalate the issue to the next two levels i.e. Departmental Head and Managing Director/ Executive Director. As a part of the corporate ESMS, grievance redressal framework has been developed based on the existing mechanism and also includes the format for reporting grievance and includes the requirement of developing site-specific grievance management mechanism.  As indicated in ESAP item #8, the Company will develop and implement formal employee grievance mechanisms in line with ESMS and PS2 provisions which will be accessible to all workers. With respect to its EPC and other contractors, the Company will ensure that a formal grievance mechanism is accessible to all workers and subcontractors (ESAP item#3). The implementation and effectiveness of the grievance mechanism will be monitored by the Company through third party EHSS audits during the construction and operation phases (refer ESAP item#5). 

Protecting the Work Force:

SCL has a policy on prevention of child labor and forced labour and will contractually ensure that EPC contractor also implements the same as stated in ESAP item#6.

Occupational Health and Safety:

SCL has EHSS policy in place committing to ensure a healthy and safe work environment to employees. Like other group companies of SCL, the project company will also outline objectives to achieve zero occurrences of the accidents, lost time, and ill health due to occupation related activities. Potential hazards will be identified and maintained under facility risk assessment form and job risk assessment form as is done for other group companies of SCL. 

The Company will in the O&M phase address OHS aspects under the OHSAS 18001 certified OHS management system it proposes to implement, which will also incorporate GIIP on occupational health and safety. Workplace inspection will be regularly carried out on a monthly basis to assess OHS aspects related to training, work processes, machine guarding, tools and machinery, confined spaces, housekeeping, elevating devices, sound/ noise level, first aid facilities, PPE, materials handling and storage amongst other aspects. 

Workers Engaged by Third Parties:

The third party EHSS audit (ESAP item#5) will also check compliance of the EPC contractor and its subcontractors with applicable statutory requirements especially those related to payment of minimum wages and overtime, PS2 and IFC’s labor and OHS standards; consistency of worker accommodation with IFC guidance on worker accommodation and implementation of grievance mechanism and in accordance with PS2 provisions.

Resource Efficiency and GHG Emissions:

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. HSD will be used only as a back-up fuel. The greenhouse gas (“GHG”) emissions are expected to be approximately 333 g CO2-eq /kWh with a total direct annual GHG emission of approximately 17,39,969 tonnes CO2-eq. 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. The water system is a close circuit system and water will be reused in the cooling towers. This will help in reducing the total water consumption as against a once-through system, which requires a lot more water. The Company plans to implement a program to monitor water consumption, and identify and harness conservation and efficiency opportunities. 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. 

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 will be fugitive dust emissions from the power plant site including excavation and filling, materials handling, emissions from vehicle movement and non-road machineries. The most significant operational phase air quality impact will be power plant stack emissions due to combustion of natural gas and HSD (to be used only incase of interruptions in gas supply) during the operation of the Project. 

The ESIA included a detailed evaluation of background air quality at eight (8) selected baseline air sampling locations for eight weeks from Dec 2017 to January 2018 using portable testing equipment. The background air quality was measured for Suspended Particulate Matter (SPM), Particulate Matter (PM10 and PM2.5), Oxides of Nitrogen (NOx), Sulfur dioxide (SO2), Carbon Monoxide (CO), and Ozone (O3). Average background concentrations of NOx and SO2 were observed to be within the National Ambient Air Quality Standard (NAAQS) of Bangladesh (average NOx values varying from 25-31 µg/m3 as against the standard of 100 µg/m3). Average background concentrations are consistent with those of a degraded airshed for PM due to the presence of average SPM values exceeding NAAQS of 200 µg/m3 at all locations and with maximum average value of 323 µg/m3 at receptor located 0.65 km from the power hub. The higher PM emissions may be attributed due to construction activities and fugitive emission from road and vehicular emission in the study area and due to operation of five cement plants in the near vicinity. Construction activities will temporarily contribute to increased levels of dust. 

The Project will be designed to operate continuously throughout the year in combined cycle mode.  The operation of the plant with RLNG as fuel in simple and combined cycles will generate flue gas emissions primarily NOx. 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 and PM. Use of HSD as fuel for power generation in the Project will be only in case of interruption in natural gas supply. 

The assessment of cumulative impacts consisted of the evaluation of emissions from the Project as well as existing and proposed potential additional sources of emissions including: (a) RLNG based 750 MW CCPP to be developed by Reliance Power planned to be developed by 2020; and (b) 650 MW coal based power plant at Char Balaki planned to be developed by 2022.  The existing sources of emissions considered already operating 450 MW gas based CCPP) operated by Power Tech, Pendekar; 100 MW HFO based plant operated by Orion Power; 337 MW HSD based CCPP operated by Summit Meghna Power Co. Ltd. and five cement plants located in the industrial zone. Potential incremental impacts from existing and proposed projects were evaluated through the use of predictive models (AERMOD). Modeling results indicate that even for worst case scenario, the Ground Level Concentration (GLC) of NOx and SO2 will continue to remain much below the NAAQS from the cumulative effect of all these sources while GLC of PM 10   emissions will exceed the NAAQS (total GLC for annual PM 10   emissions are predicted to be 56.7 µg/m3 as against the standard of 50 µg/m3 and 24 hour PM 10   values are predicted to be 378 µg/m3 as against the standard of 150 µg/m3). The high GLC for PM 10   is due to existing cement plants and contribution by the Project and other proposed plants is minimal. The Project will have a small additional contribution to background NO 2   during the operational phase. The highest project contribution at the air sensitive receivers (ASRs) is about 14.2% (1-hr averaged NO2) and 8.5% (annual averaged NO 2  ) 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 25 ppm at the stack, consistent with WBG EHS Guidelines for Thermal Power Plants (2008). Further to ensure compliance with the air emission criteria for flue gas stacks, Continuous Emission Monitoring (CEM) equipment for the measurement of NOx emission levels in the exhaust stack of HRSG will be installed.  

Water and Wastewater:

The water consumption during the construction phase is expected to be about 800 m3/day, which will be met from the nearby Meghna River. The potable water requirement during the construction phase will be provided by the EPC contractor. During the construction phase, wastewater will be generated from workers’ accommodation camps (i.e. sanitary wastewater and effluents from canteen kitchens), effluents from washing of equipment, machinery, and the concrete batching plant. The contractor will be responsible for ensuring that any wastewater discharged meets the applicable standards 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. 

Approximately 20 m3/hr of treated effluent and about 280 m3/hr (blowdown) will be discharged from the plant to the Meghna River through a buried pipe line of about 0.5 km length. It is to be noted that the discharge will not be continuous (only 3-4 hrs/day) and blow down will be retained at central monitoring basin along with other treated effluent from the plant and will be tested for water quality including temperature before discharge into the Meghna River. This discharge will be having about <3°C of intake water temperature at the outlet and discharge parameters will be meeting IFC EHS guideline values as being followed at all other plants of the Sponsor. Treated effluent generated from sewage treatment plant will be used within the site for greenbelt development.  

Noise:

The ESIA identified the main sources of noise during construction to be operation of powered mechanical equipment; site preparation, pile driving and foundation works. 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. 

Baseline noise monitoring was conducted at 10 noise sensitive receivers (NSRs) and average background noise levels were found to be marginally exceeding the guideline values both for daytime and night time at residential receptors. Potential impacts from incremental noise during construction and operation were evaluated with a noise propagation model (SoundPLAN). Ambient noise levels due to construction and operation phase of the Project will be within the applicable standard during day and night time at 5 receptors, out of total 10 receptors considered and slightly higher than the applicable standard (with < 5 dBA increase from the applicable standard) at 5 locations. The exceedances are expected due to already higher baseline noise levels during day and night time, whereas predicted noise levels were found to be meeting applicable standards with respect to land use criteria. 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) and noise analysis of all major plant components during commissioning of the plant to ensure compliance with the specification and guaranteed performance as well as ambient noise levels at the receptors located in the nearest village. 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. 

Hazardous and Non-Hazardous Waste Management:

During the construction phase of the Project, domestic wastes consisting of food waste, plastic, glass, aluminum cans and waste packages will be generated by the construction workforce together with concrete waste. 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. 

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 ESMMP includes a Waste Management Plan (WMP) for ensuring proper storage and disposal of all wastes generated during operations. The Company will undertake duty of care procedures to assess the adequacy of the hazardous waste treatment and disposal facility.

Hazardous Materials:

The Company will require 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 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. 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) . An increase in road traffic is expected due to movement of labor and transportation of some construction material during the construction phase. Traffic management plan to be developed by the EPC contractor prior to start of construction (as included in ESAP item#3) will cover aspects as: 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. As part of ESAP, the Company will also implement the stakeholder engagement and grievance redress plan/ process in consultation with the community/stakeholders (ESAP item#9).

Ecosystem Services:

The ESIA identified small-scale subsistence, artisanal fisheries near the projects cooling water discharge location. Consultations were carried out with the fishing community living in Char Balki (riverine island located 1.8 km from the project site), fishermen practicing ‘kata fishing’ (captive or cage fishing) and recreational fisherman. Around 40-50 fishermen families live in Char Balaki and nearly 150 fishermen fish within the 2 km radius. These consultations reveal that fishing activity gets impacted due to waste discharge by the chemical industries located upstream of Meghna River which occurs once or twice a year. Per the ESIA, a small number of these fishermen undertake kata fishing near the area proposed for the jetty. The movement of barges during the construction phase could potentially cause damage to kata fishing gear. 

The ESIA has recommended measures to avoid creating this impact and has recommended that the Project shall as part of its ongoing monitoring periodically monitor fishing activity in consultation with the fishing community and will develop mitigation plans if the monitoring results indicate an impact attributable to the Project. Furthermore, the Project will develop a procedure to compensate fishermen in case of damage to their equipment and/or any spillage (as included in ESAP item#10).  

 The ESIA did not identify other potential impacts associated with the Project such as those related to water intake or discharge or water consumption and the fishing communities also did not consider these to be potential risks to their activities, based on the consultation. 

During the operations phase, the Project will operate a closed-loop cooling water system and make-up water will be drawn from the Meghna River. The raw water system will consist of an intake structure on the river Meghna and vertical raw water pumps. Water requirements during the operations phase of the Project will be approximately 1000 m3/hr (0.27 m3/sec), which is about 0.0045% of the lean season flow (6,000 m3/sec).

Community Exposure to Disease:

Since significant influx of labor is expected during the construction phase and a labor camp is proposed near the project site, the Project will require the EPC contractor to implement construction labour management plan developed as part of the ESIA (ESAP item#2). 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 will be implemented.

Security Personnel:

Site security management framework (SSMF) developed as part of the ESMS will be adopted which provides a framework to ensure that security personnel engage with external stakeholders with respect and in accordance with the human rights requirements as per IFC PS requirements. The SSMF puts in place a formal process and strategy for management of engagement of security personnel and their relations with external stakeholders, through the various stages of a project lifecycle. The SSMF is thus aimed at defining the manner in which the security personnel shall interact with external stakeholders; which includes: (i) factors to be kept in mind while hiring security personnel; (ii) managing the entry and exit of external stakeholders into the project site area; (iii) understanding of the type of information which may be disclosed to external stakeholders by the security personnel; (iv) manner in which any grievance, protest or demonstration shall be handled by the security personnel; (v) situations in which force or support from government agencies shall be sought; and (vi) requirements for training for security personnel.               

The ESIA includes: (a) mapping and identification of key stakeholders; (b)a summary of consultations, interviews and focus group discussions with key stakeholder groups; and (c) a stakeholder engagement plan defining Company’s future engagement strategy for the Project taking into account the various project lifecycle phases and their implications on these stakeholder groups.

Key stakeholders consulted as a part of the ESIA process included a) relevant government institutions like the Bangladesh Power Development Board, Department of Fisheries, and line departments like Department of Environment (DoE), land revenue office; and b) local communities including residents of Pirajpur Union Parishad, fishermen in Pirajpur and its neighbouring Union Parishads, fishermen in Char Balki Island and residents. The consultations were carried out with the objective of understanding stakeholders’ interests/ expectations/ concerns and gauge their acceptance/ level of support for the Project. The details of these consultations/meetings including the summary and photographs have been included in the ESIA report.

Review of the stakeholder consultations and other documentation suggest that the communities and other stakeholder’s are aware of the Project and its impacts. They are largely supportive of the Project and view this as a positive development in their area leading to increased employment and business opportunities. They also see the project development as a key step towards addressing the power/electricity shortage in the country. The Company plans to roll out the stakeholder engagement and grievance redress plan prior to start of construction activities. Information about this community/stakeholder grievance redress mechanism will be shared with the communities and implementation of these would be monitored.                                                  

The full text of the ESIA report and the ESRS will be available in hard copy at the Company office located in Dhaka per the address mentioned below and also at the project site:

Address: Summit Centre, 18. Kawran Bazar, Dhaka-1215, Bangladesh

Mobile: +8801755521259

Email ID:  zakia@summit-centre.com  

Any queries and/or comments about the project may be directed to:

Contact Person: Md. Reaz Uddin

Company Name: Summit Meghnaghat II Power Company Limited

Mob: +8801755521259

Email ID: reaz.uddin@summit-centre.com

Facsimile: +880-02-9130853F