Environmental and Social Assessment and Management System
As part of the ESIA, a framework E&S Management System (ESMS) has been prepared for the project. This framework ESMS addresses both the Construction and Operation phases and includes policy statements, management and monitoring measures based on the risks identified, and a list of E&S management plans required for each phase. As outlined in ESAP #1, ENERSOK will build upon the ESMS framework included in the ESIA to develop and implement a project-specific Environmental & Social Management System (ESMS) appropriate for the scale and complexity of the project, per the requirements of IFC PS1, WBG EHS General and Thermal Power Plant Guidelines, and applicable national laws and regulations, addressing both construction and operation. The ESMS will include an E&S policy defining ENERSOK’s E&S objectives in line with IFC E&S standards.
The ESMS will also include a Commitments Register. The Commitments Register will list all environmental and social commitments made by the sponsors in the ESIA documentation and through acceptance of the national permits and legal agreements stipulated with the Government of Uzbekistan.
As a minimum, the ESMS will include the following Management Plans: contractor/subcontractor management plan, waste management plan, occupational health and safety plan, emergency preparedness and response plan, hazardous materials handling and storage plan, traffic management plan, community health and safety and worker influx management plan, security management plan, chance find procedure, land acquisition and livelihood restoration plan (already in place), stakeholder engagement plan (already in place), community development plan, grievance mechanism, supply chain procedure, water and wastewater management plan, noise management plan, air quality management plan, site clearance and rehabilitation plan, environmental and social monitoring plan, workers accommodation plan, sexual exploitation and abuse prevention and response plan and local recruitment plan.
Contractor/sub-contractors, including the EPC contractor, will be contractually bound to follow applicable E&S requirements, including IFC PS and WBG EHS Guidelines, and implement those portions of the ESMS that fall within its scope of work as described in the draft framework ESMS.
As part of the design phase of the project, a Project Environmental Design Criteria (EDC) Document will also be prepared as per ESAP #2. This EDC Document will list all quantitative (numeric) and qualitative standards to be complied with by the EPC contractor or other vendors when designing different components of the plant, such as, air emissions limits, wastewater discharges, noise levels, secondary containment requirements, among others. Similarly, the EDC Document will list all standards that the plant operator will be required to comply with. The project adopted standards will be based on the most stringent among applicable national requirements, IFC PS and WBG guidelines.
As outlined in ESAP #3, the EPC contractor will be required to develop and implement its own Construction ESMS, inclusive of policy statements, management and monitoring measures and aspect-specific management plans applicable to the EPC activities and tailored to the construction methodology, engineering design and commissioning phase of the project. The structure and content of the EPC contractor’s ESMS will be fully aligned with the sponsor’s ESMS and with the adopted project specific standards. The EPC contractor’s ESMS will include the necessary level of detail to enable the sponsor and external auditors to verify adherence to the specified design criteria and management measures. Roles and responsibilities for construction E&S staff will also be outlined in the construction ESMS.
ENERSOK will operate the plant after construction and commissioning. Therefore, as per ESAP #4, before commissioning, ENERSOK will develop and implement Operations Environmental and Social Management Plans (ESMPs) acceptable to IFC and consistent with the project ESMS, ESIA, IFC PS, WBG EHS Guidelines and national requirements. The content of the Operations ESMPs will reflect final equipment details, plant processes and operational schedule.
ENERSOK will liaise with the owners of the project’s Associated Facilities and will endeavor to ensure construction and operation of the AFs is consistent with the project ESMS.
Identification of Risks and Impacts
To meet lenders’ requirements, an Environmental and Social Impact Assessment (ESIA) for the project has been prepared (disclosed along with this ESRS) and it addresses relevant E&S risks and impacts at an appropriate level of detail and outlines relevant mitigation measures.
The ESIA also evaluated the cumulative impacts due to operation of the Syrdarya 1 IPP project and the Syrdarya TPP in the vicinity of the project.
A climate risk assessment has also been carried out as part of the ESIA, based on SSP5-8.85 climate change projections developed by the International Panel on Climate Change (IPCC). The assessment concludes that climate related risks on the project are not expected to be significant due to the design of the plant and other mitigants to address temperature related constraints and risks.
A gap analysis of the ESIA was conducted by the IESC, which identified that the risk assessment process for the project is generally compliant with IFCs PSs. However, as outlined in ESAP item #5, ENERSOK will identify further mitigation of water and wastewater aspects, noise management, community health and safety and landscape aspects. The final version of the ESIA will be disclosed by lenders and ENERSOK.
Stage 1 of the National (Uzbek) EIA has been approved while Stage 2 and 3 approvals will be sought by ENERSOK from the local regulatory authorities before commissioning. ENERSOK will obtain these approvals and other local permits from relevant authorities, before construction or operation as necessary.
Organizational Capacity and Competency
ENERSOK currently has a limited number of staff as a recently established company and lack E&S staff, this role currently being undertaken by the sponsor E&S teams. As per ESAP item #6, ENERSOK will engage a qualified Environment, Social, Health and Safety (ESHS) Manager who will have overall responsibility for environmental and social management as well as occupational health and safety (OHS). He/she will also be responsible for compliance with permit conditions and project E&S standards, and implementation of the ESMS and for selecting and coordinating the ESHS team, which will include environmental, social and OHS specialists.
ENERSOK’s ESHS team will be responsible for ensuring that the EPC contractor and its subcontractors are in compliance with E&S requirements. Oversight during construction will be provided by the Owner’s Engineer (OE), who will be retained prior to commencement of construction. During construction, ENERSOK will contractually delegate responsibility for day-to-day ESHS management and compliance to the EPC contractor, who will therefore be required to have suitably qualified staff in place. The EPC contractor will engage an Environment, Social, Health and Safety (ESHS) Manager for construction who will have overall responsibility for, implementation of the ESMS (including OHS aspects) and ensure oversight of sub-contractors. The EPC contractor will appoint needed qualified ESHS staff for construction as outlined in the construction ESMS and ensure sub-contractors are also suitably staffed on E&S (ESAP #6).
During operation of the plant ENERSOK will retain ESHS staff to perform day to day inspections and reporting. The final structure of the ESHS functions during operation will be finalized prior to commissioning the plant and will be documented in the final version of the ENERSOK’s Operations ESMP (ESAP #4).
Emergency Preparedness and Response
Emergency Preparedness and Response Plans (EPRPs) will be prepared as part of the construction and operations ESMS (ESAP 1 and 3), which will cover works on the project site and along the access road. The EPRPs will address plant risks and community risks. Responsibility for its enforcement will apply to ENERSOK’s personnel, EPC staff members and subcontractors’ employees. This will be complemented by Pollution Prevention and Response Plans (for construction and operation), which will identify site- specific requirements for the prevention of pollution (i.e. oil spills) and how to manage pollution incidents.
The EPRPs will identify contingencies for a variety of potential emergency situations relevant to construction, commissioning and operations, including accidental leaks and spills, explosions and fires, vehicle accidents, natural hazards, security events, as well as responding to communicable diseases. The EPRPs will outline the response mechanisms, roles, responsibilities, training and equipment requirements, internal and external communication mechanisms.
Monitoring and Review
ENERSOK and the EPC contractor will undertake regular E&S monitoring to demonstrate compliance with lender requirements for environment, social, occupational health and safety as well as national environmental standards, including permit requirements, and lenders’ requirements. E&S Monitoring Plans will be developed as part of the construction ESMS (ESAP #3) and operations ESMPs (ESAP #4), which will include clear responsibilities on monitoring activities and parameters to be monitored; monitoring locations; methods and frequency of monitoring; and criteria against which compliance and performance will be assessed. As part of the project ESMS, an Environment, Health, Safety and Social Incident Reporting Procedure will also be developed and implemented to maintain records of monitoring, accidents and incidents (including near misses).
ENERSOK and the EPC contractor will be responsible for day-to-day monitoring during construction, and bi-annual monitoring reports will be shared with the lenders. Once construction is complete, ENERSOK will implement the monitoring plan outlined in the Operation ESMS. activities During operation the project will be required to submit annual E&S monitoring reports to IFC.
Independent monitoring of environment, health and safety, labor and social aspects of construction activities will be undertaken on a regular basis during construction. As per national legislation, the relevant government authority will also monitor the project at least annually. To ensure effective and appropriate monitoring, all relevant E&S Monitoring Plans, including frequency of sampling and reporting, will be defined in project’s ESMS (ESAP #1) for the EPC contractor to comply.
Contractors and sub-contractors management
The selected EPC contractor has been made aware of the E&S requirements associated with the project through the tender documentation, which included the E&S requirements stipulated in the PPA and detailed in the technical annexes to the Request for Proposals.
After award of contract, the EPC Contractor’s obligations with respect to E&S performance will be regulated by i) the inclusion of national and lender E&S requirements in key project contracts and ii) E&S monitoring and oversight by ENERSOK throughout the pre-mobilisation and construction phase. The EPC Contract refers to the following E&S Requirements:
• the requirements of the EIA and the ESIA;
• E&S Laws and any other applicable Legal Requirements relating to pollution control and environmental standards;
• International E&S Standards ;
• Construction Environmental and Social Management Plan (CESMP) which define the EPC Contractor's obligations. The EPC contractor will be provided with the ESIA and CESMP for full transparency prior to signature of the EPC Contract.
As per ESAP #7, ENERSOK will incorporate the requirements for Environment, Social, Health and Safety (ESHS) management into an EPC Contractor E&S management Plan (CMP) documents and the EPC contractor will do the same for its sub-contractors, The CMPs will outline the process of incorporating project E&S requirements into the contractors’ work and legal terms the process to follow to adequately select, hire and manage contractors and subcontractors.