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.
PS1: Assessment and Management of Environmental and Social Risks and Impacts
E&S Policies and Management Systems: MGI has a corporate environmental health and safety (EHS) policy that is consistent with the principles of IFC’s Performance Standards (PSs). MRSML has prepared a project specific EHS policy in line with the Corporate MGI’s EHS policy. MGI has established a group-level E&S Management System (ESMS) that is certified per ISO 14001 (environmental management) and ISO 45001 (occupational health and safety). In line with MGIs group-level ESMS, the company has established and maintains a construction phase environmental and social management plan. The company is developing an operational phase ESMS using the consultant services of M/s BSE, who has been retained to operate and maintain the plant for the initial two years. The company is yet to formulate and implement the plant specific ESMS appropriate to the nature and scale of the project and commensurate with the level of its E&S risks and impacts that is aligned to national law and IFC Performance Standards (PS). Hence, the Company will, as part of the environmental and social action plan (ESAP), develop the plant operational ESMS aligned with national law, IFC PSs, WBG EHS General EHS guidelines (2007) and WBG EHS Guidelines for Integrated Steel Mills (2007). The ESMS will as a minimum include (i) policy; (ii) identification of risks and impacts; (iii) documented EHS operational manuals, procedures, practices, and plans; (iv) organizational capacity and competency; (v) emergency preparedness and response, including life & fire safety management plan; (vi) stakeholder engagement and community grievance mechanism; and (vii) monitoring, reporting and review. More details are specified in the Management Program element below (ESAP#1).
Identification of Risks and Impacts: The company undertook an independent environmental impact assessment (EIA) study for the proposed project in line with the national regulations, conducted public consultations, and obtained an environmental permit from the Department of Environment (DOE) in December 2022. The company commissioned a supplemental environmental and social impact assessment (ESIA) study including cumulative impact assessment (CIA) and risk assessment studies in accordance with the requirements of IFC PS (all three documents are disclosed along with this ESRS).
Impacts on fishing activities due to Captive Wharf operations: Based on consultations with fishermen community members in the Luterchar village (project village) of Meghna Upazila and Balukandi village of Gazaria Upazila, ESIA report documents that around 30-40 families are involved in fishing practices in main Meghna River in the south of the proposed plant area. In the immediate project vicinity, about fifteen (15) local informal fishing activities (locally known as “Katha” or brush pile fishing) were surveyed along the upstream side of the Meghna River branch channel in the project study area. Katha's are temporary fish aggregating wooden and vegetative structures constructed with branches from bushy trees and water hyacinths to create a type of shelter that attracts fish. Although these structures themselves are not permanent since as they degrade and needs to be reconstructed after every year’s fish harvesting, they are typically reconstructed in the same location. These katha fishing activities are undertaken along the banks of the river channel and not in the middle of the channel which is used by riverine vessels for navigation.
Based on the primary baseline surveys and consultations with local fisherman community and other relevant stakeholders, the ESIA report concludes to state that as there is no untreated wastewater or effluent discharge into the branch river channel and the Meghna River branch channel is intensively used for riverine transport every day (about 30 riverine vessels per day), the project operations will have no impacts on fishing livelihoods of katha fishing families that are active in the upstream side of river channel adjoining the project site except for three (3) katha fishermen who were observed to be located adjacent to wharf site and could be impacted during wharf operations while the remaining ones will not be impacted by project operations.
As part of the project E&S management plan, the Company will engage with the impacted katha fishing owners and provide them with appropriate one-time monetary compensation for the loss of assets a full replacement cost. The company will also engage with the katha fishermen community in the region as part of its stakeholder engagement plan and address their grievances through community grievance mechanism discussed below. The ESIA documents that no other river-based ecosystem services will be adversely impacted by wharf operations and riverine vessel movements (expected to be 1-2 vessel movements per day). Wharf operations and riverine transport will be suspended during adverse weather conditions such as cyclonic thunderstorms and heavy monsoon season.
As per agreed ESAP#9, Company will formulate and implement a livelihood restoration plan for the katha fishermen affected by the wharf operations focusing on improving their main source of income to mitigate the income loss from the affected kata fishing activity, if any. As per agreed ESAP#1and as part of the operational ESMS, Company will formulate and implement a fisherman community engagement plan and grievance redress mechanism which will require the company to mandatorily engage with local communities specifically the fisherman communities that are using the branch river channel for fishing livelihoods on a quarterly basis and address their livelihood concerns arising out of project operations.
Management Program: Construction Phase: The company has established construction EHS management procedures and plans aligned with national law and standards. As part of the project, the company will augment its construction EHS management procedures in accordance with the requirements of IFC PSs and WBG General Guidelines (2007) with a focus on strengthening the contractor safety manuals, method statements, EHS training program, monitoring reporting templates and procedures, audit programs and labor accommodation standards. Contractors and subcontractors will be contractually obliged to prepare and implement site-specific EHS management plans and procedures throughout the contract period (ESAP #2).
Operation and Maintenance Phase: As discussed above and as part of IFC investment, the Company agrees (ESAP#1) to develop the plant ESMS before commissioning the plant. The company will prepare a suite of operational E&S management plans in line with the national law & permit conditions, IFC PSs and WBG General EHS guidelines (2007) and WBG EHS Guidelines for Integrated Steel mills (2007).
EHS Organizational Capacity/Competency: MGI has established an EHS organizational structure at the corporate and facility levels. At the Group level, a Group Director has been assigned to manage E&S aspects and report to the MGI Management Board. The group director is assisted by the corporate EHS head, who is part of an EHS team. The Corporate EHS Head is responsible for implementing the Corporate ESMS across all MGI operations and group companies, including MRSML. Under the project, a part of the group EHS team has been assigned to work on MRSML during construction phase. Company plans to formulate and institute an appropriately sized plant’s E&S organization structure (ESAP#3) for managing O&M phase. The Company will recruit and appoint a facility EHS head, health & safety officers, and a Fire Safety officer with adequate qualifications and experience. The E&S organization will be provided with budgetary and manpower resources as required.
Emergency Preparedness and Response: As part of the construction phase EHS management plans and contractor EHS management plan, an emergency response plan is in place, which includes credible emergency scenarios, emergency response procedures, periodic training, and monthly fire/mock drills involving all contractor workers.
Among the gases handled at the project site, risk assessment report identifies NG pipeline rupture or leakage resulting in Flash fire, Jet fire or Vapor cloud explosion as a potential significant hazard scenario based on consequence analysis using ALOHA (Areal Locations of Hazardous Atmosphere) model. However, considering the project site context and the inherent limitations of consequential risk assessment using ALOHA model, Company agrees to update the consequential risk assessment study (ESAP#4) into a full-fledged quantitative risk assessment (QRA) study based on terms of reference agreed with IFC. The proposed QRA study will cover all hazardous scenarios in Plant operations including natural gas, oxygen generation plant and gas storage tank farms proposed in the project and will use PHASTRisk (or equivalent) to generate the risk metrics (e.g. LSIR, IRPA, F-N Curve outputs).
For the operational phase, the company is preparing site–specific emergency preparedness and response plan (ERP) in line with national law and GIIP standards such as WBG General EHS guidelines. As part of the operational phase ESMS development discussed above and agreed upon under ESAP#1, the company will formulate onsite ERP and prepare offsite disaster management plans as a key element of the plant ESMS in conjunction with responsible authorities. The ERP will include periodical engagement with sensitive off site social receptors (such as neighbourhood residential communities and public buildings) and community on safety measures and emergency drills; mandatory establishment and maintenance of buffer zones and green belts around the site restricting activities near the plant.
Monitoring and Review: As part of operational phase ESMS development discussed above and agreed under ESAP#1, the company would formulate and institute a monitoring and review mechanism for the project aligned with IFC PS 1 requirements. As in practice with other Meghna Group companies, the MGI Board would regularly review MRSML's E&S Performance.
PS2: Labor and Working Conditions
During the project operational phase, the project will employ approximately 700 staff and workers (including staff at both head office and site). Around 400 will be direct workers, while another 300 will be contracted workers. In the current phase of construction, around 300-350 employees and workers (including both permanent staff and contractors) are involved.
Human Resource (HR) Policies and Procedures: At the Group level, MGI has adopted and implemented HR policies and procedures that comply with national law and are broadly aligned with the requirements of IFC PS2. Both Meghna Group and MRSML have formulated an anti-harassment policy covering prevention of sexual harassment and no related incidences at the Group level has been reported. The company is formulating project-specific HR policies, manuals & procedures based on the Meghna Group HR policy and procedures. As part of IFC investment, the company will augment its HR policy and procedures in accordance with the requirements of IFC PS2 (ESAP #5) covering both direct and contracted workforce. The HR policy and procedures will cover PS2 requirements such as: working conditions and terms of employment; worker accommodation policies; worker grievance redress mechanism (GRM) including prevention of sexual harassment (POSH) and gender based violence and harassment (GBVH); retrenchment policies and procedures; policies on freedom to associate including worker committees; non-discrimination and equal opportunity; prohibition of child, forced and bonded labor practices; and workers engaged by third parties (contractors). There are no worker representatives in the worker's committee in other MGI companies, and the company will formulate policy and procedures concerning workers' organization committee in compliance with labor law, including setting up a participation committee where direct involvement of the workers shall be ensured. Further, as part of agreed ESAP#5 actions, the company will commission an independent third-party labor audit against requirements of IFC PS2 and national law to verify the effective implementation of the HR management systems within one year of commissioning the plant and implement the labor audit findings and corrective actions needed in a time-bound manner.
Worker Accommodation: As per the ESIA report and project proposal, the company proposes to provide a multi-storied (ground + 10 upper floors) administrative and worker accommodation building within the project site in CuEZ du ring the operational phase. The building will primarily serve as the administrative block and will provide accommodation to about 1000 MGI’s staff and visitors. As part of ESAP#5 discussed above, the company will formulate and implement accommodation policy and operational procedures in accordance with national law, Bangladesh national building and fire safety codes and Workers’ accommodation: Processes and standards, A guidance note by IFC and the EBRD, Aug 2009
During the ongoing construction phase, contractors have provided on-site labor accommodation camps that were largely satisfactory with scope for improvement. As per ESAP#2 discussed above, the company will audit the operational campsites for compliance to IFC Workers’ accommodation: processes and standards, August 2009 (Refer to https://www.ifc.org/content/dam/ifc/doc/mgrt/workers-accomodation.pdf) and accordingly upgrade the services to meet the IFC guidelines.
Worker’s Organization: MGI HR policies does not prohibit or discourage the formation of unions or collective bargaining of workers. There are no worker's unions in any Group companies. Workers' management committees, however, are functional, comprising the factory head/chief operating officer and the representative management-level staff members.
Protecting the Workforce: MGI does not employ children (under 18 years of age) or forced labor in its operations as part of its HR policy. The Group HR Manual and MRSML’s child labor policy include verification of the workers’ age using personal identification cards.
Occupational health and safety (OHS): IFC’s onsite appraisal assessment of ongoing construction work indicates average E&S performance by contractors, specifically with regards to enforcing personal protective equipment protocol, general housekeeping, electrical safety, and working at height. However, company reports zero fatalities since the commencement of construction. As part of the project and as per ESAP#2 discussed above, the company will strengthen the enforcement of EHS management plans and construction contractor oversight during the ongoing construction phase through improved internal auditing systems, training & capacity building and periodic management review of contractor OHS performance.
During operational phase, core steel mill operations will be automated with a minimal manual intervention required to mitigate the typical OHS risks such as exposure to heat, handling hot liquids, radiation, respiratory hazards, and noise exposure. Appropriate fugitive dust pollution control measures devices have been included in the plant design and will be installed to prevent dust generation and worker exposure. As part of the contract requirements, the technology and equipment supplier (M/s Danieli SPA, Italy) will provide and deliver OHS training modules on various safety and hazards associated with the steel plant. As part of ESAP #1, the company will complete an OHS risk assessment for the new plant (including the associated facilities) in line with national law and WBG General EHS guidelines (2007). Based on the OHS risk assessment outcome, the company will develop OHS management program that includes monitoring and reporting of workplace safety, pre-employment and periodic employee medical surveillance, occupational exposure assessments and industrial hygiene surveys by competent third party based on workplace/activity hazards, personal protective equipment protocol, establish system for monitoring and reporting of occupational accidents and incidents, define OHS training program and emergency preparedness and response arrangements.
Life and fire safety (LFS): The fire protection systems and infrastructure at the plant will be designed and installed in accordance with the national building and fire safety codes and GIIP standards. Firefighting systems, such as sprinklers, portable extinguishers (appropriate to the flammable hazard in the area), and automated fire extinguishers will be provided at strategic locations with clear labeling of the extinguisher type. For firefighting purposes, fire hydrant systems will be located at different locations of the plant. In case of power failure, the fire pumps in the fire hydrant systems will be run through diesel generator. An automated fire detection system will be in place on all floors. In addition to the fire hydrant system, each individual zone will be equipped with a fire and smoke detection alarm system. The fire detection system will be interlocked with automated water sprinklers. Ambulances with all facilities will be available around the clock. The company plans to institute a dedicated Rescue and First Aid Team that is organized and trained in first aid and rescue operations to offer timely assistance and preliminary medical care. As part of the Plant ESMS development discussed above under PS1 and agreed upon under ESAP#1, the company will formulate a stand-alone LFS management system within the larger ESMS framework comprising of LFS policy, fire safety organization, LFS manual (detailing out the SOPs, internal and external audit mechanism, periodical checklists, LFS incident investigation), LFS monitoring and reporting indicators, and LFS performance reviews.
Supply Chain: The project will import all its scrap steel requirements largely from US, Europe and Middle East. This global procurement shall be primarily through the commodity market. The company has no plans to source local steel scrap from Bangladesh commodity markets. The local scrap steel sector in Bangladesh is known to have risk of child labor and poor working conditions. MRSML has prepared a supplier selection policy and procedures; however, the company has not developed Code of Conduct for suppliers. As part of IFC investment and as per agreed ESAP #6, the company will develop and implement a supply chain management system (SCMS) that is appropriate to the nature and scale of the project and commensurate with the level of labor risks and impacts specifically in the local supply chain.
PS3: Resource Efficiency and Pollution Prevention
Resource Efficiency: The new steel plant will use resources such as electricity, water, coal/coke, and natural gas besides the metallurgical process additives like ferrous alloys (30,000 tons per annum (TPA)), lime (46,500 TPA) and dolomite (18,000 TPA). MRSML has integrated technically feasible and cost-effective resource efficiency measures in the plant's design. MRSML will procure electricity from the national power grid and consume approximately 380 kWh per ton of processed steel, which is well aligned with the industry benchmark (347 to 500 kWh/ton of product) for the EAF process as defined in Table 3 of WBG EHS Guidelines for Integrated Steel Industries (2007). The proposed steel plant will use Direct Current (DC) electric arc furnace (EAF) technology with approximately 20% less specific electric energy consumption compared with conventional blast furnaces and more energy efficient than alternating current (AC) EAF technology. The new facility will use natural gas for casting burners for billet re-heating and will be sourced from a national gas distribution company. Coal or coke (less than 10% ash content) will be used as a carbon source for slag foaming in the EAF at the rate of 13 kg/ton. As part of the E&S performance monitoring and reporting system to be developed under ESAP#1 (discussed under PS1 above), MRSML will set the key sustainability performance indicators (KPI) such as specific electricity consumption, specific water consumption, EAF process CO2 emissions, and other resources (gas, coal) and material inputs to monitor the effectiveness of resource efficiency measures to conserve raw material, water, and energy specific consumption (ESAP #1).
Water Consumption: Water would be sourced primarily from the Meghna River branch flowing next to the project site, and groundwater will be used as a backup source. The river water will be treated for utilization in the plant. About 57 cubic meters per day will be required during the construction phase. During the operation phase, the domestic water consumption shall be approximately 50 cubic meters per day. Process water requirement is approximately 13,000 cubic meters per hour for the start of operations and thereafter only 240 cubic meters per hour of make-up water due to estimated process and evaporation losses is required as the Plant is designed with a closed loop system that recycles treated wastewater. The surface or groundwater abstracted will be treated in a two-stage water treatment plant comprising of demineralization and reverse osmosis (RO) unit. The company has integrated water conservation measures into the technical design, including recycling 100% of the cooling water, with only the evaporation losses compensated and adopting a zero liquid discharge (ZLD) system. Water consumption estimated at the rate of 2.4 cum/ton of product (only make-up water is considered) aligns with the industry benchmark (3 cum/ton of product) for the EAF process as defined in Table 3 of WBG EHS Guidelines for Integrated Steel Industries (2007).
GHG Emissions: The project is expected to generate GHG emissions (Scope 1 and 2) of about 306,100 tons of CO2eq/annum, on average, over the next ten years. The EAF process CO2 emission (Scope 1 and 2) rate of 0.212 tCO2/ton of product, theoretically estimated at the planning stage based on the Plant design parameters, indicates compliance to global EAF process CO2 emission benchmark values (0.215 tCO2/ton of product) such as European Union Steel Association for 2021-2025 (Refer to EU ETS benchmark at https://www.eurofer.eu/assets/press-releases/prohibitive-energy-and-carbon-prices-risk-undermining-eu-steel-industry-decarbonisation-eu-leaders-must-act-warns-eurofer/202111_CBAM_ETS-impact_EU-steel-industry.pdf). As part of operational phase ESMS procedures discussed under PS1 (ESAP #1), the company will quantify GHG (scope 1 and scope 2) emissions annually in accordance with internationally recognized methodologies and good practices and report to IFC.
Air emissions: During operational phase, the main air emission sources are: fugitive dust emissions in scrap processing, handling and transportation areas and near EAF steel slag processing plant; process emissions from EAF that comprise of primary fumes line from the EAF roof (direct extraction system), secondary fumes line from the canopy hood arranged on the building roof over the EAF shell; fumes from Ladle Furnace (LF) for reheating the molten metal; fugitive emissions in the casting area and engine emissions from lighter riverine vessels (load capacity of 1200-4000 MT).
The process is designed to be fully mechanized to reduce fugitive emissions in scrap storage and loading areas. Water sprinkling arrangements will be provided to control fugitive dust emissions in the scrap handling area. To control air emissions from smaller riverine vessels (barges), the project will deploy barges that comply to Bangladesh’s Inland Shipping Act, 2005 regulations for the prevention of air pollution from inland shipping vessels.
Regarding process air emissions, a common fume treatment plant (FTP) is integrated into the plant design to treat the process emissions from EAF, ladle furnace, casting area, and other materials handling systems. As per the ESIA, the FTP proposed in the project is designed to meet local regulatory standards and WBG EHS Guidelines for Integrated Steel mills on air emissions. The process air emissions largely depend on scrap quality and FTP design. To demonstrate compliance, the company will, as part of the plant commissioning tests, hire a specialized and licensed third party company to perform monitoring of point source air emissions to confirm compliance with the guideline values recommended in Table 1 - Air Emission Levels for Integrated Steel Mills, WBG EHS Guidelines for Integrated Steel Mills (April 2007) and plant permit conditions. If the monitoring results indicate non-compliance, the company will assess the effectiveness of the abatement solutions and augment the pollution abatement measures in line with GIIP and repeat the air emissions monitoring to confirm compliance (ESAP #7).
As part of the ESIA, the impacts of facility air emissions from FTP on the ambient air quality have been estimated using the atmospheric dispersion model AERMOD (Ver 12.0). As per the ESIA, baseline ambient air quality monitoring data shows that the project is in a non-degraded airshed. The atmospheric dispersion modeling analysis indicates that ground-level concentrations of PM10, PM2.5, SO2, NO2, and CO, will not reach or exceed relevant national ambient quality standards. The company will, as part of the plant commissioning tests, hire a specialized and licensed third party company to perform monitoring of ambient air quality per the monitoring plan and methodology agreed with IFC to confirm compliance with the national ambient air quality standards (ESAP #7)
Cumulative air quality impact assessment undertaken as part of the project ESIA studies indicate that baseline particulate matter (PM) levels in the airshed are high but within the ambient air quality standards. The cumulative impact in the Meghnaghat airshed is expected to exceed the PM threshold level in future. However, the contribution of PM from the project is assessed to be low. Similarly, the existing baseline NOX concentration in the Meghnaghat industrial area is within the ambient air quality standards. The cumulative impact in the Meghnaghat area is not expected to exceed the NOx threshold level and impact is assessed to be moderate. The contribution of NOX from the project is also assessed to be medium.
According to the design, the new plant will have a LINDARC technology-based continuous process emission monitoring system. The company will, as part of the ESAP#1 develop air emissions and ambient air quality monitoring plan compliant with national law, permit conditions, and guideline values recommended in Table 1 - Air Emission Levels for Integrated Steel Mills, WBG EHS Guidelines for Integrated Steel Mills (April 2007).
Ambient Noise Environment: As per the ESIA, there are multiple noise-emanating sources or processes throughout the plant that have been identified to generate noise levels ranging between 80-105 dB(A). The plant design incorporates various noise abatement measures. The sensitive receptors within the plant such as office cum dormitory building has been placed near the southeastern boundary of the site and about 400m away from larger noise sources.
As part of the ESIA study, ambient noise levels at the closest onsite and offsite social receptors have been modelled using Sound PLAN 8.2 software. Modeling analysis indicates that project could add to background ambient noise levels at some of the closest sensitive social receptors by about 3.5 dB(A). However, as per ESAP#7, the company will, as part of the plant commissioning tests, hire a specialized and licensed third-party company to perform monitoring of ambient noise levels at closest off-site sensitive social receptors per the monitoring plan agreed with IFC to confirm compliance with permit conditions, national law and guideline values recommended Table 1.7.1- Noise Level Guidelines, WBG General EHS Guidelines, April 2007. If the monitoring results indicate non-compliance with referral standards, the company will augment the noise pollution abatement measures in line with GIIP, repeat monitoring to confirm compliance.
Wastewater: Project shall not generate any industrial process wastewater as water is mainly used for equipment and material cooling. A closed-circuit cooling system will be implemented, ensuring complete recyclability of the process water used. The effluent generated from cooling tower blow down and other facilities, if any, will be transferred to 1000 KLD capacity, common effluent treatment plant (CETP) that will be operated by CuEZ industrial authority. As per MGI, the CETP will be designed as zero liquid discharge (ZLD) plant and the treated water will be utilized for toilet flushing, vehicle washing, and gardening purposes in CuEZ.
Domestic Sewage Treatment: During the ongoing construction phase, domestic sewage generated from the offsite worker accommodation camp and onsite project offices are discharged into the onsite concrete septic tanks and a series of soak pits. These septic tanks and soak pits are designed as per the Bangladesh National Building Code (BNBC) 2020 guidelines. The septic tanks are periodically cleaned by availing services of the nearest municipality.
During the operation phase, 48 KLD domestic sewage generated from administration cum dormitory building, domestic use in industrial buildings, canteen, washrooms, and pantries will be discharged to onsite septic tanks. Overflow from septic tank will be treated in 720 KLD capacity, common sewage treatment plant (CSTP) that will be operated by CuEZ industrial authority. The CSTP will also be designed as a ZLD plant and treated water will be reused as stated above.
Solid and Hazardous Wastes: The plant operations shall generate EAF process waste steel slag (expected at the rate of 10-15% on the production of each ton of steel) as the main waste product. Project design includes an onsite steel slag processing facility with a capacity 30 tons of steel slag per hour and the processed slag will be reused in Meghna group concerns involved in brick manufacturing, cement, and road construction. Dust from the treatment of off-gas in FTP will be reused or disposed as per permit conditions and local regulations. Other hazardous waste streams, such as used oil and lubricant waste and mechanical workshop wastes will be limited and disposed of through a licensed service provider as per permit conditions. Domestic solid waste such as food and kitchen wastes, wood, plastic, paper, floor sweepings, gardening waste etc. will be segregated at source, appropriately recycled through third party vendors and balance waste sent to central solid waste treatment facility operated by CuEZ industrial authority. As per agreed ESAP#1, as part of the plant ESMS under IFC PS 1, the company will formulate and implement a comprehensive waste management plan and monitoring programs, that would comply with the permit conditions, local regulations and WBG General EHS guidelines and WBG EHS Guidelines for Integrated Steel Mills (April 2007).
Hazardous materials management: There are no major hazardous materials handling in the project operations, except for storage and handling of diesel, oils, gas cylinders. Besides, oxygen, nitrogen and argon gas generated from cryogenic oxygen plant will be stored onsite in dedicated tank farm area. Project will also source natural gas (NG) supplied by government utility company. A consequence modeling and risk assessment have been undertaken as part of ESIA studies. As discussed under ERP section in IFC PS 1 above, no offsite impacts on local community are anticipated as per consequence modeling study report. As per agreed ESAP#1, as part of the operational ESMS under IFC PS 1, the company will formulate and implement a comprehensive hazardous materials management plan that would comply with the permit conditions, local regulations and WBG General EHS guidelines (2007).
PS4: Community Health, Safety and Security
Infrastructure and Equipment Design and Safety: The new plant is in a designated industrial zone that is currently under development and construction. The project site is situated on the riverine floodplain land of the Meghna River branch. The low-lying flood plain area has been raised by 3-4m to prevent flooding based on historical flood risk assessment besides laying of proper drainage system. The plant layout has allocated 33% of the plot area for green vegetation development all around the perimeter of the plants to act as a natural green barrier between plant operations and neighborhood communities located within 200-500m distance from the plant boundary. During the plant operation, the company will integrate an infrastructure and equipment safety-related testing program, as part of the plant ESMS, for testing the structural stability of industrial buildings, fitness of critical process equipment that operates at high pressure and or temperature; testing of lifting equipment's, tools, and tackles etc. periodically in compliance to national building codes and standards and WBG General EHS Guidelines (ref. ESAP #1).
Traffic and transport network: The project is around 500 m from the N1 national highway (Dhaka – Chattogram highway) and adjacent to the Meghna River branch. MRSML would primarily use small riverine vessels (having a capacity of 1200-4000 MT and about 2 barges per day is the expected number of trips) to bring raw materials to the plant site and will use the road network to transport the finished products. MRSML estimates that around 45,000 to 50,000 trucks will be used annually to transport finished products and has planned a 2.5 acre truck parking facility with all driver amenities within the plant premises to avoid traffic congestion. The company will develop and implement a road & inland waterway transport management and monitoring plans separately, as part of the Plant ESMS, that would comply with the local transport regulations and WBG General EHS Guidelines (ref. ESAP #1). The transport management and monitoring plan will include: road/riverine navigation safety risk assessment and management; prohibition of child/forced labor in fleet operations; prohibition of overloading; location tracking using GPS devices; transport fleet operator screening, selection, periodical audit for regulatory compliance and evaluation of safe performance including verification of vehicle road/river worthiness; minimum basic qualification/certification of drivers, driver training on emergency preparedness in case of road/river accidents and safe driving behaviour; conducting periodical community awareness programs on road safety accidents; and gender based violence and harassment (GBVH) related training cum awareness for local communities and fleet operators and including the same in code of conduct for fleet operators with provisions for related grievance redressal mechanism.
Life and fire safety: The facility buildings and G+10 administrative cum dormitory building are designed, and is being constructed, and operated & maintained as per national building and fire safety codes, and good international industry practices, including IFC/EBRD’s Workers Accommodation Guidelines (2009). The company will identify processes and facilities and prepare site-specific emergency preparedness and response plan (ERP) as part of the facility ESMS (ESAP#1). The company will also engage a suitably qualified professional to prepare a Life and Fire Safety (L&FS) Master Plan for the project and certify that the design meets the requirements of local fire codes & regulations and in accordance with an internationally accepted L&FS standard, such as US NFPA (ESAP #8a). Before commissioning the project facility operations, the qualified professional will review built life and fire safety systems & infrastructure and certify that the construction of these systems meets national requirements and GIIP standards. The L&FS infrastructure and management systems through the project life cycle will be managed by a qualified and experienced fire safety officer to be appointed by the company before commissioning the project (ref. ESAP #8b).
Security Forces: As the Plant is located inside CuEZ Industrial estate, Company will deploy on-roll, unarmed security team at the project site. The Company briefs security personnel about policies on prevention of child labour to be verified among contractor/transport fleet workers at gate and provides training on basic safety, first-aid, fire safety and emergency response. The security team is led by Plant chief security officer who are on-roll staff. Company reports no security incident in the ongoing construction phase involving project security team and local community members till date. However, as part of IFC investment and as per agreed ESAP#1, the Company will formulate and implement a security management plan in line with para 12 of IFC PS 4 standards. This plan will be guided by the principles of proportionality and good international practice and include procedures to: assess risks posed by security arrangements especially armed guards (if provided in future); ensure hiring, rules of conduct, training on the use of force and human rights, equipping, and monitoring of security workers; screening process to select security personnel; train armed guards in the use of force and firearms; Code of Conduct for security personnel to guide their interactions with the public and employees; and to receive and resolve grievances about the security arrangements and acts of security personnel.
PS 6: Biodiversity Conservation and Sustainable Management of Living Natural Resources
Protection and Conservation of Biodiversity: The Project is in the Lower Gangetic Plains moist deciduous forests Ecoregion. This Ecoregion has been heavily cleared with little remnant forested habitats remaining. The project itself is located within cleared modified habitat. The adjacent riverine habitat of the Megha River branch channel is likely to be natural habitat, although also heavily degraded from runoff of the surrounding landscape. Ecosystem service use involving local communities fishing was identified within the aquatic habitats (known as "katha fishing"). An assessment of Critical Habitat values was completed for the project. Eight (08) species were considered as potential trigger species for Critical Habitat, including the IUCN Endangered Ganges River Dolphin, however none of these species meet the required thresholds. Impacts to aquatic natural habitats from the Project will be managed through compliance with PS3 related discharge requirements.
