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This document is the property of LBPL and the information contained herein is confidential. Persons receiving this document
are responsible to maintain confidentiality except when absolutely necessary and should be consistent with intended use.
52.2 MW Dual Fuel (HFO/Gas) FiredPower Plant Project
Comilla (Jangalia), Bangladesh
Environment & Social Monitoring Report
Report No: L125-RPT-EM-001
Date of Submission: 01-12-2014
52.2 MW Dual Fuel (HFO/Gas) Fired Power Plant ProjectComilla (Jangalia), Bangladesh
Environment & Social Monitoring Report
Page 1 of 30
ContentsExecutive Summary .............................................................................................................. 3
Chapter 1 .............................................................................................................................. 5
Basic Information .................................................................................................................. 5
1.1 Background of the Project ............................................................................................ 5
1.2 Reporting Period .......................................................................................................... 5
1.3 Current Project Status .................................................................................................. 5
1.4 Contacts ....................................................................................................................... 6
Chapter 2 .............................................................................................................................. 7
Environmental Management Plan (EMP) Implementation Status ........................................... 7
2.1 Pre-operation Phase ..................................................................................................... 7
2.2 Operation Phase ......................................................................................................... 10
2.3 Post-operation Phase .................................................................................................. 10
Chapter 3 ............................................................................................................................ 11
Institutional Arrangements and Environmental Monitoring ................................................. 11
3.1 Activity of the Environmental & Social Monitoring Unit during the reporting period . 11
3.2 Training Update ......................................................................................................... 11
3.3 Environmental Monitoring requirement and status of reporting .................................. 13
3.4 Environmental Monitoring Budget ............................................................................. 17
3.5 Additional Reporting requirement to IDCOL ............................................................. 17
Chapter 4 ............................................................................................................................ 18
Anticipated Environmental Impacts and Mitigation Measures ............................................. 18
4.1 Environmental, Social and Occupational Health & Safety Impacts during pre-
operational and operational phase .................................................................................... 18
4.2 Actions taken against the impacts .............................................................................. 18
Chapter 5 ............................................................................................................................ 23
Emergency Response and Disaster Management ................................................................. 23
52.2 MW Dual Fuel (HFO/Gas) Fired Power Plant ProjectComilla (Jangalia), Bangladesh
Environment & Social Monitoring Report
Page 2 of 30
5.1 Brief description of the plan ....................................................................................... 23
5.2 Preparedness for the plan ........................................................................................... 23
Chapter 6 ............................................................................................................................ 25
Grievance Redress Mechanism ............................................................................................ 25
6.1 Brief Description of the Mechanism and Policy ......................................................... 25
6.2 Status of Stakeholder engagement .............................................................................. 25
6.3 Allocation of Resource and Responsibilities .............................................................. 25
6.4 Reporting Status ........................................................................................................ 26
Chapter 7 ............................................................................................................................ 27
Information Disclosure, Consultation and Participation ....................................................... 27
7.1 Stakeholder Consultation ........................................................................................... 27
7.2 Response to Issue Raised by Stakeholders.................................................................. 29
7.3 Information Disclosure .............................................................................................. 29
52.2 MW Dual Fuel (HFO/Gas) Fired Power Plant ProjectComilla (Jangalia), Bangladesh
Environment & Social Monitoring Report
Page 3 of 30
Executive Summary
Lakdhanavi Bangla Power Limited (LBPL) has undertaken to develop and operate an
independent power plant project. The power plant is a dual fuel (HFO/Gas) with six internal
combustion generators with a capacity of 52.2 MW. The Power Plant is located at Jangalia,
Comilla Sadar South, Comilla District.
The main legislative with regard to environment is the Environmental Conservation Rules,
1997 of Bangladesh Government. As a part of environmental compliance, LBPL has prepared
an Initial Environmental Examination (IEE) report. The IEE report has been prepared based
on the guidelines of Department of Environment (DOE), Government of Bangladesh (GOB)
and Asian Development Bank’s (ADB) Safeguard Policy Statement. Based on this a site
clearance has been issued by the DOE.
The project site comprises about 3 acres of land. This land has been requisitioned from the
private land owners by following the required regulations of Bangladesh Government
through willing, buyer-willing, seller arrangement by the Government of Bangladesh and
Bangladesh Power Development Board (BPDB). The BPDB has leased it to the LBPL.
During the survey the land was found vacant. Therefore, for this project no resettlement
action plan was required.
The baseline survey for the proposed site was carried out for air quality, noise, physical
environment, biodiversity, deep ground water and surface ground water testing and house
hold socio-economic and an Initial Poverty & Social Impact Assessment (IPSIA) study. The
major environmental problems due to air pollution and noise generation was given utmost
attention as the plant location is in a mixed zone comprising of commercial and rural area
with settlements close to the power plant site.
A detailed analysis of the major pollutants was carried out. In combination with the baseline
air quality and on the information of the engine’s data sheet and specifications using air
dispersion modelling has been carried out. It was found that the annual concentrations of the
SOx, NOx and PM10 were within the limits set by the DOE and as well as the international
standards.
The other major concern is the noise generated due to the project activities during
construction period of the project. Based on the noise data available from engine
manufacturers and the baseline data collected a noise modelling was carried out.
52.2 MW Dual Fuel (HFO/Gas) Fired Power Plant ProjectComilla (Jangalia), Bangladesh
Environment & Social Monitoring Report
Page 4 of 30
A baseline survey for the natural environment was carried out including flora and fauna. This
was found to be typical to the floodplains of Bangladesh. Since only three acres of land has
been used by the project there was no significant impact on the natural environment.
Quantitative measurements were done for both for ground water and surface water in the
immediate vicinity of the power plant. The project has met the requirements of the ISO
14001:2004 International Environmental Standard and the applicable regulatory requirements
of Bangladesh.
Occupational Health and Safety issues have been addressed in the project appropriately.
Apart from the Bangladesh national standards LBPL had complied with the International
Occupational Health and Safety Standards such as OHSAS 18001:2007.
LBPL has considered the environmental and social compliance issues with due importance. It
has also addressed all kinds of tentative environmental and social impacts promptly. The
project had no potentiality to adversely affect the rights of indigenous community
It is carried out a house hold survey, a focussed group discussion and key informant
interviews. The objective of the consultation process was to share the views of the
respondents about the power plant project. Most of the respondents showed positive response
to the project due to the high demand for power. In addition, as they have requested the
LBPL has provided employment opportunities to local people at different phases of the
project development.
There were no negative concerns about the noise levels, water pollution which have been
clarified during the consultations. The only environmental concerns were the possibility of
high levels of noise and. They requested assurances that noise and air pollution minimizing
measures have been taken in the design stage of the power plant.
The guidelines for environment management plan, environment and social monitoring unit
and grievance redress mechanism have been prepared by the LBPL. The recommended
mitigation steps proposed in the environment management plan have been implemented in
the project and ensured satisfactory environmental monitoring and compliance. In general
there were no major environmental and social impacts due to the project activities of the pre
operational phase up to now.
52.2 MW Dual Fuel (HFO/Gas) Fired Power Plant ProjectComilla (Jangalia), Bangladesh
Environment & Social Monitoring Report
Page 5 of 30
Chapter 1Basic Information
1.1 Background of the ProjectThe Project will construct, operate and maintain the 52.2 MW Dual Fuel (HFO/Gas) Fired
Power Plant Project at Comilla (Jangalia), Bangladesh on Build, Own and Operate (BOO)
basis. Bangladesh Power Development Board (BPDB) will purchase the electricity generated
from the Project under a 15- year Power Purchase Agreement (PPA).
The project has three phases namely pre-operation, operation and post-operation. The pre-
operation phase carry out the engineering, procurement, construction, testing work and
commissioning the electrical interconnections of the 52.2 MW Dual Fuel (HFO/Gas) Fired
Power Plant Project at Comilla (Jangalia), Bangladesh. After the completion of the pre-
operation phase the operation and maintenance phase of the power plant will be started.
Major systems and equipment of the power plant consist with,
a) Six Diesel Engine coupled generator sets each at 8.9 MW
b) Fuel system including storage facility, fuel treatment and pumps
c) Fire water and water treatments system
d) Fire detection and protection system
e) Cooling water system
f) Oily water treatment system
g) LV system at 400 V
h) MV system at 11 kV
i) HV switchyard and system at 132 kV
j) Main control room, administration offices, workshop, stores etc.
1.2 Reporting PeriodFrom: April 2014
To: October 2014
1.3 Current Project StatusThe preliminaries works of the project completed. All the civil, mechanical, electrical designs
were completed. Material manufacturing & shipping has been completed. According to the
procurement plan all the purchase orders have been placed for all the civil, mechanical and
electrical purchases.
52.2 MW Dual Fuel (HFO/Gas) Fired Power Plant ProjectComilla (Jangalia), Bangladesh
Environment & Social Monitoring Report
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Altogether 90% of civil works has been completed to date. foundations of engine hall, gen-
sets, tank fire water & treated water tank, exhaust stack, fuel oil treatment building, radiator,
boiler, auxiliary boiler, fire fighting container and switch yard has been fully completed. Also
the work of farm dyke wall & grade slab, cable trenches has been completed. The work of the
boundary wall, steel buildings, service road & drainage, guard house construction, fuel
unloading station are in progress.
Electro Mechanical Erection work completed 82 % to date. All engines were placed & aligned. Stack
erection is completed. The erection work of aux module, cooling water system, crane
installation, fire tank, LFO Storage Tank, HFO buffer, HFO day tank, oily water buffer tank,
sludge tank, lube oil tank, service lube oil tank, used lube oil tank has been completed. Fuel
oil system, lube oil system, compressed air system, fire system, exhaust gas system, waste heat steam
generating system, air intake system, water treatment system, HFO storage tanks work in progress.
Pre-commissioning and commissioning of the water treatment plant, compressed air system,
overhead cranes (engine hall, FTH & workshop) has been completed.
Project Activity % Completion
1. Preliminaries 100 %
2. Design and Engineering 100 %
3. Manufacturing and Shipping 100 %
4. Civil Construction 90 %
5. Erection and Commissioning 70 %
6. Startup Testing and Reliability Run 00 %
1.4 Contacts
Name: Mr. N. SivakumarPhone: 8802-8410330
Email: [email protected]
Name: Mr. A.B Siddique
Phone: 8802-8418513
Email: [email protected]
52.2 MW Dual Fuel (HFO/Gas) Fired Power Plant ProjectComilla (Jangalia), Bangladesh
Environment & Social Monitoring Report
Page 7 of 30
Chapter 2Environmental Management Plan (EMP) Implementation Status
The environmental management plan of the LBPL is established to design, implement, asses,
and continually improve it’s environmental management practices. The system has been
designed to meet the requirements of the ISO 14001:2004 International Environmental
Standard and the regulatory requirements of Bangladesh.
The environmental aspects and their impacts are being evaluated for this project. Based on
the outcomes of those evaluations, appropriate elimination or mitigation measures are also
being implemented in the project.
2.1 Pre-operation PhaseThe established Environmental Management Plan of the LBPL measures environmental
performance in relation to the environmental objectives and targets during the pre-operation
phase. The plan encompassed all the activities which support the execution of this project in
an environmental friendly manner. The environmental management plan is supported by
several documents including environmental operating procedures, work instructions,
emergency preparedness & environment recovery plans, and regulatory compliance
requirements applicable to project activities.
Planning
The environmental planning has been done for this project at the initial stages of this project,
before the construction work started. During the planning stage it has evaluated the project
specific regulatory requirements and associated significant environmental aspects of the
project. Environment aspects are being evaluated considering the project activities.
Operational Control
The system possesses a standard set of controls. Those are being customized to achieve the
requirements of this project site. The environmental objectives and targets of the LBPL will
be achieved through implementing environmental management programs, environmental
operational procedures, and other support systems in this project.
Monitoring and Measurement
All the project activities are being closely monitored during the entire project life cycle. The
level of environmental performance, which is required to maintain regulatory compliance and
52.2 MW Dual Fuel (HFO/Gas) Fired Power Plant ProjectComilla (Jangalia), Bangladesh
Environment & Social Monitoring Report
Page 8 of 30
to achieve other environmental objectives and targets, is being monitored frequently.
Observations, data reviews, compliance verification, and internal audits are being used as
monitoring and measurement tools.
Preventive and Corrective Action
During the monitoring & measurement the necessary corrective and preventive actions are
being taken appropriately, for all non-conforming situations arise.
Management Review
The entire environmental management system is subject to periodic management reviews.
The higher management of the LBPL monitors the Environmental Management performances
of the project during the management review meetings.
Implementations
1.Air Pollution
Air pollution occurs mainly due to dust generation and due to emissions from power plant
vehicles and machinery. Mitigation measures have been implemented to minimize the air
pollution due to dust generation through maintaining the access roads and power plant
premises area in wet condition by sprinkling of water daily. And also soil with low level of
dust particles has been used in the construction of the access roads and the surrounding areas
of the site. Mitigation measures also include the inspection of vehicles and machinery for
emission levels before deploying in the power plant work and the periodic maintenance of the
vehicles and machinery. The LBPL has been carried out regular inspections on site vehicles
and machinery. During power operations and maintenance the air emissions from the engines
and through the boiler operations has been monitored and maintained within the stipulated
emission limits.
2.Land Pollution
Soil erosion can be occurred in nearby lands due to the obstruction of natural rainy water
ways due to earth moving and removing of inhabitant vegetation. As the mitigation measure
the power plant management has created alternate rainy water ways appropriately to the site
condition. The trees and major vegetation of temporary areas such as labour camp area have
not removed. Land pollution also can occur due to oil spills from equipment & machinery. To
prevent these incidents the site management has carried out regular inspections on site
equipment & machinery and done necessary maintenance as required.
52.2 MW Dual Fuel (HFO/Gas) Fired Power Plant ProjectComilla (Jangalia), Bangladesh
Environment & Social Monitoring Report
Page 9 of 30
3.Water Pollution
Water pollution occurs due to sewage disposal and effluent water disposal. The water
pollution due to sewage disposal has been prevented through the construction of sewage and
septic tanks as appropriate to the conditions of the power plant sites. The water pollution due
to effluent water disposal has been prevented through the septic tanks and sand pits were
constructed to minimize impact of effluent water disposals. The LBPL has been worked in
conformance as per the waste water rules and regulations of the local government authorities
as appropriately. Waste concrete has been disposed as per the instructions of the local
government authorities and through approved waste contractors.
4.Noise Pollution
Noise pollution will also occur due to high noise generated from equipment & machinery. As
a mitigation measure the equipment & machinery shall be checked for the availability of
necessary vibration & noise controlling parts in place before using in the site they were being.
The power plant management will carry out regular inspections on equipment & machinery.
Usage of ear mufflers shall be provided for high noise work for the power plant employees.
5.Oil and Chemical Spillages
All oil and chemical have been stored in appropriate containers with proper labels. Hazardous
chemical have been effectively isolated to avoid contamination. The small oil spillages have
been responded immediately with oil collection trays and using cotton absorbents. The
necessary preventive measures have been taken to avoid any contamination with the natural
environment such as water bodies and ground. Oil collection trays and dry cotton absorbents
are being kept at the stores in-order to use during a spillage.
6.Waste Management
The waste is being collected in to a one location of the power plant site. Some of them are be
reused while others disposed. Waste disposal has been done as appropriately as per rules and
regulations of the local government authorities. The LBPL has taken necessary measures to
prevent land pollution through the disposal of reinforcement material off cuts. During the
construction period power plant management has been instructed to collect all the
reinforcement material off cuts in to a one location of the site. Some have been reused while
some have been disposed as appropriately as per rules and regulations of the local
government authorities. Land pollution due to the disposal of excess concrete has been
minimized through accurate measure of quantities during the planning stage. The 3R system
of waste management has been introduced in the project site.
52.2 MW Dual Fuel (HFO/Gas) Fired Power Plant ProjectComilla (Jangalia), Bangladesh
Environment & Social Monitoring Report
Page 10 of 30
2.2 Operation PhaseThe operations & maintenance not yet commenced. But the environment management plan
has been already developed after evaluating the possible environment aspects and their
impacts during the operation & maintenance phase. During the operation phase the
preventive maintenance will be carried out to identify and resolve problems related to
environmental impacts, with other monitoring activities at regular intervals. Monitoring of oil
water separation and sanitary waste treatment will be done periodically to avoid water
pollution. Other environmental good practices include noise abatement, maintaining hygienic
conditions, maintenance of fire and safety equipment etc. and clearing of grass will be done
periodically and medium height tree plantation around the boundry wall will be done at the
plant areas as appropriately. (Refer: Environment Management Plan L125-PLN-EM-001)
2.3 Post-operation PhaseThe post operations plans have been drawn. Those will be executed during a post operation
condition.
52.2 MW Dual Fuel (HFO/Gas) Fired Power Plant ProjectComilla (Jangalia), Bangladesh
Environment & Social Monitoring Report
Page 11 of 30
Chapter 3Institutional Arrangements and Environmental Monitoring
3.1 Activity of the Environmental and Social Monitoring Unit during the
reporting periodAs per the monitoring the overall environmental management of the project has been good so
far.
· Carried out an environmental aspects & impacts evaluation covering all the operations of
the project and environmental procedures are being implemented in this project as
appropriately.
· Environment awareness training sessions are being carried out to enhance environment
awareness.
· The emergency situation planning has been implemented with the environment recovery
actions to be executed aftermath of emergency situations.
Environmental monitoring is being conducted to compare the change between baseline
condition and after project scenario, by testing some environmental parameters of air, water
and noise and in case of necessity soil is tested. LBPL has conducted the environmental
monitoring as well as implementation of environmental management plan. The testing of
environmental parameters has been done with sophisticated instruments, by the SGS of
Bangladesh which is an accredited institution for testing and analyzing environmental
parameters.
3.2 Training UpdateTraining is an integral part of a preventive strategy. Environmental awareness, emergency
preparedness and response trainings have been provided to the power plant staff in-order to
ensure proper implementation of effective environmental management and disaster
management plans.
The training schedule covers the all identified training needs which include trainings on basic
fire-fighting, training on environmental regulations and standards, staff training on
environmental monitoring and also on occupational health and safety measures for site
workers.
The following trainings have been carried out for the power plant site staff at the power plant
project in Comilla (Jangalia), Bangladesh. (Refer: Annexure 02 for Training Records)
52.2 MW Dual Fuel (HFO/Gas) Fired Power Plant ProjectComilla (Jangalia), Bangladesh
Environment & Social Monitoring Report
Page 12 of 30
No Training DateIn-house/
Outbound
1 Waste management in the site March -2014 In-House
2 Use of PPE & Safe Work Practices Apr-2014 In-House
3 HSEQ Awareness Program May-2014 In-House
4 Maintaining the site HSEQ records May-2014 In-House
5 Basic First Aid June-2014 In-House
6 Waste management in the site June-2014 In-House
7 Electrical safety procedures for site July-2014 In-House
8 Basic Fire Training July-2014 In-House
9 Use of PPE & Safe Work Practices Aug-2014 In-House
10Use of PPE & Safe Work Practices – Welding
workSep -2014
In-House,
on the job
11 Use of PPE & Safe Work Practices Oct-2014In-House,
on the job
12 Use of PPE & Safe Work Practices -work at height Oct-2014In-House,
on the job
Conducted awareness trainings on environment, occupational health and safety for all the site
employees.
52.2 MW Dual Fuel (HFO/Gas) Fired Power Plant ProjectComilla (Jangalia), Bangladesh
Environment & Social Monitoring Report
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3.3 Environmental Monitoring requirement and status of reportingMonitoring Requirements
EnvironmentAspect
ImpactingActivities/
Source
KeyParameters Method Frequency Location
Ambient AirQuality
-Landpreparation &earth works- Openexcavation-Developmentof access roadsfor heavy equip.transport.
SPM, PM10,PM 2.5, SOx,NOx and CO
PassiveSampling
Quarterly(routine)Analysis
At project site,residential /
commercial areaswithin 500moutside from
plant boundary
SurfaceWater
-Domesticaffluent waterrelease fromworker facilities-Waste waterfromconstructionwork
pH,Temperature,
DO, BOD,COD,
TDS,TSS, Oiland Grease
PassiveSampling
Bi–anually(pre-
monsoon& post-
monsoon)
At project site
GroundWater
-Waste waterfromconstructionwork-Domesticaffluent water
pH,Temperature,
DO, BOD,COD, TDS,
Oil andgrease
PassiveSampling
Bi–anually(pre-
monsoon& post-
monsoon)
At project site
The OHS and environment awareness meetings and trainings have been carried out
frequently to instruct the worker representatives on day to day site maintenance procedures.
52.2 MW Dual Fuel (HFO/Gas) Fired Power Plant ProjectComilla (Jangalia), Bangladesh
Environment & Social Monitoring Report
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EnvironmentAspect
ImpactingActivities/
Source
KeyParameters Method Frequency Location
Noise
-Landpreparation &earth works- Openexcavation-PilingCommissioningand Testing
Limits in dBA 5 MinuteAverage
Quarterly(routine)analysis
At four cornersof projectboundary,residential/commercialareas within100m and
300m outsidefrom plantboundary
Surfacerunoff
Landpreparation &earth works
TurbidityMonitordrainagesystem
Duringrainy days At project site
Damages toRoads,
Bridges &Culverts
Heavyequipmenttransport
Visualdamages Inspect
Dailyduringheavy
equipmenttransport
At access roads
OilSpillages
Commissioningand Testing Any leakages
Inspect,monitorvehicleservicereports
WeeklyAt the site andother relevant
areas
SewageDisposals from
employeefacilities
Quantity,Disposalmethod,
Disposingarea
Record &Analysis Weekly At project site
Solid Waste
Disposals fromemployeefacilities
Installation ofplant &
machinery
Types ofwaste,
Quantity,Disposalmethod,
Disposingarea
Record &Analysis Weekly At project site
SanitaryStatus
Maintenance ofemployeefacilities
Cleanliness,Orderliness
Tool boxmeeting Weekly At project site
52.2 MW Dual Fuel (HFO/Gas) Fired Power Plant ProjectComilla (Jangalia), Bangladesh
Environment & Social Monitoring Report
Page 15 of 30
Ambient Air Quality Test Results
The LBPL has carried out the environment parameter tests namely Ambient Air Quality Test (PM10, PM2.5, SO2, NO2, O3, CO) and the Noise
Level Tests in September 2014 at the Comilla power plant construction site. The test reports indicate normal. (Refer: Annexure 01 for Test Reports)
L1 – Engine Hall Area
L2 – Radiator Area
Aspect Regulation
Requirements
Actual ResultTesting
Date
Testing
done by
Pollutant
Max. permissible level (µg/m3) 08
Hrs Average
Ambient
Air
Quality
World bank guidelines
Thermal power:
guidelines for new
plants
(July 1998)
&
Department of
Environment (DOE) -
Bangladesh Standards
DOE -
BangladeshWorld Bank L1 L2
20/09/2014
SGS
Bangladesh
Ltd
PM 10 150 150 52 61
Sulfur
Dioxide365 125 16 19
Oxides of
Nitrogen100 150 21 23
Carbone
Monoxide10,000 NF 120 110
Ozone 157 160 17 14
52.2 MW Dual Fuel (HFO/Gas) Fired Power Plant ProjectComilla (Jangalia), Bangladesh
Environment & Social Monitoring Report
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Noise Test Results(Refer: Annexure 01 for Test Reports)
L1 – WestL2 - EastL3 – SouthL4 - North
Aspect Regulation Requirements
Actual ResultTest
Date
Testing
done by
Noise
World bank
guidelines
Thermal
power:
guidelines for
new plants
(July 1998)
&
Department of
Environment
(DOE) -
Bangladesh
Standards
(Industrial
Area)
Max. Permissible Noise levels
at boundaries (LAEq) dBA
DOE -
BangladeshWorld Bank L1 L2 L3 L4
20/09/
2014
SGS
Banglades
h Ltd
D N D N D N D N D N D N
75 70 70 70 64.29 54.11 74.33 52.39 70.29 51.19 65.17 53.44
52.2 MW Dual Fuel (HFO/Gas) Fired Power Plant ProjectComilla (Jangalia), Bangladesh
Environment & Social Monitoring Report
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3.4 Environmental Monitoring BudgetAn environment budget has been already estimated for the operation and maintenance phase. The
actual spending on environmental monitoring activities during the operation and maintenance
phase can be derived once the operation and maintenance of the power plant starts.
3.5 Additional Reporting requirement to IDCOLThis report has been compiled considering the requirements of the Infrastructure Development
Company Limited (IDCOL) which gave the financial assistance to LBPL arrange the project
financing. Required environment and social monitoring status information has been included in
this report. There are no any additional reports to be disclosed herewith. The report addresses the
aspects of the Environmental and Social Safeguards Framework (ESSF) of IDCOL.
As per the requirement of the IDCOL this report has been prepared based on the guidelines of
Department of Environment (DOE), Government of Bangladesh (GOB) and Asian Development
Bank’s (ADB’s) Safeguard Policy Statement (SPS).
52.2 MW Dual Fuel (HFO/Gas) Fired Power Plant ProjectComilla (Jangalia), Bangladesh
Environment & Social Monitoring Report
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Chapter 4Anticipated Environmental Impacts and Mitigation Measures
4.1 Environmental, Social and Occupational Health & Safety Impacts during
pre-operational and operational phaseThe project is still in the pre-operation phase and the necessary mitigation measures have been
implemented accordingly to the initial plan. The major activities during the pre-operation phase
of the proposed power plant include mobilization of equipment, materials and personnel, site
preparation, civil construction and electromechanical installation/erection etc. The LBPL has
taken several initiatives with regard to environmental aspects, social issues and as well as to
occupational health & safety conditions during pre-operation phase. The necessary preventive
and corrective actions have been taken for the environmental aspects and their impacts on
environment due to various activities during construction phase of the project. Stakeholder
grievances and other social issues are being addressed promptly. The occupational health and
safety of the site workers are being closely monitored all the time during the work.
4.2 Actions taken against the impactsThe site rounds and tool box meetings have been carried out at the project site to identify and
resolve problems at regular intervals. Other environmental good practices implemented include
minimizing air pollution, maintaining hygienic conditions, maintenance of fire and safety
equipment etc. and clearing of grass have been done periodically.
LBPL has developed a working relationship with the environment authorities of Bangladesh by
undertaking a joint monitoring program to monitor ambient air quality and also to assess whether
there is any significant noise problem. During the construction phase up to date, the LBPL has
ensured the activities such as land leveling, clearing work, access road construction, putting
proper traffic signals etc. were being carried out properly to minimize the level of impact. This
has been monitored by the Health, Safety & Environment Officer of the LBPL.
During mechanical erection phase special attention given to the occupational health and safety of
the workers. Those activities included hot work, work at height, electrical work and etc. Since,
some of the workers who are unskilled joined from the neibouring villages. They are being given
training and provided with necessary personal protective equipments.
52.2 MW Dual Fuel (HFO/Gas) Fired Power Plant ProjectComilla (Jangalia), Bangladesh
Environment & Social Monitoring Report
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Project Activity Potential Impact Mitigation Measures
Access to the site
and site clearance
Temporary obstruction of
access roads, waterways,
clearance of trees and shrubs.
· Minimized disturbance and the clearing
of vegetation.
Soil erosion in nearby lands due
to the obstruction of natural
rainy water ways due to earth
moving and removing of
inhabitant vegetation.
· Created alternate rainy water ways
appropriately to the site condition.
· The trees and major vegetation of
temporary areas such as camp area have
not removed.
Site mobilization
Impact to the external
environment by putting
construction waste.
Topographic change by cutting
existing trees, shrubs, herbs,
and filling land.
· Disposal of debris done in accordance
with local authority regulations and
advice.
· Some design changes have been done to
minimize the cutting of trees, shrubs,
herbs, and lowland filling.
· Used waste shrubs, herbs as organic
fertilizers.
· Measures taken to prevent waste
shrubs, herbs as fuel to cook or for any
controlled burning purpose.
Preparation and
level grading of
storage & site
office area
Air pollution due to dust
generation.
· Maintained the access roads and site
area in wet condition by sprinkling
water daily.
Air pollution due to emissions
from site vehicles and
machinery.
· Before deploying in the site work they
were being inspected for emission
levels and the periodic maintenance.
· Carried out regular inspections on site
vehicles and machinery.
52.2 MW Dual Fuel (HFO/Gas) Fired Power Plant ProjectComilla (Jangalia), Bangladesh
Environment & Social Monitoring Report
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Project Activity Potential Impact Mitigation Measures
Usage of
construction
vehicles,
equipment &
machinery
Land pollution due to oil spills
from construction vehicle,
equipment and machinery.
· Carried out regular inspections on site
vehicle, equipment and machinery.
· Done necessary maintenance as
required.
· Oil collection trays and dry cotton
absorbents were kept at the stores in-
order to use during a spillage.
Influx of workersGeneration of sewerage and
solid waste.
· Distributed a leaflet on site health &
safety, environmental regulations and
other general rules for the site workers.
· Erection of the information boards to
aware the workers on site cleanliness.
The sign boards contained phrases such
as “keep the site clean”.
· Constructed sanitary latrines and septic
tank system.
· Installed waste bins/cans, where
appropriate around the site.
· Implemented procedure on waste
minimization, recycle and reuse
mechanisms as required.
· Trained site workers on proper
segregation and disposal of solid waste.
Transportation of
equipment,
materials and
personnel
Deterioration of air quality from
increased vehicular movement,
affecting people in the
surrounding areas.
· Regular checking of vehicle condition
to ensure site vehicles are in good
condition.
· Took necessary actions to ensure
vehicle emission comply with local
standards and EHS guidelines, where
applicable)
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Project Activity Potential Impact Mitigation Measures
Storage of
Construction
materials and
debris
Wind-blown dust from material
(e.g. sand, fine aggregate) at
storage areas.
· Watering the access road.
· Sprinkling and covering stock piles.
· Covering top of trucks carrying
materials to the site and carrying
construction debris away from the site.
Visual degradation of areas
caused by cleaning vegetation
for lay down of materials.
· Selected suitable level area and
minimized removal of vegetation.
· No clearing of vegetation or soil by
grading with machinery has been done.
Storage of
chemicals and
materials
Contamination of receptors
(land, water, air).
· Oil securely stored above high flood
level.
· Oil collection trays placed under the
containers that are filled-up full.
Noise from
construction
equipment
operations and
maintenance
Hearing discomforts for
neighborhood and site workers.
· Install such machinery on resilient
foundations and in enclosed areas.
· Avoided, as much as possible,
construction equipment producing
excessive noise.
· Avoided prolonged exposure to noise
by workers.
· Followed construction scheduling to
avoid evening and nighttime
disruptions.
· Wearing of ear mufflers and use of
other appropriate PPEs when required.
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Project Activity Potential Impact Mitigation Measures
Dust during
construction and
exhaust gases
from construction
machinery and
vehicles
Increased SPM, PM 2.5, PM 10,
NOx, SOx levels at construction
sites, and surrounding areas
Emission of dust to the
neighboring houses, buildings.
· Avoided using equipment such as stone
crushers at site, which produces
significant amount of particulate matter.
· Immediate disposal/sale of excavated
materials and continuous watering of
bare material stock piles.
· Immediate use of construction spoils as
filling materials.
Effluent arising
from domestic
activities
Contamination with land and
water
· Released them in to a soakage pits or
septic tanks as appropriately.
Storage of fuel oil
and other types of
oil
Accidental oil spillages and fire
hazards
· Use of properly designed storage tanks
suitably located.
· Use of a proper secondary containment
to store excess.
· Implementation of necessary fire
extinguishing mechanisms.
Provision of
facilities for
power plant
workers
Contamination of receptors
(land, water, air)
· Construction workforce temporary
facilities to include proper sanitation,
water supply and waste disposal
facilities.
Nuisance to
nearby properties
Losses to neighboring land
uses/ values.
· Held awareness trainings for site
workers to implement careful work
practices.
Hazardous waste
from plant (scrap
metal, waste, lube
oils, spill oil etc)
Potential soil and groundwater
contamination.
· Secure on-site storage of hazardous
waste.
· Sell waste to the authorized vendor for
discharge in a safe place.
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Chapter 5Emergency Response and Disaster Management
5.1 Brief description of the planThe LBPL has developed an emergency response and disaster management plan to take
necessary actions to prevent any un-wanted disaster in the plant. Disaster could also be occurred
if any sudden flood, earthquake and fire occur or if the equipment/ machinery fail to work at
normal condition. In this regard provisions have been made to stop the ongoing activities
immediately during any emergency situation. Separate emergency preparedness and response
plans have been developed for each and every identified emergency situation. This plan also
includes a separate natural disaster preparedness, response & recovery Plan.
5.2 Preparedness for the planThe below preventive measures have be taken to be executed during an emergency or a disaster.
· Address soil erosion during and after heavy rainfall
· Formulation and strict implementation of safety codes and measures
· Periodic inspection of safety valves and equipment
· Preventive maintenance
· Precautionary measures for electro-magnetic wave or electrical interference
· Prohibit smoking in the site premises
· Mock firefighting drills
· Provision and inspection of firefighting equipment and fire hydrant system periodically
· Proper training of the employees about the environment compliances
· Training the employees and the residents of the surrounding villages about the actions to
be taken during an accident, disaster etc.
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Fire Prevention and response plans implemented.
Installation of Fire Extinguishers, Sand Buckets.
Designed, implemented and tested the site emergency plan.
Installed emergency siren at the site and done trial emergency evacuations.
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Chapter 6Grievance Redress Mechanism
6.1 Brief Description of the Mechanism and PolicyThis grievance procedure will ensure that all comments and complaints from any project
stakeholder, including local or regional authorities, residents of nearby residential areas, project
employees and other interested parties, are acknowledged and responded to within a reasonable
timeframe.
LBPL will accept all comments and complaints associated with the project activities. The
comments and complaints will be summarized and listed in a Complaints/Comments Log Book.
6.2 Status of Stakeholder engagementLBPL stakeholder’s engagement has taken place in a variety of contexts, and using a range of
methods. Against this background, engagement will include consultation, joint planning,
capacity building, partnerships, community-based monitoring and reporting.
LBPL has hold meetings with the participation of all the stakeholders in the project who are
impacted directly or indirectly and with the area’s public liaison committee.
Provisions have been made to evaluate the health safety aspects of the communities residing near
the project site from the project activities. The conditions will be considered and evaluated time
to time during the project execution.
6.3 Allocation of Resource and ResponsibilitiesTo ensure proper caring on grievances raised by project stakeholders the resource and
responsibilities has been allocated in two levels as are mentioned below.
Power plant site level
LBPL has assigned a dedicated person as the project stakeholder’s liaison officer at power plant
site. He has the overall responsibility for handling the consultation and information disclosure
process, at the site level. The responsibilities and activities includes,
· Organize the stakeholder awareness activities
· Communicate with identified stakeholder groups
· Collect and process comments/complaints
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· Respond to comments and complaints
Depending on the nature of a comment/complaint, some comments/complaints will be provided
to the appropriate person or committee in the company for a response.
Contact detail of resource person
Name: Mr. N. SivakumarPhone: 8802-8410330
Email: [email protected]
Corporate Level
A senior representative of LBPL is being assigned to represent the corporate level in dealing
with project stakeholder’s grievance addressing process and consultation. He is expected to
review the findings/ observations forwarded to plant level and who will be responsible for
implementing the decisions.
Contact detail of resource personName: Mr. A.B Siddique
Phone: 8802-8418513
Email: [email protected]
6.4 Reporting Status
All comments and complaints will be responded to either verbally or in writing, in accordance
with preferred method of communication by the LBPL depending on the urgency of the issue.
All grievances will be registered and acknowledged within 5 days and responded to within 20
working days. Some grievances will be resolved at the power plant site level with the
consultation with the power plant management. The issues need cooperate level involvement will
be directed to the higher management of the company immediately.
LBPL maintains a Complaints/Comments Log Book which is available at the power plant site
office. All the decisions taken with regard to project stakeholders’ grievances will be recorded
with evidence for future reference. Summary of minutes of the community meetings and records
of corporate communication programmes will be will be reported in project progress reports and
in other relevant corporate documentation as appropriately.
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Chapter 7Information Disclosure, Consultation and Participation
7.1 Stakeholder ConsultationThe main objective of the consultation meetings was to inform the local inhabitants about the
project and to seek their opinion regarding the impacts if any. The feedback of public
consultation helped to ensure that the decision making process is fair and lead to better
environmental outcomes. The findings from the public consultations were utilized in the
development of the environment management plan, especially in identifying the significant
impacts of the project and developing the corresponding mitigation measures.
The activities of the consultations were as follows:
§ Dissemination of information about the project among the stakeholders
§ Get a better understanding of existing environmental conditions
§ Aware stakeholders to contribute meaningfully in different phases of the project
§ Reduce the psychological distance between LBPL and the stakeholders
Public consultation has been carried out during different activities in the project lifecycle, using
different techniques such as public meeting, small group meeting, and informal meeting. During
such consultations the public was informed about the project in general.
Consultation meetings with local government representatives of Upazila ParishadIn general community stakeholders are categorized into two broad categories. They are directly
affected and indirectly affected. Directly affected community stakeholders include people who
will have the potentiality to be directly impacted through loss of land, crops and other assets,
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environmental and social adverse impact due to the project. Indirectly affected community
stakeholders include those people of the project area who have the potentiality to be affected by
the project activity at a limited extent.
As a part of discussion with directly impacted stakeholders, there was consultation with both
male and female representatives living in adjacent to the Project site as shown in the following
photographs. In addition, to get feelings about the indirectly impacted stakeholder, there was a
separate consultation at Jangalia Market area. In this consultation, the opinions of all classes of
people including businessman, general public were taken. These have been documented in the
following photographs.
Consultation with the villagers who can be directly and indirectly affected
There are several non-governmental organizations (NGOs) working in the project impacted area.
The NGOs are both international and local. There are several organizations that seek to
coordinate local NGO activities.
NGO activities are wide ranging, including agricultural support, health care support, micro
credit, family support, environmental advocacy and support to vulnerable groups (elderly,
orphans and abandoned children).
There are a number of NGOs operating at Jangali and Doiara. Among them Bangladesh Rural
Advancement Committee (BRAC), Jagoroni and Association for Social Advancement (ASA)
were consulted as they have the higher coverage in terms of area of operation.
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Consultation meeting at City Corporation Consultation meeting with ASA NGO
7.2 Response to Issue Raised by StakeholdersIn the stakeholder meetings and consultations, a number of issues were discussed. Among them
the major issues can be presented as follows with the response of LBPL.
Requests for employment in the power plant project
The power plant site is located in a semi urban and agricultural area and the rate of
unemployment is very high. As a result, most of the stakeholders requested for providing job
opportunities for semi-skilled and unskilled local people. In response, LBPL most of the
unskilled jobs were allocated to the locals during construction phase.
Impact on livelihood due to vehicle movements
During construction phase there were frequent movements of heavy vehicle to and from the
power plant site. To minimize adverse effects and disturbance LBPL has taken measures to
deploy vehicles in better condition to minimize the noise and the emissions of the vehicles and
limit the speed of vehicles to avoid accidents.
7.3 Information DisclosureThe LBPL has carried out several meetings and consultations with the villagers and public to
disseminate information on the project activities among the project affected persons. The formal,
informal meetings and focus group discussions have been carried out in this process. The formal
meetings were held through prior notice and invitation for all project affected persons,
households, district administration, local administration and other stakeholders in the affected
area.
Activities carried out during these meetings and consultations include,
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· Identified the project affected persons
· Identified and informed the government agencies connected with the project
· Identified the closest households or commercial institutions of the project site and make
them aware of the impacts of the project and note their concerns.
Time to the information on the project activities were disseminated to the project affected people
and also the nature of impact and compensation issues were discussed.
Dissemination of information on the project activities and information disclosure carried out
during the sample-based socio-economic survey which had covered 120 households within the
impact zones.
One large public consultation meeting has been held including all the project affected persons,
representatives from the project impacted areas, district and local administration, as well as other
community representatives including prominent local people, lawyers, journalists and
academicians.