8408P01/FICHT-17505991-v9

Due Diligence Site Audit Report

Environmental and Social Management for Thaton Combined Cycle Gas Turbine (CCGT) Power Plant

SFG3712 V2Updated Final Report June 2017

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8408P01/FICHT-17505991-v9

Disclaimer The content of this document is intended for the exclusive use of Fichtner’s client and other contractually agreed recipients. It may only be made available in whole or in part to third parties with the client’s consent and on a non-reliance basis. Fichtner is not liable to third parties for the completeness and accuracy of the information provided therein.

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Table of Contents

1.  Introduction 8 

1.1  Authorization 8 

1.2  Objective and background of the assignment 8 

1.3  Changes in the Project’s objectives 9 

1.4  Scope of work 9 

1.4.1  Socio-economic surveys 9 

2.  National EHS legal, institutional and policy framework and status 11 

2.1  Policy framework 11 

2.1.1  National Environmental Policy (1994) 11 

2.1.2  Myanmar Agenda 21 (1997) 12 

2.1.3  National Sustainable Development Strategy – NSDS (2009) 12 

2.1.4  Waste Management Policies 12 

2.2  Institutional framework 13 

2.2.1  Environmental Conservation Department (ECD) 13 

2.2.2  Institutions for waste management 14 

2.2.3  Institutions for OHS 15 

2.3  Legal framework 16 

2.3.1  Environmental Conservation Law (2012) 16 

2.3.2  Waste management 17 

2.3.3  National Environmental Quality (Emission) Guidelines 18 

2.3.4  Occupational Health and Safety (OHS) 22 

2.3.5  Employment conditions 24 

2.4  Present situation of waste management in Myanmar 24 

2.4.1  Challenges 25 

2.4.2  Yangon 26 

3.  Review of existing documents 28 

3.1  Gaps in the documentation 29 

4.  On site situation 31 

4.1  General 31 

4.2  Welfare conditions 32 

4.3  Housing area 32 

4.4  Workers rights 33 

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4.5  Wastewater 33 

4.6  Stack emissions 34 

4.7  Solid and hazardous waste 34 

4.8  Noise 34 

4.9  Monitoring and inspections 34 

4.10  EHS training 35 

4.11  Emergency procedures and first aid 35 

4.12  Polychlorinated biphenyls (PCB) 35 

4.13  Asbestos 37 

5.  Compliance with international environmental and social standards 38 

5.1  IFC Performance Standards 38 

5.1.1  PS 1: Assessment and Management of Environmental and Social Risks and Impacts 39 

5.1.2  PS 2: Labor and working conditions 40 

5.1.3  PS 3: Resource Efficiency and Pollution Prevention 41 

5.1.4  PS 4: Community Health, Safety and Security 41 

5.1.5  PS 5: Land Acquisition and Involuntary Resettlement 41 

5.1.6  PS 6: Biodiversity Conservation and Sustainable Management of Living Natural Resources 41 

5.1.7  PS 7: Indigenous Peoples 42 

5.1.8  PS 8: Cultural Heritage 42 

5.1.9  Summary of compliance with the IFC PS 42 

5.2  IFC EHS Guidelines 43 

5.2.1  Assessment of compliance 43 

6.  Environmental and Social Action Plan 44 

7.  Conclusion and future work 53 

8.  References 54 

9.  Annexes 56 

9.1  Annex 1: Photographic documentation 56 

9.1.1  Due Diligence Site Audit - 1st visit (July 2016) 56 

9.1.2  Due Diligence Site Audit - 2nd visit (September 2016) 60 

9.2  Annex 2: Certificate of the Analytical Laboratory 61 

9.3  Annex 3: Results of the PCB analyses 62 

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9.4  Annex 4: Results of the asbestos analyses 65 

9.5  Annex 5: IFC Performance Standards checklist 69 

9.6  Annex 6: IFC EHS Guidelines checklist 83 

9.7  Annex 7: First Aid Kit 95 

9.8  Annex 8: Definitions 97 

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List of Tables

Table 2-1:  Wastewater, Storm Water Runoff, Effluent and Sanitary Discharges (general application) a 19 

Table 2-2:  Site Runoff and Wastewater Discharges (construction phase) 20 Table 2-3:  WHO Ambient Air Quality Guidelines 20 Table 2-4:  Noise Limits 21 Table 2-5:  Liquid effluent Limits 21 Table 2-6:  Air Emission Limits (applicable to non-degraded air sheds) 22 Table 4-1:  Results of the analysis for PCB in oil samples from the Thaton

Power Plant 36 Table 5-1:  Summary of compliance with the IFC PS 42 Table 6-1:  Environmental and Social Action Plan for the existing Thaton

Power Plant 45 Table 9-1:  Assessment of compliance with PS 1 69 Table 9-2:  Assessment of compliance with PS 2 72 Table 9-3:  Assessment of compliance with PS 3 75 Table 9-4:  Assessment of compliance with PS 4 76 Table 9-5:  Assessment of compliance with PS 5 77 Table 9-6:  Assessment of compliance with PS 6 79 Table 9-7:  Assessment of compliance with PS 7 80 Table 9-8:  Assessment of compliance with PS 8 81 Table 9-9:  Assessment of compliance of the Thaton Power Plant with the IFC

EHS guidelines (General and Thermal Power Plants) 83 Table 9-10:  Equipment List for a large first aid kit according to DIN 13169 95 

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List of Figures Figure 4-1:  Housing area for the workers of the Thaton PP 32 Figure 6-1:  Safety instructions for chemical handling and emergency response

(bilingual, mixed text and graphics) (FGLLID, year unkown) 52 Figure 6-2:  Example of storage of hazardous liquids in bunded areas (FGLLID,

year unkown) 52 Figure 9-1:  Fall risk in a switchyard 56 Figure 9-2:  Fall risk inside the WTP 56 Figure 9-3  Cloth line inside the WTP 56 Figure 9-4:  Missing gate at a switchyard 56 Figure 9-5:  Open-air storage of HCL 56 Figure 9-6:  Tea shop and library 56 Figure 9-7:  First aid box 57 Figure 9-8:  New fire extinguishers 57 Figure 9-9:  Lunch at Thaton PP inside one of the control rooms 57 Figure 9-10  Broken fence at the GT 1 + 2 area 57 Figure 9-11:  Stacks of GT 1 and GT 2 57 Figure 9-12:  Unsafe electric installation in the administration building 57 Figure 9-13:  Battery storage inside the administration building 57 Figure 9-14:  Storage of old mercury containing light bulbs, and chemicals in the

administration building 57 Figure 9-15:  Waste scattered on site 58 Figure 9-16:  Storage of old, used oil in leaky storage building 58 Figure 9-17:  Broken ceiling in storage building, asbestos containing 58 Figure 9-18:  Storage of unlabeled, full drums inside the WTP 58 Figure 9-19:  Unstable storage of unlabeled, full drums inside the WTP 58 Figure 9-20:  Old, not longer used steam turbine building, covered with

potentially asbestos-containing panels 58 Figure 9-21:  Inside the old steam turbine building 59 Figure 9-22: Tea shop 60 Figure 9-23  Asbestos panels in the tea shop 60 Figure 9-24:  Worker on transmission line without PPE 60 Figure 9-25:  Worker without PPE 60 Figure 9-26:  Hospital in Thaton 60 Figure 9-27:  Fire Brigade in Thaton 60 

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Abbreviations and Acronyms BAT Best Available Techniques CCGT Combined Cycle Gas Turbine CEEC China Energy Engineering Company DD Due Diligence e.g. exempli gratia / for example ECC Environmental Compliance Certificate ECD Environmental Conservation Department EHS Environmental, Health, and Safety EHS-MS Environmental, Health & Safety Management Systems EIA Environmental Impact Assessment EMP environmental management plan EPA Environmental Protection Agency EPGE Electric Power Generation Enterprise ESA Environmental and Social Assessment ESAP Environmental and Social Action Plan ESMP Environmental and Social management Plan FDS Final Disposal Site FGLLID Factories and General Labour Laws Inspection

Department FMEA Failure Mode and Effects Analysis FPIC Free, Prior and Informed Consent GIIP Good International Industry Practice GT Gas Turbine H&S Health and Safety HAZID Hazard Identification HAZOP Hazardous Operations Analysis HCl hydrogen chloride ICP Informed Consultation and Participation IDA International Development Association IFC International Finance Corporation IP Indigenous Peoples ISWM Integrated Solid Waste Management MEPP Myanmar Electric Power Project MMIC Myanmar International Consultants Co. Ltd. MOECAF Ministry of Environmental Conservation and Forestry MOEE Ministry of Electricity and Energy NaOH Sodium Hydroxide NECC National Environmental Conservation Committee NGO Non-Governmental Organisation NSDS National Sustainable Development Strategy OHS Occupational Health and Safety PAPs Project Affected Persons PCB Polychlorinated Biphenyls

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PCCD Pollution Control and Cleansing Department PCDD Polychlorinated Dibenzodioxin PCDF Polychlorinated Dibenzofuran PP Power Plant PPAH Pollution Prevention and Abatement Handbook PPE Personal Protective Equipment PS Performance Standards QRA Quantitative Risk Analysis SOPs Standard Operating Procedures SWM Solid Waste Management TPP Thaton Power Plant UNDP United Nations Development Program WEHRA Working Environment Health Risk Assessment WHO World Health Organization WTP Water Treatment Plant YCDC Yangon City Development Committee

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1. Introduction

1.1 Authorization

Electric Power Generation Enterprise (EPGE), Myanmar

as Client appointed the cooperation of

FICHTNER GmbH and Co KG, Germany

as Consultant, and which subcontracted

Myanmar International Consultants Co. Ltd. (MMIC) to perform the consulting services for the Project

Environmental and Social Management for Thaton Combined Cycle Gas Turbine (CCGT) Power Plant

The Lump Sum Contract, funded by a credit from the International Development Association (IDA), entered into force on the 24th of June 2016 after signing by both parties.

1.2 Objective and background of the assignment

Myanmar is facing large electricity shortages and blackouts in the power system. The power system experienced more than 15 blackouts in 2012. Thus the Government of Myanmar through the Ministry of Electricity and Energy (MOEE) has requested the World Banks’s support in scaling-up gas fired power generation in order to rapidly reduce and eventually eliminate electricity shortages and improve reliability and quality of power supply in the country. In this sense, the Myanmar Electric Power Project (MEPP) has been launched. One of the components of the MEPP is the phased replacement of the existing gas turbines at the Thaton Power Plant in the Mon State (the “Project”). A technical study on the MEPP, and an Environmental and Social Assessment (ESA) of the Project have been undertaken by Norconsult in 2013. The main objective of Fichtner’s consultancy services is to develop and implement an Environmental, Health & Safety Management Systems (EHS-MS) for the construction and the operation of the Project. From a social point of view, the main objective of the Project is to conduct public consultations with and socio-economic surveys of the communities neighboring the plant.

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1.3 Changes in the Project’s objectives

The original idea of the Project was the replacement of the existing gas turbines at the Thaton PP. But the technical study on the MEPP recommended prioritizing the development of a new CCGT power plant at Thaton. The recommendation was based on the fact that the existing gas turbines at Thaton are very old and the existing electrical connections are good (ESA Norconsult, 2013). After the kick-off meeting for the current assignment, it became clear that there will be no replacement activities at the old Thaton PP, and that the focus is nowadays directed towards the construction of a completely new CCGT at Thaton.

1.4 Scope of work

As part of its assignment, Fichtner undertook an EHS Due Diligence (DD) Audit of the Thaton Power Plant in July 2016. In September 2016, a new visit to the power plant was undertaken to clarify open issues from the first visit. The DD aimed at the identification of the EHS risks of the existing plant. The compliance of the plant’s structures and operations with related legislation and standards has been accessed as well during the DD Audit. The site visits included interviews with the Power Plant Manager/Superintendent Engineer U Hta Linn San, with the Deputy Plant Manager/Executive Engineer U Soe Lwin and the Construction Site Manager Mr. Yin Xiangyang (S&I Contractor, China Energy Engineering Company - CEEC). This managing staff guided Fichtner’s specialists during the DD Audit. Beside the existing facilities of the old Thaton PP, the new construction site for the future workers’ camp could be visited. The construction of the new plant is, however, not in the scope of the present report. The results of the EHS DD Audit are described in Section 4 of this report.

1.4.1 Socio-economic surveys

Fichtner’s social experts updated the socio-economic survey available in the ESA (Norconsult, 2013) with new findings and results. A first general socio-economic survey was undertaken in July 2016, and a detailed one was undertaken in September 2016. The surveys collected socio-economic data related to demography, education, health, water supply and sanitation, basic infrastructure, livelihood, ethnic groups, community groups, vulnerable groups, administrative structure, wealth ranking of households, etc. Young

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people have been recruited and trained to play important roles (e.g. as numerators) in the detailed survey teams. The results of the socio-economic surveys are described in a separate report.

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2. National EHS legal, institutional and policy framework and status

To achieve ecologically sustainable development in Myanmar, it is necessary to mainstream the environmental conservation into development planning. Myanmar is increasingly investing in industry and natural resources exploitation. Most of the development projects are related to oil and gas, hydropower, urbanization and industrialization which may lead to environmental degradation and pollution. Since 2011, Myanmar has been engaged in an active process of institutional and political reform and is gearing towards rapid socio-economic change and development. As part of this process, the Government of Myanmar is putting in place the necessary legal, procedural and governance instruments while building the institutional, technical and human capacities needed to achieve sustainable development in all sectors of the economy (MINDC, 2015). It is the government’s policy to work for economic development, in parallel with environmental conservation, which has been integrated into the national development planning. Some environmental, health, and safety (EHS) issues are not presently sufficiently covered by legislation and policies, but efforts are being made at a national level to improve the situation. The present Section presents a short overview of the EHS legal, institutional and policy framework in Myanmar. The Section focuses on those issues which are relevant for the present assignment.

2.1 Policy framework

2.1.1 National Environmental Policy (1994)

Myanmar’s National Environmental Policy was developed in 1994 for integration of environmental considerations into social and economic development. Specifically, the policy aims to: achieve harmony and balance between socio-economic, natural

resources and the environment. define environmental protection as the primary objective in seeking

development. The National Environmental Policy, Framework and Master Plan (2030) is currently being developed with UNDP’s (United Nations Development Program) support and will update the National Environmental Policy (MINDC, 2015).

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2.1.2 Myanmar Agenda 21 (1997)

In 1992, 178 countries, including Myanmar, adopted a non-binding agreement on sustainable development, called Agenda 21. Agenda 21 lays out actions these countries have agreed to take on different aspects of sustainable development. In 1997, Myanmar’s government published the Myanmar Agenda 21, a document that explains how the country intends to meet its obligations under Agenda 21 (BEWG, 2012). As a consequence of its Agenda 21, Myanmar developed the National Sustainable Development Strategy (NSDS) in 2009, with help from the United Nations Environment Programme (UNEP) (see Section 2.1.3 below).

2.1.3 National Sustainable Development Strategy – NSDS (2009)

The NSDS (2009) is the guiding document for achieving harmony between the environmental, the economic and the social sectors in Myanmar. The NSDS contains programmes for: making food systems more sustainable; improving industrial production methods to make them more

sustainable; growing eco-tourism (which includes preserving the environment and

maintaining cultural integrity); supporting research into sustainable development, and building better

institutions to manage sustainable development; and conducting public sustainable development education and

participation (BEWG, 2012). Specifically in the field of waste management, the NSDS has dispositions to: formulate a solid waste management master plan and guidelines with

priority on big cities; enact a hazardous waste law; educate the general public to promote environmentally sound waste

management; develop a framework for hazardous waste management and encourage

private investments in solid waste management services.

2.1.4 Waste Management Policies

Waste management services are undertaken in Myanmar by different responsible organizations independently. Therefore, related policy statements may differ from one organization to another. However, a common essence of the different policies is “to develop a systematic waste disposal and collection system in order for the city to be free of repulsive dumpsites”. The policies also call for cooperation and

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involvement of local authorities and communities in the waste management. The National Waste Management Strategy and Action Plans are currently being developed and are expected to be completed in 2017 (MINDC, 2015).

2.2 Institutional framework

As from April 2011, the National Environmental Conservation Committee (NECC) ceased its activities as the central organization for the national environmental management in Myanmar. Instead, the Ministry of Environmental Conservation and Forestry (MOECAF) has become the focal and coordinating agency for the overall environmental management. Within the MOECAF, the Environmental Conservation Department (ECD) is now approved for the effective implementation of environmental conservation and management in Myanmar (see Section 2.2.1 below).

2.2.1 Environmental Conservation Department (ECD)

Within the ECD, the following divisions are important: Pollution Control Division, with the following responsibilities:

to lay down the guidelines for promoting clean development technology in industries;

to systematically manage industrial waste in industry estate, including hazardous waste;

to promote modern technologies for waste collection, treatment and recycling;

pollution monitoring; to conduct environmental quality assessments; to develop the environmental quality standards in close

coordination with relevant agencies; to manage waste for the prevention of pollution.

Natural resources conservation and EIA division, with the following

responsibilities:

assessment of natural resources in cooperation with relevant departments;

to conserve ecosystems, nature reserves, and biodiversity; to conserve wetlands and rivers; to develop an EIA procedure and regulations; to monitor the implementation of environmental conservation

measures; to review the EIA reports.

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2.2.2 Institutions for waste management

Responsible agencies for waste management in Myanmar are the City Development Committees in Yangon (see Section 2.2.2.1 below), Mandalay, and Nay Pyi Taw and the Township Development Committees in the townships (of 285 townships countrywide). Waste collection services and management activities are undertaken independently by each development committee. Therefore, waste management practices may vary from one township to another.

2.2.2.1 Yangon City Development Committee

In order to provide clarity on the functioning of the waste management committees, a brief explanation about the Yangon City Development Committee (YCDC) is provided. The YCDC has administrated Yangon City since enactment of the Yangon City Development Act in 1990. This act gave YCDC a ministerial status as well as a wide range of duties and responsibilities, including urban planning, urban sanitation and environmental management in Yangon City. There are twenty Departments, including the Pollution Control and Cleansing Department (PCCD). The duties and function of the PCCD are: Daily Cleaning:

waste collection (households, markets, kerbshops,commercials, clinics and others)

waste transportation; waste disposal into the final disposal site (FDS).

Pollution Control: FDS management; cemeteries management; recycling activities (YCDC and privates); green composting; awareness programs for local communities and schools.

Solid Waste Management (SWM): bell ring collection, manual loading, transport and dispose to FDS; temporary brick tanks; dust bins: transfer to push cart, load to waste truck; transport and dispose to FDS; emptying the liter dust bins; driving and maintaining the waste collection vehicles (294).

In the Thaton PP: The management of the plant’s waste is not undertaken by the Thaton Village Development Committee. Please refer to Sections 4 and 5 of this report.

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There are various types of vehicles used in transportation of solid waste butmany of them are old fashioned and no longer effective. The PCCD has two main final disposal sites. Each site possesses one dozer for dozing all the waste. The dumping duration for one site is normally two to five years. Data for 2012-2013 point to a current Generation of 1,690 tons of waste per day in Yangon, of which 1,550 tons are collected. The main challenges in solid waste management in Yangon are identified as follows: lack of detailed planning; inefficient waste collection system; old equipment for waste collection and rransportation; improper final disposal; unclear enforcement of hazardous/infectious waste management; weakness of SWM registration.

2.2.3 Institutions for OHS

There are many public agencies in Myanmar which are responsible for protection of the Ocupational Health and Safety (OHS) and for the improvement of working conditions, as follows:

Factories and General Labour Laws Inspection Department (FGLLID)

under the Ministry of Labour. Boiler and Electrical Inspection Division, Department of Industrial

Supervisory and Inspection, under Ministry of Industry. Occupational Health Unit, Health Department under Ministry of

Health. Ministry of Construction. All these agencies have jurisdiction nation-wide and therefore also in Thaton.

2.2.3.1 Factories and General Labour Laws Inspection Department (FGLLID)

The purpose and functions of FGLLID is to secure the enforcement of the legal provisions which are related to work conditions and the protection of workers. Each of the factory inspectors has the responsibility to ensure proper factory inspections, AND MAKE investigations of industrial accidents and dangerous occurences. The FGLLID inspectors are trained overseas (FGLLID, year unkown). The FGLLID conducts as well education and training activities in the field of health and safety. The target audience of such tranings is composed of health and safety officers, supervisors, and workers from various industries (FGLLID, year unkown).

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Although the establishement of Safety Committees is not foreseen in the existing labour legislation, the FGLLID has been able to establish such committees in large industrial enterprises. Since 1981, 447 factories employing over 100 employees have formed safety committees voluntarily.

2.3 Legal framework

The 2008 Constitution confirms that the Government will protect and conserve Myanmar’s natural environment. However there is no right to a clean environment and instead citizens have a duty to assist the Union Government in environmental conservation (SIWA, 2014). Many of Myanmar’s laws dating back to the colonial period and post-independence period are, with more or less changes, still in force. Since the country’s political and economic opening, Myanmar’s government has commenced a comprehensive reform process. Existing laws were revised or replaced, and new laws enacted (Luther, 2016). The Environmental Conservation Law (see Section 2.3.1 below) requires MOECAF to put in place a comprehensive waste and pollutant monitoring scheme. The MOECAF has just adopted the Environmental Conservation Rules (2014) and is in the process of developing environmental quality, starting with effluent standards. UNDP is supporting the Government in the Development of the National Environmental Management Framework and Action (SIWA, 2014).

2.3.1 Environmental Conservation Law (2012)

The National Environmental Conservation Law was enacted in 2012 with the following main objectives: to establish an Integrated Environmental Monitoring System in the

country; to establish Environmental Impact Assessment (EIA) processes for

developing projects, including environmental management plans for the mitigation of environmental impacts;

to develop standards for environmental quality;

In the Thaton PP: The existence of a Safety Committee is unknown. Please refer to Sections 4 and 5 of this report.

In the Thaton PP: No training on OHS issues is undertaken. During Fichtner’s visit in September 2016, it was suggested that training from FGLLID should be organized. Please refer to Sections 4 and 5 of this report.

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to encourage green initiatives to adopt its strategies and action plan for mainstreaming into the development sectors.

funds for environmental conservation.

The law includes: specifying categories and classes of hazardous wastes; treatment of solid wastes, effluents and emissions which contain toxic

and hazardous substances; installing environmental friendly equipment to reduce environmental

pollution; controlling the wastes in accordance with environmentally sound

methods.

In addition to the framework Environmental Conservation Law, there are currently 44 existing laws with some form of obligations on operators in respect of pollution, disposal, and other harmful impacts on the environment and local society (SIWA, 2014).

2.3.2 Waste management

Several laws in Myanmair pertain to waste management, such as: The Yangon Water-Work Act (1885); The City of Yangon Municipal Act (1922); The Water Power Act (1927); The Underground Water Act (1930); The City of Yangon Development Law (1990); The Development Committees Law (1993); The City of Mandalay Development Law (2002); The Nay Pyi Taw Development Law (2009). Chemical Safety Law. Environmental Conservation Rules (2014)

Besides these, the City and the Township Development Committees promulgated the Solid Waste Disposal and Collection By-law as a legal basis at local level.

In the Thaton PP: The management of the plant’s waste is not undertaken by the Thaton Village Development Committee. Please refer to Sections 4 and 5 of this report.

In the Thaton PP: Waste management at the plant is not properly undertaken, and environmental pollution is not controlled nor monitored. Please refer to Sections 4 and 5 of this report.

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Gaps in the waste management framework are identified as follows: Specific rules, regulations and guidelines; Coordination mechanism and institutional strengthening; Technology; Financial mechanism; Waste management and national waste management strategies

frameworks formulation; Monitoring system. The existing legislation does not address waste management adequately or sufficiently. Also, coordination and supervision of waste management at all levels in the country is not clearly developed and needs further strengthening. A national environmental management action plan should be implemented to manage practices at all levels (township, regional and national). See Section 0 of this report for further information.

2.3.3 National Environmental Quality (Emission) Guidelines

Myanmar developed a set of National Environmental Quality Guidelines (“Guidelines”) which are available online, and have been primarly excerpted from the International Finance Corporation (IFC) Environmental Health and Safety (EHS) Guidelines. The Guidelines have been as well partly based on the World Bank’s Pollution Prevention and Abatement Handbook (PPAH), 1998 (WB, 1999). However, and according to information available on the IFC’s website, the PPAH is no longer in use and is still provided on-line for reference only (URL 1). The Guidelines have been launched on 14 January 2016 in Nay Pyi Taw and provide the basis for regulation and control of noise and vibration, air emissions, and liquid discharges from various sources. The Guidelines apply to projects that generate noise or air emissions, and / or that have either direct or indirect discharge of process water, wastewater from utility operations or storm water to the environment. Provisions of the general and applicable industry-specific Guidelines shall be reflected in the project’s environmental management plan (EMP) and environmental compliance certificate (ECC). Together they constitute a project’s commitment to take necessary measures to avoid, minimize and control adverse impacts to human health and safety and the environment through reducing the total amount of emissions generation.The EMP and the ECC shall also show the project’s commitment to adopting process modifications, including waste minimization to lower the load of pollutants requiring treatment and as necessary, to apply treatment techniques to further reduce the load of contaminants prior to release or discharge. The following sub-sections present those guideline values which are applicable to the Project.

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2.3.3.1 Wastewater

Projects with the potential to generate process wastewater, sanitary sewage, or storm water should incorporate the necessary precautions to avoid, minimize, and control adverse impacts to human health, safety or the environment. Industry-specific guidelines shall be applied by all projects, where applicable, to ensure that effluent emissions conform to good industry practice. For project types where industry-specific guidelines are not set out, the following general guidelines (Table 2-1) should be applied.

Table 2-1: Wastewater, Storm Water Runoff, Effluent and Sanitary Discharges (general application) a

Parameter Unit Guideline Value

5-day Biochemical oxygen demand mg/l 50 Ammonia mg/l 10 Arsenic mg/l 0.1 Cadmium mg/l 0.1 Chemical oxygen demand mg/l 250 Chlorine (total residual) mg/l 0.2 Chromium (hexavalent) mg/l 0.1 Chromium (total) mg/l 0.5 Copper mg/l 0.5 Cyanide (free) mg/l 0.1 Cyanide (total) mg/l 1 Fluoride mg/l 20 Heavy metals (total) mg/l 10 Iron mg/l 3.5 Lead mg/l 0.1 Mercury mg/l 0.01 Nickel mg/l 0.5 Oil & Grease mg/l 10 pH S.U.b 6-9 Phenols mg/l 0.5 Selenium mg/l 0.1 Silver mg/l 0.5 Sulphide mg/l 1 Temperature increase C° <3c Total coliform bacteria 100ml 400 Total phosphorus mg/l 2 Total suspended solids mg/l 50 Zinc mg/l 2 aPollution prevention and abatement handbook. 1998. Toward cleaner production. World Bank Group in collaboration with United Nations Environment Programme and the United Nations Industrial Development Organization. bStandard unit

In the Thaton PP: No monitoring of environmental parameters is undertaken. Please refer to Sections 4 and 5 of this report.

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c At the edge of a scientifically established mixing zone which takes into account ambient water quality, receiving water use, potential receptors and assimilative capacity; when the zone is not defined, use 100 meters from the point of discharge The following guideline values ( Table 2-2) should be applied during the construction phase of the projects, covering storm water and sanitary wastewater discharges from all project sites.

Table 2-2: Site Runoff and Wastewater Discharges (construction phase)

Parameter Unit Maximum Concentration

Biological oxygen demand mg/l 30 Chemical oxygen demand mg/l 125 Oil and grease mg/l 10 pH S.U.b 6-9 Total coliform bacteriaa 100ml 400 Total nitrogen mg/l 10 Total phosphorus mg/l 2 Total suspended solids mg/l 50 aColiforms refer to a group of bacteria which are found in the intestines of warm blooded animals and therefore are present in sewage, and on / in soils, surface waters and vegetation. bStandard unit

2.3.3.2 Air quality

There are no air quality standards in place in Myanmar, nor is there advanced technology (or capacity) for air quality measurement (SWIA, 2014). It is the prerogative to the Ministry of Environmental Conservation and Forestry to decide how the Guidelines should be applied to the existing projects. Projects with significant sources of air emissions, and potential for significant impacts to ambient air quality, should prevent or minimize impacts by ensuring that: (i) emissions do not result in concentrations that reach or exceed national ambient quality guidelines and standards, or in their absence current World Health Organization (WHO) Air Quality Guidelines for the most common pollutants as summarized below (Table 2-3); and (ii) emissions do not contribute a significant portion to the attainment of relevant ambient air quality guidelines or standards (i.e. not exceeding 25 percent of the applicable air quality standards) to allow additional, future sustainable development in the same air shed.

Table 2-3: WHO Ambient Air Quality Guidelines

Parameter Averaging Period Guideline Value μg/m3

Sulfur dioxide 24-hour 10-minute

20 500

Nitrogen dioxide(NO2) 1-year 1-hour

40 200

Particulate matter PM10a

1-year 24-hour

20 50

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Particulate matter PM2.5 b 1-year

24-hour 10 25

Ozone 8-hour daily maximum 100 a Particulate matter 10 micrometers or less in diameter b Particulate matter 2.5 micrometers or less in diameter

2.3.3.3 Noise levels

According to the National Environmental Quality Guidelines, noise prevention and mitigation measures should be taken by all projects where predicted or measured noise impacts from a project facility or operation exceed the applicable noise level guideline at the most sensitive point of reception. Noise impacts should not exceed the levels shown below (Table 2-4), or result in a maximum increase in background levels of three decibels at the nearest receptor location off-site.

Table 2-4: Noise Limits

Receptor

One Hour LAeq (dBA)a Daytime 07:00 - 22:00 (10:00 - 22:00 for public holidays)

Nighttime 22:00 - 07:00 (22:00 - 10:00 for Public holidays)

Residential, institutional, educational

55 45

Industrial, commercial

70 70 a Equivalent continuous sound level in decibels

2.3.3.4 Industrial Pollution Control - Thermal Power Plants

This guideline (Table 2-5) applies to combustion facilities fueled by gaseous, liquid, and solid fuels and biomass designed to deliver electrical or mechanical power, steam, heat, or any combination of these, regardless of the fuel type (except for solid waste which is covered under the guideline for Waste Management Facilities), with a total rated heat input capacity above 50 megawatt thermal input on high heating value basis. It applies to boilers, reciprocating engines, and combustion turbines in new and existing facilities. It applies, therefore, to the existing and the new Thaton Power Plants.

Table 2-5: Liquid effluent Limits

Parameter Unit Guideline ValueArsenic mg/l 0.5 Cadmium mg/l 0.1 Chromium mg/l 0.5 Copper mg/l 0.5 Iron mg/l 1 Lead mg/l 0.5 Mercury mg/l 0.005 Oil and Grease mg/l 10

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pH S.U.a 6-9 Temperature increase °C <3b Total residual chlorine mg/l 0.2 Total suspended solids mg/l 50 Zinc mg/l 1 aStandard Unit bTemperature increase due to discharge of once-through cooling water Table 2-6: Air Emission Limits (applicable to non-degraded air sheds)

Combustion Technology / Fuel

Parameter / Guideline Values Particulatematter PM/TSPa

Sulfur dioxide

Nitrogen oxides

Natural gas (all turbine types; unit> 50 MW)

- - 100 mg/Nm3

a The Myanmar National Environmental Quality Guidelines define an air emission limit for PM10, but according to the IFC EHS Guidelines for Thermal Power Plants, the limit is set for PM/TSP and not PM10

Odor As specified in the IFC EHS General Guidelines, point and diffuse source odors from industries should be minimized using available prevention and control techniques. According to the Myanmar National Environmental Quality Guidelines, projects should control odors to ensure that those that are offensive or unacceptable to neighbors do not occur. Generally, odor levels shouldnot exceed five to ten odorant units at the edge of populated areas in the vicinity of a project. This meansin practice that offensive odor can only be judged by public reaction to the odor, with the nuisance level being as low as two odorant units and as high as ten odorant units for less offensive odors. An odor assessment criteria of five to ten odorant units is likely to represent the level below under which offensive odors should not occur.

2.3.4 Occupational Health and Safety (OHS)

Two legal documents provide basic OHS protection requisites in Myanmar: Myanmar Basic Constitution 2008, article 24: “The Union shall enact

laws to protect the rights of workers if necessary” Law of Public workers’ fundamental rights & duties (1964):”

Arrangements shall be provided to facilities, for health, safety, welfare, first aid treatment and fire fighting for workers”.

In addition to the above, the Factories Act (1951 - amended in 2016) foresees the liability of managers to protect workers and includes the following provisions (FGLLID, year unkown; URL 2). Safety Provisions, as for example:

fencing the dangerous parts of the moving machineries,

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women and children are not allowed to clean, lubricate or adjust any part of the machineries.

young persons must not be allowed to work on the machineries without a proper training.

Health Provisions, as for example:

Effective arangement shall be made for the disposal of wastes and effluents.

Workrooms must be adequately ventilated. All floors, steps, passages and gangways should be properly

maintained. Every vessel, sump, tank, pit or opening in the ground or in the

floor shall be either securely covered or strongly fenced. Every plant must be provided with escape exits and fire

extinguishers. Welfare Provisions, as for example:

First aid box in every industry; first aid room or dispensary for industries with more than 250 workers;

Adequate and suitable washing facilities; A canteen (more than 250 workers); Adequate and suitable rest and dining rooms (more than 100

workers); Creches (more than 50 women working) for children under the age

of six.

The Factories Act 1951, Session 42 mentions that if any building or any part of the passage ways, machinery or plant involves imminent danger to human life, the inspectors can prohibit its use until it is properly repaired or altered. In case of any fatal accident or dangerous occurrence, the Director General or the Factory Inspector shall investigate this accident, prohibit further operation and establish necessary instructions for corrective control measures. The operation can restart once this is deemed to no longer impose a danger to the health & safety of the workers.

In the Thaton PP: Several passage ways have holes, and the machinery is old and under eminent risk of breakdown. Inspections have reportedly never been undertaken at the plant and consequently no prohibition of use has been set. No severe accidents have been registered at the plant. Please refer to Sections 4 and 5 of this report.

In the Thaton PP: Several of the above provisions are not respected or not fully respected (for example regarding the washing facilities, the first aid box, the escape exits, the floors, etc.). Please refer to Sections 4 and 5 of this report.

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2.3.5 Employment conditions

Some relevant laws in Myanmar regarding employment conditions are: Workman’s Compensation Act (1923) as amended in 2005 Leave and Holidays Act (1951) as amended in 2014 Factories Act (1951) – as amended in 2016 Labour Organization Law (2011) Social Security Law (2012) Minimum Wage Law (2013) Payment of Wages Law (2016) Some relevant provisions of this framework are (Luther, 2016): Employment and Skill Development Law (2013):

provides that any employment contract must be registered; provides that a written employment contract shall contain certain

minimum terms such as the type of employment, probation period, salary, working hours, leave and termination.

Factories Act (1951) provides for 44 hours of work per week; 48h for work which has to

be done continuously. Notification 2/2015:

the minimum wage is MMK 3,600 per day for eight (8) hours of work (excluding break time);

it is prescribed for all enterprises with more than 15 employees. Since 2011, labour unions may be formed at the factory level if at

least 30 workers and at least 10 % of all workers of the factory approve the formation of the labour union. Employees organized in a labour union may, under certain conditions, go on strike if the general dispute resolution mechanisms failed. Essential sectors are excluded.

2.4 Present situation of waste management in Myanmar

Solid waste collection in Myanmar is labor intensive and relies on manual collection with non-specialized vehicles, ranging from pushcarts to garbage trucks. The following waste collection activities are undertaken: block collection, communal depot collection, house-to-house collection, limited collection, and street sweeping (Mann and Myint, year unknown).

In the Thaton PP: The national law is said to be respected regarding workers rights and contractual clauses. Please refer to Sections 4 and 5 of this report.

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Sanitation waste, household waste Non hazardous waste collection systems consist of house-to-house collection, centralized collection at a communal waste depots or communal block, and limited collection for specialized or specific waste. Sewage and black water is mostly collected in septic tank systems, pit latrines, or flows untreated into surface waters. There are only a few wastewater treatment plants, located in Nay Pyi Taw and Yangon. These connect only a small part of the cities to a conventional sewage system.

Hazardous Waste Management (e.g. asbestos, acids, oils containing PCB) Hazardous wastes are collected and recycled by cities or townships development committees. There is no specific government institution assigned with the task of overall management of toxic chemicals and hazardous wastes. According to the Myanmar’s National OHS Profile report (FGLLID, year unkown), hazardous waste are disposed in designated landfill areas. There are sectoral laws and regulations related to management of toxic chemicals and legislation such as the Factories Act (1951) and Public Health Law (1972) which are related to management of hazardous waste. In general, the national legislation on the management of hazardous wastes is not yet clearly developed.

2.4.1 Challenges

Presently the waste management in Myanmar presents some important challenges, namely: Limited information on waste generation; No segregation of waste according to categories; Insufficient knowledge on and practice of health-care waste

minimization; Reuse and recycling approach at township and sub-levels; Lack of regional/centralized disposal facility to handle large quantities

of healthcare waste;

In the Thaton PP: The hazardous waste generated at the plant is managed by EPGE, who stores it in unspecified locations and sells it. The Thaton Township Development Committee does not collect the waste from the plant. Please refer to Sections 4 and 5 of this report.

In the Thaton PP: The non-hazardous waste generated at the plant is burnt on site. There is no collection. Please refer to Sections 4 and 5 of this report.

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Low level of awareness of and poor compliance with code of conduct, universal precaution and technical guidelines for safety measures;

Lack of written standards for waste operation procedures. Generally, improvement of waste management practices is not a high priority among the national development goals, and therefore budgets for waste management are usually low. To overcome these challenges, an environmentaly sound National Waste Management Strategy has yet to be implemented and the following is still necessary:

Formulate the National Waste Management Strategic Policy

Framework; Develop national waste management Rules and Regulations; Develop sectoral waste management Regulations and Guidelines; Promote green investment in waste gectors; Formulate Environmental Quality Standards; Identify priority waste issues and develop the respective Action Plan; Promote technology; Promote people participation through Environmental Awareness

Programs; Promote regional level and international level cooperation; Strengthen the institutions and provide capacity building, and

strenghten the coordination mechanism. The National Waste Management Strategy and Action Plans are currently being developed and are expected to be completed in 2017 (MINDC, 2015).

2.4.2 Yangon

In order to provide clarity on the waste management practices in Myanmar, a brief explanation about those undertaken in Yangon is provided. In the year 2010, 300 ton/day of waste were recycled in Yangon city. Some materials such as paper, plastic and glass are collected separately from the mixed municipal waste and recycled by the Yangon City Development Committee (YCDC). Small paper mills, glass factories and plastic industry recycle these materials into new products. At present, recycling of municipal solid waste is not fully and systematically developed. The budget allocation covers only routine works. Additional financial supports are needed to fulfill advanced and sufficient facilities. City Development Committees and Township Development Committees face problems of damping waste disposal amongst constraints of inadequate vehicles, workers and scarce funds. There are six dumping sites in Yangon, namely in Hlaw Gar Township, Shwe Pyi Thar Township, Htain Bin Township, Dala Township, Kyi Su Township and Htawe Chaung Township.

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The dumpsite at Htain Bin is the biggest open dumpsite under the management of YCDC. 847 tonnes of incoming waste are disposed per day. YCDC is under way to implement a landfill gas-to-energy recovery plant to replace this open dumpsite. The dumpsite at Htwei Chaung is the second biggest open dumpsite, where 612 tonnes of incoming waste is disposed per day. YCDC is in process of installation of waste-to energy incineration plant. According to YCDC, 86 tonnes/day of the generated waste is recycled. Valuable recyclables are stored at household level and sell to the nearby junkshops. YCDC also runs a small-scale plastic recycling plant and green and blue plastic bags ars produced using the waste plastic. The current waste management in Yangon is a conventional practice of ‘collection and disposal’, which is unsustainable due to its resource inefficiency, environmental impacts and socio-economic impacts. There are difficulties in finding suitable landfill sites/dumping sites and large costs associated with collection and disposal. Recently, Yangon has initiated an Integrated Solid Waste Management (ISWM) solution by incorporating effective waste collection and transportation services, one waste sorting facility for recovery of recyclables, one anaerobic digestion facility, one composting facility, and raising some farm animals to feed organic waste to, among others.

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3. Review of existing documents

After the kick-off meeting the following documents have been sent to Fichtner which are used as the baseline for this DD Report: ESA 2013: Environmental and Social Assessment (ESA) for the

Thaton Gas-Fired Power Plant, Mon State, Myanmar, incl. the Environmental and Social management Plan (ESMP) (August 2013, Norconsult) The ESA report has been prepared for the installation of a new power plant at the Thaton Power Plant site. However, at the same time, it includes a (mostly) qualitative assessment of impacts of the existing plant. Some of this information has been usefull for the present DD Report. However, information is missing or is insufficient on the existing plant regarding air quality and emission levels, water quality, waste generation, soil contamination, etc. A Social Study available in the ESA Report provides details about education and living standards at the surrounding villages, and characterizes the project affected persons (PAPs). It outlines as well the nature and magnitude of direct and indirect impacts on the local communities from the construction of a new plant and recommends appropriate mitigation measures and monitoring. To complement the results of this study, Fichtner conducted a new and comprehensive social surevey of the area (please see Section 1.4.1 for details).

FS 2013: Feasibility Study of Thaton Gas Power Plant (August 2013, Norconsult) The Feasibility Study analysed the technical conditions of three existing plants in Myanmar: Shwedaung, Myanaung and Thaton. Recommendations are made regarding the upgrading of these plants. The overall recommendation is to investigate the possibilities for installing a new power plant at Thaton. A brief summary of environmental and health & safety issues has also been presented in the Feasibility Study. Recommendations to ensure that the new power plant is implemented in an environmentally and socially responsible way have been added.

RFS 2014: Requirements and Functional Specification for a complete

CCGT power plant at Thaton, Mon State, Myanmar, Revision: 02 Issued for Tender Date: 04th March 2014 ‘Health, safety and environment (EHS)’.

The Requirements and Functional Specifications for the new Thaton Power Plant clearly define the main obligations of the Contractor in order to meet the “zero harm“ goal. It sets out the steps for developing a successful EHS Plan for the construction and operation of the new Thaton Power Plant.

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The document states that the Contractor shall provide (see Annex 8 for definitions):

Dedicated EHS resources to be available at site, inclusively a person

to liaise with the consultants that are responsible for preparation of the EHS-Management System (in this case, Fichtner).

A follow up system and register for EHS issues; EHS risk assessments for the construction phase; Safe Job Analysis (SJA) for activities that are hazardous and not

covered by existing procedures/instructions; Working Environment Health Risk Assessment (WEHRA); Environmental Design Review; A safety strategy for the design and operational phases; A Hazard Identification workshop (HAZID), A Hazardous Operations Analysis (HAZOP) of critical activities; A Hazard register; A Quantitative Risk Analysis (QRA).

The Specifications dedicate one section to the working environment requirements of the project, inclusive limits for luminance level, temperature, relative humidity and noise. The environmental standards and requirements to be respected by the project shall be based upon international standards such as ISO 14001, the Environmental and Social Management Plan (assumed to be the one available in the ESA) and Best Available Techniques (BAT).

An additional very useful report about the refurbishment/new construction of the Thaton PP was found in the www: HRRA 2014: Human Rights Risk Assessment, Thaton Power Station,

NomoGaia, 2014

This NGO report focuses on social problems around the Thaton PP site and describes environmental, human rights, and health & safety risks related to the existing and the new power plant, including those related to drinking water, food sources and workplace safety. This short report provides some hints on what are the relevant risks and on what needs to be further investigated in relation to the Project. In particular, the report states that the community has offered 100% support for the Project on the condition that they receive improved access to electricity.

3.1 Gaps in the documentation

During the site visits it became obvious that written documentation concerning EHS issues does not exist in the plant. A regular reporting routine (e.g. to the headquarters or to relevant ministries) does not take place. Because no severe accident happened (according to the

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information disclosed to Fichtner), no related reports became necessary. Consequently such documentation could not be screened and assorted. A first overview revealed that the mitigation and monitoring measures for construction of the new plant presented by Norconsult in the ESA (ESMP) are appropriate, but will be supplemented where needed. However, this ESMP does not cover the new proposed water pipeline, pumping station and eventually a new needed power line running from Thaton PP to Donthami River. For this purpose proper mitigation and environmental measures have to be developed. Especially on the social side, compensation measures have to be elaborated and added to Norconsult’s ESMP. This will be undertaken by Fichtner under this assignment, but the results will be made available in a different deliverable. For construction activities, the S&I Contractor has to develop a construction site EHS Plan. According to the site manager such a EHS Plan will be at hand in October 2016, when the construction of the new power plant will start (after the rainy season is over). Fichtner requested that this plan is sent 4 weeks before the construction activities on site begin, but so far it has not been received.

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4. On site situation

This Section presents the findings of the site visits undertaken by Fichtner in July and in September 2016. The hereby description of the Plant’s condition is based on information provided orally to Fichtner by the TPP management, on a sensorial assessment, on laboratory analysis of samples, and on discussions with local communities. No document regarding the TPP’s EHS management is availabe at site nor has been delivered to Fichtner.

4.1 General

The Thaton PP was built in 1985. It consists of 3 gas turbines with an installed capacity of 54 MW. The TPP runs in a closed cycle but the produced steam is not used for producing additional energy. Instead, it is sold to the neighboring rubber plant. Water is obtained from the rubber plant which sources the water via an own pipeline and pumping station from the Donthami River nearby. The water is used for domestic needs in the TPP, as well as for cooling and as process water. The plant site, equipment, and buildings are generally in very poor conditions (see Annex 1: Photographic Documentation). Within the last decades no obvious general maintenance took place, except for some technical refurbishment (turbine renovation). In the three storage buildings, Fichtner encountered broken asbestos-containing ceilings (see Section 4.13 below for further details). The floor in one of the control rooms and on the transformer station has holes, some of which large enough to pose a severe injury risk. Some open and unprotected man holes have also been identified. Although the steam turbine is not used nowadays, its old building is of free access to any worker and animal. The old structures and pipes inside the building are not secured, there are no safety or warning signs, and there is no light. Dogs walk freely throughout the plant’s installations, and seem to have no fear of approaching the structures, buildings and people. On site 85 employees (55 males and 30 females) are working in 4 shifts. This includes also 1 health officer sited in the workers’ residential area nearby the plant. At night 11 people are present. None of the employees is under 18 years old. The female employees that work in the offices are allowed to have their children with them during the day. No additional facilities for children are provided. The whole area of the PP is fenced. The external fence is in good conditions. Some internal fences (for example the one surrounding the transformer station) are degraded and require repairs. Since two years the

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site is guarded by police officers who sit in a small police station very close to the PP site.

4.2 Welfare conditions

A little tea shop with an adjacent eating room is available where the workers eat their own food. There is no canteen available on site, but the workers can purchase tea, coffe and food prepared by two female employees at the tea shop. The shop and eating room is generally dirty and covered by asbestos plates. A small library is available adjacent to the tea shop and the eating room. The books are very old and it seems that they are not borrowed by the workers anymore. 3 toilets inside the control building and 8 toilets outside are installed and are separated by gender. Tap water is available but the quality is not monitored. The exterior toilets are kept in deplorable conditions and there is a plan to dismount them. There are no showers on site.

4.3 Housing area

Neraby the plant (800 m to the south), there is a housing area for the workers of the Thaton Power Plant and for the workers of the rubber plant (Figure 4-1).

Figure 4-1: Housing area for the workers of the Thaton PP

Housing area

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All workers are allowed to rent a house in this area for them and their families. 75% of all employees use the housing area, and the remaining 25% live in Thaton. During the dry season water is only supplied to the housing area two times a day for 30 minutes. The power plant’s management sees therefore as highest priority to improve the water supply situation of the employees housing area. A new water pipeline to supply the new power plant is planned to be built as part of the Project. It is the strong demand of the power plant’s management to include a connection to the housing area to solve the supply problems.

4.4 Workers rights

The plant’s management does not have a formal human resources policy, nor are the employees‘ rights described in the working contract. However, the national legislation on the matter is said to be respected at the Thaton Power Plant, as well as in every power plant at national level. The same salary is guaranteed for all workers undertaking the same job; every worker, independently of her/his position, is allowed to use the accomodation services provided nearby the plant. No workers unions exist at the Thaton Power Plant. This is a new theme in the country, as only since 2011 labour unions may be formed at the factory level (Luther, 2016 and Section 2.3.5 of this report). Children are not employed at the plant, but are allowed to spend the day with their mothers within the office area. However, no area or infrastructure dedicated to child care exists at the plant. It is not clear presently for how long the existing Thaton Power Plant will continue operating. It is as well unclear whether the workers of the existing Thaton Power Plant will be transferred to the new plant or be let go in case the old plant closes down.

4.5 Wastewater

The sanitary waste water is collected in pits, which are emptied approximately once every 4 years by the municipality. It is not known what happens with this wastewater. A waste water treatment is not in place at Thaton. Storm waters are drained and sent down to the river. Fichtner visited the power plant twice during the rainy season and it seems that the drainage channels are working well, despite the lack of maintenance (plants grow and garbage is deposited inside some of the channels). No oil separators are installed.

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4.6 Stack emissions

The stacks of the gas turbines are about 30 feet high (9 m) and are not equipped with any air pollution control equipment. Air emissions monitoring is not conducted, as no monitoring devices are available.

4.7 Solid and hazardous waste

Old used oil, old batteries, and small amounts of mercury from energy saving light bulbs, HCl and NaOH are collected, stored in unspecified locations everywhere on site and sold. There is not a specific plan to manage the plant‘s waste. For example, old oil is stored ca. 5 years on site before being sold. For other waste typologies, no information could be given regarding storage time. Solid waste such as domestic waste or packages is burnt on site.

4.8 Noise

The noise levels at site are generally very high. For example, close to the gas turbine 3 (GT 3), a conversation cannot be held without considerably rasing the voice tone. Silencers or any other noise reduction structures around the turbines do not exist. The walls and windows from the offices and control rooms provide little dampening effect from the exterior noises. The ESA report (Norconsult, 2013) provides a quantitative assessment of the noise levels at site, showing that these exceed noise limits such as those considered in the National Environmental Quality Guidelines (see Table 2-4 in Section 2.3.3.3). Despite the noisy environment, no workers have been seen wearing ear protection. The closest sensitive receptors to the site are located in the power plant’s housing area, ca. 800 meters away. Normally, the noises from the power plant are masked by other noises, especially traffic related, at these locations.

4.9 Monitoring and inspections

There is no supervision of EHS issues on site, either internal or performed by relevant official authorities. No monitoring of air emissions, air quality, noise, waste water, surface water or groundwater is undertaken at site. The process water received from the rubber/tire plant undergoes a certain monitoring regarding pH and hardness.

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4.10 EHS training

The staff undergoes a quarterly general training in Nay Pyi Taw, but no EHS issues are covered. A record of these training sessions was not available. During Fichtner’s visit in September 2016, it was suggested that a training session in H&S issues is provided at the plant by the FGLLID. The summary and results of the session will be provided in future deliverables of the present assignement.

4.11 Emergency procedures and first aid

First aid equipment onsite consists of one poorly equipped first aid box. In the small workers’ housing area nearby the plant site, a health officer (senior main nurse) provides first aid measures in case of small injuries of the employees and their families. According to the health officer, no severe accidents happened in the last years. In case patients have severe problems, they are sent to the nearest hospital, located in Thaton city. An Emergency Response Plan in written form is not available. Fichtner was informed that a plan of this kind has been developed in the past. The TPP’s management added that this plan is not available on site nor people receive training on its dispositions because “nowadays all workers are aware of what to do in case of an emergency”. Reports to the headquarters (MOEE) are only written in case of unfavorable weather conditions to justify an eventual shutdown or loss of efficiency of the power plant. In case of severe accidents, also a report shall be written. According to the TPP’s management, such severe accidents never happened. Several hand-held fire-extinguishers are located inside one of the control rooms. Some of them are new (dated February 2016) and still covered in plastic wrap, some are old and outdated. There is no fire brigade on site, but there is one in Thaton and one in the adjacent tyre factory. There are no emergency exit signs or maps in the plant.

4.12 Polychlorinated biphenyls (PCB)

In former times, polychlorinated biphenyls (PCB) were widely-used as coolants and lubricants in transformers, capacitors, and other electrical equipment because PCB possess good insulating properties and are fire retardant. These substances consist of two phenyl-rings that can contain different amounts of chlorine molecules. In general, the acute toxicity of PCB is small, but regarding its chronic effects, PCB has a high toxic potential. Especially when burned with low temperatures (below 1.000°C), PCB can be turned into highly toxic and carcinogenic dibenzofurans (PCDF) and dibenzodioxins (PCDD). Therefore, special attention has to be put on this issue. Proper special

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incineration plants for PCB containing fluids operate with temperatures of around 1.200°C. Three samples of oil (old, used and new transformer oil as well as old, used and new turbine oil) were taken during the first visit of Fichtner to the Thaton PP in July 2016, transported in closed plastic containers to Germany and analyzed for PCB in a certified laboratory (see Annex 2). In Table 4-1, the results of the PCB analyses are summarized (for details see Annex 3):

Table 4-1: Results of the analysis for PCB in oil samples from the Thaton Power Plant

Sample PCB [ppm]

Old, used turbine oil < 0.2

New Turbine oil < 0.2

Old, used transformer oil 9.95

New transformer oil < 0.2

Detection limit for PCB = 0.2 ppm According to US EPA, a transformer is ‘a transformer that contains PCB’ if the concentration of PCB is higher than 500 ppm. Oil containing between 50 and 499 ppm PCB is considered to be polluted with PCB and therefore specific methods for removal are necessary (e.g. specific incineration plants). According to the EU Directive 75/439/EEC and its amendments, oil containing less than 50 ppm PCB can be burned in a regular incineration plant. According to the above, none of the samples is polluted with PCB. Only the sample of old, used transformer oil showed traces of PCB (9.95 ppm) which is, however, far below the threshold of 50 ppm. From these findings it can be reasonably assumed that none of the oil used at Thaton PP contains PCB. This statement is in accordance with Fichtner’s experience gained in at least six other projects in central Asia: in big transformers (others than those installed in connection with distribution systems) and turbines, PCB has never been found. Capacitors, however, contain very often the so called PCB 28 (trichlorobiphenyl). But, as capacitors are not in use at the Thaton PP, this problem will not occur. In summary, the oil used at Thaton PP site is most probably free of PCB. Therefore, no special treatment has to be done and no special disposal procedure has to be followed. This oil can either be recycled, reused, sold, or burned in a regular oil fired power plant without PCB-related environmental constraints.

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4.13 Asbestos

At three different sites at Thaton PP, broken panel material used to cover roof and walls have been collected and analyzed for asbestos fibers. These parts were taken from ceiling panels from the warehouse nr. 3 (where oil is stored), and from wall panels from the tea house/library and the old steam turbine building. The referring material analyses (also done in a certified laboratory in Germany) have revealed that all three samples contain asbestos fibers. In all samples amphibole asbestos and chrysotile asbestos were detected (content of fibers between 1 and 15 %). Chrysotile asbestos is known as “white asbestos”. Its fibers are generally finer than amphibole asbestos types. The results can be consulted in Annex 4 to this report. All types of asbestos cause lung cancer, mesotheliom, cancer of the larynx and ovary, and asbestosis (fibrosis of the lungs). Exposure to asbestos occurs through inhalation of fibers in air in the working environment, ambient air in the vicinity of point sources such as factories handling asbestos, or indoor air in housing and buildings containing friable (crumbly) asbestos materials (URL 3). Most critical is, if panels containing asbestos are demolished and break during eventual demolition works. During such activities, asbestos fibers are freed and might be inhaled by workers. This means that wearing a surgical mask (better is a real respiration filter) is essential when working with such panels. However, because there is no appropriate disposal site for asbestos available in Myanmar at the moment, the panels which are not damaged should be left untouched, if there is not a real urgent need to remove them. In order to protect asbestos fibers from being released from the damaged panels, painting of the panels would be a proper method to minimize the risks of exposure. Regarding the specific case of the tea shop/library, where damaged wall panels containg asbestos are present, Fichtner recommends the closure of this building and its replacement by a new building (see the Environmental and Social Action Plan presented in Section 6).

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5. Compliance with international environmental and social standards

As part of the Due Diligence, this section presents an evaluation of the compliance of the existing Thaton Power Plant and its EHS procedures with environmental and social standards issued by the World Bank group (including as well community and occupational health & safety), namely: IFC Performance Standards (PS) on Environmental and Social

Sustainability (2012); IFC EHS Guidelines for Thermal Power Plants (2008); IFC General EHS Guidelines (2007). Fichtner prepared detailed questionnaires regarding the criteria of each of the standards above listed (Annex 5 to this report). Based on the data and findings of the DD Site Audit, the questionnaires were filled and the results are presented in this section. The answers provided to the questionnaires were alternatively: Yes = the criteria is fulfilled No = the criteria is not fulfilled Partly = the criteria is partly fulfilled Not applicable = the criteria does not apply No information = there is no information that allows answering the

question Whenever relevant, a justification is given for the assessment, as well as a suggestion for achieving compliance. An Environmental and Social Action Plan is presented in Section 6 and further describes the measures that shall be undertaken. The answer to the questionnaires ultimately allowed defining the compliance of the existing Thaton Power Plant with each of the standards as: Compliant Non-compliant Partly compliant For the purpose of this section, and considering the nature of the plant, some criteria of each of the PS have been classified by Fichtner as “key criteria”. These are marked with the symbol “K” in the respective questionnaires.

5.1 IFC Performance Standards

As part of its Sustainability Framework, IFC developed eight Performance Standards (PS) designed to help avoid, mitigate, and manage risks and impacts as a way of doing business in a sustainable way. The PS are briefly described as follows.

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PS 1: Assessment and Management of Environmental and Social Risks

and Impacts - it states the need for the conduction of a process of environmental and social assessment, and described the necessary content.

PS 2: Labor and working conditions - it has the objective of guarantying that the fundamental rights of the workers are protected, among them the right of access to a safe and healthy working environment, the right of benefiting from equivalent terms and conditions independently of one’s origin, the right to form workers’ organizations, etc.

PS 3: Resource Efficiency and Pollution Prevention - it aims at assuring that the project makes use of the best technologies to promote an efficient and effective resource usage and to prevent pollution to air, water and land.

PS 4: Community Health, Safety and Security - it addresses risks and impacts from project activities, equipment and infrastructure or community exposure.

PS 5: Land Acquisition and Involuntary Resettlement - it aims to avoid or at least minimize the negative impacts driven by economical or physical resettlement, as well as by land acquisition or restrictions on land use due to the project’s implementation.

PS 6: Biodiversity Conservation and Sustainable Management of Living Natural Resources - it demands that the project includes measures to protect and conserve biodiversity, as well as to sustainably manage the living natural resources and maintain the benefits from the ecosystem.

PS 7: Indigenous Peoples - it recognizes that Indigenous Peoples shall be taken special care in the project’s planning and implementation in order to ensure the full respect for their human rights, dignity, aspirations, livelihoods, culture, knowledge and practices.

PS 8: Cultural Heritage - it has the objective of guarantying that the project will not negatively impact the cultural heritage 1 of the area (tangible moveable or immovable objects, natural features, cultural knowledge, etc.).

5.1.1 PS 1: Assessment and Management of Environmental and Social Risks and Impacts

The existing Thaton Power Plant is non-compliant with IFC PS 1. There is not an Environmental and Social Impact Assessment for the existing plant, but the ESA (Environmental and Social Assessment)

1 Cultural heritage in the sense of PS 8 means (i) tangible forms of cultural heritage, such as tangible moveable or immovable objects, property, sites, structures, or groups of structures, having archaeological (prehistoric), paleontological, historical, cultural, artistic, and religious values; (ii) unique natural features or tangible objects that embody cultural values, such as sacred groves, rocks, lakes, and waterfalls; and (iii) certain instances of intangible forms of culture that are proposed to be used for commercial purposes, such as cultural knowledge, innovations, and practices of communities embodying traditional lifestyles.

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elaborated by Norconsult for the new plant includes a (mostly) qualitative assessment of impacts of the existing plant. However, information is missing or is insufficient on the existing plant regarding air quality and emission levels, water quality, waste generation, soil contamination, etc. To complement the existing baseline data, information on PCBs and asbestos has been collected by Fichtner on the existing plant by means of random samples (please see Section 4 of this report for details). The existing plant does not have an EHS management plan or system, implying that the impacts delivered by its activities are not monitored nor mitigated. This includes as well the absence of an Emergency Response Plan. There is not an EHS management team, and no information is provided to the public about the plant’s performance. There is no official possibility for presentation of complaints nor a register thereof. The stakeholders (incl. potentially affected persons) have been identified for the new project during the elaboration of the ESA (Norconsult, 2013). Since the existing power plant is located in the same area, one can state that the stakeholders for the existing plant have been identified as well. A process of consultation has been undertaken by Norconsult and will be continued by Fichtner during the construction of the new plant. This process informs about the existing plant’s risks and impacts, and about the way these are expected to be overcome by constructing the new plant. Please refer to Annex 5 for the filled IFC PS 1 questionnaire.

5.1.2 PS 2: Labor and working conditions

The existing Thaton Power Plant is partly compliant with IFC PS 2. The plant’s management does not have a human resources policy. Fichtner was informed that, despite that fact, the national law is respected regarding workers rights and contractual clauses. Please refer to Section 4.4 of this report for further details. Regarding the provision of a „safe and healthy work environment“, the power plant is non-compliant with the requirements of PS 2. As described in Section 1 of this report, the conditions of the plant’s buildings are very bad, there is not enough first aid equipment on site, no worker has been seen wearing any kind of personal protection equipment, there are holes on the ground, no hygienic eating installations are provided, etc. Please refer to Annex 5 for the filled IFC PS 2 questionnaire.

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5.1.3 PS 3: Resource Efficiency and Pollution Prevention

The Thaton Power Plant in non-compliant with IFC PS 3. The plant is not a significant consumer of water, because it works in closed cycle. The water is sourced from the nearby rubber plant and the hot steam is sent back to this facility. From the results of the site audit, no resource and energy conservation/efficiency measures are considered during the plant’s operation, the release of pollutants is not controlled, and the waste is not sustainably managed (but instead directly burnt at site). For further details, please refer to Section 1 of this report. Please refer to Annex 5 for the filled IFC PS 3 questionnaire.

5.1.4 PS 4: Community Health, Safety and Security

The ESA for the new plant (Norconsult, 2013) makes a brief assessment (mostly qualitative) of the impacts and risks of the existing plant. Regarding community health & safety, the assessment covers in detail the noise levels around the plant. However, no detailed information is given regarding other issues that may affect the communities such as air quality, soil contamination and receiving water quality. The plant’s structures are very old and degraded. Despite the provision of security personell, the risk for community exposure to accidents (fires or explosions) cannot be excluded. Police elements make the security of the site, for what it is assumed that the demands of PS 4 regarding security forces (consideration of national law and good international practice, training, etc.) are respected. It can be concluded that the existing Power Plant is non-compliant with IFC PS 4. Please refer to Annex 5 for the filled IFC PS 4 questionnaire.

5.1.5 PS 5: Land Acquisition and Involuntary Resettlement

The Thaton Power plant was built around 30 years ago. No information regarding the process of land acquisition and/or resettlement that occurred at the time was made available. Given that the plant was constructed more than 30 years ago, IFC PS 5 is considered not applicable.

5.1.6 PS 6: Biodiversity Conservation and Sustainable Management of Living Natural Resources

There is no information regarding the type of habitat areas (natural, critical, or protected) that have been converted to construct the Thaton Power Plant.

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The ESA for the new plant (Norconsult, 2013) mentions some impacts and risks of the existing plant, but none related to biodiversity aspects. The impacts on ecosystem services caused by the existing plant’s activities are not considered, i.e, there are no data regarding the water quality of the drainage-receiving river or regarding the quality of the agricultural soil surrounding the plant. Given the above, the power plant is deemed as non-compliant with IFC PS 6. Please refer to Annex 5 for the filled IFC PS 6 questionnaire.

5.1.7 PS 7: Indigenous Peoples

Presently, it is not possible to assess the project’s compliance with IFC PS 7. This will be done in the final DD Audit Report, once the results of the full socio-economic survey are available.

5.1.8 PS 8: Cultural Heritage

An assessment of the cultural heritage value of the area before construction of the existing Thaton Power Plant is not available. The ESA for the new plant states, however, that “the project does not border any sites of cultural or archaeological significance”. For this reason, PS 8 is considered not applicable.

5.1.9 Summary of compliance with the IFC PS

Table 5-1 summarizes the compliance of the existing Thaton Power Plant with the IFC PS. The project is non-compliant with PS 1, 3, 4, and 6; there is a partial compliance with PS 2; the compliance with PS 7 will be assessed once new socio-economic data is available; PS 5 and 8 are not applicable.

Table 5-1: Summary of compliance with the IFC PS

Performance Standard Compliance

PS 1 Non compliant

PS 2 Partly compliant

PS 3 Non compliant

PS 4 Non compliant

PS 5 Not applicable

PS 6 Non compliant

PS 7 Not possible to assess compliance

PS 8 Not applicable

Given the state of degradation of the Thaton Power Plant (which motivated the decision for construction of a new plant instead of its renovation), it is

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not possible to propose feasible actions to achieve compliance with all items of all IFC PS. It is Fichtner’s opinion that for the existing plant only emergency measures to achieve some level of compliance can be developed. These measures are described in an Environmental and Social Action Plan, presented in Section 6 of this report.

5.2 IFC EHS Guidelines

The Environmental, Health, and Safety (EHS) Guidelines of IFC are technical reference documents with general and industry-specific examples of Good International Industry Practice (GIIP). For the purpose of this DD, the dispositions of the IFC General EHS Guidelines (2007) and the IFC EHS Guidelines for Thermal Power Plants (2008) have been considered.

5.2.1 Assessment of compliance

Table 9-9 in Annex 6 describes the criteria from the two IFC EHS guidelines considered in the assessment which are applicable to the Thaton Power Plant. It further assesses the compliance of the plant’s structures, operations, and EHS management with the applicable criteria. Issues covered by the guidelines but which are unrelated to the Thaton Power Plant have been left out such as ash management, SO2 emission reduction measures, water intakes, process water discharges, etc. The main conclusion from the assessment is that the Thaton Power Plant is non-compliant with the IFC EHS General Guidelines and with the IFC EHS Guidelines for Thermal Power Plants. This is true despite the fact that some of the criteria are fulfilled by the plant, namely the usage of a low sulfur fuel and of a closed circuit dry cooling system. For the same reasons given under Section 5.1.9, feasible actions to achieve compliance with all applicable items of the IFC EHS Guidelines cannot be proposed. Emergency measures are proposed in an Environmental and Social Action Plan presented in Section 6 of this report.

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6. Environmental and Social Action Plan

As described in the previous Section, the Thaton Power Plant is non-compliant with international EHS standards. Given the state of degradation of the facilities (which motivated the decision for construction of a new plant instead of its renovation), it is not possible to propose feasible actions to achieve full compliance. It is Fichtner’s opinion that for the existing plant only emergency measures to achieve some level of compliance can be developed. These measures are described below in an Environmental and Social Action Plan - ESAP (Table 6-1). The ESAP for the Thaton Power Plant follows a conservative approach. Fichtner considered the country’s and the plant’s financial, tecnical, human and legal limitations which are presently a reality and which hinder the realization of deep re-structuring measures. In an ideal case, the plant would be immediatelly shut down due to serious safety issues and human health hazards. However, the city of Thaton relies on the power plant for power supply and for provision of mostly needed job positions. The application of the measures foreseen in the ESAP will help to keep the plant operating while at the same time the most serious EHS issues can be handled as good as the available resources allow.

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Table 6-1: Environmental and Social Action Plan for the existing Thaton Power Plant

Nr. What Description Responsibility When Monitoring indicators

1. Overarching actions (Part of the overall Project and of Fichtner’s assignment)

1.1 Capacity building within EPGE

Fichtner will assist EPGE to set up an Environmental and Social Management Unit (ESMU) under EPGE’s Thermal Power Department by:

conducting a skills and organizational assessment to identify suitable staff;

conducting a training needs assessment for staff recruited to the ESMU;

recommending suitable training courses for the ESMU-staff

provide on-the job training and mentoring support to ESMU.

EPGE

The establishment of a ESMU shall start immediately after a Facilitator is available for the Project’s team On the job training starts in October 2016 and will be undertaken every 6 months until October 2018 Capacity Building Report to be ready in June 2018

Capacity Building Report (part of the overall Project and of Fichtner’s assignment) Bi-annual Site Visit Reports

1.2 EHS Management System within EPGE

Development of an EHS Policy within EPGE and establishment of an Environmental Management System (EMS)

Development of EHS Procedures and technical guidelines and their dissemination to the employees

Elaboration of training programs

Preparation works for getting certification according to ISO 14001, ISO 9001, OHSAS 18001

EPGE Q1 - 2018

EHS-MS Report (part of the overall Project and of Fichtner’s assignment)

1.3 Public consultation and information

Consultation events with local communities will be organized to ensure that people will have an opportunity to express their opinion on the existing and the new power plant, especially on matters sensitive to their lifes (soil and water quality; noise; economical growth; etc.). Also an advocacy program with the State Government and related government departments and civil society organizations will be undertaken to raise their interest in the public hearing and invite them to participate in the public meetings.

EPGE Q2 - 2017 Minutes of the consultation events

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Nr. What Description Responsibility When Monitoring indicators

2. EHS Management and Training at site

2.1

Hire a EHS Manager for the Thaton Power Plant

A EHS Manager shall be hired for the Thaton Power Plant. The EHS Manager shall be empowered to do the daily EHS management of the power plant, which includes implementation and follow-up of this Action Plan. The EHS Manager shall be trained on the national legal EHS requirements and on EHS best international practices.

EPGE Q2 - 2017

Working contract of the EHS Manager Training records of the EHS Manager

2.2 Train all workers of the plant in EHS procedures

The EHS Manager shall provide training to the workers of the plant on EHS issues at site. This training shall be refreshed regularly.

Thaton Power Plant EHS Manager

One time after beginning of functions of the EHS Manager Every time a new worker joins the plant At least once per year

Training plan Training records (materials used and distributed, pictures, signed list of presence)

3. Occupational Health and Safety

3.1 Provide personal protective equipment (PPE)

Provide personal protective equipment (PPE) at least for the workers undertaking the following tasks:

Maintenance works (electrical; civil; others); Works in the turbines area; Works in the transformer stations.

The PPE to provide shall at least consist of:

Ear muffs (for works in the turbine area); Helmets; Gloves; Safety shoes.

In addition to the above, earplugs shall be made available in the offices for free usage by any worker.

EPGE Q1 - 2017

PPE Purchase order Pictures of the PPE received

3.2 Warning signs and labels

Place warning signs along the power plant in the hazardous areas and warning labels on the hazardous materials. The signs shall be written in Burmese and have a mixture of text and images where possible (see example in Figure 6-1 below). For example, the following locations/materials shall be included:

EPGE Q1 - 2017 Pictures of the signs and the labels

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Nr. What Description Responsibility When Monitoring indicators

Fences of the switchyards;

GT areas; Containers of HCL and NaOH.

3.3 Close and/or signalize open ducts and holes

The holes on the floor of the small control room and switch yards shall be repaired. For those holes which need to remain open for technical reasons, a fence shall be placed around them with a respective warning sign in Burmese.

EPGE Q2 - 2017 Pictures of the repaired holes and warning signs

3.4 Repair damaged fences

The damaged fences around the complex of GT 1 and GT 2 and around the switch yards shall be repaired. The fence gates shall be kept closed and the respective keys shall be given to the workers responsible for that particular area of the plant.

EPGE Q2 - 2017 Pictures of the repaired fences

3.5 Register of the occurrence of asbestos

A register shall be made of the asbestos containing materials (walls and ceilings) at the substations, control buildings, warehouses, tea shop, library, water treatment plant, and other structures. The register shall include a list of the locations of asbestos containing materials, a description of the status of the materials (damaged or not damaged), and pictures.

EPGE Q1 - 2017 Register (list of locations; status of the panels; pictures)

3.6 Protection from exposure to asbestos

After the creation of the asbestos register, a plan for reduction of exposure of workers to asbestos at the Plant shall be developed by EPGE. The following shall at least be considered: o Non damaged panels:

Because there is no appropriate disposal site for asbestos available in Myanmar at the moment, the panels which are not damaged should be left untouched, if there is not a real urgent need to remove them.

If panels which are not damaged need to be removed, this shall be undertaken by people wearing protective equipment (closed clothes and shoes, masks and gloves). The removed panels shall be stored inside one of the warehouses, properly labeled and enclosed until a final disposal solution is found.

o Damaged panels:

EPGE Q2 - 2017

Plan for reduction of exposure of workers to asbestos Pictures of the measures undertaken

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Nr. What Description Responsibility When Monitoring indicators

In order to protect asbestos fibers from being released from broken asbestos panels, painting of the panels shall be undertaken to minimize the risks of exposure. This shall be undertaken only as a temporary solution to stop the release of fibers until all panels are removed.

3.7 Closure of abandoned buildings

The access to the abandoned steam turbine building shall be blocked. The door to the building and any other entrances shall be closed and locked with chains. The workers shall be instructed not to enter the building. No materials or waste shall be allowed inside.

EPGE Q1 - 2017 Pictures of the locked door

3.8 Smoking prohibition and smoking area

Smoking shall be strictly forbidden inside the buildings of the plant, and particularly inside the control rooms and the warehouses where oil is stored. Smoking in the open areas of the plant shall be restricted to one or more demarcated areas, which shall be signed and supplied with ashtrays. These areas shall be placed away from the switch yards, the GTs, the WTP, and the warehouses.

EPGE Q1 - 2017 Pictures of the demarcated smoking area

3.9 Fire extinguishers in the buildings

Fire extinguishers in working conditions (within the due date) shall be spread throughout the buildings of the plant, inclusive the tea shop, the warehouses, etc. Those available presently at site but not distributed yet shall be verified for its validity and used. Fire extinguishers are typically fitted in buildings at an easily-accessible location, such as against a wall in a high person-traffic area. Fire extinguishers need to be suitably sited to ensure that they are obvious and available for use. In general they should be situated so they are:

Compliant with countries maximum travel distance (ex.: UK 30 m)

Conspicuous and accessible (handle not over 1.1 m above the floor)

In corridors, inside doorways or at a point of specific use.

EPGE Q1 - 2017 Pictures of the fire extinguishers

3.10 Fire extinguishers in the GT areas

3 sets of CO2 fire extinguishers shall be provided in the GT areas (GT 1 + 2 and GT 3) (similar fire extinguishers sets as

EPGE Q1 - 2017 Pictures of the fire extinguishers

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Nr. What Description Responsibility When Monitoring indicators

those existing in the Ahlone & Hlawga Power Plants are proposed)

3.11 Fire extinguishers in the switch yards

Dry powder fire extinguishers shall be made available in each of the 3 switchyards

EPGE Q1 - 2017 Pictures of the fire extinguishers

3.12 New first aid kit

A new large first aid kit shall be acquired for the plant and be available in the office building. It is suggested that the components as per the German Norm DIN 13169 are included in the kit (see Annex 7 to this report for details).

EPGE Q1 - 2017 Pictures of the new large first-aid kit

3.13 Update of the Emergency Response Plan

The existing Emergency Response Plan shall be updated. Thaton Power Plant EHS Manager

Q3 - 2017 Updated Emergency Response Plan

3.14 Repair of electrical sockets and wires

The open and damaged electrical sockets and wires inside the office building shall be repaired and covered.

EPGE Q1 - 2017

Pictures of the repaired and covered electrical sockets and wires

3.15 Ventilation of battery room

A ventilation system shall be built for the batteries room (in a similar way as what is available in the Ahlone & Hlawga Power Plants). The windows of the batteries room shall be kept closed once the ventilation system is in place.

EPGE Q1 - 2017 Pictures of the ventilation system

3.16 Labeling of facilities

All large facilities of the Power Plant, wether abandoned or functioning, shall be labeled with:

name of the facility (switchyard, turbine nr.,etc.); potencial dangers (electrocution, burning, asbestos,

noisy, hazardous to eyes and skin, etc.); protection measures (mandatory usage of PPE,

entrance forbidden, etc.).

EPGE Q3 - 2017 Pictures of the labels

4. Welfare conditions

4.1 Provision of facilities for children

Provision of installations dedicated to children welfare in the office building. This space shall allow the children of the workers to spend their time in the plant in safe conditions and in a pleasant environment appropriate for their age. The space shall be equipped with educational entertainment equipment, such as children books, puzzles, etc. If deemed necessary, one person shall be hired as child care assistant.

EPGE Q3 - 2017 Pictures of the installations

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Nr. What Description Responsibility When Monitoring indicators

4.2 New eating facilities

The tea shop shall be closed due to the presence of damaged asbestos-containing panels. A new building shall be built in the nearby area that shall be large enough to accommodate the workers of the plant in different shifts. After this building is ready, the prohibition of eating inside the control rooms shall be imposed.

EPGE Q4 - 2017

New tea shop plan/designs and time plan Pictures of the new installations

5. Social risks

5.1 Avoiding unemployment

Elaborate a plan for re-integration of the workers in the new power plant in case of shut down of the existing power plant. This plan shall include technical, administrative and EHS training.

EPGE Q1 - 2017 Plan for re-integration of the workers

5.2 Provision of water to the housing areas

A new water pipeline to supply the new Power Plant is planned to be built as part of the overall Project. This shall include a connection to the housing area to solve the water supply problems presently faced by the workers of the existing plant which live there.

EPGE 2018

Contractual documents Design documents

6. Environment and Community Health & Safety

6.1 Reduction of noise emissions from the GT

If the old Power Plant will continue to operate, provide enclosures for the GT 1, 2 and 3 to reduce the noise emissions

EPGE Q3 - 2017 Pictures of the enclosures

6.2 Procure a solution for waste disposal

Contact the Thaton Village Development Committee and procure a solution for waste disposal. The solution shall involve the collection and disposal of non-hazardous garbage by the village committee. Burning trash on site shall then be stopped.

EPGE Q1 - 2017 Results of conversations

6.3

Provide a dedicated burning area at site (if 6.2 is not implemented)

In case a solution is not encountered with the Thaton Village Development Committee, provide a designated area on site where rubbish can be burned. This area shall be signalized, and be located away from trees and from the plant’s buildings. The burning of waste shall be conducted by a worker with appropriate PPE under a designated time frame.

EPGE Q2 - 2017 Pictures of the designated burning area

6.4 Proper storage of liquid chemical materials

The storage of liquid materials for usage in the WTP (HCl and NaOH) shall be done inside the WTP in bunded areas to retain leakages (see example in Figure 6-2 below). These designated areas shall be located in the zones of the WTP which are

EPGE Q1 - 2017 Pictures of the storage area and exterior of the WTP

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Nr. What Description Responsibility When Monitoring indicators

nowadays not in use.

6.5 Proper storage of hazardous waste

Hazardous waste such as used oil and mercury containing lamps shall be stored in specific locations within the warehouses 1, 2 and /or 3.

EPGE Q1 - 2017 Pictures of storage areas for hazardous waste

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Figure 6-1: Safety instructions for chemical handling and emergency response (bilingual, mixed text and graphics) (FGLLID, year unkown)

Figure 6-2: Example of storage of hazardous liquids in bunded areas (FGLLID, year unkown)

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7. Conclusion and future work

The DD Audit at the Thaton Power Plant revealed that the plant is working under unsafe and environmentally unsound conditions. Given the present dependency of the town on the power plant for needed jobs and energy supply, an immediate shutdown of the installations cannot be recommended. Instead, Fichtner prepared an Environmental and Social Action Plan with some overarching and other specific measures to be undertaken at the plant within the next two years. The work on the measures shall start immediately.

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8. References

BEWG, 2012: Advocating for Sustainable Development in Burma, Burma Environmental Working Group, 2012. Available at: http://www.burmalibrary.org/docs22/Advocating_for_SD_-_English.pdf

ESA, 2013: Environmental and Social Assessment for the Thaton Gas-Fired Power Plant, Mon State, Myanmar, incl. the Environmental and Social management Plan (ESMP), Norconsult, August 2013

FGLLID, year unkown: National Profile on Occupational Safety

and Health, Factories and General Labour Laws Inspection Departement, Ministry of Labour, Myanmar. Available at: http://www.ilo.org/wcmsp5/groups/public/---ed_protect/---protrav/---safework/documents/policy/wcms_242224.pdf

FS, 2013: Feasibility Study of Thaton Gas Power Plant, Norconsult, August 2013

HRRA, 2014: Human Rights Risk Assessment, Thaton Power Station, NomoGaia, 2014

Luther, 2016: Labour Law in Myanmar, Luther

Rechtsanwaltsgesellschaft GmbH, Yangon, March 2016. Available at: http://www.luther-services.com/fileadmin/user_upload/PDF/Broschueren/Geschaeftsaktivitaeten_im_Ausland/Myanmar/Labour_Law_Myanmar.pdf

Mann and Myint, year unknown: Community-based 3 Rs practices

in Myanmar, U Mann and Ohnmar Mynt, year unknown. Available at: http://www.iges.or.jp/jp/archive/wmr/pdf/activity100728/6_Myanmar_Day1_Session2.pdf

MINDC, 2015: Myanmar’s Intended Nationally Determined Contribution, The Republic of the Union of Myanmar, 25.08.2015. Available at: http://www4.unfccc.int/submissions/INDC/Published%20Documents/Myanmar/1/Myanmar's%20INDC.pdf

SWIA, 2014: MCRB, IHRB and DIHR, Myanmar Oil & Gas Sector-

Wide Impact Assessment (SWIA), Sept. 2014. Available at http://www.myanmar-responsiblebusiness.org/pdf/SWIA/Oil-Gas/00-Myanmar-Oil-and-Gas-Sector-Wide-Assessment.pdf

RFS 2014: Requirements and Functional Specification for a complete CCGT power plant at Thaton, Mon State, Myanmar, Revision: 02, Issued for Tender Date: 04th March 2014 ‘Health, safety and environment (EHS)’

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WB, 1999: Pollution Prevention and Abatement Handbook, toward cleaning production - 1998, the World Bank Group, Washington D.C., March 1999. Available at: http://www.ifc.org/wps/wcm/connect/topics_ext_content/ifc_external_corporate_site/ifc+sustainability/learning+and+adapting/knowledge+products/publications/publications_handbook_ppah__wci__1319577543003

URL 1: IFc’s website regarding the PPAH: http://www.ifc.org/wps/wcm/connect/topics_ext_content/ifc_external_corporate_site/ifc+sustainability/our+approach/risk+management/safeguards+-+pre2006#ehsppah

URL 2: The Factories Act (1951) - 2016 ammended version: http://www.ilo.org/dyn/natlex/docs/MONOGRAPH/88477/123120/F1558150740/MMR88477%20Eng%202016.pdf:

URL 3 : WHO - Asbestos: http://www.who.int/ipcs/assessment/public_health/asbestos/en/

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9. Annexes

9.1 Annex 1: Photographic documentation

9.1.1 Due Diligence Site Audit - 1st visit (July 2016)

Figure 9-1: Fall risk in a switchyard

Figure 9-2: Fall risk inside the WTP

Figure 9-3 Cloth line inside the WTP

Figure 9-4: Missing gate at a switchyard

Figure 9-5: Open-air storage of HCL

Figure 9-6: Tea shop and library

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Figure 9-7: First aid box Figure 9-8: New fire extinguishers

Figure 9-9: Lunch at Thaton PP inside one of the control rooms

Figure 9-10 Broken fence at the GT 1 + 2 area

Figure 9-11: Stacks of GT 1 and GT 2

Figure 9-12: Unsafe electric installation in the administration building

Figure 9-13: Battery storage inside the administration building

Figure 9-14: Storage of old mercury containing light bulbs, and chemicals

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in the administration building

Figure 9-15: Waste scattered on site

Figure 9-16: Storage of old, used oil in leaky storage building

Figure 9-17: Broken ceiling in storage building, asbestos containing

Figure 9-18: Storage of unlabeled, full drums inside the WTP

Figure 9-19: Unstable storage of unlabeled, full drums inside the WTP

Figure 9-20: Old, not longer used steam turbine building, covered with potentially asbestos-containing panels

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Figure 9-21: Inside the old steam turbine building

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9.1.2 Due Diligence Site Audit - 2nd visit (September 2016)

Figure 9-22: Tea shop Figure 9-23 Asbestos panels in the tea shop

Figure 9-24: Worker on transmission line without PPE

Figure 9-25: Worker without PPE

Figure 9-26: Hospital in Thaton Figure 9-27: Fire Brigade in Thaton

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9.2 Annex 2: Certificate of the Analytical Laboratory

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9.3 Annex 3: Results of the PCB analyses

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9.4 Annex 4: Results of the asbestos analyses

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9.5 Annex 5: IFC Performance Standards checklist

Table 9-1: Assessment of compliance with PS 1

Auditable Criteria of PS 1 Assessment

Policy Has a formal policy defining the environmental and social objectives and principles that guide the project been established?

No There is not a E&S policy at the Thaton Power Plant. Is the policy consistent with the principles of

the PS or other internationally recognized standards? Identification of risks and impacts

K: Is there a process to assess the environmental and social impacts and risks of the project?

Yes The ESA for the new Thaton Plant (ESA, 2013, Section 4) describes the impacts and risks of the existing Thaton Plant. Fichtner’s Due Diligence Site Audit (this report) assesses as well the impacts and risks of the existing plant.

Have recent environmental and social baseline data at an appropriate level of detail been used in the assessment?

Partly ESA, 2013, Sections 3, 4 and 5 Information is missing or is insufficient on the existing plant regarding air quality and emission levels, water quality, waste generation, soil contamination, etc. Information on PCBs and asbestos has been collected by Fichtner on the existing plant by means of random samples.

K: Have all relevant risks and impacts been assessed, including the issues identified in Performance Standards 2 through 8?

Yes The ESA for the new Thaton Plant (ESA, 2013, Section 4) describes the impacts and risks of the existing Thaton Plant. Fichtner’s Due Diligence Site Audit (this report) assesses as well the impacts and risks of the existing plant.

Are the risks and impacts related to the emission of GHG and climate change considered, as well as adaptation opportunities?

Partly Section 4 of the ESA (2013) shows an estimation of the emissions of GHG of the existing plant

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Auditable Criteria of PS 1 Assessment

Have transboundary effects been considered?

Not applicable

Have the impacts been identified in the context of the project’s area of influence?

Yes ESA, 2013 This DD Report

Have cumulative impacts been assessed?

No There is not enough information about other polluting/resource using activities in the area

Have risks and impacts related to the actions of third parties been assessed?

No The risks and impacts related to actions of third parties have not been assessed in the EIA Report.

Has the assessment considered the findings of plans, studies and assessments prepared by relevant government authorities and other parties directly related to the project?

Yes This DD Report considered the results of the ESA, 2013

Have disadvantaged or vulnerable groups been identified?

Yes ESA, 2013, Section 5 This DD Report, Section 5

If so, do any adverse impacts fall disproportionately on them?

No The vulnerable groups are not disproportionately affected.

Management Programs K: Has a program of mitigation and performance improvement measures that addresses identified impacts and risks been developed?

No The ESA, 2013 developed a program for the new plant exclusively To be addressed in an Environmental and Social Action Plan for the existing plant (this DD Report, Section 7).

Does the program take into account the engagement process with affected communities? Can the program be tracked over definite time periods?

Does the program include estimates of the resources for implementation?

Does the program include definition of the responsibilities for implementation? Organizational Capacity and Competency Are responsibilities and authorities for implementation of the management program defined and communicated appropriately through the client’s organization?

No The ESA, 2013 developed a program for the new plant exclusively To be addressed in an Environmental and Social Action Plan for the existing plant (this DD Report, Section 7).

Do the persons with responsibility for implementing the management program have the necessary knowledge, skills and experience?

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Emergency Preparedness and Response K: Are there emergency preparedness and response plans that are commensurate with the level of project risks?

No To be addressed in an Environmental and Social Action Plan for the existing plant (this DD Report, Section 6).

In the event emergency preparedness and response requires participation of the community and the local governmental agencies, have they been involved? Monitoring and Review Have procedures to monitor and measure on a regular basis the effectiveness of the management program established, including the use of external experts and/or affected communities where appropriate?

No There are no E&S monitoring and reporting procedures at the Thaton Power Plant.

Is the management program regularly updated based on the results of the monitoring? Is appropriate environmental and social performance information periodically reported internally to senior management? Stakeholder Engagement

K: Has the range of stakeholders for the project been identified?

Yes The ESA, 2013, Section 5, identified the stakeholders for the new plant. These are the same as those for the existing plant.

Has a Stakeholder Engagement Plan/Framework* been established? *Framework: in case the exact location is not yet known

No A formal Plan or Frameowork Plan has not been established.

Are differentiated measures deemed to allow the participation of those identified as disadvantaged or vulnerable included?

No A formal Plan or Framework Plan with measures has not been established.

K: Has appropriate disclosure of relevant project information to, and consultation with, affected communities been conducted? Yes

ESA, 2013, Section 5 Continuation of the process to be addressed in an Environmental and Social Action Plan for the existing plant (this DD Report, Section 6).

Has the disclosure and consultation process been:

Timely (early in the process)? Culturally appropriate (language,

gender issues)? Free of external manipulation,

interference, coercion or intimidation?

Transparent? Meaningful? Documented?

For projects with potentially significant adverse impacts on Affected Communities, has a process of Informed Consultation and Participation been undertaken?

Not possible to assess (please refer to IFC PS 7 checklist and Section 5.1.7 of this report) Are Indigenous Peoples engaged in a

process of ICP (Informed Consultation and Participation)?

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Was the Indigenous Peoples FPIC (Free, Prior and Informed Consent) obtained? External Communications and Grievance Mechanisms Is there a procedure for receiving external communications, screening and assessing the issues raised and providing answers and adjustments to the management plan?

No To be addressed in an Environmental and Social Action Plan for the existing plant (this DD Report, Section 7).

Are reports on the environmental and social sustainability of the project publicly available? K: Has an effective grievance mechanism for affected communities been established? Ongoing reporting for affected communities Are (at least) annually reports provided to the affected communities describing the progress with the implementation of the Action Plans on issues involving risks them and on those issues identified through the consultation/grievance mechanisms?

No There are no E&S reporting procedures at the Thaton Power Plant.

Table 9-2: Assessment of compliance with PS 2

Auditable Criteria of PS 2 Assessment

Human Resource Policies and Procedures

K: Are appropriate human resources policies and procedures available that address all requirements of PS 2 and national law?

No No policies are available at site, but it is stated that the national legislation is followed

Are the workers provided with information regarding their rights?

No information

Working conditions and terms of employment

Are any established collective bargaining agreement with workers’ organizations respected?

Not applicable There are no bargaining agreements. By law, the employees get the same salary in all national power plants if they are doing the same job.

Is it ensured that the migrant workers are engaged on substantially equivalent terms and conditions to the non-migrant workers carrying similar work?

Not applicable No migrant workers are employed at the old Thaton Plant.

K: Where accommodation services are provided, is it ensured that:

Policies on the quality and management of the accommodations and basic services are implemented?

Principles of non-discrimination and equal opportunity guide the accommodation services?

The accommodation’s

Partly, because:

Water supply is not proper

Every worker can rent a house in this area

The workers‘ freedom is not

restricted

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arrangements do not restrict worker’s freedom of movement or association?

Workers‘ Organizations

K: Is there a compliance with the national law in allowing workers to form and join workers organizations?

No information There are no workers organizations at the plant, but the reason thereof has not been shared with Fichtner. The national law allows the formation of workers organizations under certain conditions.

If national law substantially restricts workers organizations, have there been restrictions imposed to workers to express their grievances and protect their rights organizations? Non-discrimination and Equal Opportunity Is it ensured that employment decisions are not made on the basis of personal characteristics unrelated to job requirements?

Yes No discrimination is reportedly faced at the plant.

Is harassment, intimidation and/or exploitation of workers, especially women and migrant workers, avoided?

Yes No harassment, intoimidation or exploitation is reportedly faced at the plant.

Retrenchment

If any collective dismissal was applied, has an analysis of alternatives to retrenchment been made?

Not applicable There was never a collective dismissal in the plant.

If retrenchment of a significant number of employees is expected, has a plan been developed to implement the retrenchment in compliance with all legal and contractual requirements?

No It is not clear whether the workers of the existing plant will be let go or not once this plant closes. To be addressed in an Environmental and Social Action Plan for the existing plant (this DD Report, Section 6).

Grievance mechanism K: Is a grievance mechanism for workers provided to raise workplace concerns that: is easily accessible; is understandable? is transparent? allows anonymous complains?

Partly Workers are allowed to raise oral complaints, but no formal grievance mechanism is available.

Child Labour

K: Does the project employ children?

No No children reportedly work at the plant.

Where national laws allow the employment of minors:

are the provisions of those laws followed by the client?

are minors kept away from hazardous work?

are minors subject to appropriate risk assessment and regular

Not applicable

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monitoring of health, working conditions and hours of work?

Forced Labour

K: Does the project employ forced labour or trafficked persons?

No No forced or trafficked persons reportedly work at the plant.

Occupational Health & Safety (OHS) K: Does the project provide the workers with a safe and healthy work environment?

No See description in Section 4 of this DD report

Have steps been taken to prevent accidents, injury, and disease?

Have the workers been trained in occupational health and safety? Are occupational accidents, diseases, and incidents documented and reported? K: Is there an emergency prevention, preparedness and response arrangement for the project?

Workers Engaged by Third Parties Are there policies and procedures for managing and monitoring the performance of third party employers in relation to the requirements of this PS?

Not applicable There are no third party employers at the plant. Is the access of the workers engaged

by third parties to a grievance mechanism guaranteed? Supply Chain If there is a high risk of child or forced labour in the primary supply chain, are these risks identified and monitored, and are the necessary steps taken to remedy them?

Not applicable

If there is a high risk of significant safety issues related to supply chain workers, is it ensured that the primary suppliers are preventing these situations? In case of need, does the project shift its primary supply chain to suppliers that can demonstrate the compliance with this PS?

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Table 9-3: Assessment of compliance with PS 3

Auditable Criteria of PS 3 Assessment

Resource Efficiency

K: Have the project’s operations incorporated resource conservation and energy efficiency measures?

No The power plant is old and inefficient.

Where GHG emissions (direct plus indirect from purchased electricity) exceed 25,000 tons CO2 annually, is annual quantification undertaken?

No There are no E&S reporting procedures at the Thaton Power Plant.

In case the project is a potentially significant consumer of water, have measures to avoid or reduce the water usage been adopted?

Not applicable The power plant works in close cycle.

Pollution Prevention

K: Is the release of pollutants avoided/minimized?

No The power plant is old and inefficient.

Have the following factors been included in the assessment of potential adverse project impacts: existing ambient conditions; the finite assimilative capacity of the environment; existing and future land use; the project’s proximity to areas of importance to biodiversity; and the potential for cumulative impacts?

Yes The ESA for the new Thaton Plant (ESA, 2013, Section 4) describes the impacts and risks of the existing Thaton Power Plant. Fichtner’s Due Diligence Site Audit (this report) assesses as well the impacts and risks of the existing plant.

Is the following hierarchy for waste management followed: avoidance, reduction, recovery, re-usage, treatment, destruction and final environmentally sound disposal?

No To be addressed in an Environmental and Social Action Plan for the existing plant (this DD Report, Section 6).

K: Are special provisions for hazardous waste disposal considered?

Partly Quantities of hazardous waste are communicated to the headquarters, which then manages it.

Is the release of hazardous materials avoided/minimized/controlled?

No To be addressed in an Environmental and Social Action Plan for the existing plant (this DD Report, Section 6).

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Are hazardous materials which are subject to international bans or phase-outs used?

No information

If pesticides are used, is their selection and management consistent with good international industry practice and part of an integrated pest management and/or vector management strategy?

No information

Table 9-4: Assessment of compliance with PS 4

Auditable Criteria of PS 4 Assessment

Comunity Health and Safety

K: Has the potential for community risks and impacts associated with the project been evaluated?

Partly ESA, 2013, Section 4 Noise impacts in the communities of the existing plant have been evaluated; missing detailed information on air quality, soil and water contamination, etc.

Have preventive and control measures consistent with GIIP been established?

No The plant is very old and the buildings are unsafe

Infrastructure and Equipment Design and Safety Have the structural elements of the project been designed, constructed, operated and decommissioned in accordance with GIIP?

No The plant is very old and the structures are unsafe

Hazardous Materials Management and Safety

Is the potential for community exposure to hazardous materials and substances that may be released by the project avoided or minimized?

No To be addressed in an Environmental and Social Action Plan for the existing plant (this DD Report, Section 6).

Ecosystem Services

K: Have impacts and risks on priority ecosystem services in use by the Affected Communities been identified?

No There is no impact assessment on receiving water quality, or on soil

Community Exposure to Disease Does the project avoid or minimize the potential for community exposure to water-related and vector-borne diseases caused by the project, including influx of labour?

Not applicable

Emergency Preparedness and Response

See PS 1

Security Personnel Have security arrangements guided by principles of proportionality, good international practice, and the national law been made?

Yes The police makes the security of the site

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Auditable Criteria of PS 4 Assessment

Is it assured that the security personnel has not been implied in past abuses?

Have the security personnel been provided training in the use of force and conduct towards the community? Has the community been provided with a grievance mechanism through which complains regarding the security arrangements can be done?

No A community grievance mechanism is not available.

Table 9-5: Assessment of compliance with PS 5

Auditable Criteria of PS 5 Assessment

Project design K: Have alternative designs to avoid or minimize economic and physical displacement been considered? Not

applicable Have the poor and vulnerable been given special attention?

Compensation and Benefits for Displaced Persons

K: When displacement cannot be avoided, has it been offered displaced communities and persons compensation for loss of assets at full replacement cost and other assistance?

Not applicable

Where livelihoods of displaced persons are land-based, or where land is collectively owned, has it been offered the displaced land-based compensation?

K: Has it been taken possession of acquired land and related assets only after compensation has been made available and, where applicable, resettlement sites and moving allowances have been provided?

Have opportunities been provided to displaced persons and communities to derive appropriate development benefits from the project?

Community Engagement

See PS 1

Grievance Mechanism K: Has a grievance mechanism to receive and address specific concerns related to compensation and relocation been established?

Not applicable

Resettlement and Livelihood Restoration Planning and Implementation Have persons to be displaced by the project and those eligible for compensation and assistance been identified through a baseline census with appropriate socio-economic baseline data?

Not applicable

Has a cutoff date for eligibility been established or disseminated?

Not applicable

If expropriation or other legal procedures are conducted (in case persons reject compensation offers), is there a collaboration with the responsible governmental agency? Where the exact nature or magnitude of the resettlement-related impacts is unknown due to the stage of project development, has a Resettlement and/or Livelihood Restoration

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Framework outlining general principles been developed?

Where the exact nature or magnitude of the resettlement-related impacts is known, has a specific Resettlement Action Plan (RAP) or a Livelihood Restoration Plan (LRP) been developed? Have procedures to monitor and evaluate the implementation of a RAP or LRP, including an external completion audit, been established? Physical Displacement K: In case of physical displacement, and independently of the number of persons affected, has a RAP following PS 5 been developed?

Not applicable

If people shall move to another location, have they been offered choices amongst resettlement options, and provided relocation assistance? For physically displaced persons with a land title or a claim to the land, have they been offered the choice of replacement property of equal or higher value, security of tenure, equivalent or better characteristics, and advantages of location or cash compensation? For physically displaced persons without neither a land title nor a claim to the land, have they been offered a choice of options for adequate housing with security of tenure? For physically displaced persons without neither a land title nor a claim to the land, but which own and occupy structures, have they been offered compensation for the loss of assets instead of land at full replacement cost? Have forced evictions been carried out? If yes, were these made in accordance to the national law and the requirements of PS 5? Economic Displacement

K: For exclusively economically displaced persons, has a Livelihood Restoration Plan (LRP) been developed?

Not applicable

Have economically displaced persons who face loss of assets or access to assets been compensated at full replacement cost? Have economically displaced persons whose livelihoods or income levels are adversely affected been provided opportunities to improve, or at least restore, their means of income-earning capacity, production levels, and standards of living?

Has transitional support been provided as necessary to all economically displaced persons?

Private Sector Responsibilities under Government-Managed Resettlement

Have government actions been supplemented, and any gaps between the government-assigned entitlements and this PS been bridged (by means of a Supplemental Resettlement Plan or an Environmental and Social Action Plan)?

Not applicable

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Table 9-6: Assessment of compliance with PS 6

Auditable Criteria of PS 6 Assessment

General

K: Has the significance of project impacts on biodiversity and ecosystem services been specifically addressed as part of its social and environmental assessment process?

No The ESA (2013) mentions some impacts of the existing plant, but not on biodiversity or ecosystem services

Has the practice of adaptive management been adopted?

No There is no adaptative management of E&S issues at the Plant.

Protection and Conservation of Biodiversity

K: Has a hierarchy of avoidance, minimization, restoration and compensation (biodiversity offsets) been considered?

No The ESA (2013) mentions some minimization measures to tackle impacts of the existing plant, but nothing related to biodiversity or ecosystem services

Have natural habitat areas been conversed or degraded? If yes, have the conditions of PS 6 been respected?

No information

Have natural habitat areas suffered a net loss of biodiversity? Has the implementation of project activities been undertaken in critical habitat? If yes, have the conditions of PS 6 been respected? If critical habitat is affected, has a Biodiversity Action Plan been designed to achieve net gains of biodiversity? Has the implementation of project activities been undertaken in a protected or internationally recognized area? If yes, have the conditions of PS 6 been respected? Do the project activities imply the introduction of invasive species and/or of alien species with a high risk of invasive behavior?

No Introduction of alien and invasive species is not part of the Project.

If applicable, has the intentional introduction of alien species been carried out according to specific regulatory framework?

Not applicable Have measures been designed to avoid unintentional introduction or spreading of alien species?

Management of Ecosystem Services

If ecosystems services are affected by the project, have priority ecosystem services been identified with the support of the affected communities that depend on them?

No The ESA (2013) mentions some impacts of the existing plant, but not on biodiversity or ecosystem services

Sustainable Management of Living Natural Resources

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Have living natural resources which the project will use been identified, and is there a commitment to managing them in a sustainable manner?

Not applicable

Supply Chain Where primary production is being purchased from regions where there is a risk of significant conversion of natural and/or critical habitats, have systems and verification practices as part of the ESMS been introduced?

Not applicable

Table 9-7: Assessment of compliance with PS 7

Auditable Criteria of PS 7 Assessment

Avoidance of Adverse Impacts K: Has the environmental and social impact assessment process identified all communities of Indigenous Peoples (IP) who may be affected by the project, as well as the nature and degree of the impacts? Not possible to

assess Has a hierarchy of avoidance, minimization, restoration and compensation been applied to the impacts on IP in a culturally appropriate matter? K: Has an Indigenous Peoples Plan been developed?

Participation and Consent K: Have the IP been involved in the engagement process of the project, and has a FPIC (Free, Prior and Informed Consent) been obtained thereof?

Not possible to assess

Impacts on Lands and Natural Resources Subject to Traditional Ownership or Under Customary Use

In case of such impacts, has the project: Avoided or minimized the proposed project area? Avoided or minimized impacts on natural resources and natural areas of importance to IP? Identified and reviewed all property interests and traditional resource uses prior to purchasing or leasing land? Assessed and documented the IP’s resource use without prejudicing any IP’s land claim? Assured that the IP’s are informed of their land rights? Offered IP’s compensation and due process in the case of commercial development of their land and natural resources, together with culturally appropriate sustainable development opportunities?

Not possible to assess

Relocation of Indigenous Peoples from Lands and Natural Resources Subject to Traditional Ownership or Under Customary Use

Where relocation of IP’s is unavoidable, has the IP’s FPIC been obtained?

Not possible to assess

Has the relocation process been undertaken based on the requirements of PS 5?

Critical Cultural Heritage

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Auditable Criteria of PS 7 Assessment

Where significant impacts on critical cultural heritage of IP’s are unavoidable, or where this will be used for commercial purposes, has the IP’s FPIC been obtained? Not possible to

assess Where cultural heritage will be used for commercial purposes, has the fair and equitable sharing of benefits been ensured?

Private Sector Responsibilities Where Government is Responsible for Managing Indigenous Peoples Issues Has there been collaboration with the government where this is responsible for the management of IP’s project-related issues, including the preparation of a plan to address all requirements of PS 7 together with the government documents?

Not possible to assess

Table 9-8: Assessment of compliance with PS 8

Auditable Criteria of PS 8 Assessment

Protection of Cultural Heritage in Project Design and Execution

K: Has cultural heritage been considered as part of the environmental and social assessment?

Yes The ESA for the new Thaton Plant (ESA, 2013, Section 4) describes the impacts and risks of the existing Thaton Plant.

If the project is located in an area where cultural heritage is expected to be found, has a Chance Find Procedure been established?

Not applicable

Have the Affected Communities who use or have used the cultural heritage for long-standing cultural purposes been consulted? Is continued access allowed to the cultural site or is an alternative route provided, in case of affectation of sites used for long-standing cultural purposes? Has a hierarchy of avoidance, minimization, restoration in situ and restoration off site, and compensation been undertaken? If non-replicable cultural heritage needs to be removed, have the following conditions of PS 8 been satisfied?:

no technically or financially feasible alternatives existed;

the benefits of the projects outweighed the anticipated cultural heritage loss from removal; and

removal was conducted by the best available technique.

If critical heritage is removed, significantly altered, or damaged by the project, have a process of ICP been undertaken with the Affected Communities? If the project is located in a legally protected area or a legally defined buffer zone, have the

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Auditable Criteria of PS 8 Assessment

following conditions of PS 8 been satisfied?: compliance with defined regulations and the protected area management plans; consultation with the protected area sponsors and managers, local communities and other key stakeholders? Implementation of additional programs as appropriate to promote and enhance the conservation aims of the protected area. Project’s use of cultural heritage If the project will use cultural resources, knowledge, innovations, or practices of local communities embodying traditional lifestyles for commercial purposes, has the client entered a process of ICP?

Not applicable

Have fair and equitable sharing of benefits been ensured?

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9.6 Annex 6: IFC EHS Guidelines checklist

Table 9-9: Assessment of compliance of the Thaton Power Plant with the IFC EHS guidelines (General and Thermal Power Plants)

Subject Auditable Criteria Assessment

Air emissions

General

Stack heights: Stack heights are designed according to Good International Industry Practice (GIIP).

No

Choice of fuel: A fuel type with lower sulfur content is selected (e.g. natural gas).

Yes

Incremental impacts in degraded airsheds If the facility is situated in a degraded airshed it minimizes incremental impacts by achieving emission values according to Table 6 of the IFC guidelines No information

There is no air emissions or air quality monitoring data for the plant and surroundings

Share of total emissions in the airshed: Emissions from this project contribute less than 25 % of the applicant ambient air quality standards to allow additional future sustainable development in the same airshed.

Guideline limit values The plant complies with emissions guidelines as outlined in table 6(B) (please refer to page 21).

Air Emission Monitoring Parameters The Plant undertakes air emission monitoring according to table 7 of the Guidelines (please refer to page 23).

No

Nitrogen Oxides NOx combustors / reduction equipment Dry low-NOx combustors are used.

No

Water Consumption and Aquatic Habitat Alteration

General Water cooling system A closed-cycle, recirculating cooling water system or closed circuit dry cooling water system is used in the event that unacceptable adverse impacts on water resources are expected.

Yes Closed circuit dry cooling is used

Liquid effluents

Waste water - general

Understanding types The following types are relevant and are understood by the project owner in terms of quantity, frequency and sources, routes and discharge points:

Partly There are no records of quantities

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material storage runoff metal cleaning wastewater floor and yard drains and sumps laboratory waste water waste water from process water treatment plant

or frequency of discharges; the discharge route and point for runoff water is known

Segregation The segregation of liquid effluents is planned and implemented (e.g. into process water, sanitary sewage, stormwater)

No

Opportunities to prevent or reuse Opportunities are identified to prevent or reuse wastewater pollution through the following measures: recycling, reuse within the facility, input substitution, process modification.

No

Standards The compliance of waste water discharges is assessed against (applicable standard (if waste water is discharged to a surface water or sewer), and water quality standards for a specific reuse Applicable standards are those national, local, or, in their absence, those from the IFC EHS Guidelines.

No

Treatment Wastewater treatment techniques are implemented (if required to further reduce the load of contaminants prior to discharge)

No

Stormwater

Separation Stormwater is separated from any type of process and sanitary wastewater.

Yes

Runoffs Surface runoff from process areas or potential sources of contamination is prevented.

No

Runoffs / segregation If there is no prevention of run-off, the runoff from process and storage areas is segregated from potentially less contaminated runoff.

No

Runoffs / segregation If there is no prevention of run-off, measures are implemented to reduce the peak discharge rate (e.g. by using vegetated swales and retention ponds).

No

Oil and grease treatment Oil water separators and grease traps are installed and maintained as appropriate at refueling facilities, workshops, parking areas, fuel storage and containment areas.

No

Sludge treatment The sludge from stormwater catchments and/or treatment systems is disposed in compliance with local regulatory requirements?

No

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Mode of using stormwater The stormwater is managed as a resource, either for groundwater recharge or for meeting water needs at the facility.

No

Sanitary Wastewater Sanitary wastewater from industrial facilities may include effluents from domestic sewage, food service, and laundry facilities. Miscellaneous wastewater from laboratories, medical infirmaries, water softening etc. may also be discharged to the sanitary wastewater treatment system.

Types of effluents All types, sources and flows of sanitary effluents are understood. The different fractions are segregated to ensure compatibility with selected treatment options.

No All sanitary sewage is stored in a tank at site and is collected by the authorities every 4 years; the applied treatment and disposal is unknown

Pre-treatment Oily and greasy effluents are pre-treated prior to discharge into sewer system.

No

Standards / indicative guideline values In case there is discharge to surface water, treatment is done to meet national or local standards for sanitary wastewater discharges. In absence of national /regional standards, indicative guideline values applicable to sanitary wastewater discharges according to the General EHS Guidelines are met (Please refer to table 1.3.1).

No

Standards / indicative guideline values In case sewage is discharged to a septic system, or where land is used as part of the treatment systems, treatment meets applicable or national standards.

No information Sewage is stored in a tank at site and is collected by the authorities every 4 years; the applied treatment and disposal is unknown

Sludge disposal Sludge from sanitary wastewater treatment systems is disposed in compliance with local regulatory requirements.

Solid waste

General (non-hazardous and hazardous waste)

Segregation Hazardous wastes are segregated from nonhazardous wastes.

No

Waste Management Planning The plant characterizes all generated waste according to composition, source, types of wastes produced, generation rates, or according to local regulatory requirements.

No

Waste Management Planning Effective planning and implementation of waste management strategies are implemented and include: Review of new waste sources during planning, siting, and design activities, including during equipment modifications and process alterations, to identify expected waste generation, pollution prevention opportunities, and necessary treatment, storage, and disposal infrastructure

No

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Collection of data and information about the process and waste streams in existing facilities, including characterization of waste streams by type, quantities, and potential use/disposition Establishment of priorities based on a risk analysis that takes into account the potential EHS risks during the waste cycle and the availability of infrastructure to manage the waste in an environmentally sound manner Definition of opportunities for source reduction, as well as reuse and recycling Definition of procedures and operational controls for onsite storage Definition of options / procedures / operational controls for treatment and final disposal Waste Prevention Processes are designed and operated to prevent, or minimize, the quantities of wastes generated and hazards associated with the wastes generated (Further details see General EHS Guidelines, page 47)

No

Waste Recycling and Reuse The total amount of waste is significantly reduced through the implementation of recycling plans

No

Treatment and Disposal Waste materials are treated and disposed of and all measures are taken to avoid potential impacts to human health and the environment. Selected management approaches are consistent with the characteristics of the waste and local regulations. (Further details see General EHS Guidelines, page 48)

No

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Subject Auditable Criteria Assessment

Monitoring Regular visual inspection of all waste storage collection and storage areas for evidence of accidental releases; verification if wastes are properly labeled and stored. When significant quantities of hazardous wastes are generated and stored on site, monitoring activities should include: Inspection of vessels for leaks, drips or other indications of loss Identification of cracks, corrosion, or damage to tanks, protective equipment, or floors Verification of locks, emergency valves, and other safety devices for easy operation (lubricating if required and employing the practice of keeping locks and safety equipment in standby position when the area is not occupied) Checking the operability of emergency systems Documenting results of testing for integrity, emissions, or monitoring stations (air, soil vapor, or groundwater) Documenting any changes to the storage facility, and any significant changes in the quantity of materials in storage Regular audits of waste segregation and collection practices are undertaken Waste generation trends are tracked by type and amount of waste generated, preferably by facility departments Waste at the beginning of generation of a new waste stream is characterized; the characteristics and proper management of the waste, especially hazardous wastes, are periodically documented Keeping manifests or other records that document the amount of waste generated and its destination Third party treatment, and disposal services including re-use and recycling facilities are periodically audited when significant quantities of hazardous wastes are managed by third parties. Whenever possible, audits should include site visits to the treatment storage and disposal location.

No There is not a EHS-responsible person at site undertaking regular monitoring

Hazardous solid waste

Understanding hazardous waste Potential impacts and risks associated with the management of any hazardous waste during its complete life cycle is understood

Partly Quantities of hazardous waste are communicated to the headquarters, which then manages it.

Handling hazardous waste Contractors handling, treating and disposing of hazardous waste are reputable and legitimate enterprises, licensed by the relevant regulatory agencies and following good international industry practice for the waste being handled.

No information Quantities of hazardous waste are communicated to the headquarters, which then manages it.

Compliance Compliance with applicable local and international regulations is ensured

Storage Hazardous waste is stored so as to prevent or control accidental release to air, soil, and water resources in area location where

No Waste oil is stored together with

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Waste is stored in a manner that prevents the commingling or contact between incompatible wastes, and allows for inspection between containers to monitor leaks or spills. Examples include sufficient space between incompatibles or physical separation such as walls or containment curbs Waste is stored in closed containers away from direct sun, wind and rain Secondary containment systems are constructed with materials appropriate for the wastes being contained and adequate to prevent loss to the environment. Adequate ventilation is provided where volatile wastes are stored.

other wastes, no secondary containment is provided and some containers are stored in open air.

Transportation On-site and off-site transportation of waste is conducted so as to prevent or minimize spills, releases, and exposures to employees and the public.

No information Quantities of hazardous waste are communicated to the headquarters, which then manages it

Transportation All waste containers designated for off-site shipment are secured and labeled with the contents and associated hazards, are properly loaded on the transport vehicles before leaving the site, and are accompanied by a shipping paper Transportation It is ensured that the volume, nature, integrity and protection of packaging and containers used for transport are appropriate for the type and quantity of hazardous material and modes of transport involved It is ensured that there are adequate transport vehicle specifications There is training of employees involved in the transportation of hazardous materials regarding proper shipping procedures and emergency procedures Labeling and placarding (external signs on transport vehicles) are used as required The necessary means for emergency response on call 24 hours/day exist Management/Monitoring Hazardous waste storage activities are subject to special management actions, conducted by employees who have received specific training in handling and storage of hazardous wastes: Provision of readily available information on chemical compatibility to employees, including labeling each container to identify its contents Limiting access to hazardous waste storage areas to employees who have received proper training Clearly identifying (label) and demarcating the area, including documentation of its location on a facility map or site plan Periodic inspections of waste storage areas are conducted and the findings are documented Spill response and emergency plans are prepared and implemented to address their accidental release Underground storage tanks and underground piping of hazardous waste is avoided

No

Monitoring Groundwater quality is regularly monitored in cases of Hazardous Waste on site storage and/or pretreatment and disposal.

No

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Monitoring Monitoring records for hazardous waste collected, stored, or shipped includes inter alia: Name and identification number of the material(s) composing the hazardous waste Physical state (i.e., solid, liquid, gaseous or a combination of one, or more, of these) Quantity (e.g., kilograms or liters, number of containers) Waste shipment tracking documentation to include, quantity and type, date dispatched, date transported and date received, record of the originator, the receiver and the transporter Method and date of storing, repacking, treating, or disposing at the facility, cross-referenced to specific manifest document numbers applicable to the hazardous waste Location of each hazardous waste within the facility, and the quantity at each location

Partly Quantities of hazardous waste are communicated to the headquarters, which then manages it

Hazardous Materials and Oil

Hazardous Materials and Oil

Hazardous Materials Management Plan A Hazardous Materials Management Plan is developed and maintained containing: Hazard Assessment performed by specialized professionals using internationally-accepted methodologies such as Hazardous Operations Analysis (HAZOP), Failure Mode and Effects Analysis (FMEA), and Hazard Identification (HAZID). Management Actions commensurate with the level of potential risks Preventive Measures Control Measures

No

Hazardous materials management Hazardous materials management priorities are established based on hazard analysis of risky operations identified through Social and Environmental Assessment.

No

Hazardous materials management The use of hazardous materials is avoided or minimized where possible.

No information

Hazardous materials management Uncontrolled releases of hazardous materials to the environment or uncontrolled reactions that might result in fire or explosion are prevented.

No Hazardous materials such as oils and chemicals used in the WTP are stored partly in open air, and no secondary containment or

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proper labeling is provided

Hazardous materials management Engineering controls (containment, automatic alarms, and shut-off systems) are used that commensurate with the nature of hazard.

No

Hazardous materials management Management controls (procedures, inspections, communications, training, and drills) are implemented to address residual risks that have not been prevented or controlled through engineering measures.

No

Emergency Preparedness and Response

Emergency Preparedness and Response Plan

Emergency Preparedness and Response Plan An Emergency Preparedness and Response Plan exists.

Partly An Emergency Plan has been developed in the past, but it is not available on site nor people receive training on its dispositions because “nowadays all workers are aware of what to do in case of an emergency”.

Emergency Preparedness and Response Plan This Plan includes the following basic elements: Administration (purpose, policy, distribution, definitions, etc) Organization of emergency areas (command centers, medical stations, etc) Roles and responsibilities Communication systems Emergency response procedure Emergency resources Training and updating Checklists (role and action list and equipment list)

No

Measures to notify alarms Warning systems are tested at least annually, fire alarms monthly. In case more frequent testing is required as per local regulations, equipment, or other considerations, these special requirements are implemented.

No There is no evidence of the existence of fire alarms nor of other warning systems.

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Spill Control, Prevention, and Countermeasure Plan Such plan is prepared as separate component of the Emergency Preparedness and Response Plan if there is risk of a spill of uncontrolled hazardous materials. Such plan includes: Training modalities of operators on release prevention Implementation of inspection programs Preparation of written Standard Operating Procedures (SOPs) for filling USTs, ASTs or other containers or Equipment SOPs for the management of secondary containment Structures Identification of locations of hazardous materials and associated activities on an emergency plan site map Documentation of availability of specific personal protective equipment and training needed to respond to an emergency Documentation of availability of spill response equipment sufficient to handle at least initial stages of a spill and a list of external resources for equipment and personnel, if necessary, to supplement internal resources Description of response activities in the event of a spill, release, or other chemical emergency Further details on different measures are outlined in the General EHS Guidelines, chapter 1.5, page 38 ff.

No

Backup system for communication A backup system for communications is installed on-site with off-site resources, such as fire departments, in the event that normal communication methods may be inoperable during an emergency.

No

Community notification Communication measures to notify local communities at risk are established, such as: Audible alarms, such as fire bells or sirens Emergency telephone numbers list Vehicle mounted speakers Communicating details of the nature of the emergency Communication protection options (evacuation, quarantine) Providing advise on selecting an appropriate protection option

No

Fire Services The company has considered the level of local fire fighting capacity and whether equipment is available for use at the facility in the event of a major emergency or natural disaster.

Partly Several hand-held fire-extinguishers (new and old) are located inside one of the control rooms. There is no fire brigade on

Fire Services If insufficient capacity is available, own fire fighting capacity has been acquired (e.g. pumps, water supplies, trucks, and training for personnel).

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site, but there is one in Thaton. There is no training of the workers on emergency procedures.

Medical services The company provides first aid attendants for the facility as well as medical equipment suitable for the personnel, type of operation, and the degree of treatment likely to be required prior to transportation to hospital.

Partly The first aid equipment onsite consists of one poorly equipped first aid box. In the small workers’ housing area nearby the plant site a health officer (senior main nurse) provides first aid measures.

Availability of Resources The company maintains a list of external equipment, personnel, facilities, funding, expert knowledge, and materials that may be required to respond to emergencies? The list includes personnel with specialized expertise for spill-up, flood control, engineering, water treatment, environmental science, etc.?

No

Availability of Resources There is personnel available who can readily call up resources, as required.

No information Availability of Resources The company tracks and manages costs associated with emergency resources.

Availability of Resources The quantity, response time, capability, limitations, cost of these resources, for both site-specific emergencies, and community or regional emergencies are considered. Training and updating Training needs based on the roles and responsibilities, capabilities and requirements of personnel in an emergency are identified.

No There is no training of the workers on emergency procedures.

Training and updating A training plan is developed to address needs, particularly for fire fighting, spill response, and evacuation.

Training and updating A training plan is developed to address needs, particularly for fire fighting, spill response, and evacuation.

Noise

Ambient noise

Location/ distance to noise receptors The new facility/ies are sited with consideration of distances from the noise sources to the receptors

No information

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(e.g. residential receptors, schools, hospitals, religious places) to the extent possible and according to the zoning of local land:

Noise control techniques Noise control techniques are implemented at site: They could comprise: - acoustic machine enclosures, - selecting structures according to their noise isolation effect to envelop the building, - using mufflers or silencers in intake and exhaust channels, - using sound-absorptive materials in walls and ceilings - using vibration isolators and flexible connections - applying a design to prevent possible poise leakage through openings to minimize pressure variations in piping.

No

Noise barriers Noise barriers are implemented such as berms and vegetation to limit ambient noise at plant property lines, especially where sensitive noise receptors are present.

Partly The site is partly surrounded by vegetation

Noise levels Noise impacts do not exceed the levels for daytime and nighttime as presented in Table 1.7.1. of the General EHS Guidelines, page 53.

No The ESA Report (Section 4.6) states the levels are above the limits at some locations.

Noise monitoring Noise monitoring is carried out for the purpose of establishing the existing ambient noise levels in the area of the plant and/or for verifying operational phase noise levels.

No There is no monitoring of noise levels at site.

Noise minimization Sound-insulated control rooms with noise levels below 60 dBA are provided.

No See ESA Report (Section 4.6):

Occupational noise

Technical measures Generators are designed to meet applicable occupational noise levels.

No See ESA Report (Section 4.6):

Noise protection High noise areas are identified and marked and require personal noise protecting gear used all the time when working in such high noise areas (typically areas with noise levels >85 dBA). No

Workers do not wear hearing protection.

Noise limits for working conditions No employee is exposed to a noise level greater than 85 dB(A) for a duration of more than 8 hours per day without hearing protection. In addition, no unprotected ear is exposed to a peak sound pressure level (instantaneous) of more than 140 dB(C).

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Noise protection The use of hearing protection is enforced actively when the equivalent sound level over 8 hours reaches 85 dB(A), the peak sound levels reach 140 dB(C), or the average maximum sound level reaches 110dB(A). Hearing protective devices provided are capable of reducing sound levels at the ear to at least 85 dB(A). Noise protection Prior to the issuance of hearing protective devices as the final control mechanism, use of acoustic insulating materials, isolation of the noise source, and other engineering controls is investigated and implemented, where feasible.

No

Medical checks Periodic medical hearing checks are performed on workers exposed to high noise levels.

No

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9.7 Annex 7: First Aid Kit

Table 9-10: Equipment List for a large first aid kit according to DIN 13169

DIN 13169a Large First Aid Kit

Description

2 Sticking plaster/adhesing plaster 500 cm x 2,5 cm, Coil with external protection

16 Adhesive bandage 10 cm x 16 cm

8 Finger Tip Bandage

8 Thumb Bandage 12 cm x 2 cm

8 Plasterstrips 1,9 cm x 7,2 cm

16 Plasterstrips 2,5 cm x 7,2 cm

2 Gauze Bandage DIN 13151 - K, 300 cm x 6 cm with compress 6 cm x 8 cm

6 Gauze Bandage DIN 13151 - M

2 DIN 13151 – G, 400 cm x 10 cm with compress 10 cm x 12 cm

- Sterile Dressing DIN 13152 – BR, 40 cm x 60 cm

2 Sterile Dressing DIN 13152 – A, 60 cm x 80 cm

4 Fixation Bandage DIN 61634 – FB 6, 400 cm x 6 cm

4 Fixation Bandage DIN 61634 – FB 8, 400 cm x 8 cm

2 Emergency Blanke at least 210 cm x 160 cm

12 Compress 10 cm x 10 cm

4 Eye Compress 5 cm x 7 cm

2 Cold Immediately-compress at least 200 cm²

4 Triangle Towel DIN 13168 - D

- First Aid Scissors DIN 58279 – A 145

1 First Aid Scissors DIN 58279 - B 190

8 Medical gloves for single use

4 Foil Bag

10 Non Woven Cloth

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DIN 13169a Large First Aid Kit

Description

- Damp cloth to clean non-injured skin

1 First Aid Brochure/ Instructions for first aid

1 Table of Contents aLarge First Aid Kit for Companies/Factories - DIN 13169 ,,First Aid Material - First Aid Kit E”

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9.8 Annex 8: Definitions

EHS-Management System: A management system is the framework of policies, processes and procedures used by an organization to ensure that it can fulfill all the tasks required to achieve its objectives. For instance, an environmental management system enables organizations to improve their environmental performance and an occupational health and safety management system (OHSMS) enables an organization to control its occupational health and safety risks, etc.

EHS risk assessments: The overall process of hazard identification,

risk analysis, and risk evaluation with respect to environment, health & safety (learn more at https://www.ccohs.ca/oshanswers/hsprograms/risk_assessment.html)

Safe Job Analysis (SJA): A job safety analysis (JSA) is a procedure which helps integrate accepted safety and health principles and practices into a particular task or job operation (learn more at http://www.ccohs.ca/oshanswers/hsprograms/job-haz.html).

Working Environment Health Risk Assessment (WEHRA): The overall process of hazard identification, risk analysis, and risk evaluation with respect to the working environment of a specific workplace.

Hazard Identification workshop (HAZID): A (work) process of identifying hazards, which forms the essential first step of a risk assessment of the project (learn more at http://www.theprojectdefinition.com/hazard-identification-hazid/).

Hazardous Operations Analysis (HAZOP) of critical activities: A hazard and operability study (HAZOP) is a structured and systematic examination of a complex planned or existing process or operation in order to identify and evaluate problems that may represent risks to personnel or equipment.

Hazard register: A collection of generic risk assessment documents, which outline the significant hazards and general controls required across a range of different safety management activities that take place within an organisation's operations and for which there is a potential exposure to the organization (learn more at http://academlib.com/7223/management/what_hazard_register)

Quantitative Risk Analysis (QRA): Analysis has here the same understanding as assessment. The overall process of hazard identification, risk analysis, and risk evaluation based on a numeric generated value with respect to environment, health & safety.