Triconboston Wind Power Project (Pakistan) · 2 days ago · Environmental and Social Monitoring Report Environmental and Social Monitoring Report – FY June 2019 Project Number:

Environmental and Social Monitoring Report

Environmental and Social Monitoring Report – FY June 2019 Project Number: 50200-001 30 September 2019

Triconboston Wind Power Project (Pakistan)

Prepared by Triconboston Consulting Corporation (Private) Limited for the Asian Development Bank

This environmental and social monitoring report is a document of the borrower. The views expressed herein do not necessarily represent those of ADB's Board of Directors, Management, or staff, and may be preliminary in nature. Your attention is directed to the “Terms of Use” section of this website.

In preparing any country program or strategy, financing any project, or by making any designation of or reference to a particular territory or geographic area in this document, the Asian Development Bank does not intend to make any judgments as to the legal or other status of any territory or area.

Environmental & Social Performance Annual Monitoring Report-2018-19

3 x 49.735 MW Wind Power Projects

AMR SECTION I

INTRODUCTION

IFC’s I est e t Ag ee e t e ui es fo the Tricon Boston Consulting Corp. Pvt. Ltd. (TBCC), 3 x 49.735

MW Wind farm projects, to prepare a comprehensive Annual Monitoring Report (AMR) on the

Environmental and Social (E&S) performance of its facilities and operations. This document comprises

IFC’s p efe ed fo at fo E&“ pe fo a e epo ti g. This epo t for the period July 2018-June 2019 is

supplemented with annexes mainly related to Birds Monitoring Report (BMR), Stakeholders Engagement

Meetings (SEM) records, Grievance Records, Internal EHS and CSR Audit Reports, EHS Inspection Reports,

Training Evidences and CSR implementation evidences as appropriate in order to ensure that all relevant

information on project performance is reported.

Contents:

• Project Information

• Clie t’s Rep ese tatio “tate e t y “po so autho ized ep ese tati e

• Summary of Key E&S Aspects during the Reporting Period

o Compliance Evaluation

o Major Environmental and Social Achievements

o Major Challenges and Issues

• Key Project Implementation data relevant to E&S Performance Evaluation

• Compliance with IFC Performance Standards

• Action Plan Status and Update

• Deviations/non-compliances

• Clie t’s Feed a k



AMR SECTION II

Project Information

Project Name 3 x 49.735 MW TriconBoston Consulting Corp. Pvt. Ltd.

Project Scope Construction and Operation of 3 x 49.735 MW Wind Farm

Current Stage Operations Phase

Project Chief Operating Officer Khalid Aslam

Plant Director Saquib Saeed

TBCC HSE Manager Abid Hussain

Admin & HR Manager Junaid Nizamani

O&M Contractor General Electric

O&M HSE Manager Arif Malik

HSE & CSR

Independent Monitoring Company

Arch Associates



AMR SECTION I

INTRODUCTION

IFC’s Common Terms Agreement requires for TriconBoston Consulting Corporation Pvt. Ltd (TBCC)

project to prepare a comprehensive Annual Monitoring Report (AMR) on the environmental and social

(E&S) performance of its facilities and ope atio s. This do u e t o p ises IFC’s p efe ed fo at fo E&S performance reporting for the period July 2018-June 2019. The following template is

supplemented with annexes as appropriate to ensure all relevant information on project performance is

reported.

Contents:

• Project Information

• Clie t’s Rep ese tatio “tate e t y “po so autho ized ep ese tati e

• Summary of Key E&S Aspects during the Reporting Period

• Action Plan Status and Update

• Deviations/non-compliances

• Clie t’s Feed a k



AMR SECTION II

Clie t’s Represe tatio “tate e t “po sor authorized represe tati e

I Khalid Aslam in my role of Chief Operating Officer and representing TriconBoston Consulting

Corporation Pvt Ltd certify that

a) The Project is in compliance with all applicable E & S Requirements as described in the Common Terms

Agreement, and all actions required to be undertaken pursuant to the Environmental and Social

Action Plan (ESAP) and any subsequent supplemental action plans.

b) Beyond what is reported in this AMR for the current reporting period, in relation to the Project, to the

best of my knowledge, after due inquiry, there are no:

• Circumstances or occurrences that have given or would give rise to violations of E &S and labor

Laws or E &S and labor Claims;

• Social unrest, local population disruption or negative NGO attention due to the project

• Material social or environmental risks or issues in relation to the Project other than those

identified by the E&S Assessment and the Environmental and Social Review Summary.

• Existing or threatened complaint, order, directive, claim, citation or notice from any Authority.

• Any written communication from any Person, in either case, concerning the Project's failure to

comply with any matter covered by the Performance Standards;

• Ongoing or, threatened, strikes, slowdowns or work stoppages by employees of the Borrower or

any contractor or subcontractor with respect to the Project;

c) All information contained in this AMR is true, complete and accurate in all respects at the time of

submission and no such document or material omitted any information the omission of which would

have made such document or material misleading.

d) There have not been any new company activities (e.g. expansions, construction works, etc) that could

generate adverse environmental effects and there have been no new ESIA studies, audits, or E&S

action plans conducted by or on behalf of TriconBoston Consulting Corporation, with respect to any

Environmental or Social standards/regulation/ applicable to the Project that IFC has not been notified

of

September 30, 2019

Signature Date



AMR SECTION III

(a) Summary of Key E&S Aspects during the Reporting Period

This section aims to identify the key E&S progress/activities/incidents during the Reporting period

(include Summary of Key Findings for the Reporting Period e.g. non-compliances, significant incidents1,

social unrest, significant improvements/initiatives regarding E&S performance. Etc)

1. Key Project implementation data relevant to E&S performance evaluation:

1.1 Start of construction date: 04 Aug 2017

1.2 Start of commercial operation date: 04 September 2018

1.3 Gross electricity generation capacity (MW):3 x 49.735 MW (Total: 149.205 MW)

1.4 Net electricity generation capacity (MW): 149.205 MW

1.5 Gross Electricity generated during the reporting year (GWh/year): Tricon A: 136.9 GWh; Tricon B: 109.6

GWh; Tricon C: 111.8 GWh [Post COD Stats for respective plant]

1.6 Net Electricity generated during the reporting year (GWh/year): Tricon A: 133.9 GWh; Tricon B: 106.9 GWh;

Tricon C: 109.6 GWh [Post COD Stats for respective plant]

1.7 Plant capacity factor (%) – Gross Electricity generated (GWh/year) / Gross electricity generation capacity

MW x 8,760 hour/year: Tricon A: 31.4%; Tricon B: 24.5% ; Tricon C: 25.1% [Post COD Stats for respective

plant]

Please report on:

• Compliance with ESMP

o Currently Issue 1 of Operational Phase ESMP is followed for implementation. The

following areas has been updated w.r.t Operation Phase

▪ Environmental and Social Management Plan

▪ Stakeholders Engagement Plan implementation

▪ Birds Monitoring Plan

▪ Organization Structure and Job Descriptions

▪ Training Plans

▪ System Procedures related to O&M activities

▪ Emergency Preparedness and Response Plan

• Regular ornithological monitoring reports / on-site bird monitoring data

o Birds Monitoring Reports (BMR) for the period Jul 2018-Jun 2019 are attached in

Annexure -1. First Quarter 2019 data reflects the back migration while April-June 2019

data shows decline in birds population and number of species observed in the area

mainly due to high temperature in the area during summer

1 Examples of significant incidents follow. Chemical and/or hydrocarbon materials spills; fire, explosion or

unplanned releases, including during transportation; ecological damage/destruction; local population impact,

complaint or protest; failure of emissions or effluent treatment; legal/administrative notice of violation;

penalties, fines, or increase in pollution charges; negative media attention; chance cultural finds; labor unrest

or disputes; local community concerns.



• Progress in ESAP implementation and any updates in relations to ESAP action items

o All the construction phase related ESAP items have been closed.

o Noise Monitoring and Shadow Flicker Monitoring has been initiated in Operational

Phase as required by ESAP

• Major Environmental and Social Achievements

o No equipment safety related incident during transportation and installation of 696

components of WTGs

o Based on the E&S compliance during construction phase, IFC has rated Tricon Boston

Consulting Corp Pvt Ltd E&S perfor a e as E elle t o Using ISO standards, initiation of development and implementation of Quality,

Environment, Occupational Health & Safety, Social, Energy and Asset Management

Systems development as single integrated management system in Tricon Boston

Consulting Corp Pvt Ltd

o Fully Equipped Clinic with ambulatory support to handle the emergencies has been

established at Tricon Boston site. The clinic will cater to both, personal working at

project site as well as to Tricon Boston neighborhood community.

• Major Challenges and Issues for the company

o Cost Effective waste management as due to absence of Sindh Environmental Protection

Agency (SEPA) authorized /approved Waste Management Company in the local vicinity,

the cost of waste disposal through urban center based SEPA approved waste

management companies is high.

o Inclusion of O&M Contractor w.r.t. E&S implementation and their willingness to offer

compliance records for third party/independent verification

Project Status

Select the current status of the project and provide a brief description of the developments in relation to

the project over the reporting period. For example, has construction been started or completed, has new

equipment been installed, has production capacity increased, or is the investment in new projects

considered?

❑Design ❑Construction ❑ Expansion ❑Operation❑ Closure ❑ Other (specify)

Currently project is in Operation Phase since August / September 2018

PS1: Assessment and Management of Environmental and Social Risks and Impacts

Please provide details on the status of the following voluntary Management systems certification schemes

at your facility, provide details below?

Not being

considered

Future

consideration

Planning to

Implement

Currently

implementing

Successfully

implemented

Date of

certification/

re-certification

ISO 9001-Quality Management

System

❑ ❑ ❑ ❑ ❑ ❑

ISO 14001-Environment

Management System

❑ ❑ ❑ ❑ ❑ ❑



OHSAS 18001-Occupational

Health & Safety Management

System

❑ ❑ ❑ ❑ ❑ ❑

ISO 50001-Energy

Management System

❑ ❑ ❑ ❑ ❑ ❑

SA 8000-Social Accountability

Management System

❑ ❑ ❑ ❑ ❑ ❑

ISO 55001-Asset Management

System

❑ ❑ ❑ ❑ ❑ ❑

Other

• Identification of Risks and Impacts: Based on the actual operation of the Company during the

reporting year, please provide a summary of the key risks and impacts that the Company was

faced with and the actions taken.

o Formal implementation of the CSR initiatives

o Improvement in Local Labor Laws compliance level by O & M Contractor and Sub

Contractors including Security Contractor

• Describe any changes in the organizational structure to manage environment, health and safety,

labor and social aspects during the reporting period. Describe number of personnel in charge of

E&S issues.

o For the Operational Phase, organizational structure of TBC has been revised mainly

w.r.t. HSE Manager. HSE Manager has now been re-desig ated as Co plia e Ma ager ith ajor respo si ilit of H“E I plementation and Monitoring and

Monitoring of Social aspects compliance. Compliance Manager and Administration

Manager of Tricon Boston and HSE Manager of O&M Contractor are in charge of E&S

issues.

• Describe the level of environmental, social and health and safety training provided to staff.

Provide annex with list of topics, hours of training and number of participants.

o Annex-3 provides List of Trainings during the period July 2018-Jun2019, Attendance

Sheets and Training Records.

• During the reporting period, are you aware of any events that may have caused damage; brought

about injuries or fatalities or other health problems; attracted the attention of outside parties;

affected project labor or adjacent populations; affected cultural property; or created liabilities for

your company?

❑Yes ❑No

Provide details Not Applicable

• Stakeholders Engagement---Describe any ongoing public consultation and disclosure, liaison with

non-governmental organizations (NGOs), civil society, local communities or public relations

efforts on environmental and social aspects.



o Currently regular engagement with local communities is in place. This engagement is

done formally as well as informally. During informal engagements done by Community

Liaison Officer (CLO) of Tricon Boston Consulting, feedback including grievances are

seeked a d do u e ted. For for al e gage e ts, stakeholder’s e gage e t eeti gs are planned, community is informed and meeting conducted either at project site or at

neighboring village. Two (02) Stakeholders Engagement meetings have been conducted

till Jun 2019. Annex-6 has record of Stakeholders meetings.

• Briefly describe new initiatives implemented during the reporting period or additional managerial

efforts on E&S aspects (e.g. Energy/water savings, sustainability report, waste minimization, etc)

o Commissioning of 100 kW Solar Pant during the construction phase was one major

energy saving initiative.

o Implementation of ISO 50001 Standard under UNIDO EnMS/REEE program and with the

objective of reducing Energy Losses (reducing plant auxiliary load) identified through

Energy Audit

• Briefly describe the number and type of comments and/or grievances received by the Company

in relation to E&S Issues? How many have been resolved and how many are pending? (Please

attach a table with grievance redress registry)

o During the reporting period of July 2018-June 2019, total eight (8) grievances were

recorded out of which three (03) were internal grievances. All the grievances have been

closed during the reporting phase. During the period May 2019 to June 2019, no

grievance was recorded by O and M Contractor nor by TBC Admin/HR. (Annexure -07)

o Formal recording of grievances has been identified by IMC as area for improvement and

advised TBC Admin to play active role in the resolution of external as well as internal

grievances.

• Provide an update on consultation, if any, with IUCN, WWF, Sindh Wildlife Department, Sindh

Environmental Protection Agency (SEPA) and Sindh Forestry Department.

o No consultation with IUCN, WWF, Sindh Wildlife Department, Sindh Environmental

Protection Agency (SEPA) and Sindh Forestry Department was done during the

reporting period.

• Provide a summary of complaints, if applicable, from the Social Compliant Register (SCR) that you

have committed to develop to document all complaints received from the local communities or

any other stakeholder and to take action and implement the mitigation measure.

Annex-7 includes records related to grievances received from local communities and workers

and their resolution



PS2. Labour and Working Conditions

• Have you changed your Human Resources (HR) policies, procedures or working conditions during

the reporting period?

❑Yes ❑No Provide details

o During audit of HR/Admin and based on the external grievances received, need for

additional procedures was identified in order to document the processes mainly related to

Workers Interview, Skill Assessment and Worker Termination.

• Provide the following information regarding your workforce:

Site # of direct

employees

# female direct

employees

# employees

terminated*

# employees

hired*

# Contractor

employees2

Project Site

(Total) 161 0

Project Owner 34

EPC Contractor

(HydroChina) 38 0

GE,AEPL & Descon etc) 54 0

Retrenchment: If the Company undertook any involuntary retrenchment during the reporting year, please

provide retrenchment data including a copy of the retrenchment plan.

o Tricon Boston Consulting EPC Contractor and its Sub Contractors clearly communicated

to the employees the temporary nature of their job and this was covered in the

Employment Contracts with workers. EPC Contractor prepared a retrenchment plan to

manage the laying off of workers near the end of civil construction phase. Subsequently,

following the completion of installation of WTGs and Sub Station equipments, , the

layoff process has been initiated as per the retrenchment plan and more than 90% of

the workers have left project site. Annex-11 contains the Retrenchment Plan and

sample of Daily Strength Report which records the employees released.

Grievance Mechanism: Please provide a summary of the latest grievance mechanism in effect for workers

to raise workplace concerns (also indicate nature of EHS and social issues raised by workers, communities

and other stakeholders during the reporting period, and the nature of corrective actions taken, its

outcome and status).

o For Internal Grievance Mechanism, following methods are used by workers.

▪ Verbal and / or written complain to Admin & HR of HydroChina & GE

▪ Verbal and / or Written complain to Admin & HR of Tricon Boston Consulting, if

there is no action by the Admin & HR of HydroChina

2 Contractors performing core functions for the Company in the premises of the Company or in the name of

the Company



▪ Verbal complaints during Stakeholders Meetings

▪ Complaint Boxes provided at different locations within project area but workers

prefer to use verbal means.

Child Labor / Forced Labor: Please state whether the Company remained compliant with the Child Labor

and Forced Labor requirements of the Performance Standards.

o Tricon Boston Consulting, its EPC Contractor HydroChina and EPC Contractor Chinese

and Local sub-contractors remain complaint with the IFC Child Labor and Forced Labor

requirements during the reporting period.

o Tricon Boston Consulting as placed Child Labor Prohibition sign boards in local language

at different locations for information of local communities and sub-contractors.

Occupational Health and Safety

• Describe the main changes implemented in terms of Occupational Health and Safety (OHS) during

the reporting period, e.g. identification of hazards, substitution of chemicals, new controls, etc.

o Since this is the first operational year of project, therefore no changes have been in the

systems and plans developed/upgraded for operational phase e.g. Environment and

Social Management Plan (ESMP), Stakeholders Engagement Plan (SEP) etc. However

internal audit observations will help in identification of changes in systems and plans in

order to improve effectiveness of compliance.

• Please provide details (description, pictures,) on the accommodation standards if the construction

camp is to be established for the workforce on the site

o Currently Project is in Operational Phase and construction camp for workers

accommodation is not in use.

Occupational Health and Safety Indicators

Report Total numbers for each

parameter This reporting period Reporting period – Previous

year

Direct

employees

Contractor

employees

Direct employees Contractor

employees

Total number of Workers 35

Male Workers 35

Female Workers 0 0

Total Number of Direct Workers 35

Total Number of workers who are

members of workers organization

34 0

Name of Workers Organization

Total man-hours worked – Annual

Total number of lost time occupational

injuries

0



Total number of lost workdays due to

injuries

0

Number of fatalities 0

Occupational Health and Safety Performance (Construction / Operation Phase) (IFC E&S DOTS Indicator)

Item Number Target

Employees Contractors Total

A: Fatalities:3

0 0 0 0

B: Total Lost Time Accidents

(including vehicular):4

0 0 0 N.A.

C: Total number of lost workdays

resulting from incidents: 5

0 0 0 N.A.

D: Total man-hours worked this

reporting period:

0 0 0 N.A.

E: Incidence during this reporting

period:

(Note: Incidence = total lost

workdays / total hours worked)

0 0 0 N.A.

F: Lost Time Injury Frequency

Rate

(Number of lost time accidents x

1,000,000 hours / total man-

hours worked = injuries per

million hours worked)

0 0 0 11.0 or less

(construction phase)

4.5 or less (operational

phase)

G: Lost Time Severity Rate

(Total Lost workdays x 1,000,000

hours / total man-hours worked

= lost workdays per million hours

worked)

0 0 0 N.A.

• Provide details for the non-fatal injuries during this reporting period

None to report

3 Please attach separate reports detailing the circumstances of each fatality.

4 In capacity to work for at least one full workday beyond the day on which the accident or illness occurred.



Company or

contractor

employee?

Total

workdays

lost

Description of injury5 Cause of accident Corrective measures

to prevent

reoccurrence

Project Owner 0

EPC & O&M

Contractor 0

EPC & O&M

Contractor Sub-Contractor

0

• Describe in detail fatalities and vehicle accidents, including corrective measures (provide copies

of OHS investigation and respective corrective plan).n

None to report

Date of

Incident

Type of Incident

(drop down list)

Brief Description

of Incident

Fatalities?

(Y/N)

# of

Fatalities

Preventive measures

taken after the incident

Note: Choose the Type of Incident from the drop down list.

Improvement Trend of Occupational Health and Safety Performance

Item 2017 2018 2019 2020

A: Fatalities:

[Employees] [Contractors] [Total]

0 0 0

B: Total Lost Time Accidents (including vehicular):


0 0 0

C: Total number of lost workdays resulting from incidents:


0 0 0

D: Total man-hours worked this reporting period:


0 0 0

E: Incidence during this reporting period:


0 0 0

F: Lost Time Injury Frequency Rate


0 0 0

G: Lost Time Severity Rate


0 0 0

5 Injury: Incapacity to work for at least one full workday beyond the day on which the accident or illness

occurred.

Lost workdays are the number of workdays (consecutive or not) beyond the date of injury or onset of illness

that the employee was away from work or limited to restricted work activity because of an occupational

injury or illness.



Workers Engaged by Third Parties: Please provide a summary of how the Company is managing and

monitoring the performance of third party employees in relation to the requirements of the Performance

Standards.

• TBC performs through IMC Quarterly audit of EPC/O and M Contractor (HydroChina)/GE for HSE

and Social Accountability (HR & Admin) systems implementation. Similarly TBC binds HC to

performs audits of its sub-contractors and report the audit results and performance ratings.

PS3. Resource Efficiency and Pollution Prevention

• Provide the following environmental monitoring data for this reporting period. If you already have

all the data requested available in another format, this can be submitted instead. Please provide

a scaled facility map showing the precise locations of all monitoring points.

o IMC advised EPC/O and M Contractor to perform Noise Monitoring on weekly basis and

report the results in the HSE Performance Reports. Annex-14 includes Noise Monitoring

Reports for the period July 2018-June2019.

Ambient Noise Residential, Institutional or Educational Monitoring Point Location6:

Ambient Noise Industrial or Commercial Monitoring Point Location8:

Ambient Noise Parameters Collection

Frequency

WBG/IFC

Maximum

Levels

(WBG/IFC Units)

TBCC Performance

(WBG/IFC Units)

Annual average of

quarterly samples

Pakistani

Maximum Levels

(Pakistani Units)

TBCC Performance

(Pakistani Units)

Annual average of

quarterly samples

Nearest Residential,

Institutional or Educational

Receptors

Daytime (07:00-22:00 hours) Quarterly 55 dB(A) dB(A)

Nearest Residential,

Institutional or Educational

Receptors

Nighttime (22:00-07:00 hours) Quarterly 45 dB(A) dB(A)

Nearest Industrial or

Commercial Receptors

Daytime (07:00-22:00 hours) Quarterly 70 dB(A) dB(A)

Nearest Industrial or

Commercial Receptors

Nighttime (22:00-07:00 hours) Quarterly 70 dB(A) dB(A)

Distance from the site

boundary to the closest noise

receptors m 20-30 m

Greenhouse Gases

6 Provide latitude, longitude of ambient noise monitoring points. Alternatively provide a scaled map showing

the precise location of the monitoring points.



• Whilst this is a carbon friendly project that may generate carbon credits, please provide an

approximate measurement of total GHG emissions from the project (e.g., vehicles, generators

etc.)

• GHG emissions avoidance of the Project (IFC E&S DOTS Indicator)

As the project is not opting for carbon credits at this moment, therefore GHG emissions due to

diesel and other fuel consumed at the project site during O&M phase are not calculated.

However fossil fuel consumption data for backup generator and vehicles is recorded by O&M

team

Year Gross

electricity

generation

(MWh /

year)

Auxiliary

electricity

consumption

(MWh / year)

Net

electricity

generation

(MWh / year)

Grid emission

factor

(tonCO2 /

MWh)

GHG

emissions

avoidance

(tonCO2 /

year)

A B C = A – B D E = C x D

PDD for

CDM

Actual

[2016]

2017

2018

• Note: PDD for CDM (Project Design Document, completed [date])

• Estimated CO2 Emissions from Mobile Sources (Gasoline Vehicles)

Total

number

of

vehicles

Total

length of

distance

travelled

(km)

Gasoline

consumed

Gasoline

vehicle

efficiency

(litre /

km)

CO2

emissions

factor

(kgCO2/TJ-

LHV)

CO2

emissions

(tonCO2) (litre) (TJ -

LHV)

A B C D=B/A D=69300 E=BxD/1000

2016 69300



[2017]

[2018]

[2019]

-----

• Note: CO2 emissions factor (gasoline) 69300 kgCO2/TJ-LHV from 2006 IPCC Guidelines.

• Estimated CO2 Emissions from Mobile Sources (Diesel Vehicles)

Total

number

of

vehicles

Total

length of

distance

travelled

(km)

Diesel

consumed

Diesel

vehicle

efficiency

(litre /

km)

CO2

emissions

factor

(kgCO2/TJ-

LHV)

CO2

emissions

(tonCO2) (litre) (TJ -

LHV)

A B C D=B/A D=74100 E=BxD/1000

2017 74100

2018

2019

2020

2021

Resource Efficiency – Wate Co se atio Measu es: Du i g app aisal of the P oje t, a out [●] 3 pe day of water was estimated to be required during the operational phase of the Project, and considering

the general scarcity of water in the region, the Company was planning to adopt water conservation

measures including using recycled water as much as possible. Please provide a summary of the water

conservation measures implemented during the reporting year.

Compared to construction phase, water consumption quantity in operational phase is not significant.

Plant operations and maintenance activities do not require water and all the water requirement is

limited to accommodation building. As water is purchased to meet the accommodation building

requirements, therefore water consumption data is recorded, however as this is the first operational

year, therefore water conservation and efficiency opportunities cannot be identified unless second

operational year water consumption data is compared with the first year.

Pollution Prevention – Waste: Please provide a summary of non-hazardous and hazardous waste

generation and minimization activities using the table below. Please add a summary description of major

recycling activities conducted.



Waste and Hazardous Materials

• Tricon Boston ESMP has ensured that O and M Contractor collects and quantifies the disposed

waste. Since Jan 2019 O and M Contractor has started quantification of waste

6.11. Solid Waste Management

Solid Waste refers to non-liquid, non-soluble materials that contain complex substances. Examples of

solid waste include sewage sludge, agricultural refuse, demolition wastes, and mining residues, some

which are applicable only to specific sectors.7

TBCC is required to monitor methods of collection, storage, handling, recycling, reuse and/or disposal of

solid waste, and report these methods and measured quantities to IFC. Please complete the information

below.

Solid Waste Management Summary

IMC as a result of formal audits of Waste Management Plan, proposed number of practical actions for

improving the current state of hazardous and non-hazardous handling and solid and liquid waste

collection, quantification and disposal of waste including monitoring of waste disposal activities

performed by Waste Management Company.

Solid Waste Type

Includes description

Annual

Quantity

TBCC Method of Storage, Handling and/or Treatment

Waste from Kitchen

and accommodation

building including

offices

60,000 kg

from Project

A, B & C

All the waste (paper, plastic, metal etc) are collected from the

source by sweepers. In the waste yard, paper, plastic and

metal waste are stored in separate large size drums. No

treatment of any waste is performed. Similarly any waste if

generated at the WTG locations is collected and stored in the

waste yard.

Solid Waste Type

(Same as Above,

Description not

Included)

TBCC Method of Recycling, Reuse or Disposal8

Waste from Kitchen

and accommodation

building including

offices

Presently TBCC is not using any option of Reuse or Disposal and all the waste

collected at the project site is sold to Waste Disposal company who further

sells the plastic and metal waste to contractors/middle men collecting waste

for the recycled industry. Oil and Grease waste generated at WTG during

maintenance activity has not been sold to any contractor and presently

stored at the site. This waste is under the administrative control of O&M

Contractor and in future it will be sold to contractor/middlemen who further

sells to Lubricating plant for extraction of baseline from these waste.

7 Pollution Prevention and Abatement Handbook, Glossary of Environmental Terms

8 Describe disposal method (e.g. landfill, incineration, land farming, reuse, etc.) Provide name and location of

disposal facility used; state if waste is sold as byproduct, scrap or a material to be used by others; state name



6.12. Hazardous Materials Management

• Hazardous materials are those materials that represent an excessive risk to property, the

environment or human health because of their physical and/or chemical characteristics.

Examples include explosives, toxic or flammable gases, flammable liquids and solids, oxidizing

substances, radioactive materials and corrosive substances.

Presently no Hazardous and Hazardous waste is recycled at the project site and sold to

Waste Management Company

• Non-hazardous and Hazardous Waste Minimization Activities

Item Non-hazardous waste Hazardous waste

Generated

(ton)

Re-

cycled

(ton)

Disposed

(ton)

Recycling

ratio (%)

Generated

(ton)

Re-

cycled

(ton)

Disposed

(ton)

Recycling

ratio (%)

A B C=A-B D=B/A E F G=E-F H=F/E

• Please add a summary description of major recycling activities conducted.

No recycling activity done at the project site during the review period

• TBCC is required to monitor methods of collection, storage and disposal of hazardous materials9,

and report these methods and measured quantities to IFC. Please refer to the Hazardous

Materials Management guideline for additional information.

1. Please update us on your Hazardous Materials Management Program. You should include your

Emergency Preparedness and Response Plans, and if available, your Hazardous Materials Risk

Management Plan, Hazardous Materials Transportation Plan and/or Hazardous Waste

Management Plan.

Hazardous Material Management Plan is included in the annexure of Environment and Social

Action Plan

and business of purchaser. Provide additional sheets as needed to fully describe disposal, organizations

involved in waste management, facility permits, and agency authorizations.

9 Hazardous materials include ignitable, reactive, flammable, radioactive, corrosive and toxic substances.



Pollution Prevention – Liquid Effluent Monitoring Results: For the diesel generators installed for

emergency power supply to be operated only as back-up, please provide a summary of how the

small quantity of oil/oily water was treated by oil/water separator during the reporting year.

• Oil/Grease from the generator is collected but not drained but stored separately.

Pollution Prevention – Noise: Please provide a summary of the noise monitoring results showing

that the monitored ambient noise levels at Project affected communities were in compliance

with Pakistan noise standards and IFC EHS Guideline noise limits of 45 dBA nighttime and 55 dBA

daytime.

During the operational phase, Noise Monitoring w.r.t. WTGs is performed for Tricon A,

B & C and data attached in Annex-14

Pollution Prevention – Shadow flicker: Please provide a summary of the shadow flicker

monitoring results and evaluation of the accumulated exposure on residential

properties/hamlets against recommended criteria of 30 hours per year, and whether additional

mitigation measures were determined to be necessary, and if so, how they were implemented.

• Shadow Flickering data –Annexure -14

PS4 - Community Health, Safety and Security

• Using the table below list and briefly describe any new initiatives implemented in relation to

community health and safety during the reporting period. Include risk assessments, new

infrastructure and equipment; hazardous materials and safety management, transportation and

exposure to disease.

o Fully equipped Clinic has been established at Tricon Boston to manage the emergencies

related to project employees and to neighborhood villages.

Mitigation Measure Expected or actual date

of Implementation Planned future

mitigation efforts?

• During the reporting period any emergency drills have been conducted with community

participation? Are the communities aware of the emergency response plans?

o Fire Drills were conducted but No emergency evacuation drill conducted during the

reporting period. Emergency Drill is planned for last quarter of 2019

• Please des i e a y ha ges i the Co pa y’s e gage e t ith p i ate/public security forces

during the reporting period and any corresponding agreements.

o No change in TBC engagement with private / public security forces.



• Implementation of key actions for community health and safety: Please provide a summary of the planned

key mitigation measures of the following during the reporting year:

• Cordoning off the construction site from free public access;

o No physical barrier is erected to prevent access of local villagers. Only work sites

are e.g. WTG, Sub-Station etc. are properly barricaded to prevent free public

access due to safety of the public and the people working at the site.

o Security Guards and watchmen have been trained to prevent movement of

public /non-related persons to the construction site. Refer Annex-3 for records

• Placing information boards about public safety hazards and emergency contact information in

the Project area in the local language;

o Safety sign boards are placed at the work sites. Contact Numbers are

displayed at the TSF entrance / reception.

• Ensuring that construction phase workers are housed in labor accommodation facilities built

at least 1km from any communities;

o Workers accommodation is constructed within the TSF boundary and

away from the neighboring villages

• Providing health and safety training to raise awareness about STDs and HIV;

o Not yet conducted.

• Maintaining worker behavior standards;

o Admin Officer of HC and TBCC ensure discipline within the project boundary.

• Requiring each contractor to ensure that communities be advised in advance of project

progress and near term activities where transport issues have the potential to impact local

communities.

o Community Liaison Officer of TBC and HC and GE informs to the local villagers

duri g i for al i tera tio s. This is also do e through stakeholder’s engagement meetings.

b) Implementation of key actions for security personnel management: Please provide a summary of

the planned key mitigation measures of the following during the reporting year:

• Providing necessary trainings to the security staff about the appropriate use of force where

applicable toward workers and affected communities in line with IFC PS4.

• TriconBoston Consulting has developed Security Management Plan (SMP)

based on IFC PS 4. Security Consultants conducted first monitoring visit in Sep

2017 followed by training sessions of Security Company and local watchmen

trainings on SMP protocols. Third implementation monitoring of SMP was

conducted in March 2019 and Monitoring reports and training records are

included



PS6 – Biodiversity Conservation and Sustainable Management of Living Natural Resources

Birds Monitoring and Turbine Shutdown System

(i) Please provide detailed summaries of all birds monitoring data, bird strikes, shutdown

orders as per the requirements of the ESAP and the EMP (as appropriate use the template below

to report this information).

• Collision Risk Analysis is provided in Annexure-1

(ii) Please provide summary of monitoring undertaken (name of consultants (if used), hours

and frequency of monitoring techniques and survey methodologies used for birds.

• Arch Associates is performing the Ornithological studies. An Ex-WWF Ornithologist

and three surveyors perform the monitoring activities based on the Birds Monitoring

Plan. Birds Monitoring Plan is developed using the Scottish Natural Heritage guideline

(referred by IFC in EHS Guideline for Wind farms Aug 2015). Currently during

construction phase, Vantage Point methodology is used. Three Vantage Points have

been identified across Project A, B & C and monitoring is done on daily basis during

morning and evening hours. Refer to Annex-1 for Birds Monitoring Report..

Biodiversity Value Key Performance Indicator Comment

Collision Risk Analysis summary Bird mortality (wintering,

migratory, breeding species).

List species killed and

conservation status

Annexure-1

Turbine shutdown System

TBCC will retain an

Independent Ornithological

Expert (IOE) to establish a

monitoring program that would

contain an agreed protocol for

mitigation measures, including

the reduction of the speed of

the turbines or, potentially, for

the turbines to be temporarily

turned off should a migrant

flock be observed to be

approaching either site.

Date and duration

Specify whether species are

resident, migratory, breeding or

over-wintering in the area

• Please attach monitoring reports and data as necessary



Implementation status of the key actions: Please provide the implementation status / key

findings and follow-up actions of the following: • [Bird monitoring activities by a bird monitoring consultant ([name]) retained by the Company];

o TriconBoston Consulting Corporation (TBCC) has retained Arch Associates (AA) as consultant for

performing the ornithological studies. An Ex.WWF Ornithologist and three surveyors perform

the birds monitoring using the Vantage Point methodology as per Scottish Natural Heritage

protocols.

• Detailed and prolonged studies on the impacts on birds to be conducted during the migratory season of

birds (October – March) and the bird monitoring report issued by [name];

o Birds monitoring studies were conducted initially during the period of September 2015-March

2016. The second Birds monitoring study under ESAP commenced from October 2016 and

continued to date. Five reports covering the migratory season have been developed and issued

for the period October 2016-December 2016, January 2017 to June 2017, Jul-Sep 2017 and Oct-

Dec 2017 and Jan-Jun 2018 and July 2018 to June 2019. Refer to Annex-1 for reports for the

period July 2018-Jun 2019

• Bird mortality count in the immediate vicinity to establish any links between the wind turbines and birds

mortality for two years starting from the commissioning of the wind farm;

o Ground Search Method

• Review of the results and recommendations of the [bird monitoring study], and the need for additional

mitigation measures beyond what were described in the [Final Initial Environmental Examination Update].

o The fi al itigatio easures a ’t e deter i ed at this stage as the proje t area has undergone major change w.r.t. food availability due to last rainfall (July-Aug 2017) which has led

to increase in number of birds (birds count) and number of species. The winter migratory season

under the changed environment i.e. with high food availability witnessed high population in Oct

2017 however in Nov-Dec 2017 population decreased most likely due to the construction

activities (Noise). However the population observed and reported in Birds Monitoring Report for

the period upto June 2019 confirmed that Jhimpir is the migratory birds fly path /route. The area

continued to experience birds movement till the period April 2019 however with the increase in

temperature in May-till June 2019, birds population decreased. As per the weather forecast,

Jhimpir area is expected to receive high rainfall in coming months Jul-Sep 2019 which will impact

the birds population as well as birds species in positive manner

(iii) What changes, if any are being proposed to the ESMP based on this monitoring?

• Yes, monitoring of area rehabilitation needs to be included in the ESMP based on the

Ecological Assessment

• As the project has completed its construction phase, ESMP and other related has been

amended w.r.t. Operational Phase activities

(iv) Summary of any coordination or engagement with any local or international bird NGOs/

conservation organizations.

• Formal engagement with any local or international NGO regarding conservation is planned for

2020. For this TBC will arrange consultation workshop in March 2020 at project site with SEPA,

WWF, IUCN, Wild Life, District Government, Wind Farm Association and Local NGO



(vi) Please summarize any changes in Pakistani law relating to any Environmental Matter

concerning the Project

• Recent No Objection Certificates (NOC) issued by Sindh Environmental Protection Agency

(SEPA) to wind farms, explicitly mention the IFC Performance Standards as the criteria for

compliance w.r.t. EHS.

• Sindh Government has issued Occupational Safety & Health Bill 2017 which requires

consideration of psychosocial factors in the Risk Assessment Process. Therefore TBC HSE in

coordination with EPC Contractor HSE and O&M Contractor HSE will perform the Job based

Risk Assessment considering all parameters e.g. ergonomic, psychosocial etc as required by

the law

(vii) Please provide a summary of any changes to the Jhimpir wind corridor area and any new

regulatory action associated with the area including management requirements or restrictions.

• Atleast ten new wind farms will be constructed in the area adjacent to Tricon Boston during

the period Dec 2019-April 2021

• Since some of the wind farm projects comes under China-Pakistan Economic Corridor (CPEC),

therefore Government of Pakistan has increased the security of the area.

(viii) Please provide a summary of any agricultural crop management restrictions or controls that

TBCC has required/ implemented to control or mitigate risks to biodiversity

• Except for the required excavation as per the approved drawings for the construction of access

roads, WTG foundations, TSF and Sub-Station and cabling trench, no other area (within the

project boundary) has been excavated by EPC Contractor or their sub-contractor and TBC HSE

and IMC HSE team monitoring the area for compliance. EPC Contractor has excavated some

land within the buffer zone area for the purpose of backfilling at WTG foundation. These

excavated lands have been backfilled with top layer and surface restored to original. Few

excavated lands have been left on the request of villagers as they want to use those excavated

lands as the water storage tanks during rainfall. Local neighborhood will use these water

storage ponds to manage their water requirements for agriculture produce.

Using the table below describe any new activities or expansions that have increased the project footprint

into new areas of habitat during the reporting period.

New activity/expansion Total area covered Habitat type

No new activity Same as per original

plan/layout

Using the table below provide details of (deforestation i.e. removing the plantation) conducted during

the reporting period.

Site Total area

cleared of

mangroves/

plantation

Type of species

lost Total area

replanted Type of

species

planted

Replanted

mangroves for

commercial

use Y/N



Tricon Boston

Consulting Corp

Ecological Assessment was conducted and report submitted to TBC. If the project area experiences

heaving rain in coming months Jul-Sep 2019, then Ecological Assessment report validation will be

performed

Corporate sustainability activities: Please provide a summary of the Co pa y’s o po ate sustainability activities (e.g. corporate social responsibility activities, corporate community

support activities, corporate sustainability reporting activities), if conducted during the reporting

year.

o Since the Micro level household survey is now completed, TBC Admin/HR department will now

finalize CSR Activities and develop implementation plans for the Operational phase

o CSR Activities under implementation by EPC Contractor (HydroChina)

• Provision of Drinking water to all seventeen neighboring villages

• Access to Medical Clinic facility to local villagers

2. Implementation status of the Environmental and Social Action Plan (ESAP): Please provide a summary of the

implementation status of the ESAP using the table below. Please add relevant supporting documents / reports

as necessary.

E“AP (i luded i IFC’s E i o e tal a d “o ial Re ie “u a y, dis losed o [date])

Task Title & Description Anticipated

Completion

Date

Implementation

Status

No. 1: The Company will get the Social Environment

Health & Safety Policy signed by its management, and

will display at its corporate office, the project

operation site and at the Co pa y’s e site.

Policies related to

Environment,

Occupational Health

& Safety and Social

Responsibility are

displayed at

different locations

within project site.

No. 2: The Company will monitor the CPPA-G’s [a d National Transmission and Despatch Company (NTDC)

Li ited’s] p og ess of thei E i o e tal I pa t Assessments for associated transmission lines and a

NTDC Environmental

Study conducted and

copy will be seeked

from NTDC or Sindh

Environmental

Protection Agency

(SEPA) office or




Completion

Date

Implementation

Status

substation that are needed for successful

implementation of the Project.

confirmation from

SEPA will be seeked

No. 3: The Company will update the Corporate Social

Responsibility (CSR) program to meet the requirement

of the Sindh EPA IEE approval of [date].

DEC 2019 Community

Development Plan /

Corporate Social

Responsibility (CSR)

Plan has been

developed with

different short and

long term action

items. The plan is

yet to be presented

to Sapphire Group

board for approval

and budget

allocation.

No. 4: The Company will appoint (i) EHS Manager and

Community Relationship Officer prior to start of the

construction, and (ii) Engineering and EHS Manager,

prior to start of the operation.

Appointed and

deputed at the

project site. EHS

Manager and

Community

Relationship Officer

submitted in last

report

No. 5: The Company will establish its HR policy and

procedures in line with IFC Performance Standard 2.

Developed and

Implemented.

No. 6: The Company will develop an Employment Plan

which defines requirements and procedures on

identifying and developing employment

opportunities, managing employees, recording and

reporting employment data, terminating work

contracts, and other labor-related issues, with an aim

to enhance local employment. The Plan will include a

skill development program to help enhance

employability of the local population, and a local hiring

program to ensure that unskilled and semi-skilled

labor be hired from the local communities.

Employment Plan is

covered as one of

the action item

under the

Community

Development Plan /

CSR Plan.

No. 7: The Company will prepare the storm water

diversion plan that will help to increase irrigation of

the surrounding open area for the local villagers.

Storm Water

Diversion Plan has

been developed and

its implementation

will be monitored




Completion

Date

Implementation

Status

by IMC. Also

effectiveness of

these plans will be

verified if the

project area

experiences heavy

monsoon rains in

coming months of

Jul-Sep 2019

No. 8: The Company will review the results and

recommendations of the bird monitoring study to be

conducted by [name to be provided], and determine

the need for additional mitigation measures beyond

what were described in the [date] IEE Update (e.g.

operational turbine shut-off).

Birds Monitoring

Reports for period

from Jul 2018 till Jun

2019 are attached in

Annex-1. Monitored

data indicated

increased birds

population at

Project C as the area

has thick vegetation

and food

availability.

However the birds

population

decreased in the

project area as the

temperature

increased in May-

Jun 2019

No. 9: The Company will re-engage with the IUCN /

WWF-Pakistan and other wind farm developers in the

Jhimpir Wind Corridor to initiate discussion about

benefit of sharing bird monitoring data and expertise

so far accumulated and feasibility for a joint

evaluation of cumulative impacts of wind farms on the

birds and bats. Based on this discussion, the Company

will prepare an action plan way forward and start

implementation.

Currently no

progress has been

made as not all

wind farms mainly

those having local

lenders are not

performing formal

birds monitoring.

3. Implementation status of the Environmental and Social Management Plan:



Please provide a summary of the implementation status of the following:

3.1 I ple e tatio status of the [ P oposed E i o e tal a d “o ial Ma age e t Pla fo the TBCCL Wind

Energy Proje t ]. (Please atta h opies o ele a t audit epo ts a d o o itoring results).

o Refer to Annex-4 (HSE Inspection Records) ,5 (HSE Audits) ,12 (HR/Admin Audits), 15 (EPC/O&M

Contractor and Sub-Contractor HSE Performance Reports)

3.2 Implementation status of [(Mitigation Measures) of the Shadow Flicker Study Report of 150 MW Wind

Power Project of TBCCL].

o Since the project has completed its construction phase in September, WTG Noise Monitoring

and Shadow Flicker Study has been initiated and reports attached in Annex-14

3.3 Implementation status of [Stakeholder Engagement Plan, Tricon Boston Consulting Corporation (Private)

Limited].

o As per the Stakeholders Engagement Plan, 2 meetings have been conducted since the Operation

phase started. Evidences of stakeholder meetings are attached in Annex-6.

4. Conclusion/Recommendation (Please p o ide su a y assess e t of Co pa y’s pe fo a e a d suggested

next steps)

o The project is in overall compliance with most of the applicable IFC Performance

Standards at the maximum w.r.t. Environment, Occupational Safety and Social

Accountability standards compliance at work

o TBC HR/Admin will identify CSR activities which TBC and O&M Contractor will

undertake after EPC Contractor warranty period ends and include these in Community

Development /CSR Plan

o It is suggested that from July 2019, TBC HSE and Admin/HR heads conduct regular in-

depth audits of EPC Contractor and Sub-Contractor against IFC Performance Standards

and compile the observations as data and track E&S compliance performance through

data analysis.

o The Operational Phase Stakeholders Engagement Plan requires quarterly formal

eeti gs/e gage e ts duri g i itial ears of Operatio al. It’s ad isa le that TBC HR/Admin follows the meeting frequency as recommended in the Stakeholders

Engagement Plan and reports to senior management of TBC value component derived

through these engagements which should be meaning full for both TBC and neighboring

community

o Security Management Plan needs to be updated in the context of Operational Phase

requirements and should be supported by specific security related standard operating

procedures related to access control, CCTV surveillance, theft and pilferage control etc

o Occupational Safety and Health Hazards related to armed Security Guard activities e.g.

weapon cleaning, weapon issuance and storage, needs to be identified and

incorporated formally in the HSE System

o As TBC has the advantage of having strong IT infrastructure and human resource

available at site, this resource can be used for digitalization of HSE and HR/Admin



related activities e.g. tracking of HSE violations, Tracking of Grievances, tracking of audit

non-conformities, data analysis etc

Documents

Triconboston Wind Power Project (Pakistan) · 2 days ago · Environmental and Social Monitoring Report Environmental and Social Monitoring Report – FY June 2019 Project Number: