52.2 MW Dual Fuel (HFO/Gas) Fired Power Plant Project Social Monitoring Report... · 52.2 MW Dual...

This document is the property of LBPL and the information contained herein is confidential. Persons receiving this document

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52.2 MW Dual Fuel (HFO/Gas) FiredPower Plant Project

Comilla (Jangalia), Bangladesh

Environment & Social Monitoring Report

Report No: L125-RPT-EM-001

Date of Submission: 01-12-2014

52.2 MW Dual Fuel (HFO/Gas) Fired Power Plant ProjectComilla (Jangalia), Bangladesh


Page 1 of 30

ContentsExecutive Summary .............................................................................................................. 3

Chapter 1 .............................................................................................................................. 5

Basic Information .................................................................................................................. 5

1.1 Background of the Project ............................................................................................ 5

1.2 Reporting Period .......................................................................................................... 5

1.3 Current Project Status .................................................................................................. 5

1.4 Contacts ....................................................................................................................... 6

Chapter 2 .............................................................................................................................. 7

Environmental Management Plan (EMP) Implementation Status ........................................... 7

2.1 Pre-operation Phase ..................................................................................................... 7

2.2 Operation Phase ......................................................................................................... 10

2.3 Post-operation Phase .................................................................................................. 10

Chapter 3 ............................................................................................................................ 11

Institutional Arrangements and Environmental Monitoring ................................................. 11

3.1 Activity of the Environmental & Social Monitoring Unit during the reporting period . 11

3.2 Training Update ......................................................................................................... 11

3.3 Environmental Monitoring requirement and status of reporting .................................. 13

3.4 Environmental Monitoring Budget ............................................................................. 17

3.5 Additional Reporting requirement to IDCOL ............................................................. 17

Chapter 4 ............................................................................................................................ 18

Anticipated Environmental Impacts and Mitigation Measures ............................................. 18

4.1 Environmental, Social and Occupational Health & Safety Impacts during pre-

operational and operational phase .................................................................................... 18

4.2 Actions taken against the impacts .............................................................................. 18

Chapter 5 ............................................................................................................................ 23

Emergency Response and Disaster Management ................................................................. 23



Page 2 of 30

5.1 Brief description of the plan ....................................................................................... 23

5.2 Preparedness for the plan ........................................................................................... 23

Chapter 6 ............................................................................................................................ 25

Grievance Redress Mechanism ............................................................................................ 25

6.1 Brief Description of the Mechanism and Policy ......................................................... 25

6.2 Status of Stakeholder engagement .............................................................................. 25

6.3 Allocation of Resource and Responsibilities .............................................................. 25

6.4 Reporting Status ........................................................................................................ 26

Chapter 7 ............................................................................................................................ 27

Information Disclosure, Consultation and Participation ....................................................... 27

7.1 Stakeholder Consultation ........................................................................................... 27

7.2 Response to Issue Raised by Stakeholders.................................................................. 29

7.3 Information Disclosure .............................................................................................. 29



Page 3 of 30

Executive Summary

Lakdhanavi Bangla Power Limited (LBPL) has undertaken to develop and operate an

independent power plant project. The power plant is a dual fuel (HFO/Gas) with six internal

combustion generators with a capacity of 52.2 MW. The Power Plant is located at Jangalia,

Comilla Sadar South, Comilla District.

The main legislative with regard to environment is the Environmental Conservation Rules,

1997 of Bangladesh Government. As a part of environmental compliance, LBPL has prepared

an Initial Environmental Examination (IEE) report. The IEE report has been prepared based

on the guidelines of Department of Environment (DOE), Government of Bangladesh (GOB)

and Asian Development Bank’s (ADB) Safeguard Policy Statement. Based on this a site

clearance has been issued by the DOE.

The project site comprises about 3 acres of land. This land has been requisitioned from the

private land owners by following the required regulations of Bangladesh Government

through willing, buyer-willing, seller arrangement by the Government of Bangladesh and

Bangladesh Power Development Board (BPDB). The BPDB has leased it to the LBPL.

During the survey the land was found vacant. Therefore, for this project no resettlement

action plan was required.

The baseline survey for the proposed site was carried out for air quality, noise, physical

environment, biodiversity, deep ground water and surface ground water testing and house

hold socio-economic and an Initial Poverty & Social Impact Assessment (IPSIA) study. The

major environmental problems due to air pollution and noise generation was given utmost

attention as the plant location is in a mixed zone comprising of commercial and rural area

with settlements close to the power plant site.

A detailed analysis of the major pollutants was carried out. In combination with the baseline

air quality and on the information of the engine’s data sheet and specifications using air

dispersion modelling has been carried out. It was found that the annual concentrations of the

SOx, NOx and PM10 were within the limits set by the DOE and as well as the international

standards.

The other major concern is the noise generated due to the project activities during

construction period of the project. Based on the noise data available from engine

manufacturers and the baseline data collected a noise modelling was carried out.



Page 4 of 30

A baseline survey for the natural environment was carried out including flora and fauna. This

was found to be typical to the floodplains of Bangladesh. Since only three acres of land has

been used by the project there was no significant impact on the natural environment.

Quantitative measurements were done for both for ground water and surface water in the

immediate vicinity of the power plant. The project has met the requirements of the ISO

14001:2004 International Environmental Standard and the applicable regulatory requirements

of Bangladesh.

Occupational Health and Safety issues have been addressed in the project appropriately.

Apart from the Bangladesh national standards LBPL had complied with the International

Occupational Health and Safety Standards such as OHSAS 18001:2007.

LBPL has considered the environmental and social compliance issues with due importance. It

has also addressed all kinds of tentative environmental and social impacts promptly. The

project had no potentiality to adversely affect the rights of indigenous community

It is carried out a house hold survey, a focussed group discussion and key informant

interviews. The objective of the consultation process was to share the views of the

respondents about the power plant project. Most of the respondents showed positive response

to the project due to the high demand for power. In addition, as they have requested the

LBPL has provided employment opportunities to local people at different phases of the

project development.

There were no negative concerns about the noise levels, water pollution which have been

clarified during the consultations. The only environmental concerns were the possibility of

high levels of noise and. They requested assurances that noise and air pollution minimizing

measures have been taken in the design stage of the power plant.

The guidelines for environment management plan, environment and social monitoring unit

and grievance redress mechanism have been prepared by the LBPL. The recommended

mitigation steps proposed in the environment management plan have been implemented in

the project and ensured satisfactory environmental monitoring and compliance. In general

there were no major environmental and social impacts due to the project activities of the pre

operational phase up to now.



Page 5 of 30

Chapter 1Basic Information

1.1 Background of the ProjectThe Project will construct, operate and maintain the 52.2 MW Dual Fuel (HFO/Gas) Fired

Power Plant Project at Comilla (Jangalia), Bangladesh on Build, Own and Operate (BOO)

basis. Bangladesh Power Development Board (BPDB) will purchase the electricity generated

from the Project under a 15- year Power Purchase Agreement (PPA).

The project has three phases namely pre-operation, operation and post-operation. The pre-

operation phase carry out the engineering, procurement, construction, testing work and

commissioning the electrical interconnections of the 52.2 MW Dual Fuel (HFO/Gas) Fired

Power Plant Project at Comilla (Jangalia), Bangladesh. After the completion of the pre-

operation phase the operation and maintenance phase of the power plant will be started.

Major systems and equipment of the power plant consist with,

a) Six Diesel Engine coupled generator sets each at 8.9 MW

b) Fuel system including storage facility, fuel treatment and pumps

c) Fire water and water treatments system

d) Fire detection and protection system

e) Cooling water system

f) Oily water treatment system

g) LV system at 400 V

h) MV system at 11 kV

i) HV switchyard and system at 132 kV

j) Main control room, administration offices, workshop, stores etc.

1.2 Reporting PeriodFrom: April 2014

To: October 2014

1.3 Current Project StatusThe preliminaries works of the project completed. All the civil, mechanical, electrical designs

were completed. Material manufacturing & shipping has been completed. According to the

procurement plan all the purchase orders have been placed for all the civil, mechanical and

electrical purchases.



Page 6 of 30

Altogether 90% of civil works has been completed to date. foundations of engine hall, gen-

sets, tank fire water & treated water tank, exhaust stack, fuel oil treatment building, radiator,

boiler, auxiliary boiler, fire fighting container and switch yard has been fully completed. Also

the work of farm dyke wall & grade slab, cable trenches has been completed. The work of the

boundary wall, steel buildings, service road & drainage, guard house construction, fuel

unloading station are in progress.

Electro Mechanical Erection work completed 82 % to date. All engines were placed & aligned. Stack

erection is completed. The erection work of aux module, cooling water system, crane

installation, fire tank, LFO Storage Tank, HFO buffer, HFO day tank, oily water buffer tank,

sludge tank, lube oil tank, service lube oil tank, used lube oil tank has been completed. Fuel

oil system, lube oil system, compressed air system, fire system, exhaust gas system, waste heat steam

generating system, air intake system, water treatment system, HFO storage tanks work in progress.

Pre-commissioning and commissioning of the water treatment plant, compressed air system,

overhead cranes (engine hall, FTH & workshop) has been completed.

Project Activity % Completion

1. Preliminaries 100 %

2. Design and Engineering 100 %

3. Manufacturing and Shipping 100 %

4. Civil Construction 90 %

5. Erection and Commissioning 70 %

6. Startup Testing and Reliability Run 00 %

1.4 Contacts

Name: Mr. N. SivakumarPhone: 8802-8410330

Email: [email protected]

Name: Mr. A.B Siddique

Phone: 8802-8418513




Page 7 of 30

Chapter 2Environmental Management Plan (EMP) Implementation Status

The environmental management plan of the LBPL is established to design, implement, asses,

and continually improve it’s environmental management practices. The system has been

designed to meet the requirements of the ISO 14001:2004 International Environmental

Standard and the regulatory requirements of Bangladesh.

The environmental aspects and their impacts are being evaluated for this project. Based on

the outcomes of those evaluations, appropriate elimination or mitigation measures are also

being implemented in the project.

2.1 Pre-operation PhaseThe established Environmental Management Plan of the LBPL measures environmental

performance in relation to the environmental objectives and targets during the pre-operation

phase. The plan encompassed all the activities which support the execution of this project in

an environmental friendly manner. The environmental management plan is supported by

several documents including environmental operating procedures, work instructions,

emergency preparedness & environment recovery plans, and regulatory compliance

requirements applicable to project activities.

Planning

The environmental planning has been done for this project at the initial stages of this project,

before the construction work started. During the planning stage it has evaluated the project

specific regulatory requirements and associated significant environmental aspects of the

project. Environment aspects are being evaluated considering the project activities.

Operational Control

The system possesses a standard set of controls. Those are being customized to achieve the

requirements of this project site. The environmental objectives and targets of the LBPL will

be achieved through implementing environmental management programs, environmental

operational procedures, and other support systems in this project.

Monitoring and Measurement

All the project activities are being closely monitored during the entire project life cycle. The

level of environmental performance, which is required to maintain regulatory compliance and



Page 8 of 30

to achieve other environmental objectives and targets, is being monitored frequently.

Observations, data reviews, compliance verification, and internal audits are being used as

monitoring and measurement tools.

Preventive and Corrective Action

During the monitoring & measurement the necessary corrective and preventive actions are

being taken appropriately, for all non-conforming situations arise.

Management Review

The entire environmental management system is subject to periodic management reviews.

The higher management of the LBPL monitors the Environmental Management performances

of the project during the management review meetings.

Implementations

1.Air Pollution

Air pollution occurs mainly due to dust generation and due to emissions from power plant

vehicles and machinery. Mitigation measures have been implemented to minimize the air

pollution due to dust generation through maintaining the access roads and power plant

premises area in wet condition by sprinkling of water daily. And also soil with low level of

dust particles has been used in the construction of the access roads and the surrounding areas

of the site. Mitigation measures also include the inspection of vehicles and machinery for

emission levels before deploying in the power plant work and the periodic maintenance of the

vehicles and machinery. The LBPL has been carried out regular inspections on site vehicles

and machinery. During power operations and maintenance the air emissions from the engines

and through the boiler operations has been monitored and maintained within the stipulated

emission limits.

2.Land Pollution

Soil erosion can be occurred in nearby lands due to the obstruction of natural rainy water

ways due to earth moving and removing of inhabitant vegetation. As the mitigation measure

the power plant management has created alternate rainy water ways appropriately to the site

condition. The trees and major vegetation of temporary areas such as labour camp area have

not removed. Land pollution also can occur due to oil spills from equipment & machinery. To

prevent these incidents the site management has carried out regular inspections on site

equipment & machinery and done necessary maintenance as required.



Page 9 of 30

3.Water Pollution

Water pollution occurs due to sewage disposal and effluent water disposal. The water

pollution due to sewage disposal has been prevented through the construction of sewage and

septic tanks as appropriate to the conditions of the power plant sites. The water pollution due

to effluent water disposal has been prevented through the septic tanks and sand pits were

constructed to minimize impact of effluent water disposals. The LBPL has been worked in

conformance as per the waste water rules and regulations of the local government authorities

as appropriately. Waste concrete has been disposed as per the instructions of the local

government authorities and through approved waste contractors.

4.Noise Pollution

Noise pollution will also occur due to high noise generated from equipment & machinery. As

a mitigation measure the equipment & machinery shall be checked for the availability of

necessary vibration & noise controlling parts in place before using in the site they were being.

The power plant management will carry out regular inspections on equipment & machinery.

Usage of ear mufflers shall be provided for high noise work for the power plant employees.

5.Oil and Chemical Spillages

All oil and chemical have been stored in appropriate containers with proper labels. Hazardous

chemical have been effectively isolated to avoid contamination. The small oil spillages have

been responded immediately with oil collection trays and using cotton absorbents. The

necessary preventive measures have been taken to avoid any contamination with the natural

environment such as water bodies and ground. Oil collection trays and dry cotton absorbents

are being kept at the stores in-order to use during a spillage.

6.Waste Management

The waste is being collected in to a one location of the power plant site. Some of them are be

reused while others disposed. Waste disposal has been done as appropriately as per rules and

regulations of the local government authorities. The LBPL has taken necessary measures to

prevent land pollution through the disposal of reinforcement material off cuts. During the

construction period power plant management has been instructed to collect all the

reinforcement material off cuts in to a one location of the site. Some have been reused while

some have been disposed as appropriately as per rules and regulations of the local

government authorities. Land pollution due to the disposal of excess concrete has been

minimized through accurate measure of quantities during the planning stage. The 3R system

of waste management has been introduced in the project site.



Page 10 of 30

2.2 Operation PhaseThe operations & maintenance not yet commenced. But the environment management plan

has been already developed after evaluating the possible environment aspects and their

impacts during the operation & maintenance phase. During the operation phase the

preventive maintenance will be carried out to identify and resolve problems related to

environmental impacts, with other monitoring activities at regular intervals. Monitoring of oil

water separation and sanitary waste treatment will be done periodically to avoid water

pollution. Other environmental good practices include noise abatement, maintaining hygienic

conditions, maintenance of fire and safety equipment etc. and clearing of grass will be done

periodically and medium height tree plantation around the boundry wall will be done at the

plant areas as appropriately. (Refer: Environment Management Plan L125-PLN-EM-001)

2.3 Post-operation PhaseThe post operations plans have been drawn. Those will be executed during a post operation

condition.



Page 11 of 30

Chapter 3Institutional Arrangements and Environmental Monitoring

3.1 Activity of the Environmental and Social Monitoring Unit during the

reporting periodAs per the monitoring the overall environmental management of the project has been good so

far.

· Carried out an environmental aspects & impacts evaluation covering all the operations of

the project and environmental procedures are being implemented in this project as

appropriately.

· Environment awareness training sessions are being carried out to enhance environment

awareness.

· The emergency situation planning has been implemented with the environment recovery

actions to be executed aftermath of emergency situations.

Environmental monitoring is being conducted to compare the change between baseline

condition and after project scenario, by testing some environmental parameters of air, water

and noise and in case of necessity soil is tested. LBPL has conducted the environmental

monitoring as well as implementation of environmental management plan. The testing of

environmental parameters has been done with sophisticated instruments, by the SGS of

Bangladesh which is an accredited institution for testing and analyzing environmental

parameters.

3.2 Training UpdateTraining is an integral part of a preventive strategy. Environmental awareness, emergency

preparedness and response trainings have been provided to the power plant staff in-order to

ensure proper implementation of effective environmental management and disaster

management plans.

The training schedule covers the all identified training needs which include trainings on basic

fire-fighting, training on environmental regulations and standards, staff training on

environmental monitoring and also on occupational health and safety measures for site

workers.

The following trainings have been carried out for the power plant site staff at the power plant

project in Comilla (Jangalia), Bangladesh. (Refer: Annexure 02 for Training Records)



Page 12 of 30

No Training DateIn-house/

Outbound

1 Waste management in the site March -2014 In-House

2 Use of PPE & Safe Work Practices Apr-2014 In-House

3 HSEQ Awareness Program May-2014 In-House

4 Maintaining the site HSEQ records May-2014 In-House

5 Basic First Aid June-2014 In-House

6 Waste management in the site June-2014 In-House

7 Electrical safety procedures for site July-2014 In-House

8 Basic Fire Training July-2014 In-House

9 Use of PPE & Safe Work Practices Aug-2014 In-House

10Use of PPE & Safe Work Practices – Welding

workSep -2014

In-House,

on the job

11 Use of PPE & Safe Work Practices Oct-2014In-House,

on the job

12 Use of PPE & Safe Work Practices -work at height Oct-2014In-House,

on the job

Conducted awareness trainings on environment, occupational health and safety for all the site

employees.



Page 13 of 30

3.3 Environmental Monitoring requirement and status of reportingMonitoring Requirements

EnvironmentAspect

ImpactingActivities/

Source

KeyParameters Method Frequency Location

Ambient AirQuality

-Landpreparation &earth works- Openexcavation-Developmentof access roadsfor heavy equip.transport.

SPM, PM10,PM 2.5, SOx,NOx and CO

PassiveSampling

Quarterly(routine)Analysis

At project site,residential /

commercial areaswithin 500moutside from

plant boundary

SurfaceWater

-Domesticaffluent waterrelease fromworker facilities-Waste waterfromconstructionwork

pH,Temperature,

DO, BOD,COD,

TDS,TSS, Oiland Grease

PassiveSampling

Bi–anually(pre-

monsoon& post-

monsoon)

At project site

GroundWater

-Waste waterfromconstructionwork-Domesticaffluent water

pH,Temperature,

DO, BOD,COD, TDS,

Oil andgrease

PassiveSampling

Bi–anually(pre-

monsoon& post-

monsoon)

At project site

The OHS and environment awareness meetings and trainings have been carried out

frequently to instruct the worker representatives on day to day site maintenance procedures.



Page 14 of 30

EnvironmentAspect

ImpactingActivities/

Source

KeyParameters Method Frequency Location

Noise

-Landpreparation &earth works- Openexcavation-PilingCommissioningand Testing

Limits in dBA 5 MinuteAverage

Quarterly(routine)analysis

At four cornersof projectboundary,residential/commercialareas within100m and

300m outsidefrom plantboundary

Surfacerunoff

Landpreparation &earth works

TurbidityMonitordrainagesystem

Duringrainy days At project site

Damages toRoads,

Bridges &Culverts

Heavyequipmenttransport

Visualdamages Inspect

Dailyduringheavy

equipmenttransport

At access roads

OilSpillages

Commissioningand Testing Any leakages

Inspect,monitorvehicleservicereports

WeeklyAt the site andother relevant

areas

SewageDisposals from

employeefacilities

Quantity,Disposalmethod,

Disposingarea

Record &Analysis Weekly At project site

Solid Waste

Disposals fromemployeefacilities

Installation ofplant &

machinery

Types ofwaste,

Quantity,Disposalmethod,

Disposingarea

Record &Analysis Weekly At project site

SanitaryStatus

Maintenance ofemployeefacilities

Cleanliness,Orderliness

Tool boxmeeting Weekly At project site



Page 15 of 30

Ambient Air Quality Test Results

The LBPL has carried out the environment parameter tests namely Ambient Air Quality Test (PM10, PM2.5, SO2, NO2, O3, CO) and the Noise

Level Tests in September 2014 at the Comilla power plant construction site. The test reports indicate normal. (Refer: Annexure 01 for Test Reports)

L1 – Engine Hall Area

L2 – Radiator Area

Aspect Regulation

Requirements

Actual ResultTesting

Date

Testing

done by

Pollutant

Max. permissible level (µg/m3) 08

Hrs Average

Ambient

Air

Quality

World bank guidelines

Thermal power:

guidelines for new

plants

(July 1998)

&

Department of

Environment (DOE) -

Bangladesh Standards

DOE -

BangladeshWorld Bank L1 L2

20/09/2014

SGS

Bangladesh

Ltd

PM 10 150 150 52 61

Sulfur

Dioxide365 125 16 19

Oxides of

Nitrogen100 150 21 23

Carbone

Monoxide10,000 NF 120 110

Ozone 157 160 17 14



Page 16 of 30

Noise Test Results(Refer: Annexure 01 for Test Reports)

L1 – WestL2 - EastL3 – SouthL4 - North

Aspect Regulation Requirements

Actual ResultTest

Date

Testing

done by

Noise

World bank

guidelines

Thermal

power:

guidelines for

new plants

(July 1998)

&

Department of

Environment

(DOE) -

Bangladesh

Standards

(Industrial

Area)

Max. Permissible Noise levels

at boundaries (LAEq) dBA

DOE -

BangladeshWorld Bank L1 L2 L3 L4

20/09/

2014

SGS

Banglades

h Ltd

D N D N D N D N D N D N

75 70 70 70 64.29 54.11 74.33 52.39 70.29 51.19 65.17 53.44



Page 17 of 30

3.4 Environmental Monitoring BudgetAn environment budget has been already estimated for the operation and maintenance phase. The

actual spending on environmental monitoring activities during the operation and maintenance

phase can be derived once the operation and maintenance of the power plant starts.

3.5 Additional Reporting requirement to IDCOLThis report has been compiled considering the requirements of the Infrastructure Development

Company Limited (IDCOL) which gave the financial assistance to LBPL arrange the project

financing. Required environment and social monitoring status information has been included in

this report. There are no any additional reports to be disclosed herewith. The report addresses the

aspects of the Environmental and Social Safeguards Framework (ESSF) of IDCOL.

As per the requirement of the IDCOL this report has been prepared based on the guidelines of

Department of Environment (DOE), Government of Bangladesh (GOB) and Asian Development

Bank’s (ADB’s) Safeguard Policy Statement (SPS).



Page 18 of 30

Chapter 4Anticipated Environmental Impacts and Mitigation Measures

4.1 Environmental, Social and Occupational Health & Safety Impacts during

pre-operational and operational phaseThe project is still in the pre-operation phase and the necessary mitigation measures have been

implemented accordingly to the initial plan. The major activities during the pre-operation phase

of the proposed power plant include mobilization of equipment, materials and personnel, site

preparation, civil construction and electromechanical installation/erection etc. The LBPL has

taken several initiatives with regard to environmental aspects, social issues and as well as to

occupational health & safety conditions during pre-operation phase. The necessary preventive

and corrective actions have been taken for the environmental aspects and their impacts on

environment due to various activities during construction phase of the project. Stakeholder

grievances and other social issues are being addressed promptly. The occupational health and

safety of the site workers are being closely monitored all the time during the work.

4.2 Actions taken against the impactsThe site rounds and tool box meetings have been carried out at the project site to identify and

resolve problems at regular intervals. Other environmental good practices implemented include

minimizing air pollution, maintaining hygienic conditions, maintenance of fire and safety

equipment etc. and clearing of grass have been done periodically.

LBPL has developed a working relationship with the environment authorities of Bangladesh by

undertaking a joint monitoring program to monitor ambient air quality and also to assess whether

there is any significant noise problem. During the construction phase up to date, the LBPL has

ensured the activities such as land leveling, clearing work, access road construction, putting

proper traffic signals etc. were being carried out properly to minimize the level of impact. This

has been monitored by the Health, Safety & Environment Officer of the LBPL.

During mechanical erection phase special attention given to the occupational health and safety of

the workers. Those activities included hot work, work at height, electrical work and etc. Since,

some of the workers who are unskilled joined from the neibouring villages. They are being given

training and provided with necessary personal protective equipments.



Page 19 of 30

Project Activity Potential Impact Mitigation Measures

Access to the site

and site clearance

Temporary obstruction of

access roads, waterways,

clearance of trees and shrubs.

· Minimized disturbance and the clearing

of vegetation.

Soil erosion in nearby lands due

to the obstruction of natural

rainy water ways due to earth

moving and removing of

inhabitant vegetation.

· Created alternate rainy water ways

appropriately to the site condition.

· The trees and major vegetation of

temporary areas such as camp area have

not removed.

Site mobilization

Impact to the external

environment by putting

construction waste.

Topographic change by cutting

existing trees, shrubs, herbs,

and filling land.

· Disposal of debris done in accordance

with local authority regulations and

advice.

· Some design changes have been done to

minimize the cutting of trees, shrubs,

herbs, and lowland filling.

· Used waste shrubs, herbs as organic

fertilizers.

· Measures taken to prevent waste

shrubs, herbs as fuel to cook or for any

controlled burning purpose.

Preparation and

level grading of

storage & site

office area

Air pollution due to dust

generation.

· Maintained the access roads and site

area in wet condition by sprinkling

water daily.

Air pollution due to emissions

from site vehicles and

machinery.

· Before deploying in the site work they

were being inspected for emission

levels and the periodic maintenance.

· Carried out regular inspections on site

vehicles and machinery.



Page 20 of 30


Usage of

construction

vehicles,

equipment &

machinery

Land pollution due to oil spills

from construction vehicle,

equipment and machinery.

· Carried out regular inspections on site

vehicle, equipment and machinery.

· Done necessary maintenance as

required.

· Oil collection trays and dry cotton

absorbents were kept at the stores in-

order to use during a spillage.

Influx of workersGeneration of sewerage and

solid waste.

· Distributed a leaflet on site health &

safety, environmental regulations and

other general rules for the site workers.

· Erection of the information boards to

aware the workers on site cleanliness.

The sign boards contained phrases such

as “keep the site clean”.

· Constructed sanitary latrines and septic

tank system.

· Installed waste bins/cans, where

appropriate around the site.

· Implemented procedure on waste

minimization, recycle and reuse

mechanisms as required.

· Trained site workers on proper

segregation and disposal of solid waste.

Transportation of

equipment,

materials and

personnel

Deterioration of air quality from

increased vehicular movement,

affecting people in the

surrounding areas.

· Regular checking of vehicle condition

to ensure site vehicles are in good

condition.

· Took necessary actions to ensure

vehicle emission comply with local

standards and EHS guidelines, where

applicable)



Page 21 of 30


Storage of

Construction

materials and

debris

Wind-blown dust from material

(e.g. sand, fine aggregate) at

storage areas.

· Watering the access road.

· Sprinkling and covering stock piles.

· Covering top of trucks carrying

materials to the site and carrying

construction debris away from the site.

Visual degradation of areas

caused by cleaning vegetation

for lay down of materials.

· Selected suitable level area and

minimized removal of vegetation.

· No clearing of vegetation or soil by

grading with machinery has been done.

Storage of

chemicals and

materials

Contamination of receptors

(land, water, air).

· Oil securely stored above high flood

level.

· Oil collection trays placed under the

containers that are filled-up full.

Noise from

construction

equipment

operations and

maintenance

Hearing discomforts for

neighborhood and site workers.

· Install such machinery on resilient

foundations and in enclosed areas.

· Avoided, as much as possible,

construction equipment producing

excessive noise.

· Avoided prolonged exposure to noise

by workers.

· Followed construction scheduling to

avoid evening and nighttime

disruptions.

· Wearing of ear mufflers and use of

other appropriate PPEs when required.



Page 22 of 30


Dust during

construction and

exhaust gases

from construction

machinery and

vehicles

Increased SPM, PM 2.5, PM 10,

NOx, SOx levels at construction

sites, and surrounding areas

Emission of dust to the

neighboring houses, buildings.

· Avoided using equipment such as stone

crushers at site, which produces

significant amount of particulate matter.

· Immediate disposal/sale of excavated

materials and continuous watering of

bare material stock piles.

· Immediate use of construction spoils as

filling materials.

Effluent arising

from domestic

activities

Contamination with land and

water

· Released them in to a soakage pits or

septic tanks as appropriately.

Storage of fuel oil

and other types of

oil

Accidental oil spillages and fire

hazards

· Use of properly designed storage tanks

suitably located.

· Use of a proper secondary containment

to store excess.

· Implementation of necessary fire

extinguishing mechanisms.

Provision of

facilities for

power plant

workers

Contamination of receptors

(land, water, air)

· Construction workforce temporary

facilities to include proper sanitation,

water supply and waste disposal

facilities.

Nuisance to

nearby properties

Losses to neighboring land

uses/ values.

· Held awareness trainings for site

workers to implement careful work

practices.

Hazardous waste

from plant (scrap

metal, waste, lube

oils, spill oil etc)

Potential soil and groundwater

contamination.

· Secure on-site storage of hazardous

waste.

· Sell waste to the authorized vendor for

discharge in a safe place.



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Chapter 5Emergency Response and Disaster Management

5.1 Brief description of the planThe LBPL has developed an emergency response and disaster management plan to take

necessary actions to prevent any un-wanted disaster in the plant. Disaster could also be occurred

if any sudden flood, earthquake and fire occur or if the equipment/ machinery fail to work at

normal condition. In this regard provisions have been made to stop the ongoing activities

immediately during any emergency situation. Separate emergency preparedness and response

plans have been developed for each and every identified emergency situation. This plan also

includes a separate natural disaster preparedness, response & recovery Plan.

5.2 Preparedness for the planThe below preventive measures have be taken to be executed during an emergency or a disaster.

· Address soil erosion during and after heavy rainfall

· Formulation and strict implementation of safety codes and measures

· Periodic inspection of safety valves and equipment

· Preventive maintenance

· Precautionary measures for electro-magnetic wave or electrical interference

· Prohibit smoking in the site premises

· Mock firefighting drills

· Provision and inspection of firefighting equipment and fire hydrant system periodically

· Proper training of the employees about the environment compliances

· Training the employees and the residents of the surrounding villages about the actions to

be taken during an accident, disaster etc.



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Fire Prevention and response plans implemented.

Installation of Fire Extinguishers, Sand Buckets.

Designed, implemented and tested the site emergency plan.

Installed emergency siren at the site and done trial emergency evacuations.



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Chapter 6Grievance Redress Mechanism

6.1 Brief Description of the Mechanism and PolicyThis grievance procedure will ensure that all comments and complaints from any project

stakeholder, including local or regional authorities, residents of nearby residential areas, project

employees and other interested parties, are acknowledged and responded to within a reasonable

timeframe.

LBPL will accept all comments and complaints associated with the project activities. The

comments and complaints will be summarized and listed in a Complaints/Comments Log Book.

6.2 Status of Stakeholder engagementLBPL stakeholder’s engagement has taken place in a variety of contexts, and using a range of

methods. Against this background, engagement will include consultation, joint planning,

capacity building, partnerships, community-based monitoring and reporting.

LBPL has hold meetings with the participation of all the stakeholders in the project who are

impacted directly or indirectly and with the area’s public liaison committee.

Provisions have been made to evaluate the health safety aspects of the communities residing near

the project site from the project activities. The conditions will be considered and evaluated time

to time during the project execution.

6.3 Allocation of Resource and ResponsibilitiesTo ensure proper caring on grievances raised by project stakeholders the resource and

responsibilities has been allocated in two levels as are mentioned below.

Power plant site level

LBPL has assigned a dedicated person as the project stakeholder’s liaison officer at power plant

site. He has the overall responsibility for handling the consultation and information disclosure

process, at the site level. The responsibilities and activities includes,

· Organize the stakeholder awareness activities

· Communicate with identified stakeholder groups

· Collect and process comments/complaints



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· Respond to comments and complaints

Depending on the nature of a comment/complaint, some comments/complaints will be provided

to the appropriate person or committee in the company for a response.

Contact detail of resource person

Name: Mr. N. SivakumarPhone: 8802-8410330


Corporate Level

A senior representative of LBPL is being assigned to represent the corporate level in dealing

with project stakeholder’s grievance addressing process and consultation. He is expected to

review the findings/ observations forwarded to plant level and who will be responsible for

implementing the decisions.

Contact detail of resource personName: Mr. A.B Siddique

Phone: 8802-8418513


6.4 Reporting Status

All comments and complaints will be responded to either verbally or in writing, in accordance

with preferred method of communication by the LBPL depending on the urgency of the issue.

All grievances will be registered and acknowledged within 5 days and responded to within 20

working days. Some grievances will be resolved at the power plant site level with the

consultation with the power plant management. The issues need cooperate level involvement will

be directed to the higher management of the company immediately.

LBPL maintains a Complaints/Comments Log Book which is available at the power plant site

office. All the decisions taken with regard to project stakeholders’ grievances will be recorded

with evidence for future reference. Summary of minutes of the community meetings and records

of corporate communication programmes will be will be reported in project progress reports and

in other relevant corporate documentation as appropriately.



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Chapter 7Information Disclosure, Consultation and Participation

7.1 Stakeholder ConsultationThe main objective of the consultation meetings was to inform the local inhabitants about the

project and to seek their opinion regarding the impacts if any. The feedback of public

consultation helped to ensure that the decision making process is fair and lead to better

environmental outcomes. The findings from the public consultations were utilized in the

development of the environment management plan, especially in identifying the significant

impacts of the project and developing the corresponding mitigation measures.

The activities of the consultations were as follows:

§ Dissemination of information about the project among the stakeholders

§ Get a better understanding of existing environmental conditions

§ Aware stakeholders to contribute meaningfully in different phases of the project

§ Reduce the psychological distance between LBPL and the stakeholders

Public consultation has been carried out during different activities in the project lifecycle, using

different techniques such as public meeting, small group meeting, and informal meeting. During

such consultations the public was informed about the project in general.

Consultation meetings with local government representatives of Upazila ParishadIn general community stakeholders are categorized into two broad categories. They are directly

affected and indirectly affected. Directly affected community stakeholders include people who

will have the potentiality to be directly impacted through loss of land, crops and other assets,



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environmental and social adverse impact due to the project. Indirectly affected community

stakeholders include those people of the project area who have the potentiality to be affected by

the project activity at a limited extent.

As a part of discussion with directly impacted stakeholders, there was consultation with both

male and female representatives living in adjacent to the Project site as shown in the following

photographs. In addition, to get feelings about the indirectly impacted stakeholder, there was a

separate consultation at Jangalia Market area. In this consultation, the opinions of all classes of

people including businessman, general public were taken. These have been documented in the

following photographs.

Consultation with the villagers who can be directly and indirectly affected

There are several non-governmental organizations (NGOs) working in the project impacted area.

The NGOs are both international and local. There are several organizations that seek to

coordinate local NGO activities.

NGO activities are wide ranging, including agricultural support, health care support, micro

credit, family support, environmental advocacy and support to vulnerable groups (elderly,

orphans and abandoned children).

There are a number of NGOs operating at Jangali and Doiara. Among them Bangladesh Rural

Advancement Committee (BRAC), Jagoroni and Association for Social Advancement (ASA)

were consulted as they have the higher coverage in terms of area of operation.



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Consultation meeting at City Corporation Consultation meeting with ASA NGO

7.2 Response to Issue Raised by StakeholdersIn the stakeholder meetings and consultations, a number of issues were discussed. Among them

the major issues can be presented as follows with the response of LBPL.

Requests for employment in the power plant project

The power plant site is located in a semi urban and agricultural area and the rate of

unemployment is very high. As a result, most of the stakeholders requested for providing job

opportunities for semi-skilled and unskilled local people. In response, LBPL most of the

unskilled jobs were allocated to the locals during construction phase.

Impact on livelihood due to vehicle movements

During construction phase there were frequent movements of heavy vehicle to and from the

power plant site. To minimize adverse effects and disturbance LBPL has taken measures to

deploy vehicles in better condition to minimize the noise and the emissions of the vehicles and

limit the speed of vehicles to avoid accidents.

7.3 Information DisclosureThe LBPL has carried out several meetings and consultations with the villagers and public to

disseminate information on the project activities among the project affected persons. The formal,

informal meetings and focus group discussions have been carried out in this process. The formal

meetings were held through prior notice and invitation for all project affected persons,

households, district administration, local administration and other stakeholders in the affected

area.

Activities carried out during these meetings and consultations include,



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· Identified the project affected persons

· Identified and informed the government agencies connected with the project

· Identified the closest households or commercial institutions of the project site and make

them aware of the impacts of the project and note their concerns.

Time to the information on the project activities were disseminated to the project affected people

and also the nature of impact and compensation issues were discussed.

Dissemination of information on the project activities and information disclosure carried out

during the sample-based socio-economic survey which had covered 120 households within the

impact zones.

One large public consultation meeting has been held including all the project affected persons,

representatives from the project impacted areas, district and local administration, as well as other

community representatives including prominent local people, lawyers, journalists and

academicians.

Annexure 01

Environmental Parameter Test Report

Annexure 02

Training Records

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