Set V - ESDD report for pro

Transcription

Environmental and Social Due
Diligence report for Projects under
KPCL
May 2016
Environmental and Social Due Diligence report for
projects under KPCL
Environment and Social Due-Diligence Report
Prepared for
Summit Corporation Limited
Prepared by
AECOM India Pvt. Ltd.
May 2016
© AECOM
The information contained in this document is solely for the use of the client identified on the
cover sheet, and for the purposes specified herein. AECOM accepts no responsibility and
undertakes no duty to any third party who may rely on this document.
All rights reserved. No section or element of this document may be removed from this
document, reproduced, electronically stored, or transmitted in any form without the written
permission of AECOM.
Environmental and Social Due Diligence report for
projects under KPCL
Quality Information
Site Visit, Review and Report Preparation
The site visit and report preparation were undertaken by the following AECOM professionals from AECOM’s, Gurgaon office,
Haryana, India
40 MW KJAPC- Noapara, Jessore
and 110 MW and 115 MW KPCL Goalpara, Khulna Reports.
Ajay Pillai, Associate Diroctor
Reela Mishra, Senior
Environmental Consultant
Quality Control Review
A Quality Control Review of this report was conducted by Dr. Somnath Mukherjee, in AECOM’s Gurgaon Office, Haryana,
India office
Signature:
____________________________________
Dr. Somnath Mukherjee,
Executive Director, Environment, India
Revision History
Authorized
Revision
Revision Date
Details
Name/Position
Ajay Pillai
Revision No. 1
27 May 2016
Project Director
Signature
Environmental and Social Due Diligence report for projects
under KPCL
3
1.0 Introduction
Summit Group of Companies is one of the leading private sector conglomerates of Bangladesh comprising a chain
of business units including power, shipping and communications. Summit Group is one of the pioneers in power
generation in Bangladesh with eleven power plants in operation. Summit Corporation Limited (hereinafter referred
to as ‘SCL/ Summit’), formerly known as Summit Industrial and Mercantile Corporation (Pvt.) Ltd., was established
in 1985, as a holding company sponsoring its subsidiary companies to own, build and operate infrastructure
projects in power sector.
SCL has eight subsidiary companies that are part of the Summit Group. Apart from these, SCL also holds stakes in
Khulna Power Company Ltd. (KPCL), an independent entity with other shareholders. SCL currently produces
around 1,260 MW of power, which is around 13% of total capacity of Bangladesh. The total net worth of SCL,
including all its subsidiaries, is USD 600 million as on FY-15.
Figure 1-1: SCL and Subsidiary Companies
SCL operates both gas based and Heavy Fuel Oil (HFO) based power plants through its subsidiary Turbine division
and Summit Power Limited. SCL has a Turbine Division for development and operation of units using turbines for
generating electricity. The Turbine Division currently comprises two subsidiary companies, SMPCL and SBIIPCL.
The subsidiaries formed under the Turbine Division follow the policies and procedures of the holding company,
SCL.
SPL which is a subsidiary of SCL is a holding company and comprises of five subsidiary companies including: (i)
Summit Narayanganj Power Ltd. (SNPL), (ii) Summit Purbanchal Power Company Ltd. (SPPCL), (iii) Summit
Uttaranchal Power Company Ltd. (SUPCL), (iv) Summit Narayanganj Power Unit ll Ltd. (SNPUIIL); and (v) Summit
Barisal Power Ltd. (SBPL). SPL also holds 17.64% of the ownership of Khulna Power Company Limited (KPCL)
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which has three HFO based power plants: (i) 110 MW (operational since 1998) at Goalpara, Khulna (ii) 115 MW
(operational since 2011) at Goalpara, Khulna and (iii) 40 MW (operational since 2011) at Noapara, Jessore.
Khulna Power Company Limited (KPCL) owns and operates nine (3) power plants at different locations across
Bangladesh with a total capacity of 265 MW. The list of operational units under KPCL has been presented in Table
2-1.
SNo
Project Company
Location
Capacity
Fuel
1
Khan Jahan Ali Power Company (KJAPC) - subsidiary
of KPCL
Noapara, Jessore
40 MW
HFO
2
Khulna Power Company Limited (KPCL)
Goalpara, Khulna
110 MW
HFO
3
Goalpara, Khulna
115 MW
HFO
Total
265 MW
1.1 Purpose
SCL intends to hold 20% of the country’s generation capacity. As power generation is a capital-intensive sector,
SCL has planned to go international market for expanding its equity base. As part of this endeavour, SCL has
signed an Appraisal letter with the International Finance Corporation (hereinafter referred to as ‘IFC’) for
investment in the company to be made by latter and its co-investors, subject to satisfactory outcome of a due
diligence process.
As per the requirements of IFC, due diligence on Environmental & Social aspects of the Company is required
before making any decision on investment/financing in any company. SCL and IFC have therefore engaged
AECOM India Private Limited (hereinafter referred to as ‘AECOM’) to review and assess the environmental, H&S
and social performance of Holding company (SCL), subsidiaries, operating assets, assets under construction, and
proposed assets under SCL against the following reference framework:

Bangladesh Environmental, Health, Safety and Social regulations related to all aspects that are covered in
the IFC Performance Standards, 2012;

IFC Sustainability Framework , including IFC Performance Standards 1 through 8 dated January 2012;

The IFC General Environmental, Health and Safety (“EHS”) Guidelines, dated 2007;

The IFC Sector EHS Guidelines for Thermal Power Plants dated 2008;

Power Sector EHS Guidelines for Electric Power Transmission and Distribution dated 2007 (except
Section 3.2 and 3.3);
As part of the due-diligence exercise, AECOM has conducted site visits to operational projects, and has undertaken
desktop based assessment for projects under construction, and proposed projects. This report presents details of
observations made as part of Environmental and Social Due Diligence report for all the three (3) projects under
The present assessment has been undertaken as per the predefined scope of work (under Section 1.2 of this
report) and methodology (under Section 1.3) in the AECOM proposal for the assessment dated 06
th
February,
2016. The observations made by AECOM professionals during the assessment are detailed under Section 3.0 of
the report along with recommendations to mitigate or minimize the Environment and Social (E&S) risk or impact(s),
if any.
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1.2 Scope of Work
The scope of work for the E&S DD of operational assets includes the following tasks:

Identification and description of the main environmental and social risks and impacts;

Assess the compliance of the Company’s environment, health, safety and social management systems
(ESMS) with the provisions of applicable standards presented in Section 1.1;

Assessment of the compliance status of the Project against EHS&S regulatory requirements and
requirements of Applicable Standards and identify any non-compliances ;

Characterization of the environmental setting, current surrounding land use, historical land use (on & offsite) of the Project and related issues concerning the environmental context of the Project, which may be
of relevance to operation related risks and impacts;

Evaluation of current and past operational activities and related practices at the Project in order to
establish known or potential sources of soil, groundwater and/or surface water impact;

Review of the management systems, mechanisms, policies and procedures in place for the management
of environmental and social issues at both holding company and individual operations, including
organization, objectives, targets, training, performance monitoring and auditing, and staffing, budgeting,
and management review including covering matters related to use and management of contractors;

Identification from media and other relevant sources if there are any concerns regarding potential
environmental and social issues in relation to the Investment or the Sponsor, including outstanding
litigation, notices or orders from courts or regulators, negative Non-Governmental Organization and/or
affected community attention, that may lead to reputational risk;

Interview of key stakeholders including affected communities to assess risk, issues, concerns and
opportunities;

Assessment of the capacity and resources of the Investment to implement the Environmental and Social
Management System and the Action Plan;
1.3 Methodology
The approach and methodology broadly applied for the execution of the assessment has been detailed below:

AECOM reviewed the existing Environmental and Social Management System (ESMS) of the project in
order to assess its adequacy and effectiveness of implementation, and identify gaps with the reference
framework;

Project specific environment and social risks and impacts were evaluated as per the reference framework,
such as:

o
Resource consumption (energy and water), emissions and discharges;
o
Waste management;
o
Impacts on nearby communities;
o
Labor working conditions;
o
Occupational health and safety;
o
Community health, safety and security and others.
Review of the adequacy and status of implementation of management and monitoring plans for the project
operations, developed as part of the project’s ESIA including the effectiveness of existing monitoring
system in place, was undertaken;
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Review of other relevant environmental and social risks and impacts or issues that may emerge out of
review of public information and/or stakeholder consultations was also undertaken;

Verification of compliance with various commitments of the project as part of ESIA and clearances
obtained from relevant agencies was undertaken; and

Post site visit, AECOM collated and analysed the project data, site visit observations and interviews and
presented the same in this report.

Dispersion modeling using AERMOD 8.1 to compute the contribution to emissions by the operating assets
was conducted for:

o
NOx emissions for gas based projects and
o
SO2, NOx and PM for HFO based projects
The total Ground Level Concentration (GLC) for specific parameters and comparison of the GLC with
national guideline values and IFC EHS guideline values have been provided as Annexure B of the report.
Specifically, the methodology for undertaking the due diligence of the project has adhered to the following line of
action:

A list of information required for the project was shared with the company after the kick-off meeting.

Review of all existing documents pertaining to project has been undertaken as detailed in Section 1.4 of
the report.

A two member team comprising of Environment, Health Safety and Social experts from AECOM undertook
reconnaissance site visit of the facility on 16th March 2016 and the following activities were carried out:
o
Direct observation of the entire project area, with a focus on the sensitive environmental, health/
safety and social features and receptors;
o
Consultation with the project developers, to understand the project details, how the project
proponents are meeting the statutory requirements (permits, licenses etc.), and the challenges
they have been facing in terms of environmental, health & safety and social issues if any;
o
Discussions with the communities (representatives) has been undertaken to assess overall
perceptions and opinions about the project and to identify any potential issues of conflicts;
o
Assessment of the capacity and management structure of the company was undertaken to
address environment, labour, health & safety issues and impacts;
o
Review of the adequacy of the designs/measures (including any proposed actions),
skills/capacities of the team, budget etc. (relevant to E&S) was undertaken; and
o
Assessment was undertaken with respect to relevant commitments made by the project under
various consents and clearances for the project and associated facilities

Based on review and verifications, the present report has been prepared which comprises of observations
on compliance to and gaps with respect to the reference framework, as detailed under Section 3.0; and

Recommendations of additional actions to close the gaps detailing actions to be implemented,
budgets/estimated costs and timeframes for completion of such actions/measures has been provided
under Section 4.0 of this report.
Furthermore, the observations made in the report are subjected to material threshold in relation to expenditures
required to meet compliance with the Applicable Standards. This material threshold is a monetary value and relates
to costs considered necessary to address findings identified during the assessment. Expenditures greater than the
material threshold have been considered to have the potential to impact either the value or the operability of the
assets. In the context of this due diligence, the threshold has been defined as an Environmental or Social (including
safety, security and community) issue that:

Would require more than USD 250,000 to rectify;

May result in significant business interruption/criminal proceedings or a major environmental incident;

Has resulted in community or NGO protest (as identified through an internet search); and/or
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Could result in a risk of multiple serious injuries or fatalities.
1.4 Limitations and Data Gaps
This report presents the observations made by AECOM professionals based on the scope of work and agreed
approach and methodology with Summit and lenders. The present report has been developed to identify the
potential EHS and social issues and conditions associated with the activities of the project for which the
assessment has been carried out. During the course of this assessment, AECOM has attempted to independently
assess the potential presence of EHS and social issues or conditions within the limits of the established scope of
work as described in the contract between IFC, Summit and AECOM.
As with any assessment exercise, there is a certain degree of dependence upon verbal information provided by the
point of contact for assessment, limited number of documents available for review and information available in the
public domain, which is not readily verifiable. CAP developed for the facility constitutes a summary of the
recommended actions, whereas a full description is presented in the body of this report on the nature of the
findings, distinguishing between:

Those aspects that could not be verified based on the available information; and

Those areas in which a non-compliance with IFC Performance International Standards or Bangladesh
National Regulations was observed.
This report has been prepared by AECOM for the benefit of its client, Summit and IFC. AECOM's client may release
the information to third parties, who may use and rely upon the information at their discretion. However, any use of
or reliance upon the information by any party shall be solely at the risk of such party and without legal recourse
against AECOM, its parent, its subsidiaries and affiliates; or their respective employees, officers, or directors;
regardless of whether the action in which recovery of damages is sought is based upon contract, tort (including the
sole, concurrent, or other negligence and strict liability of AECOM), statute, or otherwise. This information shall not
be used or relied upon by a party that does not agree to be bound by the above statement.
The EHSS Due Diligence of the KPCL Plants is largely based on the documents made available, and discussions
with stake holder and observations from site walk through undertaken by AECOM professionals during the site visit.
Wherever documentation, policies and procedures for evaluation were not available for review, it has been
highlighted in the report at relevant sections. In addition, wherever AECOM has not been able to make a judgment
or assess any process, it has been highlighted as an information gap and a way forward has been suggested.
1.5
Layout of the Report
This report includes the following sections under each site specific reports:

Section 2: provides a description of each HFO Power plant, its operation and procedures and a review of
compliance status to the reference frame work;

Section 3: reviews the status of compliance of the each facility with respect to the IFC Performance
Standards and applicable reference framework. A consolidated table at the end of Section 3 on summary
of findings is also provided for each report; and

Section 4: provides a consolidated Corrective Action Plan (CAP) based on the gaps for all facilities along
with timeline for completion.
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Site specific reports have been presented in the following sequence:
1.
40 MW Khan Jahan Ali Power Company (KJAPC), Noapara, Jessore
2.
110 MW and 115 MW Khulna Power Company Limited (KPCL), Goalpara, Khulna
May 2016
ENVIRONMENT AND SOCIAL DUE
DILIGENCE
40 MW HFO Based Power Plant of KJAPCL at
Noapara, Jessore, Khulna Division, Bangladesh
May 2016
Prepared for
INTERNATIONAL FINANCE CORPORATION
SUMMIT CORPORATION LIMITED
ESDD as per IFC Sustainability
Framework 40MW Khan Jahan Ali
Plant
Executive Summary ................................................................................................................................................... i
2.0
40 MW Khanjahan Ali Power Company Limited............................................................................................... 6
2.1
Background........................................................................................................................................... 6
2.2
Organisation Structure ........................................................................................................................... 6
2.3
Facility Details ....................................................................................................................................... 7
2.3.1
Process Description ....................................................................................................................... 8
2.3.2
Details of Engine and Specifications ............................................................................................... 9
2.3.3
Utilities and Associated Facilities .................................................................................................. 10
2.3.4
Status of Permits ......................................................................................................................... 12
2.4
2.4.1
Environment ................................................................................................................................ 13
2.4.2
Health and Safety ........................................................................................................................ 15
2.4.3
Social and Stakeholder ................................................................................................................ 15
2.5
3.0
Environment Health, Safety and Social Scenario .................................................................................. 13
Project Categorization ......................................................................................................................... 16
Document Review and Assessment of Compliance ...................................................................................... 17
3.1
Performance Standard (PS) 1: Assessment and Management of Social & Environmental Risks and
Impacts ........................................................................................................................................................... 17
3.1.1
Environment and Social Management System .............................................................................. 17
3.1.2
Policy .......................................................................................................................................... 18
3.1.3
Identification of Risks and Impacts................................................................................................ 18
3.1.4
Management Programs ................................................................................................................ 19
3.1.5
Organizational Capacity and Competency .................................................................................... 20
3.1.6
Emergency Preparedness and Response ..................................................................................... 21
3.1.7
Monitoring and Review ................................................................................................................. 22
3.1.8
Stakeholder Analysis and Engagement Planning .......................................................................... 23
3.1.9
Disclosure of information .............................................................................................................. 24
3.1.10
External Communications and Grievance Mechanisms ................................................................. 24
3.1.11
Status of Compliance to PS-1....................................................................................................... 25
3.1.12
Recommendations ....................................................................................................................... 25
3.1.13
Material Liability ........................................................................................................................... 26
3.2
Performance Standard (PS) 2: Labour and Working Conditions ............................................................ 26
3.2.1
Working Conditions and Management of Worker Relationship ....................................................... 26
3.2.2
Workers’ Organization.................................................................................................................. 28
3.2.3
Non-Discrimination and Equal Opportunity .................................................................................... 28
3.2.4
Retrenchment .............................................................................................................................. 28
3.2.5
Grievance Mechanism ................................................................................................................. 29
3.2.6
Protecting the Work Force ............................................................................................................ 29
3.2.7
Occupational Health and Safety ................................................................................................... 30
3.2.8
Supply Chain ............................................................................................................................... 35
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3.2.9
Status of Compliance to PS-2....................................................................................................... 35
3.2.10
3.2.11
3.3
Performance Standard (PS) 3: Resource Efficiency and Pollution Prevention ........................................ 37
3.3.1
Resource Efficiency ..................................................................................................................... 37
3.3.2
Greenhouse Gases ...................................................................................................................... 38
3.3.3
Pollution Prevention ..................................................................................................................... 38
3.3.4
Hazardous Materials Management ............................................................................................... 41
3.3.5
Status of Compliance with PS-3 ................................................................................................... 42
3.3.6
3.3.7
3.4
Performance Standard (PS) 4: Community Health Safety and Security.................................................. 44
3.4.1
Community Health and Safety ...................................................................................................... 44
3.4.2
Security Personnel ....................................................................................................................... 44
3.4.3
3.4.4
3.4.5
3.5
Performance Standard (PS) 5: Land Acquisition and Involuntary Resettlement ...................................... 45
3.5.1
Land Acquisition .......................................................................................................................... 45
3.5.2
3.5.3
3.5.4
3.6
Performance Standard (PS) 6: Biodiversity Conservation and Sustainable Management of Living
Natural Resources........................................................................................................................................... 46
3.6.1
Biodiversity Conservation ............................................................................................................. 46
3.6.2
3.6.3
3.6.4
3.7
Performance Standard (PS) -7: Indigenous People............................................................................... 47
3.7.1
Avoidance of Adverse Impacts ..................................................................................................... 47
3.7.2
3.7.3
3.7.4
3.8
Performance Standard (PS) - 8: Cultural Heritage ................................................................................ 47
3.8.1
Cultural Heritage .......................................................................................................................... 47
3.8.2
3.8.3
3.8.4
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List of Tables
Table 2-1: Site Setting
Table 2-2: Technical data Wartsila 20V32GD
Table 2-3: Details of Boilers
Table 2-4: Status of Permits
Table 3-1: Fire Equipment
Table 3-2: Safety Training Plan KPCL – Year 2016
Table 3-3: KPCL Emergency Mock Drill Plan for Year 2016
Table 3-4: Safety Statistics for KJAPCL Plant (as on Feb 2016)
Table 3-5: Results of Stack Emission Monitoring (November 2015)
Table 3-6: Ambient Air Quality Monitoring Results (for 24 hourly monitoring period) – Oct to Dec 2015
Table 3-7: Ambient Noise Monitoring Results
Table 3-8: Summary of Key Observations and Recommendations
7
9
12
12
22
32
33
34
39
39
41
49
List of Figures
Figure 2-1: Shareholding Pattern for KPCL
Figure 2-2: Location of the 40 MW Khanjahan Ali Power Plant
Figure 2-3: Process flow Diagram : 40 MW Khanjahan Ali Power Plant
Figure 2-4: Fuel System
Figure 2-5: EMS Organisation Chart, Roles and Responsibilties
Figure 3-1: Organisation Chart- KJAPC
6
8
9
10
15
21
List of Annexures
Annexure A: Photo Log
Annexure B: Air Dispersion Modelling
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Abbreviations
ACGIH
American Conference of Governmental Industrial Hygienists
BIWTA
Bangladesh Inland Water Transport Authority
BLL
Bangladesh Labour Law
BPDB
Bangladesh Power Development Board
COD
Commercial Operation Date
CSR
Corporate Social Responsibility
CIP
Continuous Improvement Plan
dB
Decibel
DM
Demineralization
DMF
Dual Media Filter
EHS&S
Environment Health & Safety and Social
EMF
Electro-Magnetic Field
ESMS
Environmental and Social Management System
EMS
Environment Management System
EPC
Engineering, Procurement and Construction
EPRP
Emergency Preparedness and Response Plan
E&SDD
Environmental & Social Due Diligence
FSS
Falcon Security Services
GHG
Greenhouse Gases
GIIP
Good International Industry Practice
HFO
Heavy Fuel Oil
HIRA
Hazard Identification Risk Assessment
HT
High-temperature
IFC
International Finance Corporation
ILO
International Labour Organization
IPP
Independent Power Producer
IMS
Integrated Management Systems
KJAPCL
Khanjahan Ali Power Company Ltd
KPCL
Khulna Power Company Ltd
LFO
Light Fuel Oil
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LT
Low-temperature
LNG
Liquefied Natural Gas
MW
Megawatt
MR
Management Representative
NGO
Non-Governmental Organization
OH&S
Occupational Health and Safety
OHSAS
Occupational Health and Safety Advisory Services
ORS
Oral Rehydration Supplements
O&M
Operation & Maintenance
PDCA
Plan-Do-Check-Act
PPE
Personal Protection Equipment
PS
Performance Standard
RO
Reverse Osmosis
SPM
Suspended Particulate Matter
TBN
Total base number
UN
United Nations
VIC
Variable Inlet Valve Closure
WB
World Bank
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Executive Summary
Summit Corporation Limited ( hereinafter referred to as ’SCL’) established in 1985, is a holding company sponsoring
its subsidiary companies to own, build and operate infrastructure projects in Power sector. The Group currently
produces around 1,260 MW (including two under commissioning plant), which is around 13% of total capacity of the
country. Summit intends to hold 20% of the country’s generation capacity and has signed an appraisal letter with
International Finance Corporation (IFC) for investment to be made by latter. As per IFC requirements, an
Environmental and Social Due diligence (ESDD) is required to be undertaken for the holding company and individual
assets of Summit. SCL and IFC have thereby engaged AECOM India Private Limited to conduct the ESDD for the
assets being operated and managed by Khanjahan Ali Power Company Ltd. (KJAPCL), which is a subsidiary
company of Khulna Power Company Ltd. (KPCL). KPCL being an independent entity has developed separate
policies and procedures, with SCL having limited authority to take decisions for KPCL operations.
Two AECOM professionals visited the 40 MW HFO based power plant at Noapara, Jessore (hereinafter referred to
as ‘Project’) on 16th March 2016. The ESDD was carried out to assess alignment of SCL’s and KJAPCL’s
Environmental and Social Management System (ESMS) and plant’s EHS performance with respect to Bangladesh
Environmental, Health, Safety and Social regulations, IFC Performance Standards, 2012, The IFC General
Environmental, Health and Safety (“EHS”) Guidelines, dated 2007, IFC Sector EHS Guidelines for Thermal Power
Plants dated 2008 and Power Sector EHS Guidelines for Electric Power Transmission and Distribution dated 2007.
Key observations and findings as part of the Environmental and Social Due Diligence conducted for the Project are
presented below. Detailed observation and recommendations in the form of a Corrective Action Plan has been
presented in subsequent sections of this report.
PS-1: Assessment and Management of Social & Environmental Risks and Impacts
KPCL, including its subsidiaries, has developed an Integrated Management System (IMS) in accordance with the
requirements of ISO 9001:2008 (quality management), ISO 14001: 2004 (environmental management) and BS
OHSAS 18001:2007 (occupational health and safety management) for operation and maintenance of its plants.
Accordingly, Bureau Veritas has granted certification to KPCL (for all three plants) for operation and maintenance of
HFO based power plants including associated activities. KPCL has developed an IMS Manual (dated June 2014 and
subsequently revised), and integrated the standards for compliance and appropriate implementation. KPCL has
developed procedures for identification of EHS risks and impacts and maintained document pertaining to results of
identification of hazards, risk assessments and controls provided.
Overall compliance of the project with PS1 is adequate, however, following non-compliances against IFC PS1 have
been observed during the assessment process.

ESMS: The IMS Manual developed by KPCL is focused on O&M aspects of the plant, however it may be
inadequate in case of any future expansion or additional land requirement, as it does not cover pre
construction and construction stage management. Moreover, the IMS adequately covers environment and
H&S aspects for operation phase, however it does not focus on social aspects.

Identification of risks and impacts: Reportedly, Environmental and Social Impact Assessment study was
not conducted for the plant. Though KPCL has established Environmental Aspect and Impact procedures
for the plant, details on Environment aspect and Impact significance were not available for dredging of river
bed near Jetty area.
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
Organizational Capacity and Competency: There is no dedicated team for implementing environmental
and social management system. KPCL has identified an Environmental Officer and a Safety Officer, which
are additional responsibilities given to Senior Engineers, to handle site specific environmental and H&S
issues for all the plants. The team member identified as Environmental Officer is adequately experienced
but not formally qualified in the subject. Moreover, the plant does not have dedicated staff to engage with
community on regular basis.

Emergency Response: Fire hydrants in the plant were observed as functional, however foam-flooding unit
was not observed at the designated place in the engine room. Boom for Oil spill containment/ Spill kit was
not provided at the unloading area (jetty) of the Jessore facility.

Stakeholder Engagement: KPCL has engaged NGO Paribartan for community development activities.
However all CSR activities are limited to the plants at Khalispur, Khulna and no community welfare works
specific to KJAPC were observed or reported.

External Communications and Grievance Mechanism: The project has not outlined a formal structure /
procedures for information disclosure to the local community on project’s conformance with environmental
compliance requirements and plant’s EHS performance. The existing Grievance redressal mechanism is
informal in nature and does not have well defined escalation levels.
PS-2: Labour and Working Conditions
KPCL has put in place well documented Employment Policy and Procedure Manual (February 2014), which is
separate from that of SCL’s HR Policy and applicable to operations at all three plants. The Policy has been prepared
with the intention of keeping it subservient to the government laws and commits to modification with any change in
legal requirement in future. The employees are made aware of the policy document and terms and conditions.
Occupational health and safety management is adequately covered through the various procedures of IMS.
The project is largely compliant to PS-2, however considerable non-compliances with respect to adherence to
Bangladesh Labour Law (2006) have been observed during the assessment process. These include the following:

Human Resources Policies and Procedures: The Employment Policy Document of KPCL does not
adhere to requirements of Bangladesh Labour Law (2006) on aspects related to notice period for
termination, retirement age of employees, total working hours including overtime hours and calculation of
overtime compensation. The Policy is also silent on the company’s willingness to collective bargaining or
formation of trade unions as per the BLL and non-engagement of child/ forced labour in its operations.
Further, the Policy does not provide procedures to prevent and address harassment, intimidation, and/or
exploitation, especially with regard to women.

Employee grievance management: The grievances reported by employees are not recorded, and in case
of redressal of grievances, the actions taken are not documented in order to track satisfactory closure of
grievances raised.

Contract Worker Management: KJAPCL does not have a mechanism to monitor the adherence of labour
laws on payment of minimum wages, child labour verification and working hours for contract workers
engaged through contractors.

Occupational Health: KPCL does not monitor the occupational health of employees in terms of exposure
to high noise levels, high temperatures and EMF.

Supply Chain Monitoring: Though a supplier verification process exists, it does not provide mechanism to
verify labour aspects including child labour in the primary supply chain.
May 2016
ii
Plant
PS-3: Resource Efficiency and Pollution Prevention
A detailed Environmental Management System, including environmental monitoring, is put in place by KPCL and
implemented through the IMS. KPCL has developed, and maintains register on Environmental Aspects associated
with project operation. Task wise aspects and impacts have been identified at different locations inside the plant
vicinity. The project also undertakes a compliance evaluation with respect to applicable legislation and regulatory
requirements and maintains such records in Legal Compliance Register.
Monitoring of stack emissions, ambient air and ambient noise is conducted by the management at the facility and
quarterly reports are submitted to DoE. Stack emission monitoring is carried out on annual basis by third party. The
stack emission values of Sulphur dioxide and oxides of nitrogen are within the permissible IFC limits, though the
sulphur content in fuel is more than the permissible IFC value of 2%.
An air dispersion modelling exercise using AERMOD 8.1.0 was conducted for the operation of the plant to ascertain
the impact of air emissions from combustion of HFO at existing firing rate. As per the results, maximum incremental
concentration is expected towards the North and north east of the Plant at a distance of 175 - 400 m. The maximum
incremental Ground Level Concentration of PM, SO2 and NOx due to operation of KJAPC is significantly high.
Although the baseline data suggests that the current condition of air shed is non-degraded, the cumulative
contribution of the plant is expected to make the air shed degraded. The details are presented in Annexure B of the
report.
Non-compliances with respect to PS3 as observed during the assessment process include the following:

Resource Efficiency: Groundwater extraction records are not being maintained as the bore well at site is
not metered. Though the management has considered water conservation measures and has installed
rainwater harvesting structures, the tanks were observed as defunct and not under use.

Stack emissions: Particulate matter emissions from all stacks exceed the permissible limits as stipulated
by IFC WB guidelines, though the stack emission monitoring report has not captured this.

Ambient air quality monitoring: The NOx levels monitored for the facility are recorded for 24 hourly
periods and therefore not comparable to permissible standards due to absence of 24-hourly guidelines by
IFC-WB and Bangladesh national standards.

Noise Monitoring: Instantaneous noise level readings in db(A) are recorded for day time and night time
instead of weighted average values, which does not give clear representation of ambient noise quality of the
area. Moreover, although the measured values prescribe to limits for industrial area, with the residential
area in close proximity, the attenuation of noise to residential levels at the households is less likely. Noise
level monitoring through external laboratory is also not conducted for the plant.

Surface water quality monitoring: River water quality is not being monitored by the site management.
Treated water from oily water treatment unit is not analyzed for oil and grease content, prior to discharge
into the river. Further, no records pertaining to discharge quantities are maintained at site.
PS-4: Community Health Safety and Security
The project has established Environmental, Health and Safety aspects associated with emergency preparedness
and response measures as part of its IMS. These procedures identify potential for emergency situations, establish
response mechanism to such emergency situations and prevent / mitigate associated adverse environmental, H&S
and social consequences. However following non-compliances have been identified under PS-4:
May 2016
iii
Plant

Site Specific Emergency Response Plan: Quantitative risks associated with emergencies due to tank fire
and dyke fire scenario for the storage area and identification of potential areas of concern along with
significance of impact in and around the plant vicinity have not been assessed and addressed as part of
Emergency Preparedness and Response plan.

Dissemination of ERP: Though the local community is encouraged to participate in emergency and fire
mock drills, no formal communication or dissemination of information regarding ERP to the community was
observed to have been undertaken by KJAPCL.
PS-5: Land Acquisition and Involuntary Resettlement
The plant is located on 3.5 acres of land leased to KJAPC by BPDB. It is understood from the review of past satellite
imagery (2004) that the land was used for agricultural purpose prior to development of the power plant. In addition,
there are no structures or encroachments visible in past imageries. The acquisition of land was reportedly
undertaken by BPDB prior to 2010 and was later leased to the company through execution of the lease deed,
however the year of procurement is not known.Further, no details were available with KJAPC on the past ownership
of the site. Based on the media search and discussions with the plant management it is understood that there are no
litigations regarding the ownership of this land. As per discussions with site management, there were no outstanding
claims on the land, for compensation or loss of livelihood.
The status of compliance of the project to the requirements of PS-5 could not be established due to unavailability of
details pertaining to past land ownership and compensation or loss of livelihood. However, based on current
assessment and discussions with site management, it is understood that the project is compliant to the requirements
of PS-5.
PS-6: Biodiversity Conservation and Sustainable Management of Living Natural Resources
The project is located in an urban set up in Noapara, Jessore. The area is largely commercial with no identified
significant natural vegetation. There are no legally protected areas or critical habitats reported within 5km radius from
the plant. The River Bhairab is an ecologically important river in the area. River Bhairab has been in news for high
pollution levels in June 2015 wherein fishes of different species were seen floating dead in the river near Noapara
industrial area, the reason was attributed to high pollution levels in water. However, the KJAPC plant does not make
any significant discharges to the river. As the plant utilizes radiator based cooling system, no thermal discharges are
released into the river.
With respect to observations gathered on PS-6, it is understood that the project is compliant to PS-6, except that it
does not assess the quality of discharge to ensure insignificant impacts on receiving water body.
PS-7: Indigenous People
Based on the review of secondary literature, it is understood that the indigenous peoples of Bangladesh refer to
native ethnic minorities in Chittagong Hill Tracts, Sylhet Division, Rajshahi Division and Mymensingh District. The
project district Jessore as well as the Noapara area has not reported presence of any indigenous community. The
land on which the project is developed has been leased to KJAPC by BPDB. Since past ownership details are not
available for review, presence of IPs on the specific piece of land cannot be commented upon. However from
discussions with site management and review of secondary information, the project area does not report presence of
IPs. Hence it can be inferred that the project is compliant to the requirements of PS-7.
May 2016
iv
Plant
PS-8: Cultural Heritage
The western boundary of the plant is aligned along a graveyard, which has local religious significance, however the
operations of plant has no interference with it. In addition, no grievance pertaining to the same was observed during
discussions. Besides the graveyard, the site or its surroundings do not have any structure of cultural importance. No
tangible or intangible site, structure or custom of cultural importance was observed during the site visit and
secondary data review. Therefore, the project is compliant to the requirements of PS-8.
Project Categorization
The project is categorized as Category B, based on the review of documents and on-site assessment of
environmental and social aspects. The categorization is based on the following observations (which are detailed in
the subsequent sections of the report):

The project land was acquired by BPDB and subsequently leased to the project. The site was a suitable
location adjacent to existing switchyard of BPDB and no resettlement of residents was required. The area
around the site is largely commercial mostly warehousing facilities and commercial storages for bulk goods.

The project has opted for radiator cooling thereby reducing any impact on water resources as well as
ensured minimal discharge to river.

The plant being an engine based power plant requires optimal tuning and adequate maintenance to ensure
compliance to emission levels. The existing GLC levels observed are high however by maintaining
appropriate air to fuel ratio and injection timing retard; it is observed that the existing impact is largely
reversible.
Areas of improvement have been identified and corrective actions have been provided in Section 4.0.
May 2016
v
ESDD Report as per IFC Sustainability
Plant
6
2.0 40 MW Khanjahan Ali Power Company Limited
2.1
Background
Khanjahan Ali Power Company Ltd. (KJAPCL) was formed on July 19, 2010 for setting up of 40 MW power plant
under a contract with Bangladesh Power Development Board (BPDB) signed on July 25, 2010 for supplying
electricity on rental basis initially for 5 years with a provision for extension of terms for a further period of minimum 5
years. The 90% shares of KJAPCL are owned by KPCL1. The plant is located at Noapara, Jessore. The plant
achieved Commercial Operation Date (COD) on May 29, 2011 and since then it has been supplying electricity to the
national grid.
It has Heavy Fuel Oil (HFO) fired five (5) Wärtsilä Finland 20V32 engines of capacity 8.9 MW each, which produce a
combined output of 40 MW. The facility comprises of 33/11 KV electrical substations and complete fuel oil handling
facilities with fuel tanks along with the main plant and machinery. The project cost was US$25 million and the total
EPC works was accomplished by Neptune Commercial Ltd (NCL), a subsidiary of United Group. The KJAPCL was
amalgamated with KPCL from September 30, 2014. Prior to which the plant was being operated and maintained by
Wärtsilä Bangladesh Ltd., a 100% owned subsidiary of Wärtsilä OY, Finland; the manufacturer and EPC contractor
of these plants under a long term O&M Agreement. As of now, these plants are being operated and maintained by
the companies itself with full sets of experienced engineers and staff as engaged earlier.
2.2
Organisation Structure
Khulna Power Company Ltd. (KPCL) is the first Independent Power Producer (IPP) in the country, established under
the Private Sector Power Generation Policy of Bangladesh. The KJAPCL is a subsidiary of Khulna Power Company
Limited. The current shareholding pattern of KPCL is as provided:

United Enterprises &
Company limited:
35.28%

Summit Industrial &
Mercantile Corporation
(Pvt.) Limited : 17.64%

Summit Power Limited :
17.64%

Other Sponsors: 0.02%

General Investors:
29.41%
The Managing Director of KPCL is the final approver of all decision making. The Managing Director is the Head of
the subsidiary, who along with the Asset Manager and the Financial Controller maintain their office at Dhaka. The
1
KPCL Project was initially sponsored by Summit Group and United Group along with their foreign partner El Paso Corporation (El Paso), USA, one
of the world’s largest and most diversified natural gas exploration and pipeline companies and Wärtsilä Corporation (Wärtsilä), Finland, a leading
power plant manufacturer of the world. In 2008, El Paso, as part of its global repositioning strategy disposed of its shares in KPCL to Summit Group
and United Group. Later in 2009 Wärtsilä’s share was also acquired by Summit and United. Khulna Power Company Ltd. has two subsidiary
companies named as: i) Khulna Power Company Unit II Ltd.; and ii) Khanjahan Ali Power Company Ltd.
May 2016
Plant
7
Plant Manager sitting at site office is responsible for O & M activities of the plant. The KJAPC plant has 30 staff
members with twelve (12) in Operations and eighteen (18) in Maintenance.
2.3
Facility Details
The plant is located in the Noapara village, Jessore district, Khulna division of Bangladesh. The facility is spread over
an area of 3.5 Acres and comprises of 05 units of 8.9MW ([20V-32DG] Reciprocating type) Wartsila engines. The
installed capacity of the unit is 44.5 MW while the Guaranteed Capacity is 40 MW. The HFO based plant became
th
commercially operational (COD) on the 29 of May 2011.
The site setting and details of its surroundings are provided as per Table 2-1.
Table 2-1: Site Setting
Direction to Plant
Features
North
To the North, North West is a Warehouse,
which extends for another 200m. To the
North east is River Bhairab
West
All along West is residential area with a
graveyard immediately close to site. The
residential area is about 100m from the
gate,
South
To the south is the BPDB switchyard
followed by another warehouse further
south.
East
Towards the east is Bhairab River
The location of the plant along Bhairab River is illustrated in the Figure 2.2.
May 2016
Plant
8
Figure 2-2: Location of the 40 MW Khanjahan Ali Power Plant
2.3.1
Process Description
The general process involved in the operation at the KJAPC is summarised in the flow diagram given in Figure 2.3.
The plant operates on Heavy Fuel Oil (HFO), which is received at a permanents Jetty on Bhairab River along the
3
North-eastern boundary of the plant. The fuel is transferred and stored in two onshore storage tanks with 915 m and
3
1500 m each, located towards the North of the facility.
Transfer pumps are used to transfer the fuel to buffer tanks maintained at 60°C, to enable settling of impurities. The
fuel is then passed through booster unit for Boosting HFO to Engines through filters and pumps. The fuel is then
pumped into engine cylinder at a pressure of 600-500 bars. A total of 5 diesel engines with ABB generators produce
electricity at an installed capacity of 8.8 MW each. The 11kV voltage generated is then stepped up by the
transformers and evacuated to Regional Electricity Board via 33 KV line.
May 2016
Plant
9
Figure 2-3: Process flow Diagram : 40 MW Khanjahan Ali Power Plant
2.3.2
Details of Engine and Specifications
The plant is based on reciprocating engines with five [20V-32DG] Reciprocating type engines of Wartsila –Finland
make. It has a modular structure and consists of multiple parallel engine-generator sets with an output of 8.9 MW
each (installed capacity). Modules are mutually independent from functional point of view, their only common
systems are fuel supply system, switchgear and transformer station, and other systems used to top-up process
media. All electrical, automation, cooling and exhaust systems are engine-specific, thus improving general reliability
of the plant.
The Wartsila 32 is equipped with a Variable Inlet Valve Closure (VIC) unit. This makes it possible to apply early inlet
valve closure at high load, which in turn enables minimized NOx levels and reduced fuel consumption. By switching
to late inlet valve closure, good part load and transient performance is assured. The overall operational benefits
include improved part load performance, smoke reduction, and improved load acceptance. The engine control
system incorporates automatic monitoring and control for optimal operating efficiency.
Table 2-2: Technical data Wartsila 20V32GD
S. No.
Aspect
Unit
Value
50 Hz/ 750 rpm- 20V32GD
1.
Power, electrical
MW
8.9
3
Heat rate
kJ/kWh
8049
4
Electrical efficiency
%
44.7
5
Length
mm
12890
6
Width
mm
3300
7
Height
mm
4440
8
Weight (Dry weight)
tonnes
130
May 2016
Plant
2.3.3
10
Utilities and Associated Facilities
The plant comprises of following facilities:
Fuel Storage and HFO separator
Heavy fuel oil (HFO) for plant is procured from Summit Asia Pacific Pte Ltd. The fuel is supplied through oil tankers
via River Bhairab up to the jetty. The fuel received is highly viscous, having viscosity of 180 cSt at 50°C and a
maximum Sulphur content of 3.5%. The fuel is received from the oil tankers and pumped into two HFO storage tanks
3
3
of 915 m and 1500 m capacity each. Besides HFO storage tanks the fuel storage area comprises a HFO buffer
tank (Capacity 80 m 3), Sludge tank (Capacity 50m3), used Lube Oil tank (Capacity 10m 3), new Lube Oil tank
3
3
(Capacity 20m ), HFO day tank (Capacity 300 m ) and LFO tank. The tank farm area is provided with a secondary
containment (2.9m high) and is connected to the oil water separation tank.
The HFO contains a large amount of impurities and it has to be purified before it can be used, hence it is passed
through a HFO separator (2 units) which uses a centrifugal action to clean the fuel off impurities. HFO separator is a
mechanical device which is used to separate unwanted liquid and solid particle from HFO. HFO separator works on
the basis of centrifugal force. This centrifugal force generated by the rotation of the bowl (rotor). When liquid or
particles of different specific gravity enters to the bowl, the different centrifugal force acts on them. Liquid or particle
having higher specific gravity faces higher centrifugal force and moves away from the Centre. So heavier liquid and
particles move toward the periphery of the bowl and collect into sludge space. This heavier liquid and particles are
known as sludge which is discharged from the bowl by opening sludge port.
The fuel is then stored in a HFO day tank. The HFO day tank contains clean purified fuel ready for use. The sludge
from the HFO separator is collected in a sludge tank and sent for treatment. The HFO feeder pump pumps the fuel to
the HFO booster unit at a pressure of around 4 to 5 bar. From here, fuel passes to the fuel oil unit and finally to the
engine.
The fuel system is the most important auxiliary system of an engine, the fuel being the most necessary criterion for
the engine to function. The outline of fuel system is provided in Figure 2.4.
Figure 2-4: Fuel System
1. Unloading pump, 2. HFO storage tank, 3.HFO transfer pump, 4. HFO buffer tank, 5. HFO separator, 6. HFO day
tank, 7. HFO feeder pump, 8. HFO booster unit, 9. Fuel oil unit, 10. Diesel engine, 11. Storage tank
Lubricating Oil System
All Wartsila 32 engines are equipped with a complete lube oil system, i.e. an engine-driven main pump, electrically
driven pre-lubricating pump, cooler, full flow filter and centrifugal filter. This system ensures lubrication of the engine
parts. Lubricating oil used at KJAPC is Petronas and is of grade SAE 40. It also serves as the coolant for the engine.
Lubricating oil is stored in the sump of the engine.
May 2016
Plant
11
The normal working temperature of lubricating oil is 60 - 70°C. The quality of lubricating oil is determined by TBN
(Total base number) value, which is 40 for fresh lubricating oil. As the lubricating oil passes through the engine parts,
impurities and suspended particles get mixed with it, this reduces the quality of the oil. As a result, the lubricant oil
has to be filtered from time to time. The lube oil filtration is based on an automatic back-flushing filter requiring
minimum maintenance. The filter elements are made of seamless sleeve fabric with high temperature resistance.
Pumps are provided to control the flow of lubricating oil in the engine. The pre-lubricating pump ensures that there is
sufficient lubricating oil pressure when the engine is started. Another pump maintains the flow of lubricating oil when
the engine is running. If the temperature of the lubricating oil exceeds 54°C a three way valve redirects the oil flow
through a low temperature cooling system.
Cooling System
The cooling system is split into two separate circuits, the high-temperature (HT) and the low-temperature (LT)
circuits. The cylinder liner and the cylinder head temperatures are controlled through the HT circuit. The system
temperature is kept at a high level, about 95 °C, for safe ignition/combustion of low-quality heavy fuels, also at low
loads. An additional advantage is maximum heat recovery and total efficiency in cogeneration plants. To further
increase the recoverable heat from this circuit it is connected to the high-temperature part of the double-stage charge
air cooler.
The HT water pump and thermostatic valve are integrated with the pump cover module at the free end of the engine.
The complete HT circuit is thus virtually free of pipes. HT cooling is mainly used for cooling of engine parts. HT water
is maintained at temperature of about 70 to 95°C, when temperature of water falls below the required limit, a three
way valve operates and water flows through a temperature maintaining device. This device maintains the required
temperature with the help of steam from the steam system.
The LT circuit serves the low-temperature part of the charge air cooler and the built-on lube oil cooler. It is fully
integrated with engine parts such as the LT water pump with pump cover module, the LT thermostatic valve with the
lube oil module and transfer channels in the engine block. Low temperature cooling system is used for cooling parts
whose operating temperatures are low. LT system is used for the cooling of lubricating oil. Here water is maintained
at a temperature of 40 to 50°C. A three way valve operates when the temperature falls below the present value, and
directs the flow of water to a healer to maintain the temperature.
Demineralizing Plant
Water used in the plant has to be free from minerals, harmful chemicals to avoid corrosion. The dematerialized water
from the DM plant is mainly supplied to the boiler and floor use.
Demineralization is done using the principle of reverse osmosis. Firstly it is passed through dual media filter
(DMF).The output of this unit is fed to cartridge filter in which particle sized up to 10 microns are sieved out. From
cartridge filter water is passed through softener which contains resins. Water is then fed to the Reverse Osmosis
(RO) unit for reverse osmosis. The DM water is stored in a storage tank from which it is supplied to the necessary
units.
Boilers
The plant has three boilers (including one auxiliary) which recover heat from the engine cooling water system. The
details of the boilers are as provided below:
May 2016
Plant
12
Table 2-3: Details of Boilers
S.No
Boiler Number
Boiler Rating
Pressure (bars)
1
BB: 7114
3529
10
2
BB: 7115
3529
10
3
BB: 7116
117
10
The steam generated is used for pre-heating of HFO to ensure reduction in viscosity of the fuel.
Jetty
The only associated facility is a wooden jetty extended upto Bhairab River along the North eastern boundary. The
jetty is provided with hose pipe to draw oil from supply tankers with the help of a pump dedicated for unloading.
Transmission Lines
Power is evacuated at the BPDB substation adjacent to the facility towards south west. Hence transmission lines
have not been set up as part of the project.
2.3.4
Status of Permits
The plant has obtained following consents and approvals from various government agencies:
S. No.
1.
2.
Law
Status
Validity
Remarks
Valid till August 24,
2016
The Environment
Conservation Rules
1997/01-04-2003
 Environmental clearance
The Factories Rules, 1979
 Factory License (No. 352)
 Valid for 2016-17
All contractors of KPCL
also have valid
clearance as detailed
below
 Abdullah Traders:
valid till October 15,
2016
 Joint Fuel: valid
upto December 30,
2016
 Tur Traders: Valid
up to December 21,
2016
--
 Factory Inspector’s
certificate for Lifting
devices and pressure
vessels for a year
 Registration of Boilers
7114-16, Number D-922016(4) 76-78
 Certificate from Asstt.
Director, Fire service &
civil defence, Khulna
 License from Explosive
Inspector for fuel storage
 Valid upto January
28, 2017
--
 Valid upto July 10,
2016
--
 Valid upto June 30,
2016
--
 Certificate/License
 Valid upto March
3.
The Boilers Act, 1923
4.
Fire Prevention & Dosing
Act – 2003
5.
Petroleum Act, 1937
6.
Energy Regulatory
Commission Act 2003;
Energy regulatory
commission License
certificate, which also
prescribes need for
approved vendors for
Hazardous waste
management
 Valid upto
December 31, 2015
09, 2016
Application has been
filed for renewal of
license
Application has been
filed for renewal of
license
May 2016
Plant
S. No.
Law
Status
Validity
13
Remarks
regulation 2006
2.4
7.
Power purchase/ Rental
Agreement with BPDB
 Contract no 09766 date
25.07.10
 Valid upto May 28,
2016
Process has started for
extension of agreement
8.
Insurance with Pragati
Insurance Ltd. as per
Laws of Bangladesh
 Policy no PIL/HO/PPPI/P0134/06/2013
 Valid upto June 19,
2016
--
Environment Health, Safety and Social Scenario
The company is certified by Bureau Veritas on plant operation and maintenance guided by Integrated Management
Systems (IMS) complying with three International standards - ISO 9001:2008 for Quality, ISO 14001: 2004 for
environment and British Standards (BS) OH&S 18001:2007 for occupational health and safety.
2.4.1
Environment
The operations of KPCL are guided by the IMS manual, which includes the requirements under ISO 14001:2004, the
same is applicable to Khan Jahan Ali Power Company. Khulna Power Company as part of its Operations &
Maintenance has established, documented, implemented and maintained an Environmental management system
with thirteen mandatory procedures to meet ISO 14001:2004 requirements by establishing an Environmental
management program (Plan-Do-Check-Act principle) as part of the Integrated Management System.
The company has formulated an Integrated Management System (IMS) Policy which provides for following
commitments on environmental management:

Support for conservation of the physical environment and the prevention of pollution at the facilities.

Proactively comply with all applicable safety, environmental, legal and regulatory requirements to which it
subscribes.
KPCL has established and employed metrics that are used to measure its performance against core objectives that
cover operational parameters such as health and safety, quality, the environment, materials management, and
customer satisfaction. KPCL subscribes to continual improvement by monitoring its objectives through internal
auditing, analyzing data, reviewing performance and implementing corrective and preventive actions.
The key procedures maintained at KPCL (applicable to KJAPC also) are:


Planning
o
Environmental Aspects
o
Legal and other requirements
o
Objectives, Targets and Programs
Implementation and Operation
o
Resources, Roles, Responsibility and Authority
o
Competence, Training & Awareness
o
Communication
o
Documentation
o
Control of Documents
May 2016
Plant

o
Operational Control
o
Emergency preparedness and response
14
Checking
o
Monitoring and measurement
o
Evaluation of compliance
o
Nonconformity, Corrective and preventive action
o
Control of records
o
Internal Audit
o
Management Review
KPCL has identified key staff members and their responsibilities towards implementation of requirements of the
Environment Management. At the company level all plants are headed by the Chairman Mr. Hassan Mahmood Raja,
along with Mr. Abdur Rahim, Managing Director and Mr. AMM Atiqul Islam, Asset Manager. The KJAPC at the plant
level is headed by the Plant Manager, Mr. Sreenath Acharaya.
The Managing Director also has the additional responsibility of being the Environmental Coordinator at the Company
level, while the plant manager is responsible for development planning and implementation of the EMS Manual as
Management Representative (MR), besides conducting training and internal audits.
A Management Team under the Plant Manager reviews the Environment Management System and its
implementation. The Environment Officer identified under the Plant Manager also functions as the operative EMS
Advisor and is responsible for monitoring and reporting of environmental aspect. The Environmental Officer is also
responsible for implementation, verification of equipment and trainings on Emergency Preparedness and Response.
A technician identified under the Environmental Officer is responsible for environmental monitoring.
The Logistics Officer under the Plant Manager is responsible for waste disposal management, while the
Administration Manager is responsible for
implementing the EMS training matrix. The Figure 2.5 depicts the
organization chart with roles and responsibilities for EMS implementation.
May 2016
Plant
15
All Managers are responsible for operative implementation of EMS plan to their respective department, develop
procedure and train personnel.
2.4.2
Health and Safety
Khulna Power Company has established, documented, implemented and maintained an OHSAS Management
system with thirteen mandatory procedures to meet BS OHSAS 18001:2007 requirements on Plan -Do-Check-Act
principle as part of the Integrated Management System.
The OHSAS program includes HIRA, Bio-Safety checklist update prior to each activity as applicable aiming to
achieve Zero injury target, Personal Protective Equipment (PPE), First Aid, Intake of oral rehydration salts (ORS)
against dehydration and medical check-up as required. Factory Inspector’s endorsement on hazardous equipment
and tools maintenance and other controls meet safety requirements.
The IMS Policy established by KPCL management demonstrates the company’s commitment towards health &
safety by ensuring that it:

is appropriate to the purpose of the organization, including the nature and scale of its OH&S risks,

includes a commitment to meet customer requirements, prevention of pollution, injury and ill health and
continual improvement in IMS management performance and

provide a framework for establishing and reviewing IMS objectives,

is communicated to all persons working under the control of and for the organization with the intent that they
are made aware of their individual quality and /or EHS obligations, and

2.4.3
is reviewed periodically to ensure that it remains relevant and appropriate to the organization
Social and Stakeholder
The plant in general has very limited direct exposure to the neighboring community as it is surrounded by a private
godown in the north, graveyard in the east and BPDB switchyard towards the south. The river in the west has very
limited fishing activities. The nearest community is towards the west and is at about 100 m from the plant. KPCL has
May 2016
Plant
16
identified CSR programs planned with an NGO Paribartan which works for skill development, Health Care and
Education. All CSR activities involve community dialogues, focused group discussions with various stakeholders
including NGOs, Local Community, and Government. However, the CSR activities are limited to KPC plants in
Khulna and no CSR activity focused specifically for KJAPC is reported or documented.
2.5
The project is categorized as Category B, based on the review of documents and on-site assessment of
environmental and social aspects. The categorization is based on the following observations (which are detailed in
the subsequent sections):

The project land was acquired by BPDB and subsequently leased to the project. The site was a suitable
location adjacent to existing switchyard of BPDB and no resettlement of residents was required. The area
around the site is largely commercial mostly warehousing facilities and commercial storages for bulk goods.

The project opted for radiator cooling thereby reducing any impact on water resources as well as ensured
minimal discharge to river.

The plant being an engine based power plant requires optimal tuning and adequate maintenance to ensure
compliance to emission levels. The existing GLC levels observed are high however by maintaining
appropriate air to fuel ratio and injection timing retard; it is observed that the existing impact is largely
reversible.
May 2016
Plant
17
3.0 Document Review and Assessment of Compliance
This section details the compliance of the project with respect to requirements under IFC Sustainability Framework
and applicable national and local regulations. The observations made during the due diligence and gaps identified
are discussed herewith.
3.1
Performance Standard (PS) 1: Assessment and Management of Social &
Environmental Risks and Impacts
3.1.1
Environment and Social Management System
Requirement -1
Performance Standard 1 emphasizes on the need of an effective Environmental and Social Management System
(ESMS) focusing on dynamic and continuous process initiated and supported by management, and involves
engagement between the client, its workers, local communities directly affected by the project (the Affected
Communities) and, where appropriate, other stakeholders.
The client, in coordination with other responsible government agencies and third parties as appropriate, will conduct
a process of environmental and social assessment, and establish and maintain an ESMS appropriate to the nature
and scale of the project and commensurate with the level of its environmental and social risks and impacts. The
ESMS will incorporate the following elements: (i) policy; (ii) identification of risks and impacts;
(iii) management programs; (iv) organizational capacity and competency; (v) emergency preparedness and
response; (vi) stakeholder engagement; and (vii) monitoring and review.
Observation 1
KPCL and its subsidiaries (which include KJAPC) have adopted Integrated management systems ISO 9001, ISO
14001 & BS OHSAS 18001 for quality, environment and health and safety respectively and integrated the standards
for compliance and appropriate implementation.
The Integrated Management System was reviewed as part of the assessment and the observations are presented
below:

The management system is focused on Operation & Maintenance aspect of the project, which is adequate
as the project is in operational stage, however it may be inadequate in case of any future expansion or
additional land requirement as it does not cover pre construction and construction stage management.

The IMS has identified sixteen (16) core procedures on quality, environment, health and safety which
covers the following aspects for management:
o
Processes needed for environmental & OHS management system and their application throughout
the organization.
o
Sequence and interaction of these processes are determined
o
Criteria and methods needed to ensure that both operation and control of these processes are
effectively determined
o
Availability of necessary resources and information to support the operation and monitoring of
these processes is ensured.

o
The processes are monitored, measured and analyzed and
o
Actions are implemented to achieve planned results and continual improvement of the processes.
It is observed that the three-tier document adequately covers the requirement for Environmental and
Occupational Health and Safety; however, the management system does not focus on social aspects.
May 2016
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18
The team member identified as Environmental Officer is adequately experienced but not formally qualified in
the subject.
3.1.2
Policy
Requirement 2
The client will establish an overarching policy defining the environmental and social objectives and principles that
guide the project to achieve sound environmental and social performance. The policy should reflect the client’s
philosophy regarding management of environmental and social risks and impacts, and include specific objectives
and aspirations the client has set in regard to its environmental and social performance, consistent with applicable
Performance Standards.
Observations 2
It is observed that the IMS policy is consistent with the principles of the Performance Standards and expresses
commitment towards:

supporting the communities within which KPCL operate and in the practice of social responsibility

conservation of the physical environment and the prevention of pollution at all facilities

measuring performance against core objectives that cover operational parameters such as health and
safety, quality, the environment, materials management, and customer satisfaction.

continually improving effectiveness and efficiency by monitoring objectives through internal auditing,
analyzing data, reviewing performance and implementing corrective and preventive actions

developing competent human resources, enhancing personnel skill through review and actively pursuing
appropriate training policy
The policy is signed by the Management Representative (Plant Manager) and the Managing Director. It is well
communicated to the employees and is displayed at various places within the facility.
3.1.3
Identification of Risks and Impacts
Requirement 3
The client will establish and maintain a process for identifying the environmental and social risks and impacts of the
project. The type, scale, and location of the project guide the scope and level of effort devoted to the risks and
impacts identification process. When the project involves existing assets, environmental and/or social audits or
risk/hazard assessments can be appropriate and sufficient to identify risks and impacts.
Observations 3
It is reported that no ESIA or IEE study was conducted for the Jessore plant. DoE granted clearance to the Jessore
plant based on the successful operation of KPCL’s other plants.
Hazard Identification Risk Assessment (HIRA)
The plant has developed procedure for the ongoing identification of hazards, the assessment of risks and the
implementation of necessary control measures as part of Hazard Identification and Risk Assessment (HIRA). These
include:

Routine and non-routine activities of all personnel having access to the workplace (including subcontractors
and visitors)

Facilities at the workplace
May 2016
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19

Human behavior, capabilities and other human factors

Identifying hazards originating outside the workplace that can adversely affect health & safety of persons
under KPCL

Hazards created in the vicinity of the workplace by work related activities

Infrastructure, equipment and materials at the workplace

Modifications to the OH&S management system, including temporary changes and their impacts on
operations, processes and activities

Any applicable legal obligations relating to risk assessment and implementation of necessary controls

The design of work areas, processes, installations, machinery/equipment, operating procedures and work
organization, including their adaption to human capabilities
KPCL has maintained document pertaining to results of identification of hazards, risk assessments and controls
provided. Documents pertaining to HIRA of Operation, Maintenance Bunkering, Logistics and Administration were
reviewed as part of the site assessment and were observed to be in order.
Environmental Aspect and Impact
Environmental Aspect and Impact procedure has been established and procedures are maintained for:

Identification of the environmental aspects of activities, products and services within the defined scope of
environmental management system that it can control and those it can influence taking into account
planned or new developments, or new or modified activities, products and services and

Determination of those aspects that have or can have significant impact(s) on the environment (i.e.
significant environmental aspects)

Significant environmental aspects are taken into account in establishing, implementing and maintaining the
environmental management system.
It was observed during the site visit that dredging of river bed near Jetty area to improve berthing of loaded fuel ships
was proposed to be undertaken by external contractor. The BIWTA permission for the same was obtained, however
details of Environment aspect and Impact significance were not available for this activity.
3.1.4
Management Programs
Requirement 4
Consistent with the client’s policy and the objectives and principles described therein, the client will establish
management programs that, in sum, will describe mitigation and performance improvement measures and actions
that address the identified environmental and social risks and impacts of the project. As part of the management
program, the client may wish to establish its own internal performance measures to enhance positive impacts and
the desired outcomes as measurable events to the extent possible. These include measures such as performance
indicators, targets, or acceptance criteria that can be tracked over defined time periods, to ensure continuous
improvement of performance in these areas.
Observations 4
The plant follows the requirement of continual improvement and every year targets are identified for environment,
health & safety, as well as energy conservation aspects besides those related to improvement of production.
A corrective action program is maintained to investigate the cause of non-conformances and to prevent subsequent
recurrences. Documented procedures exist for:

reviewing nonconformities (including customer complaints)
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
20
investigating nonconformities, accidents, incidents, determining the causes of non-conformities and taking
actions in order to avoid recurrence,

evaluating the need for action to prevent nonconformities and implementing appropriate actions designed to
avoid recurrence

determining and implementing action needed

records of the results of action taken

identify opportunities for continual improvement

communicate the results of investigation

Reviewing corrective action taken.

The results of incident investigations shall be documented & maintained.
A preventive action program is maintained to analyze and eliminate the potential causes of non-conformities in order
to prevent their occurrence. Documented procedures exist for:

Determining the potential nonconformities and their causes

Evaluating the need for action to prevent occurrence of non-conformities

Determining and implementing action needed

Records of the results of action taken and

Reviewing the effectiveness of the preventive action taken.
The Continual Improvement targets for the year was observed as part of IMS objective, it included training on Safety,
reduction of consumables (lube oil) over last year, reduction of hazardous waste (rag consumption, used in cleaning
of oil, grease etc.), reduction in paper consumption, and reduction in chemical consumption. It was observed that
new actions were identified from time to time and implemented in a time bound manner. The follow up and
documentation was found to be robust.
3.1.5
Organizational Capacity and Competency
Requirement 5
The client, in collaboration with appropriate and relevant third parties, will establish, maintain, and strengthen as
necessary an organizational structure that defines roles, responsibilities, and authority to implement the ESMS.
Specific personnel, including management representative(s), with clear lines of responsibility and authority should be
designated.
Observation 5
The organization structure for O&M of KJAPC is as provided in Figure 3.1.
KJAPC does not have specific team for implementing the ESMS, the operations and maintenance team members
are provided with additional responsibility of Environment, Health & safety. The IMS has identified an Environmental
Officer, which is an additional responsibility given to a Senior Engineer. However all Managers are responsible for
operative implementation of EMS plan to their respective department, develop procedure and train personnel. With
respect to OH&S, a Safety Officer has been identified for monitoring and management of site specific safety issues
while all department heads are responsible for hazard identification, departmental risk assessment and execution of
OH&S related activities.
Being an ISO certified company the roles and responsibilities of EHS function are executed as per the standard
procedures laid out by the IMS, but it is observed that there is no dedicated staff for community liaison.
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21
Figure 3-1: Organisation Chart- KJAPC
3.1.6
Emergency Preparedness and Response
Requirement 6
Where the project involves specifically identified physical elements, aspects and facilities that are likely to generate
impacts, the ESMS will establish and maintain an emergency preparedness and response system to respond to
accidental and emergency situations associated with the project in a manner appropriate to prevent and mitigate any
harm to people and/or the environment.
Observation 6
KPCL has an Emergency Preparedness and Response Plan (EPRP) applicable to all the three plants. It applies to
the following possible emergencies such as Fire Incidents, Spillage, Explosions, Natural calamities, Crisis
Management, Man overboard in case of barges & Jetties, Fatal Human Injury etc. which may directly affect the
environment, personnel safety or the quality of operation and maintenance activities and status of equipment
intended for generating and supplying electrical power. However, the plant has HFO and LFO storage facility within
its boundary, however no risk assessment study has been conducted to understand tank fire and dyke fire scenario
for the storage area. This has been discussed in detail under PS-4, Section 3.4.1.

KPCL has procedures for training of the emergency response teams. The responsibility, authority and
duties of personnel with specific roles during emergency are defined and documented. KPCL has
procedures for training of the emergency response teams.

All personnel are trained in fire prevention, fire safety and firefighting. Mock drills on fire, spillage, victim
rescue are conducted on regular basis, records for which were verified.

Emergency equipment needs are identified, and tested at specified intervals for continuing operability. The
following details are maintained:
o
List of equipment for firefighting
o
Layout and location drawing for fire fighters
o
List of equipment for Spillage handling and other emergencies
o
List of Alarm systems
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
o
Emergency lighting and power
o
Critical isolation valves, switches and cut-outs
o
First-aid equipment (including emergency showers, eyewash stations, etc.)
o
Communication facilities.(Call points, Sirens, Horns, Telephone, Transport)
22
Emergency equipment and facilities (e.g., first aid stations, firefighting equipment, personal protection
equipment for the emergency response teams) were observed as available at the site.

KPCL has also formulated a procedure on Fire Prevention and Extinguisher System, which provides
guidance to ensure that the firefighting systems are operational and fully tested and employees are aware
of fire prevention methods to minimize the fire related risks and hazards at plant.

Adequate arrangement of fire extinguishers was observed within the facility and they were verified as
recently inspected. The list of equipment include:
Table 3-1: Fire Equipment
S. No.

Equipment
Type
Quantity
1.
Portable Extinguisher (5Kg)
CO2
21
2.
Trolley Type Extinguisher (25kg)
6
3.
Portable Extinguisher (6Kg)
4.
Foam Trolley (45 Ltrs)
Dry Controlled Powder
(DCP)
Dry Controlled Powder
(DCP)
Foam
5.
CO2 Flooding System (16 x 45 Kg)
Fixed
1 set
6.
Piller Hydrant with Hose and Box
Water
5
7.
Fire Hydrant with Hose and Box
Water
5
8.
Fire Brigade Connection
Water
1
12
2
Fire hydrants were observed as functional, however foam-flooding unit was not observed at the designated
place. Manual call points, Fire alarm, smoke detectors and heat detectors were also observed at the site.

Emergency contacts details were displayed at key locations in the plant. Evacuation Plan was displayed at
various places and safe assembly area, free from obstruction, was noted near the entrance gate.

KPCL has also developed an Oil Spill Response Plan outlining procedures to be followed in case of any
accidental spillage. Boom for Oil spill containment/ Spill kit was not provided at the unloading area (jetty). It
was conveyed during discussion that there is no boom available at Jessore facility.
3.1.7
Monitoring and Review
Requirement 7
The client will establish procedures to monitor and measure the effectiveness of the management program, as well
as compliance with any related legal and/or contractual obligations and regulatory requirements. In addition to
recording information to track performance and establishing relevant operational controls, the client should use
dynamic mechanisms, such as internal inspections and audits, where relevant, to verify compliance and progress
toward the desired outcomes.
Observation 7
KPCL for operation and maintenance of its plants plans and implements the checking, measurement, analysis and
improvement processes needed to ensure conformity of the IMS that includes EHS requirements. KJAPC in
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compliance with the requirements of IMS has put in place a robust monitoring and review mechanism. The
monitoring mechanism includes:

Submission of Monthly report on performance, which provides a section on Safety & Environment, which
covers the following aspects on monthly basis:

o
Emergency Preparedness
o
Housekeeping
o
OH&S and Environmental Management System
o
OH&S and Participation Committee
o
Mock Drill For Emergency Preparedness
o
Other Safety Information (including safety statistics)
Quarterly monitoring for Ambient Air Quality (SPM, SOx and NOx) is carried out and the report is submitted
to Department of Environment

OH&S and Participation Committee meeting is undertaken every month where all kinds of grievances along
with H&S issues are discussed with the employees. The feedback is noted and responded to in a timely
manner.

Records are maintained for Oily water treatment and disposal.

Detailed records are maintained for material usage and disposal on monthly basis, which is reviewed
against the identified targets as per the continuous improvement plan

Random checks on H&S are undertaken and the outcome discussed in OH&S and Participation Committee,
records of preceding months meeting was verified.

Internal Audit are carried out to ensure effective implementation of the IMS and to look for opportunities for
improvement. Internal Auditors are nominees from Departments and are trained. The audits are focused on
IMS and include EHS as part of it.

External audit are conducted annually by independent third party accredited Organization ( Bureau Veritas),
to provide certification or registration of conformity to the requirements of the ISO 9001:2008, ISO
14001:2004 and OHSAS 18001:2007 standards.

Management Review of IMS is held quarterly in the last week of December, March, June, and September
arranged by Management Representative and attended by the team members with set agenda and roles as
inputs to assess the status of the IMS and to ensure continuing suitability, adequacy & effectiveness of its
processes. The minutes of meeting were reviewed at site.
3.1.8
Stakeholder Analysis and Engagement Planning
Requirement 8
The Client should identify the range of stakeholders that may be interested in their actions and consider how external
communications might facilitate a dialog with all stakeholders.
If it is known that the project will directly and
adversely impact a local community (i.e., Affected Community), a Stakeholder Engagement Plan is required. The
level of complexity and detail of this Plan should be commensurate with the project risks to and impacts on the
Affected Community and, in some cases, it could include engagement with a broader set of stakeholders.
Observation 8

The IMS does not cover the requirements for stakeholder engagement or consultation with community
during the operation phase.

The plant is operational since 2011, and is surrounded by commercial activities in North and South and
Graveyard in the east, with River Bhairab in the West. However, with respect to communication with
community members of Noapara, there is no identified engagement plan.
May 2016
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
24
Communication with other stakeholders like suppliers, contractors and regulatory agency is maintained as
per requirements of IMS and regulatory compliance. EHS updates and trainings are shared with the
contractors and suppliers while quarterly monitoring report is shared with the DoE.

All workers are engaged through participation committee, which discusses all relevant issues on monthly
basis.

All CSR activities of KPCL is limited to the plants at Khalispur, Khulna and no documents suggesting
community welfare works specific to KJAPC were observed from document review.
3.1.9
Disclosure of information
Requirement 9
Disclosure of information is normally expected as part of the process of identification of impacts and risks, but if the
project is expected to create ongoing impacts and risks to the Affected Communities, the client should continue to
provide information during the life of the project.
Observation 9
KJAPC does not have any formal procedure to disclose any of their observations on impacts or monitoring to the
local community. Towards the east, at a distance of 100 m, lies residential area with graveyard just next to the site,
and River Bhairab in the West. There are impacts from noise generation, dredging in river etc., as well as
observations such as results of quarterly monitoring which needs to be shared with the local community on regular
basis.
3.1.10 External Communications and Grievance Mechanisms
Requirement 10
Client will implement and maintain a procedure for external communications that includes methods to (i) receive and
register external communications from the public; (ii) screen and assess the issues raised and determine how to
address them; (iii) provide, track, and document responses, if any; and (iv) adjust the management program, as
appropriate. In addition, clients are encouraged to make publicly available periodic reports on their environmental
and social sustainability.
Observation 10

It was noted that the external communication and grievance mechanism maintained by KJAPC is informal in
nature. Local community members directly approach the Plant Manager/ Admin Manager in case of
concerns and queries. There is no documentation for the complaints received from the community; the
follow up of issues is also not documented.

The Annual report of KPCL is provided at the website of the company, which is accessible to the community
however, it is limited by access to the internet. The community does not have access to the monitoring
reports submitted to DoE, or any other compliance report. Moreover, the Annual Report of KPCL does not
include key information related to the plant’s EHS performance..

The community has no access to the monitoring reports submitted to DoE, or any other compliance report.
The NGO (Poribartan) involved in CSR is the link between KPCL and community; however, it is not involved
with any work specific to KJAPC at Jessore.
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25
3.1.11 Status of Compliance to PS-1
With respect to observations during the assessment, as presented above, the project is compliant with PS-1 except
for following non-compliances that have been identified under PS-1:

ESMS: The IMS developed by KPCL is focused on O&M aspects of the plant, however it may be
H&S aspects, however it does not focus on social aspects.

Identification of risks and impacts: Reportedly, Environmental and Social Impact Assessment study was
not conducted for the plant. Though KPCL has established Environmental Aspect and Impact procedures
for the plant, details on Environment aspect and Impact significance were not available for dredging of river
bed near Jetty area.

and social management system. The team member identified as Environmental Officer is adequately
experienced but not formally qualified in the subject. Moreover, the plant does not have dedicated staff to
engage with community on regular basis.

Emergency Response: Fire hydrants in the plant were observed as functional, however foam-flooding unit
was not observed at the designated place in the engine room. Boom for Oil spill containment/ Spill kit was
not provided at the unloading area (jetty) of the Jessore facility.

Stakeholder Engagement: KPCL has engaged NGO Paribartan for community development activities.
However all CSR activities are limited to the plants at Khalispur, Khulna and no community welfare works
specific to KJAPC were observed or reported.

3.1.12 Recommendations

KPCL shall develop dedicated procedure for Social aspects, covering commitments made under the IMS
Policy.

KPCL shall make provisions for refresher courses and advanced training to Environmental Officer to
supplement their knowledge towards environmental aspects of Plant operation.

The existing team for IMS shall be provided formal short-term training on E&S requirements.

Environmental Aspect and Impact assessment shall be undertaken in a dedicated manner and documented
for all proposed activities or actions (e.g. dredging).

KJAPC shall put in place a community liaison officer to engage with community on regular basis on various
aspects, such as emergency response, grievance redressal, community development works etc.

Boom for Oil spill containment shall be provided at the Jetty and kept ready during unloading of fuel to
ensure containment of any spill.
May 2016
Plant

26
Fire safety equipment such as foam-flooding equipment etc. shall be available at the designated place at all
times.

A Stakeholder Engagement Plan limited to operation phase requirements shall be developed and
implemented to cover the interaction with community. This shall include mechanism for disclosure of
information, grievance redressal and community welfare.

KJAPC should disclose key information to community pertaining to plant’s EHS performance, such as
results of environmental monitoring and safety statistics. KJAPC could install display boards outside plant
premises providing quantitative data on EHS. Annual reports issued by KPCL should also include a section
on EHS performance of the plant.

The Grievance Redressal is informal at present, KJAPC shall put in place two tier grievance committee with
representatives from local community. There shall be formal register to record grievances, complaints,
suggestions etc. and all issues shall be resolved in a time bound manner. The second tier of the committee
shall be the escalation level at KPCL. The resolution of issues shall also be documented.
3.1.13 Material Liability
The IMS system at the Plant is robust, however social aspects needs to be covered. The issues identified do not
trigger any material liability.
3.2
Performance Standard (PS) 2: Labour and Working Conditions
Performance Standard 2 is in part guided by a number of International Labour Organization (ILO) and United Nations
(UN) Conventions. By applying Performance Standard 2, the client will be able to operate its business in a manner
consistent with the four core ILO labor Conventions. In addition, Performance Standard 2 also addresses other areas
such as working conditions and terms of employment, retrenchment, grievance mechanism, workers’
accommodation and occupational health and safety (OHS) issues. Some of these requirements refer the client to the
applicable national law. Where national law establishes standards that are less stringent than those in Performance
Standard 2, or are silent, clients will meet the requirements of Performance Standard 2.
3.2.1
Working Conditions and Management of Worker Relationship
Requirement 11
The client will adopt and implement human resources policies and procedures appropriate to its size and workforce
that set out its approach to managing workers consistent with the requirements of this Performance Standard and
national law. The client will document and communicate to all employees and workers directly contracted by the
client their working conditions and terms of employment, including their entitlement to wages and any benefits
The client will provide workers with documented information that is clear and understandable, regarding their rights
under national labor and employment law and any applicable collective agreements, including their rights related to
hours of work, wages, overtime, compensation, and benefits upon beginning the working relationship and when any
material changes occur.
Observation 11
applicable to all plants including KJAPC. The Policy has been prepared with the intention of keeping it subservient to
May 2016
Plant
27
the government laws and commits to modification with any change in legal requirement in future. The document is
available to all employees for reference in the form of a handbook.
All employees are given appointment letters in written with terms and conditions as specified in the Policy. All
employees are given an Identity card and unique employee code. The policy document provides details on following
key aspects:

Conditions of Employment

Working Hours

Holidays

Salary and Fringe Benefits

Overtime

Health & Safety
Termination: The conditions of employment states that a regular employee can be terminated with one (1) month
notice or one (1) month salary in lieu of notice, however the Bangladesh Labour Law (BLL) 2006 states that the
employment of a permanent worker may be terminated by the employer by giving to him in writing 120 days’ notice, if
he is a monthly rated worker or sixty days’ notice, in case of other worker. Thus this is a non-conformance to the
legal requirement.
Retirement: The retirement age of employee has been fixed at 60 as per KPCL policy however as per the BLL 2006,
the retirement age for workers employed in any establishment is 57. This is again inconsistent with legal
requirement.
Working Hours: Eight (8) hourly working hours with six (6) days working have been identified (i.e. 48 hours a week)
in the Policy. The plant operates in three (3) shifts and there is rotating shift to accommodate holidays. However
there is no cap on the maximum working hours for a worker including overtime hours, this is a non-conformance to
the requirements of BLL (2006) which states that an adult worker may work for more than forty-eight (48) hours in a
week, provided that the total hours of work of an adult worker shall not exceed sixty (60) hours in any week and on
the average fifty-six (56) hours per week in any year.
The Plant has engaged security services of Falcon Securities Limited, with fifteen (15) unarmed guards working on
eight (8) hourly basis (5 x 3 shifts). A rotation shift is maintained for Holidays. The working hour of 48 hours a week is
maintained as per the representative at site.
Overtime: Overtime of two (2) times the hourly wage is provided in the Policy document, which is in line with the
requirements of BLL 2006. However the calculation of overtime is made on basic salary while BLL 2006 states that in
respect of overtime work, the worker shall be entitled to allowance at the rate of twice his ordinary rate of basic wage
and dearness allowance and ad-hoc or interim pay, if any.
Health & Safety: All employees are provided with appropriate protective clothing and safety gears. Training on
Health and Safety is imparted to all employees. As the Plant is certified to OH&S, adequate arrangements and plan
for H&S aspects are provided. First aid boxes are provided at various locations in the plant and employees were
aware of it. The policy also promotes reporting of accidents and incidents.
Working Conditions: The plant staff is not provided accommodation inside the plant premises and commute daily
from nearby areas. Commutation facilities have been provided to the staff by management. The site staff is also
provided with facilities such as subsidized food cooked at site, drinking water and separate toilets for male and
female employees.
May 2016
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The policy covers temporary and contract workers, working for KJAPC, however contractors engaged by the
company i.e. security agencies (M/s Falcon Security Limited) are not covered by the Policy.
3.2.2
Workers’ Organization
Requirement 12
Where the client is a party to a collective bargaining agreement with a workers’ organization, such agreement will be
respected. Where such agreements do not exist, or do not address working conditions and terms of employment, the
client will provide reasonable working conditions and terms of employment. In countries where national law
recognizes workers’ rights to form and to join workers ‘organizations of their choosing without interference and to
bargain collectively, the client will comply with national law. The client will identify migrant workers and ensure that
they are engaged on substantially equivalent terms and conditions to non-migrant workers carrying out similar work.
Observation 12
It is observed that there is no mechanism for collective bargaining existing for the workers of KJAPC. The
employment policy does not make any commitment about workers union. It was informed during the site visit that
there is no workers union at KJAPC. The BLL 2006 states that every worker employed in any establishment has the
right to form and join a trade union of their own choice. Trade unions have the right to draw up their own constitution
and rules and to elect their representatives. Also, trade unions have the right to form and join in a federation and
such unions and federations have the right to affiliate with any international organization and confederation of trade
unions. The trade union is allowed to serve as a collective bargaining agent in any establishment. Thus the Policy
document needs to be revised to include the requirements of BLL.
The project has engaged no migrant workers (foreign workers) in its operations and it was observed that workers
engaged from different parts of Bangladesh have to follow the same Policies and Procedures as the local workers.
3.2.3
Non-Discrimination and Equal Opportunity
Requirement 13
The client will base the employment relationship on the principle of equal opportunity and fair treatment, and will not
discriminate with respect to any aspects of the employment relationship, such as recruitment and hiring,
compensation (including wages and benefits), working conditions and terms of employment, access to training,
job assignment, promotion, termination of employment or retirement, and disciplinary practices. The client will take
measures to prevent and address harassment, intimidation, and/or exploitation, especially in regard to women. The
principles of non-discrimination apply to migrant workers.
Observation 13
The Employment Policy clearly states that the company subscribes to equal opportunity regardless of age, race, sex,
or marital status. The policy further commits to the principle of fair and equal treatment for all employees. No
discriminatory terms are observed in the Policy and all procedures provided are same for all employees. However
there are no means provided to prevent and address harassment, intimidation, and/or exploitation, especially in
regard to women. Although as on the date of audit there are no female employees engaged with KJAPC.
3.2.4
Retrenchment
Requirement 14
May 2016
Plant
29
Prior to implementing any collective dismissals, the client will carry out an analysis of alternatives to retrenchment. If
the analysis does not identify viable alternatives to retrenchment, a retrenchment plan will be developed and
implemented to reduce the adverse impacts of retrenchment on workers. The retrenchment plan will be based on the
principle of non-discrimination and will reflect the client’s consultation with workers, their organizations, and, here
appropriate, the government, and comply with collective bargaining agreements if they exist.
Observation 14
The plant currently has 30 workers and mostly skilled workers, since the plant will remain operational for the
remaining lease period, there is no immediate possibility of retrenchment. The company being part of a larger group
can explore possibility to accommodate their workers across different plants in case any such need arises.
3.2.5
Grievance Mechanism
Requirement 15
Client shall put in place a grievance mechanism through which workers may raise workplace concerns, the client
should ensure that matters are brought to management’s attention and addressed expeditiously. It should also
provide feedback to those involved and should bar retribution for filing complaints. Grievance mechanisms may be
designed to direct complaints through an appropriate process in order to protect the confidentiality of the worker, and
should ensure that workers can raise concerns other than to immediate supervisors. The client needs to document
all grievances and follow up on any corrective action. The client will appoint a committee to deal with grievances,
which will include management, supervisors and workers’ representatives.
Observations 15
The company has documented a three tier Grievance Mechanism for the workers, which comprises of the following
three levels of escalation:
1.
Immediate Supervisor: The employee can raise his/her grievances related to employment, unfair
treatment, or wrongful action on part of another employee. This has to be done within 2 working days to the
immediate supervisor, who will make a decision in 3 working days’ time.
2.
Superior with HR Manager: In case the worker is not satisfied, it can be escalated to the Superior, who in
consultation with Manager HR&A and give a decision in 5 days from receipt of complaint.
3.
Plant Manager: In case the superior fails to resolve, they issues can be raised with the Plant Manager, who
would respond in 3 working days.
It was observed that the grievance committee does not have representation from workers, also no records of
grievances are maintained by the Plant, which indicates that most of the communication is verbal and resolved in an
informal manner. A significant number of issues such as evaluation of compliances to regulatory requirements, status
of OH&S objectives and programs, status of training programs, job quality and operational performance are
discussed in the Participation committee meeting, the minutes of which were reviewed. However it does not involve
individual grievance related issues.
3.2.6
Protecting the Work Force
Child Labour
Requirement 16
May 2016
Plant
30
The client will not employ children in any manner that is economically exploitative, or is likely to be hazardous or to
interfere with the child’s education, or to be harmful to the child’s health or physical, mental, spiritual, moral, or social
development. The client will identify the presence of all persons under the age of 18. Where national laws have
provisions for the employment of minors, the client will follow those laws applicable to the client.
Observation 16
The Employment Policy has no mention of abolition of Child Labour, also considering the Plant operation there is no
scope of engaging a young worker in the operations. All appointments for the plant are made after due verification of
age proof and testimonials. No child labour was observed in the facility.
In case of workers engaged through contractor, there is no process in place to verify age of the workers involved.
Forced Labour
Requirement 17
The client will not employ forced labour, which consists of any work or service not voluntarily performed that is
exacted from an individual under threat of force or penalty. This covers any kind of involuntary or compulsory labour,
such as indentured labour, bonded labour, or similar labour-contracting arrangements.
Observation 17
Although not mentioned in the policy, there is no evidence of any policy being thrusted on the workers involuntarily.
All workers are hired after due process of interview and background verification, leaving limited possibility of forced
labour.
3.2.7
Requirement 18
The client will provide a safe and healthy work environment, taking into account inherent risks in its particular sector
and specific classes of hazards in the client’s work areas, including physical, chemical, biological, and radiological
hazards, and specific threats to women. The client will take steps to prevent accidents, injury, and disease arising
from, associated with, or occurring in the course of work by minimizing, as far as reasonably practicable, the causes
of hazards. In a manner consistent with good international industry practice, as reflected in various internationally
recognized sources including the World Bank Group Environmental, Health and Safety Guidelines.
Observation 18
The Plant is BS OH&S 18001:2007 certified for occupational health and safety. As part of the IMS the plant manages
a robust OH&S management system. In concurrence with the IMS Policy, the Plant has:
Occupational Health and Safety Management System: The OH&S Management comprise of the following:

OH&S Committee: The OH&S committee is formed by the plant manager comprises at least one member
of each department as a member of the committee. The Safety committee meeting undertaken monthly and
chaired by the Safety Officer.

HIRA: The Plant has put in place process for hazard identification, risk assessments and risk control based
on operational experience and commitment to eliminate, reduce and control workplace illness and injury. It
includes:
o
Routine and non-routine activities
o
Activities of all personnel having access to the workplace including contractors and visitors
May 2016
Plant
o

31
Environment and safety Checklist: An environment and safety checklist is filled prior to commencement
of any activity. The check list provides details of possible hazards and protective measures which needs to
be taken, including Personal Protective Gear. The checklist is signed by the group leader and the
supervisor. Workers were observed to fill in the checklist and wear all requisite PPE prior to execution of
any activity.

Electrical Safety: Only qualified persons are allowed to participate in the construction, maintenance or
operation of electrical equipment. Lock out and Tag Out process is followed while working on energized
systems.

Work Permits: Hot/ Hazardous work permits and Confine space entry permits are separately maintained,
which ensures adequate protection prior to such works. These permits have clear mechanism on how to
close it after completion of work.

Testing of tools and Tackles and Pressure vessels: All lifting machines, chains, lifting tackles and ropes
are tested at periodic intervals and the test certificates were verified at site (dated January 28, 2016). All
pressure vessels and hoses used at the site are also tested (hydraulic) at regular intervals and the test
certificates were verified at site (dated January 28, 2016).

Training of workers: A detailed list of trainings and mock drills planned as part of annual itinerary is given
in Table 3-2 and Table 3-3. It is observed that a robust training plan is in place. The monthly reports on
plant performance also includes monthly training report that provides details on training programs and mock
drills conducted for the current month, scheduled date, description of training, number of participants and
name of trainer. It was noted that training programs are held as per schedule.
May 2016
Plant
32
Sl. No.
Refreshing awareness on safety
procedures
Employee Coverage
JAN
FEB
MAR
APR
MAY
JUN
JUL
AUG
SEP
OCT
NOV
DEC
No of Employees
Plan
Plan
Plan
Plan
Plan
Plan
Plan
Plan
Plan
Plan
Plan
Plan
1
Working near moving machines
KP,KPCII & KjAP
25
25
25
2
HIRA
KP,KPCII & KjAP
25
25
25
3
Housekeeping and 5S
KP,KPCII & KjAP
25
25
25
4
Rescuers training for Confined Space entry &
working at height
KP,KPCII & KjAP
25
25
25
5
Fire prevention and fighting
KP,KPCII & KjAP
25
25
25
6
Incident Management
KP,KPCII & KjAP
25
25
25
7
Emergencies and response plan
KP,KPCII & KjAP
25
25
25
8
Electrical safety
KP,KPCII & KjAP
25
25
25
9
Hot Work (Welding, gas cutting, brazing etc)
KP,KPCII & KjAP
25
25
25
10
First Aid training
KP,KPCII & KjAP
25
25
25
11
OHSAS
KP,KPCII & KjAP
25
25
25
12
Road Safety
KP,KPCII & KjAP
25
25
25
13
Use of PPE
KP,KPCII & KjAP
25
25
25
14
Manual and mechanical material handling
KP,KPCII & KjAP
25
25
25
15
Lock out Tag out (LOTO)
KP,KPCII & KjAP
25
25
25
16
Work Permit system
KP,KPCII & KjAP
25
25
25
17
Slip, Trip and Falls
KP,KPCII & KjAP
25
25
25
18
Prevention from hand injuries
KP,KPCII & KjAP
25
25
25
19
Chemical handling & MSDS
KP,KPCII & KjAP
25
25
25
20
Truck tippler operations
KP,KPCII & KjAP
25
25
25
April 2016
Plant
Sl. No.
21
33
Refreshing awareness on safety
procedures
Employee Coverage
JAN
FEB
MAR
APR
MAY
JUN
JUL
AUG
SEP
OCT
NOV
DEC
No of Employees
Plan
Plan
Plan
Plan
Plan
Plan
Plan
Plan
Plan
Plan
Plan
Plan
Safety Induction program
New Joiners
25
25
25
Sl. No.
Items
JAN
FEB
MAR
APR
MAY
JUN
JUL
AUG
SEP
OCT
NOV
DEC
1
Fire and explosion Drill
26
22
20
22
20
25
16
12
12
12
12
12
2
Flammable Liquid Spill (HSD / LDO / HFO / Lube Oil)
15
3
Hazardous Chemical Spill
15
4
Flooding & natural calamities
5
Man overboard
6
Human Injury/ slip during work/fall from height
7
Medical emergency - injuries like fractures, heart attack, asthma attack,
bleeding, severe burns, Food poisoning, snake bite, Electric shock etc.
(others)
8
Crisis
15
22
25
22
22
22
April 2016
Plant

34
Visitor Safety: The EHS requirements are applicable to all workers within the premises direct and indirect,
as well as to all visitors. OHS briefing is provided to visitors and other third parties accessing the premises.

Accident and Incident Reporting: The plant has adopted an objective of zero fatality and zero lost time
injury (LTI). A robust incident /accident reporting mechanism is in place. Documents pertaining to incident
reporting and statistics on accident/incident were reviewed at site. The OH&S Committee meets on monthly
basis to follow up on open issues. The designated Safety Officer submits a monthly report on safety to
senior management. Workers do not face any disciplinary measures or negative consequences for reporting
or raising concerns about OHS, this was evidenced from the minutes of OH&S meeting. Monthly reports on
plant performance includes safety information such as fire incidents, spillage incidents, first aid injuries, near
misses, lost time injuries and fatal incidents. The plant also displays safety statistics (days since last LTI) in
the form of safety monitor within the premises.
Following Table 3-4 presents the safety statistics as on February 2016. It was reported that since COD,
there has been only one (1) first aid injury and seven (7) near misses in the plant.
Table 3-4: Safety Statistics for KJAPCL Plant (as on Feb 2016)
S. No.
Description
Year to date (for
Since COD
2016)
1.
Total numbers of minor fire incidents
0
0
2.
Total numbers of major fire incidents
0
0
3.
Total numbers of minor spillage
0
0
0
0
0
1
0
0
0
7
0
0
(pollution) incidents
4.
Total numbers of major spillage
5.
Total numbers of first aid injuries – in
plant
6.
Total numbers of Lost Time Injuries
(LTI) – in plant
7.
Total numbers of near misses - in
plant
8.
Total numbers of fatal accidents – in
plant

Exposure to Radiation, Noise and Electro-Magnetic Field (EMF): The engine room has high room
temperature and noise levels, although appropriate PPE (Boiler suits, Ear plugs, Ear Muffs, heat resistant
gloves etc.) are provided to the workers, however there has been no evaluation of Occupational Noise or
exposure to heat with respect to the working hours of the employees. The adequacy of PPE being used for
noise cannot be confirmed, in terms of reducing sound to levels at the ear to at least 85 dB(A). The workers
are provided with Oral Rehydration Supplements (ORS), electrolyte drinks to enable adequate hydration
while working in hot ambience, however adequacy of this has not been established or monitored.
Occupational Exposure to Electro-Magnetic Field is also not being monitored for workers working near
energized equipment and switchyard.

Emergency Prevention, Preparedness, and Response: An Emergency Preparedness and Response
Plan which applies to possible emergency situations such as 1) Fire Incidents, 2) Spillage, 3) Explosions 4)
Natural Calamities, 5) Crisis Management, 6) Man overboard in case of barges and jetties 7) Fatal Human
Injury etc. which may directly affect the environment, personnel safety or the quality of operation and
maintenance activities and status of equipment is in place. The facility has not reported any major
emergency situation.
May 2016
Plant
3.2.8
35
Supply Chain
Requirement 19
Where there is a high risk of child labor or forced labor in the primary supply chain, the client will identify those risks.
If child labor or forced labor cases are identified, the client will take appropriate steps to remedy them.
Observation 19
The Plant has a supplier verification process, however it does not cover labour aspects including child labour. The
primary supply chain for power plant is HFO fuel, which is shipped from Singapore, and considering the labour laws
of Singapore it can be inferred that child labour issue may not be associated with the supplier. Other suppliers such
as for lube oil and chemicals are local dealers of international brands, it is understood that lead brands like
Petrobras, Wilhelmsen etc., have their own code of conduct for their dealer, however KPCL has no process to verify
the same.
3.2.9
Status of Compliance to PS-2
With respect to observations during the assessment, as presented above, the project is largely compliant with PS-2
except for following non-compliances that have been identified under PS-2:


grievances raised.

Contract Worker Management: KJAPCL does not have a mechanism to monitor the adherence of labour

Occupational Health: KJAPCL does not monitor the occupational health of employees in terms of
exposure to high noise levels, high temperatures and EMF.


The Employment Policy Document of KPCL shall be revised to accommodate the requirements of
Bangladesh Labour Law (2006) and include the following points besides any other identified by the
management:
o
Notice period for termination shall be 120 days for regular monthly rated worker and 60 days for
other workers instead of 30 days as being followed
May 2016
Plant
36
o
The retirement age for employee shall be 57, instead of 60 being followed
o
Document the total weekly working hours for an employee with overtime hours, which shall not
exceed sixty hours in any week and on the average fifty-six hours per week in any year
o
Calculation of Overtime shall include other benefits such as dearness allowance, instead of just
basic salary

KPCL should develop a mechanism to monitor the labour force engaged by contractor on the following
aspects:

o
Payment of Minimum wages (review of salary details)
o
Child Labour (review of age proof)
o
Work Hours (review of attendance records)
The management shall, in line with the requirements of Bangladesh Labour Law, add requisite statements
to the employment policy, indicating their willingness to collective bargaining or formation of trade unions.

The employment policy document shall be updated to include procedures to prevent and address
harassment, intimidation, and/or exploitation, especially with regard to women.

Grievance received from employees shall be documented and record shall be maintained for all follow - ups
and action taken.

The employment policy shall make clear statement on engagement of no Child Labour and Forced Labour
in its operations. This should also cover contract workers engaged by the company.

Monitoring of occupational noise should be undertaken for plant staff working in engine room and other high
noise areas. The duration of exposure and exposure levels of workers to high noise should be identified.
The following should be ensured by KPCL management:
o
No employee should be exposed to a noise level greater than 85 dB(A) for a duration of more than
8 hours per day without hearing protection. In addition, no unprotected ear should be exposed to a
peak sound pressure level (instantaneous) of more than 140 dB(C).
o
The use of hearing protection should be enforced actively when the equivalent sound level over 8
hours reaches 85 dB(A), the peak sound levels reach 140 dB(C), or the average maximum sound
level reaches 110dB(A). Hearing protective devices provided should be capable of reducing sound
levels at the ear to at least 85 dB(A).
o
Although hearing protection is preferred for any period of noise exposure in excess of 85 dB(A), an
equivalent level of protection can be obtained, but less easily managed, by limiting the duration of
noise exposure. For every 3 dB(A) increase in sound levels, the ‘allowed’ exposure period or
duration should be reduced by 50 percent.
o
Prior to the issuance of hearing protective devices as the final control mechanism, use of acoustic
insulating materials, isolation of the noise source, and other engineering controls should be
investigated and implemented, where feasible.
o
Periodic medical hearing checks should be performed on workers exposed to high noise levels
o
Refer Table 2.3.1. Noise Limits for Various Working Environments from IFC General EHS
Guidelines on Occupational Health And Safety

Every worker who works in extraordinary conditions that increase the risk of heat stress should be
personally monitored. These conditions include wearing semipermeable or impermeable clothing when the
temperature exceeds 21°C, working at extreme metabolic loads (greater than 500 kcal/hour), etc. Personal
monitoring can be done by checking the heart rate, recovery heart rate, oral temperature, or extent of body
water loss.

Adjustment of work and rest periods according to temperature stress management procedures provided by
2
ACGIH , depending on the temperature and workloads.
2
American Conference of Governmental Industrial Hygienists (ACGIH), the WBGT measures environmental temperature
conditions useful to establish work/rest schedules and exposure hazard evaluation (i.e., heat stress) but does NOT monitor worker
specific physiological responses (heat strain response) to the thermal dose received.
May 2016
Plant

37
Occupational EMF exposure should be prevented or minimized through the preparation and implementation
of an EMF safety program for workers working near energized equipment and switchyard, including the
following components:
o
Identification of potential exposure levels in the workplace, including surveys of exposure levels in
new projects and the use of personal monitors during working activities;
o
Training of workers in the identification of occupational EMF levels and hazards;
o
Establishment and identification of safety zones to differentiate between work areas with expected
elevated EMF levels compared to those acceptable for public exposure, limiting access to properly
trained workers;
o
Personal exposure monitoring equipment should be set to warn of exposure levels that are below
occupational exposure reference levels (e.g., 50 percent).
o
Action plans to address occupational exposure may include limiting exposure time through work
rotation, increasing the distance between the source and the worker, when feasible, or the use of
shielding materials.

KPCL shall put in place a mechanism to assess the labour related practices of the supply chain. This can be
brought about by adding relevant elements to the existing supplier verification form. The form can be
appended to include questions on child labour, minimum wages and working conditions.
Some elements of the Employment Policy and procedures need to be aligned with Bangladesh Labour Law (2006),
and monitoring of occupational health safety needs to include noise, heat and EMF but none of the factors can be
termed as material liability.
3.3
Performance Standard (PS) 3: Resource Efficiency and Pollution
Prevention
The client should take into account the potential impact of their activities on ambient conditions (such as ambient air
quality) and seek to avoid or minimize these impacts within the context of the nature and significance of pollutants
emitted. For small- and medium-sized projects with limited potential emissions, this may be achieved through
compliance with emissions and effluent standards and the application of other pollution prevention and control
approaches. Large projects with potentially significant emissions and/or high impacts, however, may require
monitoring of impacts on the surrounding environment (i.e., changes in ambient levels), in addition to the
implementation of control measures.
3.3.1
Resource Efficiency
Requirement 20
The client will implement technically and financially feasible and cost effective measures for improving efficiency in its
consumption of energy, water, as well as other resources and material inputs, with a focus on areas that are
considered core business activities. Such measures will integrate the principles of cleaner production into product
design and production processes with the objective of conserving raw materials, energy, and water. Where
benchmarking data are available, the client will make a comparison to establish the relative level of efficiency.
Observation 20
The plant has put in place heat recovery boilers wherein the heat recovered is used for keeping the HFO warm and
attain the required viscosity. Thus, significant amount of resources are conserved by recovery of heat from cooling
water.
May 2016
Plant
38
The consumption of water for operations is limited to make-up water for boilers, as the engines are provided with
radiators for cooling, therefore cooling water is a closed loop. The water requirement is met through groundwater
sourced from one tube well installed within site premises.The water requirement for the plant is estimated to be about
3
3
180 – 240 m / month (i.e. 6 - 8 m /day), depending on operational load. However, records pertaining to groundwater
extraction are not being maintained in order to monitor groundwater consumption, as the tube well is not metered.
The plant has provided arrangements for rainwater collection, along the south-western part of the plant, however the
tanks were observed as defunct and not under use.
The facility adopts resource conservation as a target on yearly basis and as part of resource conservation for year
2016, the plant has taken a target of reducing Chemical consumption by 5%, Paper consumption by 5%, Cotton rags
by 5%. The targets undertaken as part of Continuous Improvement Plan (CIP) are monitored on monthly basis.
The plant maintains record of consumption of all material, generation of scrap, waste, etc. on monthly basis and
ensures optimal use of all material, with minimal waste.
3.3.2
Greenhouse Gases
Requirement 21
In addition to the resource efficiency measures described above, the client will consider alternatives and implement
technically and financially feasible and cost-effective options to reduce project-related GHG emissions during the
design and operation of the project. These options may include, but are not limited to, alternative project locations,
adoption of renewable or low carbon energy sources, sustainable agricultural, forestry and livestock management
practices, the reduction of fugitive emissions and the reduction of gas flaring.
Observation 21
The plant quantifies its CO2 emissions, which is about of 0.0229 million metric tons of Carbon dioxide (as observed
between October to December 2015). The implementation of heat recovery boiler has enabled reduction in CO 2
emissions by reducing the fuel requirement/energy requirement for heating the HFO. However, ,the CO2 reduction
from heat recovery is not quantified.
HFO is not the most appropriate fuel in terms of CO2 emissions, however with an evident shortage of gas in
Bangladesh for future years, HFO is the one of better available options.
3.3.3
Pollution Prevention
Requirement 22
The client will avoid the release of pollutants or, when avoidance is not feasible, minimize and/or control the intensity
and mass flow of their release. This applies to the release of pollutants to air, water, and land due to routine, nonroutine, and accidental circumstances with the potential for local, regional, and transboundary impacts. The client
should monitor emissions to ensure that the requirements of Performance Standard 3 are being met. The frequency
with which pollutant emissions are monitored should be appropriate to the nature, scale and variability of potential
impacts.
Observation 22
The key sources of environmental pollution from Operation of the KJAPC are Air emissions, Noise and water from
blow down:
May 2016
Plant
39
Air Emission
Stack Emissions
The plant has five (5) HFO based engines with five stacks of 27m height and 1.1 m diameter, for emission of flue
gases from its operations. The key pollutants from the operations are Particulate Matter, Sulphur dioxide and Oxides
of Nitrogen. As part of the annual stack monitoring, two stacks (i.e. Engine-1 and Engine -3) were monitored in
November 2015. Three readings each were taken on 20th and 21st November of 2015 (Timing: 9.00am, 1.00 p.m.
and 4.00pm). Following observations were made with respect to emissions:
IFC Standards
3
Emission
Parameter
Average Emission
Concentrations
Engine No. 1
Engine No. 3
Observation
Particulate Matter
(at 15% O2) (in
3
mg/Nm )
Sulphur di-Oxide (at
15% O2) (in
3
mg/Nm )
56.8
55.1
57.3
981
1064
928
58.9
64.1
52.8
997
975
1016
50
The stack emission values for PM were
observed to be exceeding the IFC limits.
1170
The stack emission values of Sulphur dioxide
is within the permissible IFC limits.
Oxides of Nitrogen
3
(mg/Nm )
1276
1273
1133
1283
1231
1233
1,850
The stack emission values of oxides of
Nitrogen is within the permissible IFC limits
The stack emission values for Particulate Matter are observed to exceed the permissible limits i.e. 50 mg/Nm3 as per
IFC-WB. In order to control PM emissions the plant has emphasised on better quality of Heavy Fuel Oil, besides
maintaining higher combustion efficiency of HFO in the engines. Further, the sulphur dioxide emissions are within
permissible limits however, the latest fuel analysis reports available during the time of stack monitoring indicate
sulphur content of about 3.5% in fuel used in the plant, which is higher than the permissible sulphur content of 2% as
per IFC guidelines. Latest fuel analysis report conducted in March 2016 by Bureau Veritas for HFO supplied from
Singapore indicates that the sulphur content in fuel is 2.51%. The stack emission values of oxides of Nitrogen are
within the permissible limits i.e, 1850 mg/Nm 3.
Ambient Air Quality (Air Shed)
Ambient air quality monitoring is conducted on quarterly basis by DoE and results are submitted as part of quarterly
reports. Monitoring is conducted only at one location within plant premises. Results gathered from quarterly reports
are presented in table below.
Table 3-6: Ambient Air Quality Monitoring Results (for 24 hourly monitoring period) – Oct to Dec 2015
Parameter
Unit
Particulate Matter
µg/m
Sulphur di-Oxide
Oxides of Nitrogen
3
Recorded Value
IFC Standards
Bangladesh ECR
(Guideline values)
Standards
3
171
50 (24-hourly)
150 (24 hourly)
3
11
20 (24-hourly)
365 (24 hourly)
3
27
--
100 (Annual)
µg/m
µg/m
3
EHS guidelines on Thermal Power Plants (Table 6 (A) - Emissions Guidelines (in mg/Nm or as indicated) for Reciprocating
Engine)
May 2016
Plant
40
The air shed for the area is not degraded, which has been determined on the basis of ambient air quality monitored
on quarterly basis. As per the latest ambient air quality data monitored during October through December 2015, the
PM10, SO2 and NOx levels in the area are well within the Bangladesh Ambient Air Quality Standards. However with
3
respect to the World Bank guidelines, the PM10 emissions exceed the Interim Target-1 value of 150 µg/m for the 24
3
hourly monitoring period, which was recorded as 171 µg/m in case of the plant.
The NOx level was recorded as of 27µg/m3 for the 24 hourly monitoring period, however there are no guidelines for
24 hourly period as per WB guidelines or DoE, Bangladesh Standards. Based on International NOx norms (other
subcontinental country norms) for 24 hourly monitoring period the values observed can be considered to be well
within the limits. The SO2 level recorded during the monitoring period was 11µg/m 3 for the 24 hourly monitoring
3
3
period, which is well within the guideline value of 20 µg/m (interim target-1 of 125 µg/m ) as well as Bangladesh Air
Quality Standard of 365 µg/m3.
Air Dispersion Modelling
An air dispersion modelling exercise using AERMOD 8.1.0 was conducted for the operation of the plant to ascertain
the impact of air emissions from combustion of HFO at existing firing rate. As per the results, maximum incremental
concentration is expected towards the North and north east of the Plant at a distance of 175 - 400 m. The maximum
incremental Ground Level Concentration of PM, SO2 and NOx due to operation of KJAPC is significantly high. The
maximum GLC for:

SO2 for 24 hourly average is 124.9 g/m3 and annual average is 27.5 g/m3.

NOx for 24 hourly average is 158.33 g/m3 and annual average is 34.9 g/m3.

PM for 24 hourly average is 7.24 g/m3 and annual average is 1.6 g/m3.
Following observations have been made on the basis of results obtained:
Sulphur Dioxide: The modelled incremental values for SO2 (both 24-hourly and annual) are observed to be more
than 25% of the national ambient air quality standards (NAAQS). The 24 hourly resultant concentration of SO 2
significantly exceeds the IFC guideline value but is within prescribed limits of Bangladesh NAAQS. The annual
average resultant also exceeds the Bangladesh NAAQS.
Oxides of Nitrogen: The modelled incremental values for NOx (annual) are observed to be more than 25% of the
NAAQS. The annual average resultant exceeds IFC guideline value but is within the Bangladesh NAAQS. The 24
hourly resultant concentration of NOx is significantly high though standards are not available for comparison.
Particulate matter: The modelled incremental values for PM (24-hourly) is observed to be more than 25% of the
national ambient air quality standards (NAAQS)m though annual average values are less than 25% of NAAQS. The
24 hourly resultant concentration of PM significantly exceeds the IFC guideline value but is within prescribed limits of
Bangladesh NAAQS. The annual average resultant exceeds both the Bangladesh NAAQS and IFC guideline value.
contribution of the plant is expected to make the air shed degraded. There is a need to collect robust baseline data
within 5km radius of the plant to understand the existing impact of the air emissions, as of now the information is
limited to comment on the baseline status.
Noise
Ambient noise levels are monitored at six locations around the plant, close to the plant boundary in different
directions. The noise levels recorded are instantaneous noise at any given time during daytime or night time, this is
not comparable to the Noise Standards of Bangladesh or the WB-IFC guidelines as the standards prescribed are for
May 2016
Plant
41
Leq for day and night, which represents a time-weighted average noise level. Therefore, more values are required to
be collected at different time during the day and night to arrive at a weighted average.
Table 3-7: Ambient Noise Monitoring Results
Parameter
Range (dB(A))
67.0 – 73.0 (Sept 2015)
Leq day
68.0 – 70.2 (Feb 2016)
62.0 – 70.2 (Sept 2015)
Leq Night
64.9 – 67.4 (Feb 2016)
IFC Standards
Bangladesh ECR
Standards
70 dB(A)
75 dB(A)
70 dB(A)
70 dB(A)
The values recorded along the boundary ranges from minimum 67.0 dB(A) to maximum 73.0 dB(A) during day time
and 62.0 dB(A) to 70.2 dB(A) during the night time. If, the trend of noise continues to be same during the day as per
4
the data recorded then the plant meets the requirements of ambient noise for day time [75 dB(A)] and [70 dB(A)] for
night time.
Considering the noise levels at the boundary, it is felt that the residential area towards the west (200 m) would be
exposed to noise levels higher than 45 dB(A) during night time. Also the incremental noise level due to plant at these
receptors could be more than 3 dB(A). No monitoring have been undertaken at the receptors to verify the same,
although the noise recorded at the gate towards the west is recorded as 65 dB(A) at night. It was noted that ambient
noise level monitoring through external laboratory is not conducted for the plant.
Waste Water Discharge
The plant generates various streams of wastewater including boiler blow down, oily water and RO rejects. There is
no cooling water discharges as the plant engages a closed loop process. The plant has an oily water collection pit
near the HFO storage area; the oily water from this pit is sent to the oily water treatment unit in the fuel treatment
house. The treated water is discharged into the River Bhairab.
No reports pertaining to river water quality monitoring were available for the plant. Further, no records pertaining to
discharge quantities are maintained by site personnel. The plant also does not analyze the treated water from oily
water treatment unit, for concentration of oil and grease, prior to discharge into the river.
The sewage from toilets provided at site is connected to a septic tank. There is no accommodation provided to staff
at site.
3.3.4
Hazardous Materials Management
Requirement 23
The client will avoid or, when avoidance is not possible, minimize and control the release of hazardous materials. In
this context, the production, transportation, handling, storage, and use of hazardous materials for project activities
should be assessed. The client will consider less hazardous substitutes where hazardous materials are intended to
be used in manufacturing processes or other operations. The client will avoid the manufacture, trade, and use of
chemicals and hazardous materials subject to international bans or phase-outs due to their high toxicity to living
organisms, environmental persistence, potential for bioaccumulation, or potential for depletion of the ozone layer.
Observation 23
4
Applicable for Industrial Area as per Noise Pollution Control Rules 2006 and IFC Standards respectively
May 2016
Plant
42
The project handles and store HFO and LFO for its operations. About 2000 m3 of HFO and 500 m 3 of LFO is stored
at the site. It is reported that the National Fire Protection Association (NFPA) guidelines have been followed in
identifying the distance between the tanks and tank areas. The tank farm area was paved and provided with a
containment wall of 2.9 m height, the containment area has been designed to hold the cumulative volume of all tanks
in case of any structural failure. The containment area is linked to an Oil water separation sump, and prevents any
contamination to ground or waterbody.
Other chemicals required includes chemicals for water treatment, corrosion control etc., the MSDS of these
chemicals were available at site with adequate storage provisions.
The plant requires about 10,000 - 20,000 Litres of lube oil per month depending on the operations. The lube oil is
stored on paved surfaces, however no secondary containment or drain line to oil sump was observed around the
storage area, thus there is a potential for run offs from this area reaching unpaved surfaces or stormwater drains.
The facility generated 128KL of oily sludge on between October and December 2015 with a water content of 50-55%.
3
The oil sludge generated is collected after Oil water separation in a sludge tank 35m capacity. The sludge
generated is adequately store with secondary containment within the tank farm and is sold to authorised vendor, M/s
Abdullah Traders at regular intervals (monthly).
About 150 pairs of hand gloves and 200 kg of oily rags are also generated, which are collected in designated bins
and sold to the authorised vendors along with the Oily sludge.
Other waste material generated from the plant include, containers for thinners, paints, chemicals, rejected tyres,
metal scrap etc. All items are segregated and stored prior to being sold to appropriate vendors.
3.3.5
Status of Compliance with PS-3
With respect to observations during the assessment, as presented above, the project is partially compliant with PS-3

Resource Efficiency: Groundwater extraction records are not being maintained as the bore well at site is
not metered. Though the management has considered water conservation measures and has installed
rainwater harvesting structures, the tanks were observed as defunct and not under use.


periods and therefore not comparable to permissible standards due to absence of 24 - hourly guidelines.

level monitoring through external laboratory is also not conducted for the plant.

Surface water and treated water quality monitoring: River water quality is not being monitored by the
plant management. The plant also does not analyze the treated water from oily water treatment unit, for
concentration of oil and grease, prior to discharge into the river. Further, no records pertaining to discharge
quantities are maintained by site personnel.
May 2016
Plant
3.3.6

43
Recommendations
KJAPC to maintain records pertaining to groundwater extraction through installation of meter on bore well.
Rainwater harvesting pits should be cleared of debris and vegetation in order to ensure that they are
functional.

The plant shall quantify the energy conserved in terms of the heat recovered through heat recovery boilers
and assess its CO2 reduction based on it.

Fuel combustion of engine should be fine-tuned to reduce unburnt carbon particles. Maintenance of engines
and stacks shall be done periodically and stack emission recorded.

Monitoring of ambient air quality shall following the monitoring periods as prescribed by Bangladesh norms
or WB-IFC guidelines particularly for NOx, hourly monitoring data shall also be recorded.

Noise monitoring shall be undertaken as Leq for day and night, which represents a time-weighted average
noise level. Noise monitoring shall be undertaken for a continuous period of 24 hours and then averaged for
day and night periods to get a meaningful assessment.

Noise levels at residential areas around the western boundary shall be monitored for night time noise levels.
Adequate control measures shall be planned if noise levels exceed national standards or the incremental
noise level is more than 3 dB(A). The incremental noise level can be determined on a day when the plant is
shut for maintenance.

A third party laboratory should be engaged to monitor the noise levels in the plant and surroundings on
annual basis.

For forthcoming quarterly reports for DoE, KJAPC should ensure that updated environmental standards of
IFC-WB and Bangladesh DoE are considered in order to monitor compliance.

Water quality of Bhairab River upstream and downstream of effluent discharge point shall be monitored to
ensure that there is no discharge or impact from plant operations.

Treated effluent should be monitored to check the oil and grease content prior to discharge into river.

Lube oil storage area shall be provided with secondary containment or drains leading to oil water separation
sump.

Based on the outputs derived from the air dispersion modelling, following recommendations are proposed
for reducing stack emissions:
o
Adoption of any of the below methods for reduction of NOx emissions:

Regulate air-to-fuel ratio and ignition/injection timing to control maximum temperature and
residence time. This can reduce the concentration of NOx that is generated by reducing
peak temperature.

Valve timing adjustments to reduce residence time at peak temperature to control NOx
formation. Shall be explored

In case the above two adjustment do not yield appropriate results Chemical reduction of
NOx using catalytic converters to reduce NOx to N2 shall be considered.
o
Use of fuel with even lower sulphur content i.e. less than 2%, to reduce SO 2 emissions is
recommended.
o
Flue Gas Desulphurisation using lime scrubbers can be explored based on availability pf space.
o
In case, none of the above mentioned measures are effective, then raising stack height needs to
be considered by KJAPC.
3.3.7
Material Liability
Monitoring periods, and extent of monitoring needs to improve, however none of the issues can be termed as
material liability.
May 2016
Plant
3.4
Performance Standard (PS) 4: Community Health Safety and Security
3.4.1
Community Health and Safety
44
Requirement 24
The client will evaluate the risks and impacts to the health and safety of the Affected Communities during
the project life-cycle and will establish preventive and control measures consistent with good international
industry practice (GIIP),such as in the World Bank Group Environmental, Health and Safety Guidelines (EHS
Guidelines) or other internationally recognized sources. The client will identify risks and impacts and propose
mitigation measures that are commensurate with their nature and magnitude. These measures will favour the
avoidance of risks and impacts over minimization.
Observations 24
The plant has HFO and LFO storage facility within its boundary, however no risk assessment study has been
conducted to understand tank fire and dyke fire scenario for the storage area. Based on previous experience on such
studies it is observed that a zone of 250 m around the tank would be vulnerable to impact from incident radiation.
This would mean that exposure to community may be limited to western boundary (if any), however potential
exposure to community and workers at site will need to be assessed. The tank farm area is provided with adequate
fire control arrangements.
An Oil Spill Containment Plan is in place to manage any spill during unloading of oil, which may affect the river or
community using it. The project has also prepared detailed emergency response plan, it is reported that the
community members are involved during mock drills to make them aware of emergency preparedness. However, no
formal communication or dissemination of information regarding ERP to the community was observed.
Noise as mentioned in the earlier sections can have impact on the community as the operations are continuous and
will remain there for long periods.
3.4.2
Security Personnel
Requirement 25
When the client retains direct or contracted workers to provide security to safeguard its personnel and property, it will
assess risks posed by its security arrangements to those within and outside the project site. The client will make
reasonable inquiries to ensure that those providing security are not implicated in past abuses; will train them
adequately in the use of force (and where applicable, firearms), and appropriate conduct toward workers and
Affected Communities; and require them to act within the applicable law. The client will not sanction any use of force
except when used for preventive and defensive purposes in proportion to the nature and extent of the threat.
Observation 25
The client has engaged M/s Falcon Security Services (FSS) for security, 15 security persons are engaged for the
KJAPC plant. FSS is run by retired army officers, and reportedly it has a robust recruitment mechanism and
candidates are chosen after appropriate screening of background. The company has a training facility set up in
Dhaka where both physical training and practical class on security are conducted by a team of instructor formed by
ex-defense personnel. All the serving security personnel of the company have to undertake an annual re-certification
May 2016
Plant
45
/ re-orientation training. Besides, the management of the company does a monthly briefing on the security duties and
standard to all personnel.
The security engaged at the site is unarmed and there has been no complaints regarding their conduct as per the
discussions with the management and grievance records.
3.4.3
With respect to observations during the assessment, as presented above, the project is partially compliant with PS-4


observed to have been undertaken by KJAPC.
3.4.4

Recommendations
Quantitative Risk Assessment should be undertaken for fuel storage and identify the zone of risks in and
around the plant vicinity

Emergency Response Plan should be disseminated with the community and periodic discussions should be
organized to refresh the same
3.4.5
Material Liability
Lack of information on risk from fire to storage area can lead to loss of life of workers and affect nearby community in
case of such a disaster. Although the facility has made adequate fires safety arrangements, the lack of risk
assessment is a material liability.
3.5
Resettlement
3.5.1
Land Acquisition
(PS)
5:
Land
Acquisition
and
Involuntary
Requirement 26
Performance Standard 5 recognizes that project-related land acquisition and restrictions on land use can have
adverse impacts on communities and persons that use this land. Involuntary resettlement refers both to physical
displacement (relocation or loss of shelter) and to economic displacement (loss of assets or access to assets that
leads to loss of income sources or other means of livelihood) as a result of project-related land acquisition and/or
restrictions on land use.
Observation 26
The 3.5 acres of land on which the plant is located has been leased to KJAPC by BPDB. The details of lease and
documents pertaining to the same were not available for review. It is understood from the review of past satellite
May 2016
Plant
46
imagery (2004) that the land was used for agricultural purpose prior to development of the power plant. In addition,
there are no structures or encroachments visible in past imageries. The acquisition of land was reportedly
undertaken by BPDB prior to 2010 and was later leased to the company through execution of the lease deed,
however the year of procurement is not known. Further, no details were available with KJAPC on the past ownership
of the site.
Based on the media search and discussions with the plant management it is understood that there are no litigations
regarding the ownership of this land. As per discussions with site management, there were no outstanding claims on
the land, for compensation or loss of livelihood.
3.5.2
The status of compliance of the project to the requirements of PS-5 could not be established due to unavailability of
details pertaining to past land ownership and compensation or loss of livelihood. However, based on current
assessment and discussions with site management, it is understood that the project is compliant to the requirements
of PS-5.
3.5.3
Recommendations
No recommendations have been made.
3.5.4
Material Liability
As AECOM has not reviewed the lease deed document a conclusive statement cannot be made, however based on
discussions and secondary data available it is assessed that it is a not a material liability.
3.6
Performance Standard (PS) 6: Biodiversity Conservation and Sustainable
Management of Living Natural Resources
3.6.1
Biodiversity Conservation
Requirement 27
Performance Standard 6 recognizes that protecting and conserving biodiversity, maintaining ecosystem services,
and sustainably managing living natural resources are fundamental to sustainable development.
Observation 27
The project is located in an urban set up in Noapara, Jessore. The area is largely commercial with no identified
significant natural vegetation. There are no legally protected areas or critical habitats reported within 5km radius from
the plant. The River Bhairab is an ecologically important river in the area. River Bhairab has been in news for high
pollution levels in June 2015 wherein fishes of different species were seen floating dead in the river near Noapara
industrial area, the reason was attributed to high pollution levels in water. However, the KJAPC plant does not make
any significant discharges to the river. As the plant utilizes radiator based cooling system, no thermal discharges are
released into the river.
3.6.2
With respect to observations gathered on PS-6, it is understood that the project is compliant to PS-6, except that it
does not assess the quality of discharge to ensure insignificant impacts on receiving water body.
May 2016
Plant
3.6.3

47
Recommendations
KJPAC plant shall quantify the discharge to river as well as assess the quality of discharge to ensure no
impact on receiving waterbody.
3.6.4
Material Liability
There is no material liability pertaining to ecological impacts due to plant operations.
3.7
Performance Standard (PS) -7: Indigenous People
3.7.1
Avoidance of Adverse Impacts
Requirement 28
The client will identify, through an environmental and social risks and impacts assessment process, all communities
of Indigenous Peoples within the project area of influence who may be affected by the project, as well as the nature
and degree of the expected direct and indirect economic, social, cultural (including cultural heritage), and
environmental impacts on them.
Observation 28
native ethnic minorities in south-eastern, north-western, north-central and north-eastern regions of the country.
These regions include the Chittagong Hill Tracts, Sylhet Division, Rajshahi Division and Mymensingh District. The
project district Jessore as well as the Noapara area has not reported presence of any indigenous community.
The land on which the project is developed has been leased to KJAPC by BPDB. Since past ownership details are
not available for review, presence of IPs on the specific piece of land cannot be commented upon. However from
discussions with site management and review of secondary information, the project area does not report presence of
IPs.
3.7.2
The project is compliant to the requirements of PS-7.
3.7.3
Recommendations
No recommendations have been made.
3.7.4
Material Liability
There is no material liability pertaining to impacts on Indigenous Community due to the project operations.
3.8
Performance Standard (PS) - 8: Cultural Heritage
3.8.1
Cultural Heritage
Requirement 29
May 2016
Plant
48
In addition to complying with applicable law on the protection of cultural heritage, including national law
implementing the host country’s obligations under the Convention Concerning the Protection of the World
Cultural and Natural Heritage, the client will identify and protect cultural heritage by ensuring that internationally
recognized practices for the protection, field-based study, and documentation of cultural heritage are implemented.
Observation 29
The western boundary of the plant is aligned along a graveyard, which has local religious significance, however the
operations of plant has no interference with it. In addition, no grievance pertaining to the same was observed during
discussions.
Besides the graveyard, the site or its surroundings do not have any structure of cultural importance. No tangible or
intangible site, structure or custom of cultural importance was observed during the site visit and secondary data
review.
3.8.2
The project is compliant to the requirements of PS-8.
3.8.3

Recommendations
The grievance redressal mechanism for community shall be formally implemented to document any
concerns regarding cultural issues.
3.8.4
Material Liability
There is no material liability pertaining to impacts on cultural heritage due to the project operations.
May 2016
ESDD Report as per IFC Sustainability Framework 40MW Khan Jahan Ali Plant
49
This section delineates the list of actions required to be undertaken by the management to ensure closure of the gaps as identified in Section 3.0 of the report. The Corrective Action Plan is provided below with timelines, responsibilities and specific action items.
The CAP for the same has been furnished below:
The gaps are categorised as red, orange and yellow flag issues based on the severity of impact on the EHS and Social aspect
Flags
Remarks
Red Flag Issues
These are observations which pose high impact on the environment, health, safety and social aspects and may have legal implications.
Orange Flag Issues
These are observations which pose moderate impact on the environment, health, safety and social aspects.
Yellow Flag Issues
These are observations which pose low or least impact on the environment, health, safety and social aspects.
Table 3-8: Summary of Key Observations and Recommendations
S. No.
1.
Applicable
Performance
Standard
PS-1
Issue Identified
ESMS
Summary of Issues


The IMS does not cover pre construction
and construction stage management.
IMS does not focus on social aspects.
Flag
Proposed Action Plan


Budget and Resource
KPCL shall develop dedicated procedure
for Social aspects, covering commitments
made under the IMS Policy
Preconstruction and construction stage
management procedures should also be
outlined as part of IMS.


Responsibility
A third party consultant
shall be engaged to
develop social engagement
procedures ($3000)
Training Courses shall be
part of exiting training
budget

Timeline (from date of
finalization of this
report)

Three Months

Plant Manager (Management
Representative)
Liaison Officer
2.
PS-1
Identification of Risk

Environment aspect and Impact is not
being conducted for all activities with
diligence

assessment shall be undertaken in a
dedicated manner and documented for all
proposed activities or actions (e.g.
dredging).

No additional budget or
resource

Environment officer

One month
3.
PS-1
Organisational Capacity
and Competency

KJAPC does not have specific team for
implementing the ESMS.
Environmental officer is adequately
experienced but not formally qualified in
the subject
No dedicated staff for community liaison

Formal short-term training on E&S
requirements to be imparted to IMS team.
Refresher courses and advanced training
courses to be provided to Environmental
Officer
A community liaison officer should be
deputed to engage with community on
regular basis.

Training Courses shall be
part of exiting training
budget
New hire ($300/ month)

HR Manager

One month
Boom for Oil spill containment/ Spill kit
was not provided at the unloading area
(jetty) as the plant does not have one.
Foam flooding unit not available at
designated place in the engine room.

Boom for Oil spill containment shall be
procured and provided at the Jetty to
ensure containment of any spill.
Fire safety equipment such as foamflooding equipment etc. shall be available at
the designated place at all times.

Procure Oil Spill Boom
(cost depends on the length
of boom required)
About $1000 for 30 m

Plant Manager

Two Months
The IMS does not cover the requirement
for stakeholder engagement or
consultation with community during the
operation.
No documents suggesting community
welfare works specific to KJAPC were
observed from document review.
No formal structure / procedures for
information disclosure to the local
community on project’s conformance
with environmental compliance
requirements and plant’s EHS
performance.
External Communication and Grievance
mechanism maintained by KJAPC is
informal in nature.

A Stakeholder Engagement Plan limited to
operation phase requirements shall be
developed and implemented to cover the
interaction with community.
The Stakeholder engagement Plan shall
include mechanism for disclosure of
information, grievance redressal and
community welfare.
Key information should be disclosed to
community pertaining to plant’s EHS
performance, through display boards,
annual reports, etc.
Two tier grievance committee with
representatives from local community
should be formed and grievances to be
recorded and resolved in formal manner.

To be developed as part of
Social engagement aspect
of IMS as mentioned
above.
resource

Liaison Officer

Two Month


4.
PS-1
and Response


5.
PS-1
Stakeholder Consultation,
External Communication
and Grievance Redressal













May 2016
S. No.
6.
Applicable
Performance
Standard
PS-2
Issue Identified
Employment policy
Summary of Issues




Flag
50
Budget and Resource
Responsibility
The Employment Policy Document of
KPCL does not adhere to certain
requirements of Bangladesh Labour Law
(2006)
No policy on company’s willingness to
collective bargaining or formation of
trade unions as per the BLL and nonengagement of child/ forced labour in its
operations.
Absence of procedures to prevent and
address harassment, intimidation, and/or
exploitation, especially with regard to
women.
Policy requirements do not cover
contract workers engaged through
contractors.

The Employment Policy Document to be
revised to accommodate the requirements
of Bangladesh Labour Law (2006) on:
o
Notice period for termination
o
Retirement age
o
Document the total weekly
working hours for an employee
with overtime hours
o
Calculation of Overtime including
other benefits
o
Develop policy on collective
bargaining or formation of trade
unions
o
Anti-harassment procedures
o
Non-engagement of child/ forced
labour, directly or indirectly
o
Applicability to contract workers
engaged through contractors

resource

HR Manager
report)

One Month
7.
PS-2
Employment Policy –
Contractors

Mechanism to monitor the adherence of
labour laws on payment of minimum
wages, child labour verification and
working hours for contract workers
engaged through contractors does not
exist

Develop a mechanism to monitor the labour
force engaged by contractor on the
following aspects:
o
Payment of Minimum wages
(review of salary details)
o
Child Labour (review of age
proof)
o
Work Hours (review of
attendance records)

resource

HR Manager

One Month
8.
PS-2
Grievance Redressal for
employees

Grievances reported by employees are
not recorded, and in case of redressal of
grievances, the actions taken are not
documented in order to track satisfactory
closure of grievances raised.

A grievance received from employees shall
be documented and record shall be
maintained for all follow-ups and action
taken.

resource

HR Manager

One Month
9.
PS-2
Occupational Health &
Safety

Monitoring of occupational health of
employees in terms of exposure to high
noise levels, high temperatures and EMF
not undertaken.

Monitoring of occupational noise should be
undertaken for plant staff working in engine
room and other high noise areas.
Duration of exposure and exposure levels
of workers to heat and EMF should be
identified.
(Refer to Section 3.2.10 for details)

Occupational Noise, heat
and EMF monitoring
through third party ($
15000)
Mechanical Controls
depending on outcome of
the assessment

Safety Officer

One Month
10.
11.
PS-2
Supply Chain
PS-3
Resource Efficiency
PS-3, PS-6


KJAPCL has no process to verify labour
compliance aspects of suppliers.

Mechanism to assess the labour related
practices of the supply chain to be
developed through child labour, minimum
wages and working conditions verification
for suppliers

resource

Logistic/ Asset manager

One month

Groundwater extraction records are not
being maintained as the bore well at site
is not metered.
Rainwater harvesting structures at site
are defunct.

Installation of water meter on bore well at
site
Maintain records pertaining to groundwater
extraction
Rainwater harvesting tanks to be cleared of
debris and made functional.

Installation of water meter
on bore well (max. $ 400)

Environment Officer

Two months
CO2 emission reduction due to heat
recovery not quantified
Monitoring periods of various parameters
not in accordance with the duration
prescribed for existing norms or
guidelines to be comparable.
NOx levels monitored for the facility are
recorded for 24 hourly periods and

Quantify energy conserved in terms of the
heat recovered through heat recovery
boilers and assess its CO2 reduction
Monitoring of Ambient air quality shall follow
the monitoring periods as prescribed by
Bangladesh norms or WB-IFC guidelines
particularly for NOx, hourly monitoring data
shall also be recorded.

Changes to Monitoring
requirements; Additional
monitoring ($ 5000)
Metering of discharge ($
500)

Environment Officer

Implement
from next
monitoring
Two Months

12.









May 2016
S. No.
Applicable
Performance
Standard
Issue Identified
Summary of Issues






therefore not comparable to permissible
standards
Particulate matter emissions from all
stacks exceed the permissible limits as
stipulated by IFC WB guidelines
Dispersion modelling results suggest
that incremental Ground Level
Concentration of SO2 and NOx due to
operation of KJAPC are significantly high
and the resultant values exceed both
DoE standards and IFC guideline values.
Noise level monitoring not instantaneous
and not conducted through third party
No noise monitoring have been
undertaken at the residential receptors
outside the plant for noise levels.
River water quality not monitored.
No quantification of waste water
discharge to Bhairab River is maintained
Flag



o
o







Budget and Resource
Responsibility
report)
Quarterly reports submitted to DoE should
consider updated environmental standards
of IFC-WB and Bangladesh DoE in order to
monitor compliance.
Fuel combustion of engine should be finetuned to reduce unburnt carbon particles.
Maintenance of engines and stacks shall be
done periodically and stack emission
recorded.
Adoption of any of the below methods for
reduction of NOx emissions:
o

51
Regulate air-to-fuel ratio and
ignition/injection timing to control
maximum temperature and
residence time. This can reduce
the concentration of NOx that is
generated by reducing peak
temperature.
Valve timing adjustments to
reduce residence time at peak
temperature to control NOx
formation. Shall be explored
In case the above two adjustment
do not yield appropriate results
Chemical reduction of NOx using
catalytic converters to reduce
NOx to N2 shall be considered.
Use of fuel with even lower sulphur content
i.e. less than 2%, to reduce SO2 emissions.
Flue Gas Desulphurisation using lime
scrubbers can be explored based on
availability pf space.
Noise monitoring to be undertaken on timeweighted average basis.
Noise levels at residential areas around the
southern boundary should be monitored for
night time noise levels and adequate
control measures should be planned.
Third party laboratory should be engaged to
monitor the noise levels in the plant and
surroundings on annual basis.
Treated effluent should be monitored to
check the oil and grease content prior to
discharge into river.
Water quality of Bhairab River downstream
of effluent discharge point to be monitored.
KJPAC plant shall quantify the discharge to
river as well as assess the quality of
discharge to ensure no impact on receiving
waterbody.
13.
PS-3
Hazardous Material

No secondary containment or drain line
to oil sump was observed around the
storage area of lube oil

Lube Oil storage area shall be provided
with secondary containment or drains
leading to oil water separation sump.

Construction of drain line
($ 50,000)

Administration/Logistics

Two months
14.
PS-4
Community Health and
Safety

Exposure to community from tank failure
may be limited to western boundary (if
any), however potential exposure to
community and workers at site will needs

Undertake Quantitative Risk Assessment
for fuel storage and identify the zone of risk
in and around the plant vicinity
Disseminate the Emergency Response

Engage third party for risk
modelling ($12000)

Safety officer

Two month

May 2016
S. No.
Applicable
Performance
Standard
Issue Identified
Summary of Issues

to be assessed.
No formal communication or
dissemination of information regarding
ERP to the community was observed.
Flag
Budget and Resource
52
Responsibility
report)
Plan with the community and organise
periodic discussions to refresh the same.
May 2016
ENVIRONMENT AND SOCIAL DUE
DILIGENCE
110 MW and 115 MW HFO Based Power Plants of KPCL
Goalpara, Khulna, Khulna Division, Bangladesh
May 2016
Prepared for
INTERNATIONAL FINANCE CORPORATION
SUMMIT CORPORATION LIMITED
ESDD Report as per IFC
Sustainability Framework, HFO
Power Plant, KPCL, Khulna
Executive Summary .................................................................................................................................. i
2.0
Khulna Power Company Limited .................................................................................................... 6
2.1
Background........................................................................................................................... 6
2.2
Organisation Structure ........................................................................................................... 7
2.3
Facility Details ....................................................................................................................... 8
2.3.1
Location and Site Settings ................................................................................................. 8
2.3.2
Land Details ..................................................................................................................... 9
2.3.3
Process Description .......................................................................................................... 9
2.3.4
Details of Engine and Specifications ................................................................................ 10
2.3.5
Utilities and Associated Facilities ..................................................................................... 12
2.3.6
Status of Permits ............................................................................................................ 14
2.4
2.4.1
Environment ................................................................................................................... 15
2.4.2
Health and Safety ........................................................................................................... 17
2.4.3
Social and Stakeholder ................................................................................................... 17
2.5
3.0
Environment Health, Safety and Social Scenario .................................................................. 15
Project Categorization ......................................................................................................... 18
Document Review and Assessment of Compliance ..................................................................... 19
3.1
Performance Standard (PS) 1: Assessment and Management of Social & Environmental Risks
and Impacts .................................................................................................................................... 19
3.1.1
Environment and Social Assessment and Management System ....................................... 19
3.1.2
Policy ............................................................................................................................. 20
3.1.3
Identification of Risks and Impacts................................................................................... 20
3.1.4
Management Programs ................................................................................................... 22
3.1.5
Organizational Capacity and Competency ....................................................................... 23
3.1.6
Emergency Preparedness and Response ........................................................................ 24
3.1.7
Monitoring and Review .................................................................................................... 25
3.1.8
Stakeholder Engagement ................................................................................................ 26
3.1.9
External Communications and Grievance Mechanism ...................................................... 28
3.1.10
Status of Compliance to PS-1.......................................................................................... 28
3.1.11
Recommendations .......................................................................................................... 29
3.1.12
Material Liability .............................................................................................................. 29
3.2
Performance Standard (PS) 2: Labour and Working Conditions ............................................ 29
3.2.1
Working Conditions and Management of Worker Relationship .......................................... 29
3.2.2
Workers’ Organisation..................................................................................................... 31
3.2.3
Non-Discrimination and Equal Opportunity ....................................................................... 31
3.2.4
Retrenchment ................................................................................................................. 32
3.2.5
Grievance Mechanism .................................................................................................... 32
3.2.6
Child Labour/Bonded Labour ........................................................................................... 33
3.2.7
Occupational Health and Safety ...................................................................................... 33
May 2016
i
3.2.8
Supply Chain .................................................................................................................. 38
3.2.9
3.2.10
3.2.11
3.3
Performance Standard (PS) 3: Resource Efficiency and Pollution Prevention ........................ 40
3.3.1
Resource Efficiency ........................................................................................................ 40
3.3.2
Greenhouse Gases ......................................................................................................... 41
3.3.3
Pollution Prevention ........................................................................................................ 42
3.3.4
Hazardous Materials Management .................................................................................. 46
3.3.5
Status of Compliance with PS-3 ...................................................................................... 47
3.3.6
3.3.7
3.4
Performance Standard (PS) 4: Community Health Safety and Security.................................. 48
3.4.1
Community health and safety .......................................................................................... 48
3.4.2
Security Personnel .......................................................................................................... 49
3.4.3
Status of Compliance with PS-4 ...................................................................................... 49
3.4.4
3.4.5
3.5
Performance Standard (PS) 5: Land Acquisition and Involuntary Resettlement ...................... 50
3.6
Performance Standard (PS) 6: Biodiversity Conservation and Sustainable Management of
Living Natural Resources ................................................................................................................. 50
3.6.1
Protection and Conservation of Biodiversity ..................................................................... 50
3.6.2
3.6.3
3.6.4
3.7
Performance Standard (PS) 7: Indigenous People ................................................................ 52
3.8
Performance Standard (PS) 8: Cultural Heritage .................................................................. 52
May 2016
ii
List of Tables
Table 2-1: Technical data Wartsila VASA18V32LN and W18V46 Engines ................................................. 11
Table 2-2: List of Agreements................................................................................................................... 14
Table 2-3: Status of Permits ..................................................................................................................... 14
Table 3-1: Safety Training Plan KPCL – Year 2016 ................................................................................... 35
Table 3-2: KPCL Emergency Mock Drill Plan for Year 2016....................................................................... 36
Table 3-3: Safety Statistics for KPCL Units (as on Feb 2016) .................................................................... 37
Table 3-4: Details of Stack Monitoring ...................................................................................................... 42
Table 3-5: Results of Stack Emission Monitoring (November 2015) ........................................................... 43
Table 3-6: Ambient Air Quality Monitoring Results (for 24 hourly monitoring period) ................................... 43
Table 3-7: Ambient Noise Monitoring Results – Feb 2016 ......................................................................... 44
Table 3-8: Barge Basin Water Quality Results – Feb 2016 ........................................................................ 45
Table 3-9: Treated Sanitary Water Quality (from barge STP) – Feb 2016................................................... 46
Table 3-10: Temperature Monitoring Records ........................................................................................... 51
Table 3-11: Summary of Key Observations and Recommendations – KPCL Khulna Facility ....................... 53
List of Figures
Figure 2-1: Shareholding Pattern for KPCL .................................................................................. 6
Figure 2-2: Organizational Structure - KPCL ................................................................................ 8
Figure 2-3: Indicative Location of Power Plant ............................................................................. 9
Figure 2-4: HFO Distribution and Storage System ...................................................................... 13
Figure 2-5: EMS Organisation Chart, Roles and Responsibilties ................................................ 17
List of Annexures
Annexure A
Photo log
Annexure B
Dispersion Modelling Results
May 2016
i
Abbreviations
ACGIH
American Conference of Governmental Industrial Hygienists
BIWTA
Bangladesh Inland Water Transport Authority
BLL
Bangladesh Labour Law
BPDB
Bangladesh Power Development Board
COD
Commercial Operation Date
CSR
Corporate Social Responsibility
CIP
Continuous Improvement Plan
dB
Decibel
DM
Demineralization
DMF
Dual Media Filter
EHS&S
Environment Health & Safety and Social
EMF
Electro-Magnetic Field
ESMS
Environmental and Social Management System
EMS
Environment Management System
EPC
Engineering, Procurement and Construction
EPRP
Emergency Preparedness and Response Plan
E&SDD
Environmental & Social Due Diligence
FSS
Falcon Security Services
GHG
Greenhouse Gases
GIIP
Good International Industry Practice
HFO
Heavy Fuel Oil
HIRA
Hazard Identification Risk Assessment
HT
High-temperature
IFC
International Finance Corporation
ILO
International Labour Organization
IPP
Independent Power Producer
IMS
Integrated Management Systems
KJAPCL
Khanjahan Ali Power Company Ltd
KPCL
Khulna Power Company Ltd
LFO
Light Fuel Oil
May 2016
i
LT
Low-temperature
LNG
Liquefied Natural Gas
MW
Megawatt
MR
Management Representative
NGO
Non-Governmental Organization
OH&S
OHSAS
Occupational Health and Safety Advisory Services
ORS
Oral Rehydration Supplements
O&M
Operation & Maintenance
PDCA
Plan-Do-Check-Act
PPE
Personal Protection Equipment
PS
RO
Reverse Osmosis
SPM
Suspended Particulate Matter
TBN
Total base number
UN
United Nations
VIC
Variable Inlet Valve Closure
WB
World Bank
May 2016
ii
Executive Summary
Summit Corporation Limited ( hereinafter referred to as ’SCL’) established in 1985, is a holding company sponsoring
its subsidiary companies to own, build and operate infrastructure projects in Power sector. The Group currently
produces around 1,260 MW (including two under commissioning plant), which is around 13% of total capacity of the
country. Summit intends to hold 20% of the country’s generation capacity and has signed an appraisal letter with
International Finance Corporation (IFC) for investment to be made by latter. As per IFC requirements, an
Environmental and Social Due diligence (ESDD) is required to be undertaken for the holding company and individual
assets of Summit. SCL and IFC have thereby engaged AECOM India Private Limited to conduct the ESDD for the
assets being operated and managed by Khulna Power Company Ltd. (KPCL). KPCL being an independent entity
has developed separate policies and procedures, with SCL having limited authority to take decisions for KPCL
operations.
Two AECOM professionals visited the HFO based power plant at Khulna (hereinafter referred to as ‘Project’) on 16th
March 2016. The facility has two units – 110 MW barge mounted power plant and 115 MW land based power plant,
both operating on HFO. The ESDD was carried out to assess alignment of SCL’s and KPCL’s Environmental and
Social Management System (ESMS) and plant’s EHS performance with respect to Bangladesh Environmental,
Health, Safety and Social regulations, IFC Performance Standards, 2012, The IFC General Environmental, Health
and Safety (“EHS”) Guidelines, dated 2007, IFC Sector EHS Guidelines for Thermal Power Plants dated 2008 and
Power Sector EHS Guidelines for Electric Power Transmission and Distribution dated 2007.
Key observations and findings as part of the Environmental and Social Due Diligence conducted for the Project are
presented below. Detailed observation and recommendations in the form of a Corrective Action Plan has been
presented in subsequent sections of this report.
PS-1: Assessment and Management of Social & Environmental Risks and Impacts
KPCL has developed an Integrated Management System (IMS) in accordance with the requirements of ISO
9001:2008 (quality management), ISO 14001: 2004 (environmental management) and BS OHSAS 18001:2007
(occupational health and safety management). Accordingly, Bureau Veritas has granted certification to KPCL (for all
three plants) for operation and maintenance of HFO based power plants including associated activities. KPCL has
developed an IMS Manual (dated June 2014 and subsequently revised), and integrated the standards for compliance
and appropriate implementation. KPCL has formulated an Integrated Management System (IMS) Policy for operation
and maintenance of the Plants. KPCL has developed procedures for identification of EHS risks and impacts and
maintained document pertaining to results of identification of hazards, risk assessments and controls provided.
KPCL has implemented a ‘Community Engagement & Development CSR Programme’ in association with DEG for
the Khulna project. KPCL has engaged NGO Paribartan for the CSR works. Paribartan is actively involved in the
Khalispur area since last three (3) years for CSR activities such as skill development, health care and education. The
community also reported that they were satisfied with the ongoing community development activities of KPCL.
Overall compliance with PS1 is adequate, however, following non-compliances against IFC PS1 have been observed
during the assessment process.

ESMS: The IMS Manual developed by KPCL is focused on O&M aspects of the plant, however it may be
May 2016
i
H&S aspects for operation phase, however it does not focus on social aspects.

Identification of risks and impacts: An Environmental Impact Assessment study was conducted for Unit-1
(barge mounted unit) in 1998 which has considered environmental and social impacts due to project. It was
reported by KPCL that for the 115 MW Unit, that was subsequently set up in the same premises, impact
assessment study has not been conducted. Therefore cumulative impacts on ambient air quality, noise
levels and water resources and quality due to operation of both the units have been assessed.

and social management system. KPCL has identified an Environmental Officer and a Safety Officer, which
are additional responsibilities given to Senior Engineers, to handle site specific environmental and H&S
issues for both units. The team member identified as Environmental Officer is adequately experienced but
not formally qualified in the subject.

PS-2: Labour and Working Conditions
separate from that of SCL’s HR Policy and applicable to KPCL operations at all three plants. The Policy has been
prepared with the intention of keeping it subservient to the government laws and commits to modification with any
change in legal requirement in future. The employees are made aware of the policy document and terms and
conditions. Occupational health and safety management is adequately covered through the various procedures of
IMS.
Considerable non-compliances with respect to PS2 and adherence to Bangladesh Labour Law (2006) have been
observed during the assessment process. These include the following:


grievances raised.

Contract Worker Management: KPCL does not have a mechanism to monitor the adherence of labour


May 2016
ii
PS-3: Resource Efficiency and Pollution Prevention
A detailed Environmental Management System, including environmental monitoring, is put in place by KPCL and
implemented through the IMS. KPCL has developed, and maintains register on Environmental Aspects associated
with project operation. Task wise aspects and impacts have been identified at different locations inside the plant
vicinity. The project also undertakes a compliance evaluation with respect to applicable legislation and regulatory
requirements and maintains such records in Legal Compliance Register.
Monitoring of stack emissions, ambient air and ambient noise is conducted by the management at the facility and
quarterly reports are submitted to DoE. Stack emission monitoring is carried out on annual basis by third party. The
stack emission values of Sulphur dioxide and oxides of nitrogen are within the permissible IFC limits, though the
sulphur content in fuel is more than the permissible IFC value of 2%.
An air modelling exercise using AERMOD 8.1.0 was conducted for the operation of 115 MW plant (Unit II) to
ascertain the impact of air emissions from combustion of HFO at existing firing rate. As per the results, the maximum
incremental concentration is expected towards the North of the Plant at a distance of 160 – 200 m. The maximum
incremental Ground Level Concentration of SO2, NOx and SPM due to operation of KPCL plant is expected to be
mostly within prescribed limits. Although the baseline data suggests that the current condition of air shed is nondegraded, the cumulative contribution of the plant is not expected to make the air shed degraded. There is a need to
collect robust baseline data within 5km radius of the plant to understand the existing impact of the air emissions, as
of now the information is limited to comment on the baseline status. The details are presented in Annexure B of the
report.
Non-compliances with respect to PS3 have been observed during the assessment process. These include the
following:

Water consumption: Groundwater extraction records are not being maintained as the bore well at site is
not metered. The cumulative stress on ground water resources of the area is unascertained. Measures for
water conservation are not being practiced at site.


periods and therefore not comparable to permissible standards due to absence of 24-hourly guidelines by
IFC-WB and Bangladesh national AAQ standards

level monitoring through external laboratory is also not conducted for any of the units.

Surface water quality monitoring: Though KPCL monitors treated wastewater and basin water prior to
discharge into the river, river water quality is not being measured at any point. Only the temperature of river
water at upstream and downstream locations of intake and outfall points are measured on monthly basis
and records are maintained. Further, no records pertaining to discharge quantities are maintained at site.
PS-4: Community Health Safety and Security
The project has established Environmental, Health and Safety aspects associated with emergency preparedness
and response measures as part of its IMS. These procedures identify potential for emergency situations, establish
May 2016
iii
response mechanism to such emergency situations and prevent / mitigate associated adverse environmental, H&S
and social consequences. However following non-compliances have been identified under PS-4:


observed to have been undertaken by KPCL.
PS-5: Land Acquisition and Involuntary Resettlement
The facility is constructed over 5.5 acres of land leased from Padma Oil Company Limited through BPDB. It was
reported during interactions with site management and community that the land on which the Plant is established
was lying vacant prior to development. The project, thus, did not involve any kind of physical or economic
displacement. Based on the media search and discussions with the plant management it is also understood that
there are no litigations regarding the ownership of this land. The requirements of PS-5 are thus not triggered in this
case.
PS-6: Biodiversity Conservation and Sustainable Management of Living Natural Resources
The project is located in an urban set up in Goalpara power plant complex of Khalispur area. The area also has other
industries with no identified significant natural vegetation. There are no legally protected areas or critical habitats
reported within 5km radius from the plant. The plant thus does not have any adverse impacts on the terrestrial
ecology of the area.
Cooling water from the 110 MW Unit is drawn from the River Bhairab and discharged back into it, at a depth of 6-7
m. and it is essential to monitor and ensure that incremental change in water temperature is in compliance with the
stipulated limits.
The temperature of intake and discharged water is monitored on continuous basis through
temperature sensors installed at the intake and outfall points. KPCL monitors the process temperature difference on
real time basis from control room on the barges. River water temperature measurements are taken on monthly basis
at both upstream location of intake point and downstream location of outfall point, at every 10 m distance up to 100
m. The incremental temperatures recorded are in compliance with IFC-WB thermal discharge guidelines. The project
is therefore in compliance with the requirements of PS-6
PS-7: Indigenous People
Khalispur area of Khulna division has not reported presence of any indigenous community. Also, based on
information gathered on past land use of project site, it is understood that the project did not involve any impact on
indigenous peoples due to land procurement. Therefore, the requirements of PS-7 are not triggered in this case.
PS-8: Cultural Heritage
May 2016
iv
Secondary literature review and discussions with the site representatives and community suggest that there no
known archaeological structure of importance in or around the project site. The project operation does not affect any
structure of cultural significance. It may also be concluded that there is no possibility of chance find at the project
site, since the management does not have any proposed plans for expansion. Therefore, the requirements of PS-8
are not triggered in this case.
It was observed that the plant is in compliance with all legal requirements. A robust E&OHS management system is
implemented at site, which is well documented, monitored and reviewed from time to time. Stack emissions
monitored periodically are mostly within the DOE limits and World Bank guidelines. The management also has a
robust community engagement program implemented through a third party. Moreover, there are no media reports or
document in public domain regarding any existing litigations or disputes with community.
It was noted that IFC had funded Unit-1 of the facility in the year 1998 and on the basis of project appraisal, the
project was categorized as Category B. Subsequently, the facility was expanded and Unit – 2 (115 MW) was
installed in 2011 within the same premises, thus taking the cumulative capacity to 225 MW. The project can therefore
be categorized as Category A on the basis of following rationale:

The facility uses HFO as fuel which results in significant air pollution in the ambient environment in the form
of particulate matter, Sulphur dioxide and oxides of nitrogen levels along with greenhouse gas emissions
which contributes to climate change;

The facility releases considerable quantities of thermal discharges into the River Bhairab that potentially
have adverse impacts on aquatic ecology;

The plant operations have significant noise generation, that can potentially impact the employees and
surrounding community;

Use of HFO results in generation of significant amounts of oily sludge which is hazardous in nature and
requires proper storage and disposal mechanism; and

Large quantities of fuel storage on site pose potential safety hazards for workers and surrounding
community.
Areas of improvement have been identified and recommendations have been provided in Section 4.0.
May 2016
v
Framework, HFO Based Power Plant,
KPCL, Khulna
6
2.0 Khulna Power Company Limited
2.1
Background
Khulna Power Company Limited (KPCL) is the first independent power producer (IPP) in Bangladesh. KPCL was
established under the Private Sector Power Generation Policy of Bangladesh in 1997 as a private limited company
and was later converted into a public limited company in 2009. The shareholders in the company include United
Enterprises and Company Limited (UECL), SCL and SPL.

United Enterprises & Company
limited: 35.28%

Summit Industrial & Mercantile
Corporation
(Pvt.)
Limited
:
17.64%

Summit Power Limited : 17.64%

Other Sponsors: 0.02%

General Investors: 29.41%
KPCL started commercial operations of the 110 MW barge mounted HFO based power plant on 13th October 1998.
The formation of KPCL plant was initially sponsored by Summit Group and United Group along with their foreign
partner El Paso Corporation (El Paso), USA, and Wärtsilä Corporation (Wärtsilä), Finland. In 2008, El Paso, as part
of its global repositioning strategy disposed of its shares in KPCL to Summit Group and United Group. Later in 2009,
Wärtsilä’s share was also acquired by Summit and United.
KPCL has two subsidiary companies - Khulna Power Company Unit II Ltd. (hereinafter referred to as KPC II) and
Khanjahan Ali Power Company Ltd. (KJAPCL). KPC II was incorporated on 22nd June 2010 for setting up another
HFO based power plant with capacity 115 MW. The KPC II plant is located at the extended premises of the KPCL
plant at Khulna. The KPC II plant achieved Commercial Operation Date (COD) on 01st June 2011. Khanjahan Ali
Power Company Ltd. (KJAPCL) operates a 40 MW HFO based power plant at Noapara, Jessore.
The KPCL plant and both of its subsidiary units (KPC II and KJAPCL) subsequently amalgamated with KPCL with
effect from 30th September 2014. Since commissioning all three plants were being operated and maintained by
Wärtsilä Bangladesh Ltd., a 100% owned subsidiary of Wärtsilä OY, Finland, under a long term O&M Agreement.
However from 13th December 2013, O&M of KPCL plant and from 22nd January 2014, that of KPC II and KJAPCL
plants have been handed over to KPCL.As on date, KPCL is the common management for all three plants.
May 2016
KPCL, Khulna
7
To summarize, the HFO based facility comprises of two units (collectively referred to as ‘Plant/ facility’) within the
same premises:
Unit 1: 110 MW barge mounted HFO based power plant
The 110 MW barge mounted power plant comprises of nineteen (19) generator units placed on two floating barges
within an artificially created confined basin, with total installed capacity of 117.8 MW. The two barges are referred to
as Tiger I (comprising 9 generator units) and Tiger III (comprising 10 generator units), each having 6.2 MW
generation capacity. Each barge has dimension 91.5 m X 24.4 m and holds fuel tanks and outdoor substation. The
th
commercial operation date (COD) of Unit 1 was 13 October 1998.
Unit 2: 115 MW HFO based power plant
The 115 MW power plant comprises of seven (7) generator units each having 17 MW capacity, with total installed
st
capacity of 119 MW. The commercial operation date (COD) of Unit 2 was 01 June 2011.
2.2
Organisation Structure
The corporate office of KPCL is based out of Dhaka in Bangladesh. The Managing Director of KPCL is the
organizational head and leads the plant operations at corporate level. He is supported by the Asset Manager and
Financial Controller who maintain their office at Dhaka. The operation and maintenance team at the plant level is led
by the Plant Manager who heads the Operation, Maintenance, Administration and Logistics departments. Total
number of employees at the plant level is 145, including 70 for Unit-1 and 75 for Unit-2.
There is no dedicated EHS Department at either corporate or project level. KPCL has assigned additional
responsibility to a Senior Engineer for managing environmental and occupational health and safety issues for both
units. The Environment Officer also functions as the operative EMS Advisor and is responsible for monitoring and
reporting of environmental aspects and Emergency Preparedness and Response. A technician identified under the
Environmental Officer is responsible for environmental monitoring. The Logistics Officer under the Plant Manager is
responsible for waste disposal management, while the Administration Manager, implement the EMS training matrix.
KPCL has also assigned the H&S responsibility as Safety Officer to another of the Senior Engineers employed at
site. He is responsible for maintaining records and statistics related to OHS procedures developed for plant
operations such as incident reporting, safety inspections, fire and first aid equipment inspections, etc. The
Departmental Heads are responsible for hazard identification, departmental risk assessment and execution of OH&S
related activities. An OH&S Committee has also been formed at plant level, responsible for consultation,
communication and receiving feedback from employees. A Quality team has also been formed at plant level, for
reviewing the OH&S programs, policy and audit reports.
May 2016
KPCL, Khulna
8
Figure 2-2: Organizational Structure - KPCL
Corporate
Level
Managing Director
Financial
Controller
Asset Manager
Manager
Operations
Sr. Deputy
Manager
Operations KP &
KII
Sr. Bunkering
Engineer
Senior Laboratory
Chemist
Plant Manager
Sr. Manager
Maintenance
Dy. Manager
Mech. Maint.
Dy. Manager Elec.
Maint.
Sr. Manager
Administration
Admin. Officer
Deputy Manager
Logistics
Supdt. Engineer
Logistics
G&A Executive
Executive
Engineer Mech.
Executive
Engineer KjAP
Operations
2.3
Facility Details
This sub-section presents the details of the facility comprising both units – 110 MW and 115 MW. The location of the
plant, site settings, process used for power generation, details of the engine, utilities and associated facilities are
described below.
2.3.1
Location and Site Settings
The plant is located in Goalpara Mouza under Ward No. 7 of Khalishpur Thana (sub-district), Khulna District, Khulna
Division, Bangladesh, on the right bank of River Bhairab. The site is surrounded by River Bhairab on north, BPDB’s
Goalpara Grid Substation on the east, petroleum terminal of Padma Oil Company Limited on the west, and public
road on the south. The KPCL plant is also in close proximity to the 150 MW gas based power plant of North-West
Power Generation Co. Ltd. (NWPGCL), 100 m towards south. The plant is approachable by the public road which
passes through residential areas of Khalishpur. Figure below shows the indicative location of the KPCL Plant in
Khulna.
May 2016
KPCL, Khulna
9
Figure 2-3: Indicative Location of Power Plant
2.3.2
Land Details
The 110 MW Unit is constructed over 4.7 acres of land taken on lease by KPCL from the Padma Oil Company
Limited. The Bangladesh Power Development Board (BPDB) took lease of the land from Padma Oil through lease
deed, dated 5th February 1998, for a term of 17 years. Thereafter an indenture of lease was executed between KPCL
rd
and Bangladesh Power Development Board (BPDB) on 3 June 1998 in order to set forth the terms and conditions
th
governing the use of the land. The first amendment to the indenture was executed on 16 September 2015 wherein
the tenure of the lease was extended for another 5 years.
For installation of the 115 MW unit, KPCL further leased 0.8 acres (3100 sq. m.) of land for a period of 5 years,
through execution of indenture of lease with BPDB on 19th February 2012. BPDB had obtained this land from Padma
th
Oil, through lease agreement dated 15 February 2012. Thus the total area of the Plant comprising both units is 5.5
acres.
2.3.3
Process Description
Both units are based on power generation from reciprocating engine generator sets. Primary operation is on heavy
fuel oil (HFO). Reciprocating generators have two main components: an internal combustion (IC) engine which
converts chemical energy of fuel into mechanical energy, and an alternator for converting the mechanical energy into
electrical energy. Reciprocating IC engines that use diesel (or HFO) are compression ignited. In order to facilitate
combustion of fuel in the engine, air is compressed until the temperature rises to the auto-ignition temperature of the
fuel. As the fuel is injected into the cylinder, it immediately combusts with the hot compressed air and expanding
May 2016
KPCL, Khulna
10
combustion gases push the piston to the bottom of the cylinder. Each movement of the piston within a cylinder is
called a stroke. For electric power generation, four-stroke engines are predominately used.
For the purpose of power generation, diesel IC engines are grouped into blocks called generating sets. Every engine
is connected to a shaft which is connected to its electric generator. These generating sets provide modular electric
generating capacity. The 110 MW power plant comprises 19 generating sets (9 on Tiger I and 10 on Tiger III), each
having 6.2 MW generation capacity. Similarly, 115 MW power plant comprises seven (07) generating sets each
having 17 MW capacity. The three groups of generating sets are installed within three separate engine halls.
Heavy fuel oil (HFO) for both the units is procured from Summit Asia Pacific Pte Ltd and United Energy Trading Pte
Ltd. The fuel is supplied through oil tankers via River Bhairab up to the jetty. The fuel is transferred to the HFO
storage tanks located near the main gate, through pipeline. The fuel received is highly viscous, having viscosity of
180 cSt at 50°C, therefore it is heated by steam to a temperature of 40°C in order to increase the pump ability.
Approx. 600 MT/ day of fuel is used for power generation at Unit-1 while 550 MT/day is used in Unit-2. There are
transfer pumps for transferring HFO to buffer tanks, where the HFO settles down. The transfer pumps are equipped
with heaters for increasing the temperature to 60°C. From the buffer tanks, the HFO is sent to separation units for
purification. HFO is further heated to 95°C to facilitate separation. The purified HFO goes to the day tanks for storage
and feed, while the sludge is sent to the sludge tank for further disposal.
From the day tanks, HFO is fed to booster units via feeder pumps, at 4 - 5 bar pressure. The booster units are
equipped with filters and pumps to pump the HFO to the injection system of the engines. The viscosity of the HFO at
this stage is about 20 cSt and temperature 110 - 120°C. The fuel is injected to diesel engine cylinders at 500-600 bar
pressure. Compressed and charged air, at 2 – 3 bar pressure, is also fed into the engines to facilitate combustion.
Combustion of the air-fuel mixture in the cylinder causes an accelerated expansion of high pressure gases, which
push the piston to the bottom of the cylinder during the power stroke, imparting rotation to the crankshaft.
Combustion occurs intermittently only during the power stroke. As the piston is returned to the top of the cylinder
during the exhaust stroke, the exhaust gases are pushed out an exhaust valve. Exhaust emissions from the diesel
engine mainly consist of nitrogen, oxygen and combustion products like carbon dioxide (CO2), water vapour and
minor quantities of carbon monoxide (CO), sulphur oxides (SOx), nitrogen oxides (NOx), partially reacted and noncombusted hydrocarbons (HC) and particulate matter (PM). The exhaust gases pass through exhaust gas boiler
wherein water is heated for recirculation into the engine for heating of input fuel. The steam is released into the
atmosphere through vents and the exhaust gas comes out from the exhaust gas stack. The 110 MW plant has 19
stacks (9 on Tiger I and 10 on Tiger III) while the 115 MW plant has 7 exhaust stacks.
The engine cooling arrangement of 115 MW power plant is based on closed circuit radiator cooling and no water is
required for cooling the engines. However in case of 110 MW plant, water based cooling arrangement is used for the
engine cooling system. Cooling water is drawn from River Bhairab and the heated water is discharged back into the
river.
The power is generated by the generators (at 15 kV from Unit-1 and 11 kV from Unit-2) and stepped up by
transformers to 132 kV for transmission to the national grid. Both the plants have separate switchyards, the barges
accommodate the switchyard for the 110 MW plant while the switchyard for 115 MW plant is on shore.
2.3.4
Details of Engine and Specifications
Unit-1 comprise of 19 generating sets with engine type VASA18V32LN, Wärtsilä make, while Unit-2 has 7 generating
sets with engine type W18V46, Wärtsilä make. The reciprocating engine is comprised of cylinder block, valves,
pistons, connecting rods, and a crankshaft. The specifications of the engine are as provided below:
May 2016
KPCL, Khulna
11
Wärtsilä VASA18V32LN and W18V46 engines are 4-stroke, non-reversible, turbocharged and intercooled diesel
engines with direct fuel injection. The specification of each engine is presented below:
Table 2-1: Technical data Wartsila VASA18V32LN and W18V46 Engines
S. No.
Parameter
Specification
VASA18V32LN
for
Specification for W18V46
1.
Cylinder bore
320 mm
460 mm
2.
Stroke
350 mm
580 mm
3.
Piston displacement
32.2 l/ cylinder
96.4 l/cylinder
4.
Number of valves
2 inlet valves
2 inlet valves
2 exhaust valves
2 exhaust valves
5.
Cylinder configuration
18 in V-form
18 in V-form
6.
V-angle
55°
55°
7.
Speed
720 rpm
500 rpm
8.
Mean piston speed
8.4 m/s
9.67 m/s
9.
Compression Ratio
13.8:1
14:1
10.
Engine output
9000 kW
19200 kW
11.
Temperature at turbocharger intake, max.
45°C
45°C
12.
Air temperature after air cooler
55°C
50°C
13.
Temperature after turbocharger, 100% load
379°C
3
374°C
3
14.
Fuel flow to engine, approx.
9.1 m /h
15.1 m /h
15.
Fuel consumption at 100% load, HFO
183 g/ kWh
178 g/ kWh
Each engine has the following primary components:

Engine Block: The engine block is cast in one piece for all cylinders, with the charge air receiver located
between the cylinder banks. The engine block also comprises a hydraulic jack and oil sump.

Crankshaft: One crank shaft mounted on the engine block.

Piston: One (1) piston of composite design with nodular cast iron skirt and steel crown. Oil is fed through the
connecting rod to the cooling spaces of the piston.

Cylinder Head: This is made of grey cast iron, having inlet and exhaust valves. The bridges between the
valves are provided with cooling channels wherein cooling water can pass. A “multi-duct” casting is fitted to
the cylinder head which connects following with the cylinder head – charged air from the air receiver,
exhaust gas to exhaust system and cooling water from cylinder head to the return pipe.

Turbocharger: The engines have one turbocharger per cylinder bank, placed at the free end. The
turbocharger is supplied with inboard plain bearings, which offers easy maintenance of the cartridge from
the compressor side. The turbocharger is lubricated by engine lubricating oil with integrated connections. All
engines are provided with devices for water cleaning of the turbine and the compressor. The cleaning is
performed during operation of the engine.

Combustion air system: Combustion air is taken from the engine room through a filter on the turbocharger.
The combustion air shall be supplied by separate combustion air fans, with a capacity slightly higher than
the maximum air consumption.

Fuel injection system: The fuel injection equipment and system piping are located in a hotbox and the fuel
oil feed pipes are mounted directly to the injection pumps. There is one fuel injection pump per cylinder with
shielded high-pressure pipe to the injector.
May 2016
KPCL, Khulna

12
Lubricating oil system: The engine internal lubricating oil system includes engine driven lubricating oil pump,
electrically driven pre lubricating oil pump, thermostatic valve, filters and lubricating oil cooler. The
lubricating oil pumps are located in the free end of the engine, while the automatic filter, cooler and
thermostatic valve are integrated into one module.

Cooling water system: In case of 110 MW plant, treated fresh water containing corrosion inhibitors are
circulated through the engines to reduce the temperature. The hot water is then discharged into the river
through outlet valves. The engine’s cooling system (primary circuit) is divided into two circuits, the high
temperature circuit (HT) and low temperature circuit (LT). The HT-circuit is cooling the cylinders, the
turbocharger(s) and in engines equipped with split charge air coolers, also the first stage of the charge air.
HT water is maintained at temperature of about 70 to 95°C. The LT-circuit is cooling the second stage of the
charge air and the lube oil circuit through lube oil heat exchanger. Here water is maintained at a
temperature of 40 to 50°C. Temperature control valves regulate the temperature of the water out from the
engine, by circulating some water back to the cooling water pump inlet. The heated discharge temperature
from outlet is in the range of 37 - 38°C. The 115 MW is based on closed circuit radiator based cooling with
zero cooling water requirement.

Exhaust gas system: The exhaust gases go to the exhaust gas boiler, which is a common boiler with
separate gas sections for each engine. The system is equipped with exhaust gas silencers or stacks. The
exhaust gas boilers are of water tube with forced circulation through the evaporator unit. The water
circulation is maintained by circulation pumps. The steam is separated from the water in the steam drum.
The drum is common for several boilers. A non-return valve on the steam outlet from the drum prevents
back flow when the boiler is not in use. The boiler system consists of steam drum, feed water pumps,
condensate tank and blow down tank.
2.3.5
Utilities and Associated Facilities
Fuel Storage and HFO separator
There are two HFO storage tanks of 7500 MT each, near the main gate of the facility. Heavy fuel oil (HFO) procured
from Summit Asia Pacific Pte. Ltd. and United Energy Trading Pte. Ltd. is supplied through oil tankers via River
Bhairab up to the jetty. The fuel is transferred to the HFO storage tanks through pipeline. Approx. 600 MT/ day of fuel
is used for power generation at Unit-1 while 550 MT/day is used in Unit-2. The fuel received has viscosity of 180 cSt
at 50°C. In order to reduce the viscosity and increase the pump ability, the fuel is heated to temperature of 40°C.
3
The HFO is heated and transferred to the buffer tank of capacity 150 m , via transfer pumps, where the HFO settles
down. From the buffer tank, HFO at 60°C is passed through separation unit for purification and further heating to
temperature of 95°C. Purified HFO is stored in day tanks, while the sludge is sent to the sludge tank (50 m3) for
further disposal. The facility has one onshore day tank of 300 m 3 which is used for the 115 MW plant. Each barge
accommodates one day tank each of 730 m3 capacity. There is one lube oil tank of 50 m3 capacity. Except the HFO
storage tanks, all the other day/ buffer tanks are located in day/ storage tank area near the jetty on the northern side
of the plant. Latest fuel analysis report conducted in March 2016 by Bureau Veritas for HFO supplied from Singapore
indicates that the sulphur content in fuel is 2.51%.
May 2016
KPCL, Khulna
13
Figure 2-4: HFO Distribution and Storage System
Water Storage and Treatment
Ground water is extracted through one bore well installed within the plant premises. About 26 tonnes per day of
ground water is required in both the plants for boiler make up water. The facility has one demineralization (DM) plant
located on the northern side of the plant near the jetty area. Prior to use in the process, raw ground water is treated
in the DM plant. The reject from the DM plant is discharged into the storm water drain. The cooling system for
engines of 115 MW unit is based on closed circuit radiator cooling. The cooling water requirement for the 110 MW
unit is met through river water. Heated water is discharged back into the river at a depth of 6 -7 m. About 10m3 per
hour of cooling water is reportedly required for both barges together and the same quantity is discharged. The
temperature of intake and discharge water is monitored on continuous basis through temperature sensors installed at
the intake and outfall points A temperature difference of about 7°C is recorded between the intake and outfall points
of T-I while T-III records about 14°C temperature difference.
Sewage Treatment Plant
The domestic sewage from the toilets in the administrative block goes to septic tanks, capacity not known. Each
3
barge has a sewage treatment plant (9 m /day) located on the lower deck of the barge. The Hamworthy Super
Trident sewage treatment unit is a self-contained system that is normally installed onboard ships and marine vessels
for treatment of domestic sewage. It operates on the aerobic principle of sewage digestion coupled with treatment of
the final effluent. The unit comprises of a tank, divided into aeration compartment, settling compartment and chlorine
contact compartment. The unit is equipped with discharge pumps to discharge the treated wastewater over board
into the barge basin.
Boilers
The plant has three heat recovery boilers (one on each barge and one onshore) which recover heat from the engine
cooling water system. The steam generated is used for pre-heating of HFO to ensure reduction in viscosity of the
fuel.
Fire and Bunkering Station
The facility has a fire and bunkering station near the HFO storage area. Firefighting and fireman’s equipment is
stored inside the station. There is an underground fire bunker that will act as shelter in event of explosion due to
major fire.
May 2016
KPCL, Khulna
14
Lube Oil Storage Tanks
The facility has lube oil tanks, one near the jetty area and one each on the lower deck of the barges. For engine
lubrication and cleaning, Mobil (MOBILGARD M50) lubricating oil and Petronas (DISROL 500) is used as per the
engine manufacturer’s specification. The facility has a lube oil storage yard near the fire bunkering station where 200
liter drums of fresh lube oil are stored. Empty drum storage area has also been provided in front of the lube oil
storage yard.
Jetty
There is one permanent jetty on the northern side of the plant for receiving fuel via tankers. The jetty is common for
both the plants. The jetty is equipped with hose pipe to draw oil from supply tankers with the help of a pump
dedicated for unloading, and a manually operated oil boom.
Transmission Lines
Power is evacuated at the BPDB substation adjacent to the facility towards east. Hence transmission lines have not
been set up as part of the project.
2.3.6
Status of Permits
KPCL has entered into the following agreements for the Plant:
Table 2-2: List of Agreements
Sl. No.
1.
Agreement
Power
Purchase
Agreement
(PPA)
with
For 110 MW Unit
For 115 MW Unit
IPPA originally executed on
Agreement
th
Bangladesh Power Development Board (BPDB)
16
IPP/ Rental
on 31 March 2014, valid up
October 1997, extended
st
th
to 12 October 2018
for
supply
of
electricity on Rental basis for
5 years signed with BPDB,
executed on 23
rd
June 2010,
st
valid up to 31 May 2016
2.
3.
th
Implementation Agreement (IA) with Government
Executed
on
16
of Bangladesh
1997
Land Lease Agreement (LLA) with BPDB
Executed on 3
rd
extended on 16
th
October
June 1998,
September
rd
Executed on 23 June 2010
Executed on 19
th
February
2012, for 5 years
2015 for 5 years
The status of the various permits obtained from regulatory authorities is as provided in Table 2-3.
S.
N.
Type of Permit
Unit 1: 110 MW
1.
Factory License
Issue Date
2016
2.
Environment
Clearance certificate
nd
02 April 2015
Unit 2: 115 MW
Validity
Up to 2017
th
14
March
2016,
application filed
for renewal on
th
16 Feb 2016
Issue Date
2016
Issuing Authority
Validity
Up to 2017
th
24
2016
August
Chief Inspector
Factories
of
Department
Environment
of
May 2016
KPCL, Khulna
S.
N.
Type of Permit
Unit 1: 110 MW
3.
Permission to Store
Liquid Fuel
Validity
st
31 December
2018
4.
Fire License
Valid
5.
Boiler License
6.
License to use shore
02 December
2015;
fees
deposited
for
subsequent
year, renewed
license awaited
7.
Trade License
30 June 2016
8.
Barge Classification
certificate
Issue Date
2.4
Registration of
Boilers 211617 and 213641 of barges
Registration
no. Tiger I:
24516A
and
Tiger
III:
24531R
Unit 2: 115 MW
Issue Date
Issuing Authority
Validity
st
31 December
2018
Valid
st
01
January
2016,
application filed
for renewal of
license
Registration of
Boilers 7117-19
15
Chief Inspector
Explosives
Asstt. Director, Fire
Service
&
Civil
Defence, Khulna
st
Chief Inspector
Boilers
nd
BIWTA
th
01
January
2016,
application filed
for renewal of
license
of
of
nd
02 December
2015;
fees
deposited
for
subsequent
year, renewed
license awaited
th
30 June 2016
Khulna
Corporation
NA
Bureau Veritas (BV)
th
Tiger I: 29
June 2017
NA
City
th
Tiger III: 16
October.2017
Environment Health, Safety and Social Scenario
KPCL is certified by Bureau Veritas on plant operation and maintenance guided by Integrated Management Systems
(IMS) complying with three International standards ISO 9001:2008 for Quality, ISO 14001: 2004 for environment and
BS OH&S 18001:2007 for occupational health and safety. All the policies and procedures developed by KPCL is
independent and separate from that of Summit Corporation Limited.
2.4.1
Environment
The operations of KPCL are guided by the IMS manual, which includes the requirements under ISO 14001:2004.
KPCL, as part of its Operations & Maintenance has established, documented, implemented and maintained an
Environmental Management System (EMS) with thirteen (13) mandatory procedures to meet ISO14001:2004
requirements by establishing an environmental management program (based on Plan-Do-Check-Act principle) as
part of the Integrated Management System.
KPCL’s has formulated an Integrated Management System (IMS) Policy which provides for following commitments
on environmental management:

Support for conservation of the physical environment and the prevention of pollution at the facilities.

Proactively comply with all applicable environmental legal and regulatory requirements to which it
subscribes.
KPCL has established and employed metrics that are used to measure its performance against core objectives that
cover operational parameters such as health and safety, quality, the environment, materials management, and
May 2016
KPCL, Khulna
16
customer satisfaction. KPCL subscribes to continual improvement by monitoring its objectives through internal
auditing, analyzing data, reviewing performance and implementing corrective and preventive actions.
The key procedures maintained by KPCL are:




Planning
o
Environmental Aspects
o
Legal and other requirements
o
Objectives, Targets and Programs
Implementation and Operation
o
Resources, Roles, Responsibility and Authority
o
Competence, Training & Awareness
o
Communication
o
Documentation
o
Control of Documents
o
Operational Control
o
Checking
o
Monitoring and measurement
o
Evaluation of compliance
o
Nonconformity, Corrective and preventive action
o
Control of records
o
Internal Audit
Management Review
KPCL has identified key staff members and their responsibilities towards implementation of requirements of the
Environment Management. At the company level, all plants are headed by the Chairman Mr. Hassan Mahmood Raja,
along with Mr. Abdur Rahim, Managing Director and Mr. AMM Atiqul Islam, Asset Manager. The KPCL facilities at
plant level are headed by the Plant Manager, Mr. Sreenath Acharaya.
The Managing Director also has the additional responsibility of being the Environmental Coordinator at the Company
level, while the Plant Manager is responsible for development planning and implementation of the EMS Manual as
Management Representative (MR), besides conducting training and internal audits.
A Management Team has been formed under the Plant Manager to review the Environment Management System
and its implementation. The Environment Officer identified under the Plant Manager also functions as the operative
EMS Advisor and is responsible for monitoring and reporting of environmental aspects. The Environmental Officer is
also responsible for implementation, verification of equipment and trainings on Emergency Preparedness and
Response. A technician identified under the Environmental Officer is responsible for environmental monitoring.
The Logistics Officer under the Plant Manager is responsible for waste disposal management, while the
Administration Manager is responsible for implementing the EMS training matrix. All Managers are responsible for
operative implementation of EMS plan to their respective department, develop procedure and train personnel.
Figure 2-5 depicts the organization chart with roles and responsibilities for EMS implementation.
May 2016
KPCL, Khulna
17
2.4.2
Health and Safety
KPCL has established, documented, implemented and maintained an OHSAS Management system with thirteen (13)
mandatory procedures to meet British Standards OHSAS 18001:2007 requirements on Plan-Do-Check-Act principle
as part of the Integrated Management System (IMS).
The OHSAS program includes Hazard Identification and Risk Assessment (HIRA), Bio-Safety checklist update prior
to each activity as applicable aiming to achieve Zero injury target, use of Personal Protective Equipment (PPE), First
Aid, Intake of oral rehydration salts (ORS) against dehydration and medical check-up as required. It was also noted
that Factory Inspector’s endorsement on hazardous equipment and tools maintenance and other controls meet
safety requirements.
The IMS Policy established by KPCL management demonstrates the company’s commitment towards health &
safety by ensuring that it:

is appropriate to the purpose of the organization, including the nature and scale of its OH&S risks

includes a commitment to prevent injury and ill health and continual improvement in IMS management
performance

provide a framework for establishing and reviewing health and safety objectives

is communicated to all persons working under the control of and for the organization with the intent that they
are made aware of their individual quality and /or EHS obligations
2.4.3
Social and Stakeholder
KPCL has implemented a ‘Community Engagement & Development CSR Programme’ in association with DEG for
the Khulna project. KPCL has engaged NGO Paribartan for the CSR works. Paribartan is actively involved in the
Khalispur area since last three (3) years for CSR activities such as skill development, health care and education.
Community dialogues and focused group discussions with various stakeholders including NGOs, Local Community,
and Government are conducted on monthly basis to record grievances and receive suggestions. The CSR programs
are based on need assessment studies conducted on periodic basis. KPCL also has mechanism to monitor the
status of activities through monthly reports and periodic third party evaluation of the entire programme.
May 2016
KPCL, Khulna
18
Paribartan reported that the CSR programme has benefitted the community in terms of increased income generation
among the local people, women empowerment, cleanliness and improved health care services. The community also
reported that they were satisfied with the ongoing community development activities of KPCL.
2.5
It was observed that the plant is in compliance with all legal requirements. A robust E&OHS management system is
implemented at site, which is well documented, monitored and reviewed from time to time. Stack emissions
monitored periodically are mostly within the DOE limits and World Bank guidelines. The management also has a
robust community engagement program implemented through a third party. Moreover, there are no media reports or
document in public domain regarding any existing litigations or disputes with community.
It was noted that IFC had funded Unit-1 of the facility in the year 1998 and on the basis of project appraisal, the
project was categorized as Category B. Subsequently, the facility was expanded and Unit – 2 (115 MW) was
installed in 2011 within the same premises, thus taking the cumulative capacity to 225 MW. The project can therefore
be categorized as Category A on the basis of following rationale:

The facility uses HFO as fuel which results in significant air pollution in the ambient environment in the form
of particulate matter, Sulphur dioxide and oxides of nitrogen levels along with greenhouse gas emissions
which contributes to climate change;

The facility releases considerable quantities of thermal discharges into the River Bhairab that potentially
have adverse impacts on aquatic ecology;

The plant operations have significant noise generation, that can potentially impact the employees and
surrounding community;

Use of HFO results in generation of significant amounts of oily sludge which is hazardous in nature and
requires proper storage and disposal mechanism; and

Large quantities of fuel storage on site pose potential safety hazards for workers and surrounding
community.
Areas of improvement have been identified and recommendations have been provided in Section 4.0.
May 2016
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19
3.0 Document Review and Assessment of Compliance
This section details the compliance of the project with respect to requirements under IFC Sustainability Framework
and applicable national and local regulations. The observations made during the due diligence and gaps identified
are discussed herewith.
3.1
Performance Standard (PS) 1: Assessment and Management of Social &
Environmental Risks and Impacts
3.1.1
Environment and Social Assessment and Management System
Requirement 1
Performance Standard 1 emphasizes on the need of an effective Environmental and Social Management System
(ESMS) focusing on dynamic and continuous process initiated and supported by management, and involves
engagement between the client, its workers, local communities directly affected by the project (the Affected
Communities) and, where appropriate, other stakeholders.
As per PS 1, the client will conduct a process of environmental and social assessment establish and maintain an
Environmental and Social Management System (ESMS) appropriate to the nature and scale of the project and
commensurate with the level of social and environmental risks and impacts throughout the life cycle of the project.
The ESMS should incorporate the following elements:








Policy
Identification of risks and impacts
Management programs
Organizational capacity and competency
Stakeholder engagement
Monitoring and review
External Communication and Grievance Mechanisms
Observation 1
KPCL has developed an Integrated Management System (IMS) in accordance with the requirements of ISO
9001:2008 (quality management), ISO 14001: 2004 (environmental management) and BS OHSAS 18001:2007
(occupational health and safety management). Accordingly, Bureau Veritas has granted certification to KPCL (for all
three plants) for operation and maintenance of HFO based power plants including associated activities, vide
certificate no. IND14.5470U/Q/E/OHS, valid up to 11th November 2017, which was displayed within the plant
premises.
The Integrated Management System (IMS) of KPCL is applicable to all the three plants operational under the
company. KPCL has developed an IMS Manual (dated June 2014 and subsequently revised), and integrated the
standards for compliance and appropriate implementation.
The Integrated Management System was reviewed as part of the assessment and the observations are presented
below:

The management system is focused on Operation & Maintenance aspect of the project, which is adequate
as the project is in operational stage, however it may be inadequate in case of any future expansion or
additional land requirement, as it does not cover pre construction and construction stage management.
May 2016
KPCL, Khulna

20
The IMS has identified sixteen (16) procedures on environment, health and safety and covers the following
aspects for management:
o
Processes needed for quality, environmental & OHS management system and their application
throughout the organization.
o
Sequence and interaction of these processes
o
Criteria and methods needed to ensure that both operation and control of these processes are
effectively determined
o
Availability of necessary resources and information to support the operation and monitoring of
these processes is ensured.

o
The processes are monitored, measured and analyzed and
o
Actions are implemented to achieve planned results and continual improvement of the processes.
It is observed that the three-tier document adequately covers the requirement for Environmental and
Occupational Health and Safety; however, the management system does not focus on social aspects.

The team member identified as Environmental Officer is adequately experienced and is responsible for
monitoring and reporting of environmental aspects and Emergency Preparedness and Response, but is not
formally qualified in the subject.
3.1.2
Policy
Requirement 2
The client will establish an overarching policy defining the environmental and social objectives and principles that
guide the project to achieve sound environmental and social performance. The policy should provide a framework for
the environmental and social assessment and management process and be consistent with the principles of the
Performance Standards.
Observation 2
KPCL has formulated an Integrated Management System (IMS) Policy for operation and maintenance of the Plants.
It is observed that the IMS policy is consistent with the principles of the Performance Standards and expresses
commitment towards safe plant operation and maintenance and minimal environmental pollution. KPCL also commits
to comply with all applicable legal and regulatory requirements pertaining to environment and safety.
The company, through its IMS policy, also expresses its commitment towards supporting the community through the
practice of corporate social responsibility. The policy further indicates that the company sets performance objectives
that cover health & safety and environment amongst others. The EHS performance of the projects is monitored on
regular basis through internal audits, performance reviews and implementation of corrective and preventive actions.
The policy is signed by the Managing Director of KPCL and Plant Manager, who is also the Management
Representative (MR), and is effective from 8th December 2015. The policy was observed to be displayed inside the
office building of KPCL Plant.
3.1.3
Identification of Risks and Impacts
Requirement 3
The client will establish and maintain a process for identifying the environmental and social risks and impacts of the
project. The type, scale, and location of the project guide the scope and level of effort devoted to the risks and
impacts identification process. The process may comprise a full-scale environmental and social impact assessment,
May 2016
KPCL, Khulna
21
a limited or focused environmental and social assessment, or straightforward application of environmental siting,
pollution standards, design criteria, or construction standards.
The client will establish legal requirements for both social and environmental parameters, including those laws
implementing host country obligations under international law, will also be taken into account.
Observation 3
Environmental and Social Impact Assessment
An Environmental and Social Assessment Report was prepared for the barge-mounted power plant in 1998 by ESG
International, as per requirements of Bangladesh Environmental Conservation Rules, 1997 and International Finance
Corporation. The report adequately assessed impacts on ambient air quality, noise levels, aquatic ecology, water
quality and socio-economic environment due to construction and operational activities of the plant. Air dispersion
modelling (ISC3), noise level prediction (ENM) and thermal plume modelling (Cornell Mixing Zone Expert System)
was also undertaken as part of the study to understand the potential impacts of the project on environment. Public
consultation was also undertaken in the project area to gather inform the community about the project and
understand their concerns. Based on the impact assessment and public consultation, management measures for
construction and operation phase were suggested in the form of an environment and social management plan
(ESMP).
It was observed during review of the ESIA report that impacts related to stress on groundwater resources in the area
due to plant operations have not been assessed. This could be considering the fact that the baseline groundwater
levels at the time of assessment were high in the range of 2 - 3 m. With subsequent growth of the city and increase
in industrial activities, there is an increase in the withdrawal of groundwater. The KPCL project reportedly draws
substantial quantity of ground water, though not recorded.
This ESIA study was conducted only for the barge-mounted unit. It was reported by KPCL that for the 115 MW Unit
that was subsequently set up in the same premises, impact assessment study has not been conducted. It is
therefore understood that cumulative impacts on ambient air quality, noise levels and water resources and quality
due to operation of both the units have been assessed.
It was observed that Environmental Aspect and Impact procedures have been established for the plant. Procedures
are maintained for:

Identification of the environmental aspects of activities, products and services within the defined scope of
environmental management system that it can control and those it can influence taking into account
planned or new developments, or new or modified activities, products and services and

Determination of those aspects that have or can have significant impact(s) on the environment (i.e.
significant environmental aspects)

Significant environmental aspects are taken into account in establishing, implementing and maintaining the
environmental management system.
Hazard Identification Risk Assessment (HIRA)
The plant has developed procedure for the ongoing identification of hazards, the assessment of risks and the
implementation of necessary control measures as part of Hazard Identification Risk Assessment (HIRA). These
include:

Routine and non-routine activities of all personnel having access to the workplace (including subcontractors
and visitors)
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KPCL, Khulna
22


Human behavior, capabilities and other human factors

Identifying hazards originating outside the workplace that can adversely affect health & safety of persons
under KPCL

Hazards created in the vicinity of the workplace by work related activities

Infrastructure, equipment and materials at the workplace

Modifications to the OH&S management system, including temporary changes and their impacts on
operations, processes and activities

Any applicable legal obligations relating to risk assessment and implementation of necessary controls

The design of work areas, processes, installations, machinery/equipment, operating procedures and work
organization, including their adaption to human capabilities
KPCL has maintained document pertaining to results of identification of hazards, risk assessments and controls
provided. Documents pertaining to HIRA of Operation, Maintenance Bunkering, Logistics and Administration were
reviewed as part of the site assessment and were observed to be in order.
3.1.4
Management Programs
Requirement 4
The client will establish management programs describe mitigation and performance improvement measures
and actions that address the identified environmental and social risks and impacts of the project. Depending on
the nature and scale of the project, these programs may consist of some documented combination of operational
procedures, practices, plans, and related supporting documents (including legal agreements) that are managed in a
systematic way. The management programs will establish environmental and social Action Plans, which will define
desired outcomes and actions to address the issues raised in the risks and impacts identification process, as
measurable events to the extent possible, with elements such as performance indicators, targets, or acceptance
criteria that can be tracked over defined time periods, and with estimates of the resources and responsibilities for
implementation.
Observation 4
The plant follows the requirement of continual improvement process (CIP) and every year targets are identified for
environment, health & safety, as well as energy conservation aspects besides those related to improvement of
production. The continual improvement targets for the year were observed as part of IMS objectives and include
training on safety, zero lost time injuries, visual presentations on safety awareness, reduction of consumables (lube
oil) over last year, reduction of hazardous waste (rag consumption used in cleaning of oil, grease etc.), reduction in
paper consumption, and reduction in chemical consumption.
It was observed that new actions were identified from time to time and implemented in a time bound manner. The
follow up and documentation was found to be robust. A corrective action program is maintained to investigate the
cause of non-conformances and to prevent subsequent recurrences. Documented procedures exist for:

reviewing nonconformities (including customer complaints),

investigating nonconformities, accidents, incidents, determining the causes of non-conformities and taking
actions in order to avoid recurrence,

evaluating the need for action to prevent nonconformities and implementing appropriate actions designed to
avoid recurrence,

determining and implementing action needed,

records of the results of action taken,
May 2016
KPCL, Khulna

identify opportunities for continual improvement,

communicate the results of investigation,

Reviewing corrective action taken.
23
A preventive action program is maintained to analyze and eliminate the potential causes of non-conformities in order
to prevent their occurrence. Documented procedures exist for:

Determining the potential nonconformities and their causes

Evaluating the need for action to prevent occurrence of non-conformities

Determining and implementing action needed

Records of the results of action taken and

Reviewing the effectiveness of the preventive action taken.
As part of the Environmental Assessment Study, management measures and monitoring requirements were
suggested. It was observed that KPCL has implemented the operational phase management measures at site
through the IMS and related procedures.
3.1.5
Organizational Capacity and Competency
Requirement 5
The client, in collaboration with appropriate and relevant third parties, will establish, maintain, and strengthen as
necessary an organizational structure that defines roles, responsibilities, and authority to implement the ESMS.
Personnel within the client’s organization with direct responsibility for the project’s environmental and social
performance will have the knowledge, skills, and experience necessary to perform their work. Training will be
provided to employees and contractors with direct responsibilities for activities related to the project’s social and
environmental performance.
Observation 5
KPCL does not have specific team for implementing the ESMS, the operations and maintenance team members are
provided with additional responsibility of environment, health and safety. Being an ISO certified company, the roles
and responsibilities of EHS function are executed as per the standard procedures laid out by the IMS. The IMS has
identified an Environmental Officer, which is an additional responsibility given to a Senior Engineer. However all
Managers are responsible for operative implementation of EMS plan to their respective departments, develop
procedure and train personnel. With respect to OH&S, a Safety Officer has been identified for monitoring and
management of site specific safety issues while all department heads are responsible for hazard identification,
departmental risk assessment and execution of OH&S related activities.
KPCL has engaged an NGO Paribartan for implementation of CSR activities in Khalispur area. The NGO has a
dedicated team of four (4) persons assigned for the KPCL community development programme. The team is led by
Program Officer (Paribartan) who directly reports to the Asset Manager of KPCL at corporate level and Plant
Manager at plant level.
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KPCL, Khulna
3.1.6
24
Emergency Preparedness and Response
Requirement 6
Where the project involves specifically identified physical elements, aspects and facilities that are likely to generate
impacts, the ESMS will establish and maintain an emergency preparedness and response system so that the client,
in collaboration with appropriate and relevant third parties, will be prepared to respond to accidental and emergency
situations associated with the project in a manner appropriate to prevent and mitigate any harm to people and/or the
environment.
Where applicable, the client will also assist and collaborate with the potentially Affected Communities and the local
government agencies in their preparations to respond effectively to emergency situations, especially when their
participation and collaboration are necessary to ensure effective response. The client will document its emergency
preparedness and response activities, resources, and responsibilities, and will provide appropriate information to
potentially Affected Community and relevant government agencies.
Observation 6
KPCL has developed an Emergency Preparedness and Response Plan (EPRP) applicable to all the three plants. It
applies to possible emergencies such as Fire Incidents, Spillage, Explosions, Natural calamities, Crisis Management,
Man overboard in case of barges and jetties, Fatal Human Injury etc. which may directly affect the environment,
personnel safety or the quality of operation and maintenance activities and status of equipment intended for
generating and supplying electrical power. The plant also has HFO and LFO storage facility within its boundary,
however no risk assessment study has been conducted to understand tank fire and dyke fire scenario for the storage
area. This has been discussed in detail under PS-4, Section 3.4.1.
Further observations pertaining to emergency preparedness and response are presented below:

KPCL has formulated plant specific emergency response teams. The responsibility, authority and duties of
personnel with specific roles during emergency are defined and documented. KPCL has procedures for
training of the emergency response teams.

All personnel are trained in fire prevention, fire safety and firefighting. Mock drills on fire, spillage, victim
rescue are conducted on regular basis, records for which were verified.

Emergency equipment needs are identified, and tested at specified intervals for continuing operability. The
following details are maintained:

o
List of equipment for firefighting
o
Layout and location drawing for fire fighters
o
List of equipment for Spillage handling and other emergencies
o
List of Alarm systems
o
Emergency lighting and power
o
Critical isolation valves, switches and cut-outs
o
First-aid equipment (including emergency showers, eyewash stations, etc.)
o
Communication facilities.(Call points, Sirens, Horns, Telephone, Transport)
Emergency contacts details were observed to be displayed at key locations in the plant. Evacuation Plan
was displayed at various places (including main control rooms on both barges). Safe assembly area, free
from obstruction, was noted near the entrance gate.

Emergency equipment and facilities (e.g., first aid stations, firefighting equipment, personal protection
equipment for the emergency response teams) were observed as available at the site.

KPCL has also formulated a procedure on Fire Prevention and Extinguisher System which provides
guidance to ensure that the firefighting systems are operational and fully tested and employees are aware
of fire prevention methods to minimize the fire related risks and hazards at plant. The facility has a fire and
May 2016
KPCL, Khulna
25
bunkering station to store firefighting and fireman’s equipment. There is an underground fire bunker to act
as shelter in event of explosion due to major fire.

Adequate arrangement of fire extinguishers was observed within the facility and they were verified as
recently inspected. Fire extinguishers are inspected by the maintenance team on monthly basis and records
are maintained. Fire hydrants were observed as functional, however foam-flooding unit was not observed at
the designated place. Automatic CO2 flooding system, foam flooding units, manual call points, fire alarms,
smoke detectors and heat detectors were also observed in the plant. A detailed fire plan for entire facility
was observed as displayed in the admin block.

KPCL has also developed an Oil Spill Response Plan outlining procedures to be followed in case of any
accidental spillage. The unloading area (jetty) is provided with boom for oil spill containment. The plant also
has an emergency boat with radio facilities in case evacuation has to be carried out from riverside. KPCL
has engaged a contractor, M/s Abdullah Traders, to engage manpower for providing assistance related to
mooring of oil tankers and laying of oil boom. No major spills have been reported till date.
3.1.7
Monitoring and Review
Requirement 7
The client will establish procedures to monitor and measure the effectiveness of the management program, as well
as compliance with any related legal and/or contractual obligations and regulatory requirements. In addition to
recording information to track performance and establishing relevant operational controls, the client should use
dynamic mechanisms, such as internal inspections and audits, where relevant, to verify compliance and progress
toward the desired outcomes.
Observation 7
KPCL, for operation and maintenance of its plants, plans and implements the checking, measurement, analysis and
improvement processes needed to ensure conformity of the IMS that includes EHS requirements. KPCL has put in
place a robust monitoring and review mechanism in compliance with the requirements of the IMS. The monitoring
mechanism includes following:

Submission of monthly report on performance, which provides a section on Safety & Environment, which
covers the following aspects on monthly basis:

o
o
Housekeeping
o
OH&S and Environmental Management System
o
OH&S and Participation Committee
o
Mock Drill For Emergency Preparedness
o
Other Safety Information (including safety statistics)
Quarterly monitoring for Ambient Air Quality (SPM, SOx and NOx) is carried out and the report is submitted
to Department of Environment (DoE) in compliance with the EC conditions.

OH&S and Participation Committee meeting is undertaken every month where all kinds of grievances along
with H&S issues are discussed with the employees. The feedback is noted and responded to in a timely
manner.

Records are maintained for oily water treatment and disposal.

Detailed records are maintained for material usage and disposal on monthly basis, which is reviewed
against the identified targets as per the continuous improvement plan.

Random checks on H&S are undertaken and the outcome discussed in OH&S and Participation Committee,
records of preceding months meeting was verified.
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KPCL, Khulna

26
Internal Audit are carried out to ensure effective implementation of the IMS and to look for opportunities for
improvement. Internal Auditors are nominees from Departments and such persons are adequately trained
on those aspects. The audits are focused on the elements of IMS and include EHS as part of it.

External audits are conducted annually by independent third party accredited Organization ( Bureau
Veritas), to provide certification or registration of conformity to the requirements of the ISO 9001:2008, ISO
14001:2004 and OHSAS 18001:2007 standards.

Management Review of IMS is held quarterly in the last week of December, March, June, and September
arranged by Management Representative and attended by the team members with set agenda and roles as
inputs to assess the status of the IMS and to ensure continuing suitability, adequacy & effectiveness of its
processes. The minutes of meeting were reviewed at site.
3.1.8
Stakeholder Engagement
Requirement 8
Stakeholder Analysis and Engagement Planning: Clients should identify the range of stakeholders that may be
interested in their actions and consider how external communications might facilitate a dialog with all stakeholders.
The client will develop and implement a Stakeholder Engagement Plan that is scaled to the project risks
and impacts and development stage, and be tailored to the characteristics and interests of the Affected
Communities.
Disclosure of Information: The client will provide Affected Communities with access to relevant information on: (i) the
purpose, nature, and scale of the project; (ii) the duration of proposed project activities; (iii) any risks to and potential
impacts on such communities and relevant mitigation measures; (iv) the envisaged stakeholder engagement
process; and (v) the grievance mechanism.
Consultation: When Affected Communities are subject to identified risks and adverse impacts from a project, the
client will undertake a process of consultation in a manner that provides the Affected Communities with opportunities
to express their views on project risks, impacts and mitigation measures, and allows the client to consider and
respond to them.
The client will tailor its consultation process to the language preferences of the Affected Communities, their decisionmaking process, and the needs of disadvantaged or vulnerable groups. The consultation should also focus inclusive
engagement and be documented.
Observation 8

It was observed that the IMS does not cover the requirement for stakeholder engagement or consultation
with community during the operation phase. However KPCL has implemented a ‘Community Engagement &
Development CSR Programme’ in association with DEG, which was observed to be robust and well
executed.

KPCL has engaged NGO Paribartan since last three (3) years for identifying and undertaking CSR activities
in the Khalispur area, within 2 sq. km. radius around the KPCL plant. The program includes CSR activities
such as skill development, health care, education and employment. Following CSR activities are undertaken
as part of the programme:
o
Tailoring project, which includes provision of training on tailoring skills to underprivileged and
unemployed women. About 300 women have benefitted from the program since 2013. This
programme has helped the women to be self-employed. KPCL has also provided work order to
these women for stitching boiler suits for the plant employees.
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KPCL, Khulna
o
27
ICT project, to ensure sound knowledge of IT among underprivileged community youths and
professionals. Office-oriented Computer Training and Professional IT Skill Development are
provided as part of the project benefitting about 335 local youth.
o
Education project, to create awareness amongst the community on ensuring primary level
education for their children and provide supports to local educational institutions. Paribartan
conducts study tours for underprivileged school children, coaching for local underprivileged PSC
candidates, provides financial support for HSC admission, provides uniforms for about 1500 school
children.
o
Health project, which includes senior citizen program, medical treatment support, supply of
medicines and blankets, issue of health cards for free health services (about 3019 beneficiaries till
date), community blood bank, health camps, etc.
o
Other value added services such as awareness on waste management amongst community, daily
household waste management service (two persons from every household have been assigned for
regular cleaning of streets in Khalispur area), plantation in community household yards and public
places, etc.

Paribartan also conducts community dialogues and focused group discussions with various stakeholders
including NGOs, Local Community, and Government to understand the development needs of the
community. Grievances are received from the community and suggestions are taken.

The CSR activities planned are based on a detailed need assessment survey conducted in the area in
October 2012. It was reported that periodic surveys are conducted by Paribartan to understand community
needs and plan new activities.

Paribartan has assigned a dedicated team of four (4) staff for the KPCL CSR program. The team is headed
by the Programme Coordinator and directly report to the Plant Manager and Asset Manager of KPCL at
corporate level.

Paribartan generates monthly reports on the status of implementation of the CSR activities and targets set
as part of the programme and submits the same to KPCL. The monthly reports include progress of ongoing
activities and minutes of monthly community dialogues.

In order to evaluate the efficiency and effectiveness of the CSR programme, KPCL engaged a third party,
M/s SETU Resources and Livelihood Solutions Pvt. Ltd. and provide recommendations for improvement in
the programme. The report was submitted in February 2016 and reviewed at site. It was reported by SETU
that Paribartan has successfully implemented the CSR programme and ensured time bound implementation
of activities. Suggestions and grievances received from the community are also adequately addressed by
Paribartan. The report notes that KPCL does not have a CSR policy showcasing the company’s
commitment towards community welfare and recommends KPCL to develop one. It also indicates that since
the programme is valid till December 2017, it is advisable for KPCL to spell out a withdrawal strategy and
continue with similar activities in the future.

Communication with other stakeholders like suppliers, contractors and regulatory agency is maintained as
per requirements of IMS and regulatory compliance. EHS updates and trainings are shared with the
contractors and suppliers while quarterly monitoring report is shared with the DoE.

All workers are engaged through participation committee, which discusses all relevant issues on monthly
basis.

KPCL does not have any formal procedure to disclose any of their observations on impacts or monitoring to
the local community. The plant is located at less than 100 m from the residential area of Khalispur. There
are impacts from noise generation, stack emissions etc., as well as observations such as results of quarterly
monitoring which needs to be shared with the local community on regular basis.
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KPCL, Khulna
3.1.9
28
External Communications and Grievance Mechanism
Requirement 9
External Communications: Clients will implement and maintain a procedure for external communications.
In
addition, clients are encouraged to make publicly available periodic reports on their environmental and social
sustainability.
Grievance mechanism for Affected Communities: Where there are Affected Communities, the client will establish a
grievance mechanism to receive and facilitate resolution of Affected Communities’ concerns and grievances about
the client’s environmental and social performance. The client will inform the Affected Communities about the
mechanism in the course of the stakeholder engagement process.
Observation 9

It was noted that the external communication and grievance mechanism maintained by KPCL is informal in
nature. Local community members directly approach the Plant Manager/ Admin Manager in case of
concerns and queries. Contact numbers of the plant official are available with influential people in the
community.

It was observed from the EIA report that a public consultation was held prior to development of the plant
wherein the Khalispur residents were informed of the project details, impacts and benefits. Concerns on air
quality, noise, waste treatment and disposal were raised by the community and suggestions to mitigate
such impacts were provided. It was further reported by the community during the site visit that there was
local residents had protested when the plant was commissioned. The protests were held due to issues
related to high noise levels and dust deposition on the houses. KPCL thereafter implemented noise dampening measures in the engine room to reduce ambient noise levels. At present, no issues are reported
by the community related to plant operations.

The local community of Khalispur area raises concerns/ grievances during the monthly community
dialogues held by Paribartan. Though it was reported that there are no outstanding issues from community
dialogues, there is no documentation for the complaints received; the follow up of issues is also not
documented.

The Annual report of KPCL and CSR report by Paribartan are provided on the website of both companies,
which is accessible to the community, however, it is limited by access to the internet. The community does
not have access to the monitoring reports submitted to DoE, or any other compliance report. Moreover the
Annual Report of KPCL does not include key information related to the plant’s EHS performance.
3.1.10 Status of Compliance to PS-1

ESMS: The IMS developed by KPCL is focused on O&M aspects of the plant, however it may be
H&S aspects, however it does not focus on social aspects.

Identification of risks and impacts: An Environmental Impact Assessment study was conducted for Unit-1
in 1998 which has considered environmental and social impacts due to project. However, similar study has
not been conducted for Unit-2 considering cumulative impacts on ambient air, ambient noise and water
resources and quality due to operation of both units.
May 2016
KPCL, Khulna

29
and social management system. The team member identified as Environmental Officer is adequately
experienced but not formally qualified in the subject.


KPCL should develop a dedicated procedure for social aspects, covering commitments made under the IMS
Policy.

KPCL should make provisions for refresher courses and advanced training to Environmental Officer to
supplement their knowledge towards environmental aspects of Plant operation.

The existing team for IMS should be provided formal short-term training on environmental and social
requirements.

KPCL should disclose key information to community pertaining to plant’s EHS performance, such as results
of environmental monitoring and safety statistics. KPCL could install display boards outside plant premises
providing quantitative data on EHS. Annual reports issued by KPCL should also include a section on EHS
performance of the plant.

The Grievance Redressal is informal at present, KPCL shall put in place two tier grievance committee with
representatives from local community. There shall be formal register to record grievances, complaints,
suggestions etc. and all issues shall be resolved in a time bound manner. The second tier of the committee
shall be the escalation level at corporate office of KPCL. The resolution of issues shall also be documented.
The IMS system developed by KPCL is robust, however social aspects needs to be covered in the manual. The
issues identified do not trigger any material liability.
3.2
Performance Standard (PS) 2: Labour and Working Conditions
3.2.1
Working Conditions and Management of Worker Relationship
Requirement 10
The client will adopt and implement human resources policies and procedures appropriate to its size and workforce
that set out its approach to managing workers consistent with the requirements of the Performance Standard and
national law.
The client will provide workers with documented information that is clear and understandable, regarding their rights
under national labour and employment law and any applicable collective agreements, including their rights related to
hours of work, wages, overtime, compensation, and benefits upon beginning the working relationship and when any
material changes occur.
May 2016
KPCL, Khulna
30
Observation 10
applicable to all three plants. This Policy is an independent document and separate from that of SCL’s HR policy.
The Policy has been prepared with the intention of keeping it subservient to the government laws and commits to
modification with any change in legal requirement in future. The document is available to all employees for reference
in the form of a handbook.
All employees are given appointment letters in written with terms and conditions as specified in the Policy. All
employees are given an Identity card and unique employee code. The policy document provides details on following
key aspects:

Conditions of Employment

Working Hours

Holidays

Salary and Fringe Benefits

Overtime

Health & Safety
Termination: The conditions of employment states that a regular employee can be terminated with one (1) month
notice or one (1) month salary in lieu of notice, however the Bangladesh Labour Law (BLL) 2006 states that the
employment of a permanent worker may be terminated by the employer by giving to him in writing 120 days’ notice, if
he is a monthly rated worker or sixty days’ notice, in case of other worker. Thus this is a non-conformance to the
legal requirement.
Retirement: The retirement age of employee has been fixed at 60 as per KPCL policy however as per the BLL 2006,
the retirement age for workers employed in any establishment is 57. This is again inconsistent with legal
requirement.
Working Hours: Eight (8) hourly working hours with six (6) days working have been identified (i.e. 48 hours a week)
in the Policy. The plant operates in three (3) shifts and there is rotating shift to accommodate holidays. However
there is no cap on the maximum working hours for a worker including overtime hours, this is a non-conformance to
the requirements of BLL (2006) which states that an adult worker may work for more than forty-eight (48) hours in a
week, provided that the total hours of work of an adult worker shall not exceed sixty (60) hours in any week and on
the average fifty-six (56) hours per week in any year.
The Plant has engaged security services of Falcon Securities Limited, with 39 unarmed guards working on eight (8)
hourly basis. A rotation shift is maintained for Holidays. The working hour of 48 hours a week is maintained as per
the representative at site. The plant has also engaged canteen contractors having 10 kitchen staff.
Overtime: Overtime of two (2) times the hourly wage is provided in the Policy document, which is in line with the
requirements of BLL 2006. However the calculation of overtime is made on basic salary while BLL 2006 states that in
respect of overtime work, the worker shall be entitled to allowance at the rate of twice his ordinary rate of basic wage
and dearness allowance and ad-hoc or interim pay, if any.
Health & Safety: All employees are provided with appropriate protective clothing and safety gears. Training on
Health and Safety is imparted to all employees. As the Plant is certified to OH&S, adequate arrangements and plan
for H&S aspects are provided. First aid boxes are provided at various locations in the plant and employees were
aware of it. The policy also promotes reporting of accidents and incidents.
May 2016
KPCL, Khulna
31
Working Conditions: The plant staff is not provided accommodation inside the plant premises. About ten (10) air
conditioned buses have been engaged for providing facilitating daily commutation of site staff from local areas. The
site staff is also provided with facilities such as lunch room, subsidized food cooked at site, drinking water and
separate toilets for male and female employees.
The policy covers temporary and direct contract workers, working for KPCL, however contractors engaged by the
company i.e. security agencies (M/s Falcon Security Limited) and canteen contractor are not covered by the Policy.
3.2.2
Workers’ Organisation
Requirement 11
In countries where national law recognizes workers’ rights to form and to join workers’ organizations of their choosing
without interference and to bargain collectively, the client will comply with national law. Where national law
substantially restricts workers’ organizations, the client will not restrict workers from developing alternative
mechanisms to express their grievances and protect their rights regarding working conditions and terms of
employment.
In either case described above, and where national law is silent, the client will not discourage workers from electing
worker representatives, forming or joining workers’ organizations of their choosing, or from bargaining collectively,
and will not discriminate or retaliate against workers who participate, or seek to participate, in such organizations and
collective bargaining. The client will engage with such workers’ representatives and workers’ organizations, and
provide them with information needed for meaningful negotiation in a timely manner.
Observation 11
Though it was informed during the site visit that there is no workers union at KPCL, it was also observed that there is
no mechanism for collective bargaining existing for the workers of KPCL. The employment policy does not make any
commitment about workers union. The BLL 2006 states that every worker employed in any establishment has the
right to form and join a trade union of their own choice. Trade unions have the right to draw up their own constitution
and rules and to elect their representatives. Also, trade unions have the right to form and join in a federation and
such unions and federations have the right to affiliate with any international organization and confederation of trade
unions. The trade union is allowed to serve as a collective bargaining agent in any establishment. Thus the Policy
document needs to be revised to include the requirements of BLL.
The project has engaged no migrant workers (foreign workers) in its operations and it was observed that workers
engaged from different parts of Bangladesh have to follow the same Policies and Procedures as the local workers.
3.2.3
Non-Discrimination and Equal Opportunity
Requirement 12
The client will base the employment relationship on the principle of equal opportunity and fair treatment, and will not
discriminate with respect to any aspects of the employment relationship, such as recruitment and hiring,
compensation (including wages and benefits), working conditions and terms of employment, access to training, job
assignment, promotion, termination of employment or retirement, and disciplinary practices. The client will take
measures to prevent and address harassment, intimidation, and/or exploitation, especially in regard to women. The
principles of non-discrimination apply to migrant workers.
Observation 12
May 2016
KPCL, Khulna
32
The Employment Policy clearly states that the company subscribes to equal opportunity regardless of age, race, sex,
or marital status. The policy further commits to the principle of fair and equal treatment for all employees. No
discriminatory terms are observed in the Policy and all procedures provided are same for all employees. However
there are no means provided to prevent and address harassment, intimidation, and/or exploitation, especially in
regard to women. There are four (4) female employees in the KPCL units.
3.2.4
Retrenchment
Requirement 13
Prior to implementing any collective dismissals, the client will carry out an analysis of alternatives to retrenchment. If
the analysis does not identify viable alternatives to retrenchment, a retrenchment plan will be developed and
implemented to reduce the adverse impacts of retrenchment on workers. The retrenchment plan will be based on the
principle of non-discrimination and will reflect the client’s consultation with workers, their organizations, and, here
appropriate, the government, and comply with collective bargaining agreements if they exist.
Observation 13
Currently both units of the plant together have 145 staff and mostly skilled workers. Since the plant will remain
operational for the remaining lease period, there is no immediate possibility of retrenchment. The company being
part of a larger group can explore possibility to accommodate their workers across different plants in case any such
need arises.
3.2.5
Grievance Mechanism
Requirement 14
Client shall put in place a grievance mechanism through which workers may raise workplace concerns, the client
should ensure that matters are brought to management’s attention and addressed expeditiously. It should also
provide feedback to those involved and should bar retribution for filing complaints. Grievance mechanisms may be
designed to direct complaints through an appropriate process in order to protect the confidentiality of the worker, and
should ensure that workers can raise concerns other than to immediate supervisors. The client needs to document
all grievances and follow up on any corrective action. The client will appoint a committee to deal with grievances,
which will include management, supervisors and workers’ representatives.
Observation 14
KPCL has documented a three tier Grievance Mechanism for the workers, which comprises of the following three
levels of escalation:
1.
Immediate Supervisor: The employee can raise his/her grievances related to employment, unfair
treatment, or wrongful action on part of another employee. This has to be done within two (2) working days
to the immediate supervisor, who will make a decision in three (3) working days’ time.
2.
Superior with HR Manager: In case the worker is not satisfied, it can be escalated to the Superior, who in
consultation with Manager HR&A and give a decision in five (5) days from receipt of complaint.
3.
Plant Manager: In case the superior fails to resolve, they issues can be raised with the Plant Manager, who
would respond in three (3) working days.
It was observed that the grievance committee does not have representation from workers, also no records of
grievances are maintained by the Plant, which indicates that most of the communication is verbal and resolved in an
May 2016
KPCL, Khulna
33
informal manner. A significant number of issues, such as evaluation of compliances to regulatory requirements,
status of OH&S objectives and programs, status of training programs, job quality and operational performance are
discussed in the Participation committee meeting, the minutes of which were reviewed. However it does not involve
individual grievance related issues.
3.2.6
Child Labour/Bonded Labour
Requirement 15
The client will not employ children in any manner that is economically exploitative, or is likely to be hazardous or to
interfere with the child’s education, or to be harmful to the child’s health or physical, mental, spiritual, moral, or social
development. Children under the age of 18 will not be employed in hazardous work. All work of persons under the
age of 18 will be subject to an appropriate risk assessment and regular monitoring of health, working conditions, and
hours of work.
The client will not employ forced labour, which consists of any work or service not voluntarily performed that is
exacted from an individual under threat of force or penalty. The client will not employ trafficked persons.
Observation 15
The Employment Policy has no mention of abolition of Child Labour, also considering the Plant operation there is no
scope of engaging a young worker in the operations. All appointments for the plant are made after due verification of
age proof and testimonials.
In case of workers engaged through contractor, there is no process in place to verify age of the workers involved.
During site walkthrough, a young worker was observed amongst the canteen staff, engaged by the canteen
contractor of KPCL. The age of the worker could not be verified at site, since records were not immediately available.
However it was understood that KPCL does not have a contractor management procedure, particularly for monitoring
and verifying that child labour is not engaged within the plant premises by any of the contractors.
With respect to forced/ bonded labour, there is no evidence of any policy being thrusted on the workers involuntarily,
though the HR policy document does not mention the company’s commitment against forced/ bonded labour. All
workers are hired after due process of interview and background verification, leaving limited possibility of forced/
bonded labour.
3.2.7
Requirement 16
The client will provide a safe and healthy work environment, taking into account inherent risks in its particular sector
and specific classes of hazards in the client’s work areas, including physical, chemical, biological, and radiological
hazards, and specific threats to women. The client will take steps to prevent accidents, injury, and disease arising
from, associated with, or occurring in the course of work by minimizing, as far as reasonably practicable, the causes
of hazards. In a manner consistent with good international industry practice, as reflected in various internationally
recognized sources including the World Bank Group Environmental, Health and Safety Guidelines.
Observation 16
May 2016
KPCL, Khulna
34
The KPCL plants are certified for occupational health and safety management systems OHSAS 18001:2007. As part
of the IMS the plant manages a robust OH&S management system. The following observations were made with
respect to OH&S management system of KPCL:

OH&S Committee: KPCL has constituted an OH&S committee, headed by the Plant Manager and
comprising at least one member of each department as a member of the committee. The committee
meetings are undertaken on monthly basis and chaired by the Safety Officer.

HIRA: The Plant has put in place process for hazard identification, risk assessments and risk control based
on operational experience and commitment to eliminate, reduce and control workplace illness and injury. It
includes:

o
Routine and non-routine activities
o
Activities of all personnel having access to the workplace including contractors and visitors
o
Environment and Safety Checklist: An environment and safety checklist is filled prior to commencement
of any activity. The check list provides details of possible hazards and protective measures which needs to
be taken, including use of Personal Protective Gear. The checklist is signed by the group leader and the
supervisor. Workers were observed to fill in the checklist and wear all requisite PPE prior to execution of
any activity.

Electrical Safety: Only qualified persons are allowed to participate in the construction, maintenance or
operation of electrical equipment. Lock out and Tag Out process is followed while working on energized
systems.

Work Permits: Hot/ Hazardous work permits and Confined space entry permits are separately maintained,
which ensures adequate protection prior to such works. These permits have clear mechanism on how to
close it after completion of work.

Testing of tools and Tackles and Pressure vessels: All lifting machines, chains, lifting tackles and ropes
are tested at periodic intervals and the test certificates were verified at site (dated 28th January, 2016). All
pressure vessels and hoses used at the site are also tested (hydraulic) at regular intervals and the test
certificates were verified at site (dated January 28, 2016).

Training of workers: A detailed list of trainings and mock drills planned as part of annual itinerary is given
in Table 3-2 and Table 3-3. It is observed that a robust training plan is in place. Mock drills on fire, spillage
and other emergencies are conducted on monthly basis, as verified from the monthly reports. Each
employee is required to attend at least one drill in two months.

The monthly reports on plant performance also includes monthly training report that provides details on
training programs and mock drills conducted for the current month, scheduled date, description of training,
number of participants and name of trainer. It was noted that training programs are held as per schedule.
May 2016
KPCL, Khulna
35
Sl. No.
Refreshing
procedures
awareness
on
safety
Employee Coverage
JAN
FEB
MAR
APR
MAY
JUN
JUL
AUG
SEP
OCT
NOV
DEC
No of Employees
Plan
Plan
Plan
Plan
Plan
Plan
Plan
Plan
Plan
Plan
Plan
Plan
1
Working near moving machines
KP,KPCII & KjAP
25
25
25
2
HIRA
KP,KPCII & KjAP
25
25
25
3
Housekeeping and 5S
KP,KPCII & KjAP
25
25
25
4
Rescuers training for Confined Space entry &
working at height
KP,KPCII & KjAP
25
25
25
5
Fire prevention and fighting
KP,KPCII & KjAP
25
25
25
6
Incident Management
KP,KPCII & KjAP
25
25
25
7
Emergencies and response plan
KP,KPCII & KjAP
25
25
25
8
Electrical safety
KP,KPCII & KjAP
25
25
25
9
Hot Work (Welding, gas cutting, brazing etc)
KP,KPCII & KjAP
25
25
25
10
First Aid training
KP,KPCII & KjAP
25
25
25
11
OHSAS
KP,KPCII & KjAP
25
25
25
12
Road Safety
KP,KPCII & KjAP
25
25
25
13
Use of PPE
KP,KPCII & KjAP
25
25
25
14
Manual and mechanical material handling
KP,KPCII & KjAP
25
25
25
15
Lock out Tag out (LOTO)
KP,KPCII & KjAP
25
25
25
16
Work Permit system
KP,KPCII & KjAP
25
25
25
17
Slip, Trip and Falls
KP,KPCII & KjAP
25
25
25
18
Prevention from hand injuries
KP,KPCII & KjAP
25
25
25
19
Chemical handling & MSDS
KP,KPCII & KjAP
25
25
25
20
Truck tippler operations
KP,KPCII & KjAP
25
25
25
May 2016
KPCL, Khulna
Sl. No.
21
Refreshing
procedures
awareness
on
safety
Safety Induction program
36
Employee Coverage
JAN
FEB
MAR
APR
MAY
JUN
JUL
AUG
SEP
OCT
NOV
DEC
No of Employees
Plan
Plan
Plan
Plan
Plan
Plan
Plan
Plan
Plan
Plan
Plan
Plan
New Joiners
25
25
25
Sl. No.
Items
JAN
FEB
MAR
APR
MAY
JUN
JUL
AUG
SEP
OCT
NOV
DEC
1
Fire and explosion Drill
26
22
20
22
20
25
16
12
12
12
12
12
2
Flammable Liquid Spill (HSD / LDO / HFO / Lube Oil)
15
3
Hazardous Chemical Spill
15
4
Flooding & natural calamities
5
Man overboard
6
Human Injury/ slip during work/fall from height
7
Medical emergency - injuries like fractures, heart attack, asthma attack,
bleeding, severe burns, Food poisoning, snake bite, Electric shock etc.
(others)
8
Crisis
15
22
25
22
22
22
May 2016
KPCL, Khulna

37
Visitor Safety: The EHS requirements are applicable to all workers within the premises direct and indirect,
as well as to all visitors. OHS briefing is provided to visitors and other third parties accessing the premises.

Accident and Incident Reporting: The plant has adopted an objective of zero fatality and zero lost time
injury (LTI). A robust incident /accident reporting mechanism is in place. Documents pertaining to incident
reporting and statistics on accident/incident were reviewed at site. The OH&S Committee meets on monthly
basis to follow up on open issues. The designated Safety Officer submits a monthly report on safety to
senior management. Workers do not face any disciplinary measures or negative consequences for reporting
or raising concerns about OHS, this was evidenced from the minutes of OH&S meeting. Monthly reports on
plant performance includes safety information such as fire incidents, spillage incidents, first aid injuries, near
misses, lost time injuries and fatal incidents. The plant also displays safety statistics (days since last LTI) in
the form of safety monitor within the premises.
Following Table 3-3 presents the safety statistics as on February 2016. It was reported that the two (2)
major fire incidents in Unit I were mainly due to malfunction of engine turbocharger which initiated sparks
resulting in fire. There were no fatalities or injuries due to the fire incidents. Although some parts of the
engine were partially damaged and had to be replaced, no insurance was claimed for this. The minor fire
incidents reportedly comprise of incidents and near misses which could have resulted in potential fire.
Similarly, Unit -1 has recorded minor spill incidents such as leakage of pipes/ hose, spill of lube oil and
engine oil in the engine room and minor spills during handling of fuel. Proper measures were reportedly
taken to contain such spills in timely manner.
Table 3-3: Safety Statistics for KPCL Units (as on Feb 2016)
S. No.
Description
Year to date (for 2016)
Since COD
Unit I
Unit II
Unit I
Unit II
1.
Total numbers of minor fire incidents
-
-
17
-
2.
Total numbers of major fire incidents
-
-
2
-
3.
Total numbers of minor spillage
-
-
38
-
-
-
-
-
-
-
-
-
-
-
6
1
-
1
30
21
-
-
-
-
4.
Total numbers of major spillage
5.
Total numbers of first aid injuries – in
plant
6.
Total numbers of Lost Time Injuries
(LTI) – in plant
7.
Total numbers of near misses - in
plant
8.
Total numbers of fatal accidents – in
plant

Exposure to Radiation, Noise and Electro-Magnetic Field (EMF): The engine room has high room
temperature and noise levels, although appropriate PPE (Boiler suits, Ear plugs, Ear Muffs, heat resistant
gloves etc.) are provided to the workers, however there has been no evaluation of occupational noise or
exposure to heat with respect to the working hours of the employees. The adequacy of PPE being used for
noise cannot be confirmed, in terms of reducing sound pressure levels at the ear to at least 85 dB(A). The
workers are provided with Oral Rehydration Supplements (ORS), electrolyte drinks to enable adequate
hydration while working in hot ambience, however adequacy of this has not been established or monitored.
May 2016
KPCL, Khulna
38
Occupational Exposure to Electro-Magnetic Field for workers working near energized equipment and
switchyard is also not being monitored.

Emergency Prevention, Preparedness, and Response: An Emergency Preparedness and Response
Plan which applies to possible emergency situations such as 1) Fire Incidents, 2) Spillage, 3) Explosions 4)
Natural Calamities, 5) Crisis Management, 6) Man overboard in case of barges and jetties 7) Fatal Human
Injury etc. which may directly affect the environment, personnel safety or the quality of operation and
maintenance activities and status of equipment, is in place.
3.2.8
Supply Chain
Requirement 17
Where there is a high risk of child labor or forced labor in the primary supply chain, the client will identify those risks.
If child labor or forced labor cases are identified, the client will take appropriate steps to remedy them.
Observation 17
The Plant has a supplier verification process, however it does not cover labour aspects including child labour. The
primary supply chain for power plant is HFO fuel, which is shipped from Singapore, and considering the labour laws
of Singapore it can be inferred that child labour issue may not be associated with the supplier. Other suppliers such
as for lube oil and chemicals are local dealers of international brands, it is understood that lead brands like
Petrobras, Wilhelmsen etc., have their own code of conduct for their dealer, however KPCL has no process to verify
the same.
3.2.9


grievances raised.

Contract Worker Management: KPCL does not have a mechanism to monitor the adherence of labour

May 2016
KPCL, Khulna

39

The Employment Policy Document of KPCL should be revised to accommodate the requirements of
Bangladesh Labour Law (2006) and include the following points besides any other identified by the
management:
o
Notice period for termination shall be 120 days for regular monthly rated worker and 60 days for
other workers instead of 30 days as being followed
o
The retirement age for employee shall be 57, instead of 60 being followed
o
Document the total weekly working hours for an employee with overtime hours, which shall not
exceed sixty hours in any week and on the average fifty-six hours per week in any year
o
Calculation of Overtime shall include other benefits such as dearness allowance, instead of just
basic salary

KPCL should develop a mechanism to monitor the labour force engaged by contractor on the following
aspects:

o
Payment of Minimum wages (review of salary details)
o
o
Work Hours (review of attendance records)
The management should, in line with the requirements of Bangladesh Labour Law, add requisite statements
to the employment policy, indicating their willingness to collective bargaining or formation of trade unions.

The employment policy document should be updated to include procedures to prevent and address
harassment, intimidation, and/or exploitation, especially with regard to women.

Grievance received from employees should be documented and record should be maintained for all follow ups and action taken.

The employment policy should make clear statement on engagement of no Child Labour and Forced Labour
in its operations. This should also cover contract workers engaged by the company.

Monitoring of occupational noise should be undertaken for plant staff working in engine room and other high
noise areas. The duration of exposure and exposure levels of workers to high noise should be identified.
The following should be ensured by KPCL management:
o
No employee should be exposed to a noise level greater than 85 dB(A) for a duration of more than
8 hours per day without hearing protection. In addition, no unprotected ear should be exposed to a
peak sound pressure level (instantaneous) of more than 140 dB(C).
o
The use of hearing protection should be enforced actively when the equivalent sound level over 8
hours reaches 85 dB(A), the peak sound levels reach 140 dB(C), or the average maximum sound
level reaches 110dB(A). Hearing protective devices provided should be capable of reducing sound
levels at the ear to at least 85 dB(A).
o
Although hearing protection is preferred for any period of noise exposure in excess of 85 dB(A), an
equivalent level of protection can be obtained, but less easily managed, by limiting the duration of
noise exposure. For every 3 dB(A) increase in sound levels, the ‘allowed’ exposure period or
duration should be reduced by 50 percent.
o
Prior to the issuance of hearing protection devices as the final control mechanism, use of acoustic
insulating materials, isolation of the noise source, and other engineering controls should be
investigated and implemented, where feasible.
o
Periodic medical hearing checks should be performed on workers exposed to high noise levels
May 2016
KPCL, Khulna
o
40
Refer Table 2.3.1. Noise Limits for Various Working Environments from IFC General EHS
Guidelines on Occupational Health And Safety

Every worker who works in extraordinary conditions that increase the risk of heat stress should be
personally monitored. These conditions include wearing semipermeable or impermeable clothing when the
temperature exceeds 21°C, working at extreme metabolic loads (greater than 500 kcal/hour), etc. Personal
monitoring can be done by checking the heart rate, recovery heart rate, oral temperature, or extent of body
water loss.

Adjustment of work and rest periods should be practiced according to temperature stress management
procedures provided by ACGIH1, depending on the temperature and workloads.

Occupational EMF exposure should be prevented or minimized through the preparation and implementation
of an EMF safety program for workers working near energized equipment and switchyard, including the
following components:
o
Identification of potential exposure levels in the workplace, including surveys of exposure levels in
new projects and the use of personal monitors during working activities;
o
Training of workers in the identification of occupational EMF levels and hazards;
o
Establishment and identification of safety zones to differentiate between work areas with expected
elevated EMF levels compared to those acceptable for public exposure, limiting access to properly
trained workers;
o
Personal exposure monitoring equipment should be set to warn of exposure levels that are below
occupational exposure reference levels (e.g., 50 percent).
o
Action plans to address occupational exposure may include limiting exposure time through work
rotation, increasing the distance between the source and the worker, when feasible, or the use of
shielding materials.

KPCL should put in place a mechanism to assess the labour related practices of the supply chain. This can
be brought about by adding relevant elements to the existing supplier verification form. The form can be
appended to include questions on child labour, minimum wages and working conditions.
Some elements of the Employment Policy and procedures need to be aligned with Bangladesh Labour Law (2006),
and monitoring of occupational health safety needs to include noise, heat and EMF but none of the factors can be
termed as material liability.
3.3
Performance
Prevention
Standard
3.3.1
Resource Efficiency
(PS)
3:
Resource
Efficiency
and
Pollution
Requirement 18
The client will implement technically and financially feasible and cost effective measures for improving efficiency in its
consumption of energy, water, as well as other resources and material inputs, with a focus on areas that are
considered core business activities. Such measures will integrate the principles of cleaner production into product
design and production processes with the objective of conserving raw materials, energy, and water.
1
American Conference of Governmental Industrial Hygienists (ACGIH), the WBGT measures environmental temperature
conditions useful to establish work/rest schedules and exposure hazard evaluation (i.e., heat stress) but does NOT monitor worker
specific physiological responses (heat strain response) to the thermal dose received.
May 2016
KPCL, Khulna
41
When the project is a significant consumer of water, the client shall undertake an assessment to identify
opportunities to avoid or reduce water usage so that the project’s water consumption does not have significant
adverse impacts on others.
Observation 18
The plant has put in place heat recovery boilers wherein the heat recovered is used for keeping the HFO warm and
attain the required viscosity. Thus, significant amount of resources are conserved by recovery of heat from cooling
water.
Water is mainly consumed as make up water for heat recovery boilers. Ground water is extracted through one bore
well installed within the plant premises. About 26 TPD of ground water is reportedly required in both the plants for
boiler make up. However records pertaining to groundwater extraction are not being maintained in order to monitor
groundwater consumption as the bore well is not metered. There are two more power plants in the vicinity along with
an Oil depot, all of which are drawing ground water. It was observed during review of the ESIA report that impacts
related to stress on groundwater resources in the area due to plant operations have not been assessed. This could
be considering the fact that the baseline groundwater levels at the time of assessment were high in the range of 2 - 3
m. With subsequent growth of the city and increase in industrial activities, there is an increase in the withdrawal of
groundwater. The stress on ground water resources of the area is therefore unascertained as the ESIA study also
does not address this aspect.
The engines of the 115 MW unit are provided with radiators for cooling, therefore cooling water is a closed loop. The
barge mounted unit has once through cooling, and river water is drawn for the process which is discharged back into
the river.
The facility adopts resource conservation as a target on yearly basis and as part of resource conservation for year
2016, the plant has taken a target of reducing Chemical consumption by 5%, Paper consumption by 5%, Cotton rags
by 5%. The targets undertaken as part of Continuous Improvement Plan (CIP) are monitored on monthly basis.
The plant maintains record of consumption of all material, generation of scrap, waste, etc. on monthly basis and
ensures optimal use of all material, with minimal waste.
3.3.2
Greenhouse Gases
Requirement 19
For projects that are expected to or currently produce more than 25,000 tonnes of CO2 - equivalent annually, the
client will quantify direct emissions from the facilities owned or controlled within the physical project boundary, as well
as indirect emissions associated with the off-site production of energy used by the project. The quantification of
emissions should consider all significant sources of greenhouse gas emissions, including non-energy related sources
such as methane and nitrous oxide, among others. Quantification of GHG emissions will be conducted by the client
annually in accordance with internationally recognized methodologies and good practice. The client will consider
alternatives and implement technically and financially feasible and cost-effective options to reduce project-related
GHG emissions during the design and operation of the project.
Observation 19
KPCL quantifies CO2 emissions for both units on quarterly basis. About of 0.0947 million metric tons of Carbon
dioxide has been estimated for the period October to December 2015 as part of it quarterly reports generated for
DoE. The implementation of heat recovery boiler has enabled reduction in CO2 emissions by reducing the fuel
May 2016
KPCL, Khulna
42
requirement/energy requirement for heating the HFO. However, the CO2 reduction from heat recovery is not
quantified.
The barge-mounted power plant has duel fuel capability and can be converted to operate on natural gas operation.
Though HFO is not the most appropriate fuel in terms of CO 2 emissions, however with an evident shortage of gas in
Bangladesh for future years, HFO is the one of better available options.
3.3.3
Requirement 20
The client will avoid the release of pollutants or, when avoidance is not feasible, minimize and/or control the intensity
and mass flow of their release. This applies to the release of pollutants to air, water, and land due to routine, nonroutine, and accidental circumstances with the potential for local, regional, and transboundary impacts. The client
should monitor emissions to ensure that the requirements of Performance Standard 3 are being met. The frequency
with which pollutant emissions are monitored should be appropriate to the nature, scale and variability of potential
impacts.
Observation 20
The key sources of environmental pollution from operation of the KPCL facility are air emissions from stack, noise
generation from engines and wastewater generation. The observations gathered on each aspect have been
presented below:
Air Emissions
Stack Emission
Unit 1 has nineteen (19) HFO based engines (nine for T I and 10 for T III) with nineteen (19) stacks, for emission of
flue gases from its operations. Similarly, Unit 2 has seven (7) stacks for seven (7) HFO based engines. The key
pollutants from the operations are Particulate Matter, Sulphur dioxide and Oxides of Nitrogen. KPCL engages third
party laboratory to undertake annual stack emission monitoring. As part of the annual stack monitoring, following
stacks were monitored in November 2015.
Table 3-4: Details of Stack Monitoring
Unit
Stack
of
Engine
Stack Ht. and Dia
Date of Monitoring
TI – Engine No. 6
26.44 m, 1 m
14 Nov 2015
TI – Engine No. 9
26.44 m, 1 m
15 Nov 2015
TIII – Engine No. 1
26.44 m, 1 m
16 Nov 2015
TIII – Engine No.7
26.44 m, 1 m
17 Nov 2015
Engine No. 1
30 m, 1.6 m
18 Nov 2015
Engine No. 2
30 m, 1.6 m
19 Nov 2015
Time of Monitoring
No.
110 MW (3 readings
from each stack)
115 MW (3 readings
from each stack)
th
9.40, 12.50 and 16.00 hours
th
9.25, 12.35 and 15.50 hours
th
9.30, 12.45 and 15.45 hours
th
9.50, 13.00 and 15.55 hours
th
9.20, 12.35 and 15.40 hours
th
9.40, 13.20 and 15.50 hours
Following observations were made with respect to results of stack emission monitoring:
May 2016
KPCL, Khulna
43
110 MW Unit
115 MW Unit
Emission
IFC
2
Standards
Observation
The stack emission values
for PM were observed to
be exceeding the IFC
limits.
of Sulphur dioxide is within
the permissible IFC limits.
TI
–
Engine
No. 6
TI
–
Engine
No. 9
TIII
–
Engine
No. 1
TIII
–
Engine
No.7
Engine
No. 1
Engine
No. 2
Particulate
Matter
3
(mg/Nm )
54
60.7
61.1
63.8
61.5
62.0
59.6
59.9
68.1
56.1
58.6
54.3
53.2
65.8
59.2
63.8
60.1
59.9
50
Sulphur diOxide
916
949
944
901
921
956
924
845
940
956
957
906
1017
1110
1011
1041
1171
1050
1170
Oxides
of
Nitrogen
1574
1660
1648
1534
1629
1660
1564
1552
1751
1669
1771
1465
1594
1635
1670
1719
1696
1570
 2000
110
Unit)
 1,850
115
Unit)
(for
MW
(for
MW
of oxides of Nitrogen is
within the permissible IFC
limits
It is observed that PM emissions from stack exceed the permissible limits as stipulated by IFC WB guidelines, though
the stack emission monitoring report has not captured this. Further, the sulphur dioxide emissions are within
permissible limits however, the latest fuel analysis reports available during the time of stack monitoring indicate
sulphur content of about 2.4% and 3.5% in fuel used in both units, which is higher than the permissible sulphur
content of 2% as per IFC guidelines. Latest fuel analysis report conducted in March 2016 by Bureau Veritas for HFO
supplied from Singapore indicates that the sulphur content in fuel is 2.51%.
Ambient Air
Ambient air quality monitoring is conducted on quarterly basis by DoE and results are submitted as part of quarterly
reports. Monitoring is conducted only at one location just outside the main gate of the plant. Results gathered from
sampling reports of DoE and quarterly reports are presented in table below.
Table 3-6: Ambient Air Quality Monitoring Results (for 24 hourly monitoring period)
IFC
Parameter
Unit
110 MW Unit
115 MW Unit
Standards
(Guideline
ECR
Standards
values)
Particulate Matter
Sulphur di-Oxide
Oxides
Nitrogen
2
of
3
µg/m
3
µg/m
3
µg/m
77 (as reported for the
period Oct-Dec 2015)
11 (Feb 2016)
12 (Feb 2016)
23 (Feb 2016)
25 (Feb 2016)
50 (24-hourly)
150 (24 hourly)
365 (24 hourly)
20 (24-hourly)
--
100 (Annual)
3
EHS guidelines on Thermal Power Plants (Table 6 (A) - Emissions Guidelines (in mg/Nm or as indicated) for Reciprocating
Engine)
May 2016
KPCL, Khulna
44
The air shed for the area is not degraded, which has been determined on the basis of ambient air quality monitored
on quarterly basis. Results of sulphur dioxides are within permissible limits of IFC and Bangladesh national ambient
3
air quality standards. However, recorded particulate matter values exceed the guideline value of 50 µg/m for 24
hourly monitoring period.
3
The NOx level was recorded are in the range of 23-28 µg/m for the 24 hourly monitoring period, however there are
no guidelines for 24 hourly period as per WB guidelines or DoE and Bangladesh Standards. Based on International
NOx norms (other subcontinental country norms) for 24 hourly monitoring period, the values observed can be
considered to be well within the limits.
Air Dispersion Modelling
A dispersion modelling was carried out as part of the ESIA study for the 110 MW unit using ISCM Ver. 3. However,
the present data is not comparable with the predicted values as cumulative figures for both units are not available.
An air modelling exercise using AERMOD 8.1.0 was conducted for the operation of 115 MW plant (Unit II) to
ascertain the impact of air emissions from combustion of HFO at existing firing rate. As per the results, the maximum
incremental concentration is expected towards the North of the Plant at a distance of 160 – 200 m. The maximum
incremental Ground Level Concentration of SO2, NOx and SPM due to operation of KPCL plant is expected to be
mostly within prescribed limits.
Sulphur Dioxide: The modelled incremental values for SO2 (both 24-hourly and annual) are observed to be less
than 25% of the national ambient air quality standards (NAAQS). The 24 hourly resultant concentration of SO2
significantly exceeds the acceptable IFC guideline value but is within prescribed limits of Bangladesh NAAQS. The
annual average resultant is within the Bangladesh NAAQS.
Oxides of Nitrogen: The modelled incremental values for NOx (annual) are observed to be less than 25% of the
Bangladesh NAAQS. The annual average resultant exceeds IFC guideline value but is within prescribed limits of
Bangladesh NAAQS. The 24 hourly resultant concentration of NOx is high though standards are not available for
direct comparison.
Particulate Matter: The modelled incremental values for SPM (24 hourly) are noted to be within 25% of the
Bangladesh NAAQS. The 24-hourly resultant concentration of SPM is within the prescribed limits of Bangladesh
NAAQS. The concentration exceeds the IFC guideline value of 50 g/m 3 for particulate matter (PM10) by significant
levels. Prescribed limits or IFC guideline values are not available for comparison of SPM over annual averaging
periods. However the concentration was observed to be significantly high and exceeds the standards available for
particulate matter (PM10).
contribution of the plant is not expected to make the air shed degraded. There is a need to collect robust baseline
data within 5km radius of the plant to understand the existing impact of the air emissions, as of now the information is
Noise Emissions
KPCL conducts in-house monthly monitoring for ambient noise levels at six locations around the plant, close to the
plant boundary in different directions. Instantaneous noise level readings in db(A) are recorded for day time and night
time instead of weighted average values, which are not comparable to the Noise Standards of Bangladesh or the
WB-IFC guidelines and do not give clear representation of ambient noise quality of the area. Therefore, more values
are required to be collected at different time during the day and night to arrive at a weighted average.
Table 3-7: Ambient Noise Monitoring Results – Feb 2016
May 2016
KPCL, Khulna
45
ECR
Parameter
Range (dB(A))
IFC Standards
Leq day
71.1 - 73.1
70 dB(A)
75 dB(A)
Leq Night
66.3 - 68.0
70 dB(A)
70 dB(A)
Standards
The values recorded along the boundary (in February 2016) ranges from 71.1 - 73.1 dB(A) during day time and 66.3
- 68.0 dB(A) during the night time. If, the trend of noise continues to be same during the day as per the data recorded
3
then the plant meets the requirements of ambient noise for day time [75 dB(A)] and [70 dB(A)] for night time for
industrial area.
It is to be noted that although prescribed limits for Industrial area are met, however with the residential area in close
proximity the attenuation of noise to residential levels at the households is less likely. Considering the noise levels at
the boundary, it is felt that the residential area towards the south of the plant (i.e. in front of KPCL main gate) would
be exposed to noise levels higher than 45 dB(A) during night time. Also the incremental noise level due to plant at
these receptors could be more than 3 dB(A). No monitoring have been undertaken at the receptors to verify the
same, although the noise recorded at the gate towards the west is recorded as 66.3 dB(A) at night.
Noise level monitoring through external laboratory is not conducted for any of the units.
Surface and ground water Quality
No monitoring is conducted for assessing the surface water quality or ground water quality of the area. Since ground
water is used for drinking, water sample from the tube well at site was tested for drinking water analysis once in
December 2014 and results were well within prescribed limits.
Wastewater Discharges

Various wastewater streams from the plant include boiler blow down, oily water from barges, bilge, RO
rejects, rainwater runoff and domestic wastewater (sewage).

Sewage from onshore facilities is connected to septic tank while sewage generated from barges are treated
in sewage treatment plants (9 m3/day) located on the lower deck of each barge. The treated sewage is not
reused in any manner and discharged into the barge basin. No records pertaining to discharge quantities
are maintained by site personnel.

The oily water collected from barges gets collected in oily water tank located in the lower deck of each
barge. It is thereafter treated in oil water separator before being discharged into the barge basin. The barge
basin water quality is tested in KPCL’s in house laboratory on monthly basis. Whenever it becomes
necessary to pump water from the basin into the river to maintain a fixed level, it is ensured that sampling of
basin water has been undertaken. The results of barge basin water monitoring for the Feb 2016 is
presented in table below and were observed to be within DoE prescribed limits, though the TSS value
exceeds IFC limits:
Table 3-8: Barge Basin Water Quality Results – Feb 2016
Parameter
3
Results
DoE Prescribed
IFC
Limit
Limit
pH
7.38
6-9
6–9
BOD5 (mg/l)
28.6
50
30
Standard
Applicable for Industrial Area as per Noise Pollution Control Rules 2006 and IFC Standards
May 2016
KPCL, Khulna
Total suspended solids
78.5
150
50
9.71
10
10
46
(mg/l)
Oil and Grease (mg/l)

Treated sewage from onboard STP is also monitored for quality in KPCL’s in house laboratory prior to
discharge into the barge basin. Following results were observed with respect to treated sewage quality.
Nitrate and phosphate levels are reportedly tested through external laboratory. The results for Oct – Dec
2015 indicate values within DoE limits however TSS and coliform values exceed IFC standard limits.
Table 3-9: Treated Sanitary Water Quality (from barge STP) – Feb 2016
Parameter
Results -TI
Results - TIII
DoE Prescribed
IFC
Limit
Limit
BOD5 (mg/l)
22
23.2
40
30
Total suspended solids
66.2
65.4
100
50
Coliform (MPN/100 ml)
700
500
1000
400
Temperature (deg. C)
25.2
25.2
30
--
Standard
(mg/l)

River water temperature is monitored on monthly basis for thermal discharges from Unit I. The details are
presented in Section 3.6.1 under PS-6.
3.3.4
Hazardous Materials Management
Requirement 21
The client will avoid or, when avoidance is not possible, minimize and control the release of hazardous materials. In
this context, the production, transportation, handling, storage, and use of hazardous materials for project activities
should be assessed. The client will consider less hazardous substitutes where hazardous materials are intended to
be used in manufacturing processes or other operations. The client will avoid the manufacture, trade, and use of
chemicals and hazardous materials subject to international bans or phase-outs due to their high toxicity to living
organisms, environmental persistence, potential for bioaccumulation, or potential for depletion of the ozone layer.
Observation 21
3
The project handles and store HFO and LFO for its operations. About 15000 MT of HFO and 5000 m of LFO is
stored at the site. It is reported that the National Fire Protection Association (NFPA) guidelines have been followed in
identifying the distance between the tanks and tank areas. The tank farm area was paved and provided with a
containment wall of 2.9 m height, the containment area has been designed to hold the cumulative volume of all tanks
in case of any structural failure. The containment area is linked to an oil water separation sump, and prevents any
contamination to ground or waterbody.
Other chemicals required includes chemicals for water treatment, corrosion control etc., the MSDS of these
chemicals were available at site with adequate storage provisions.
The plant requires about 20,000 – 30,000 Litres of lube oil per month depending on the operations. The lube oil is
stored on paved surfaces in designated area, however no secondary containment or drain line to oil sump was
observed around the storage area, thus there is a potential for run offs from this area reaching unpaved surfaces or
stormwater drains.
May 2016
KPCL, Khulna
47
The facility generated 531 KL of oily water on between Oct - Dec 2015 with a water content of 65%. The oily sludge
3
generated is collected after oil water separation in a sludge tank 50 m capacity. The sludge generated is adequately
store with secondary containment within the tank farm and is sold to authorised vendor, M/s Abdullah Traders at
regular intervals (monthly). The vendor has valid DoE license for collection and disposal of hazardous waste. Oily
hand gloves and oily rags are also generated, which are collected in designated bins and sold to the authorised
vendors along with the Oily sludge.
Other waste material generated from the plant include, containers for thinners, paints, chemicals, rejected tyres,
metal scrap etc. All items are segregated and stored prior to being sold to appropriate vendors.
3.3.5

Water consumption: Groundwater extraction records are not being maintained as the bore well at site is
not metered. The cumulative stress on ground water resources of the area is unascertained as the ESIA
study also does not cover this aspect. Measures for water conservation are not being practiced at site.


periods and therefore not comparable to permissible standards due to absence of 24-hourly guidelines.

level monitoring through external laboratory is also not conducted for any of the units.

Surface water quality monitoring: Though KPCL monitors treated wastewater and basin water prior to
discharge into the river, river water quality is not being measured at any point. Only the temperature of river
water at upstream and downstream locations of intake and outfall points are measured on monthly basis
and records are maintained. Further, no records pertaining to discharge quantities are maintained by site
personnel.
3.3.6

Recommendations
KPCL to maintain records pertaining to groundwater extraction through installation of meter on bore well.
It is advisable that KPCL should conduct a study to evaluate the stress on existing groundwater resources
of the area. The study should assess the existing levels of groundwater, evaluate the water consumption
due to project and assess the impacts. Accordingly, rainwater harvesting and other water conservation
measures should be implemented at site.

The plant should quantify the energy conserved in terms of the heat recovered through heat recovery
boilers and assess its CO2 reduction based on it.

Fuel combustion of engine should be fine-tuned to reduce unburnt carbon particles. Maintenance of engines
and stacks shall be done periodically and stack emission recorded.

Monitoring of ambient air quality should follow the monitoring periods as prescribed by Bangladesh norms
or WB-IFC guidelines particularly for NOx, hourly monitoring data should also be recorded.
May 2016
KPCL, Khulna

48
Noise monitoring should be undertaken as Leq for day and night, which represents a time-weighted average
noise level. Noise levels should be recorded for a continuous period of 24 hours and then averaged for day
and night periods to get a meaningful assessment.

Noise levels at residential areas around the southern boundary should be monitored for night time noise
levels. Adequate control measures should be planned if noise levels exceed national standards or the
incremental noise level is more than 3 dB(A). The incremental noise level can be determined on a day when
the plant is shut for maintenance.

A third party laboratory should be engaged to monitor the noise levels in the plant and surroundings on
annual basis.

For forthcoming quarterly reports for DoE, KPCL should ensure that updated environmental standards of
IFC-WB and Bangladesh DoE are considered in order to monitor compliance.

Water quality of Bhairab River downstream of effluent discharge point should be monitored to ensure that
there is no discharge or impact from plant operations.

Lube oil storage area shall be provided with secondary containment or drains leading to oil water separation
sump.
3.3.7
Material Liability
Monitoring periods, and extent of monitoring needs to improve, however none of the issues can be termed as
material liability.
3.4
Performance Standard (PS) 4: Community Health Safety and Security
3.4.1
Community health and safety
Requirement 22
The client will evaluate the risks and impacts to the health and safety of the Affected Communities during
the project life-cycle and will establish preventive and control measures consistent with good international
industry practice (GIIP),such as in the World Bank Group Environmental, Health and Safety Guidelines (EHS
Guidelines) or other internationally recognized sources. The client will identify risks and impacts and propose
mitigation measures that are commensurate with their nature and magnitude. These measures will favour the
avoidance of risks and impacts over minimization.
Observation 22
The plant has HFO and LFO storage facilities within its boundary, however no risk assessment study has been
conducted to understand tank fire and dyke fire scenario for the storage area. Based on previous experience on such
studies it is observed that a zone of 250 m around the tank would be vulnerable to impact from incident radiation.
This would mean that exposure to community and neighbouring facilities may be limited to western boundary (if any),
however potential exposure to community and workers at site will need to be assessed. The tank farm area is
provided with adequate fire control arrangements.
An Oil Spill Containment Plan is in place to manage any spill during unloading of oil, which may affect the river or
community using it. The project has also prepared detailed emergency response plan, it is reported that the
community members are involved during mock drills to make them aware of emergency preparedness. However, no
May 2016
KPCL, Khulna
49
formal communication or dissemination of information regarding ERP to the community was observed, though the
community informed that few of the residents are aware of evacuation procedures through mock drill participation.
Noise as mentioned in the earlier sections can have impact on the community as the operations are continuous and
will remain there for long periods.
3.4.2
Security Personnel
Requirement 23
When the client retains direct or contracted workers to provide security to safeguard its personnel and property, it will
assess risks posed by its security arrangements to those within and outside the project site. In making such
arrangements, the client will be guided by the principles of proportionality and good international practice in relation
to hiring, rules of conduct, training, equipping, and monitoring of such workers, and by applicable law.
The client will assess and document risks arising from the project’s use of government security personnel deployed
to provide security services. The client will consider and, where appropriate, investigate all allegations of unlawful or
abusive acts of security personnel take action (or urge appropriate parties to take (action) to prevent recurrence, and
report unlawful and abusive acts to public authorities.
Observation 23
The client has engaged M/s Falcon Security Services (FSS) for security and 39 security persons are engaged for
both units of the KPCL facility, including 33 security guards, 5 supervisors and 1 coordinator. FSS is run by retired
army officers, and reportedly it has a robust recruitment mechanism and candidates are chosen after appropriate
screening of background. The company has a training facility set up in Dhaka where both physical training and
practical class on security are conducted by a team of instructor formed by ex-defense personnel. All the serving
security personnel of the company have to undertake an annual re-certification / re-orientation training. Besides, the
management of KPCL conducts monthly briefing on the security duties and standard to all personnel.
The security engaged at the site is unarmed and there has been no complaints regarding their conduct as per the
discussions with the management and grievance records.
3.4.3


observed to have been undertaken by KPCL.
3.4.4

Recommendations
Quantitative Risk Assessment should be undertaken for fuel storage and identify the zone of risks in and
around the plant vicinity.
May 2016
KPCL, Khulna

50
Emergency Response Plan should be disseminated with the community and periodic discussions should be
organized to refresh the same.
3.4.5
Material Liability
Lack of information on risk from fire to storage area can lead to loss of life of workers and affect nearby community in
case of such a disaster. Although the facility has made adequate fire safety arrangements, the lack of risk
assessment is a material liability.
3.5
Resettlement
(PS)
5:
Land
Acquisition
and
Involuntary
Requirement 24
Performance Standard 5 recognizes that project-related land acquisition and restrictions on land use can have
adverse impacts on communities and persons that use this land. Involuntary resettlement refers both to physical
displacement (relocation or loss of shelter) and to economic displacement (loss of assets or access to assets that
leads to loss of income sources or other means of livelihood) as a result of project-related land acquisition and/or
restrictions on land use.
Observation 24
The 110 MW Unit is constructed over 4.7 acres of land taken on lease by KPCL from the Padma Oil Company
Limited through lease deed dated 5th February 1998 for a term of 17 years. Thereafter an indenture of lease was
executed between KPCL and Bangladesh Power Development Board (BPDB) on 3rd June 1998 in order to set forth
the terms and conditions governing the use of the land. The first amendment to the indenture was executed on 16 th
September 2015 wherein the tenure of the lease was extended for another 5 years. For installation of the 115 MW
unit, KPCL further leased 0.8 acres (3100 sq. m.) of land for a period of 5 years, through execution of indenture of
lease with BPDB in February 2012, thus taking the total area of the Plant to 5.5 acres.
It was reported during interactions with site management and community that the land on which the Plant is
established was lying vacant prior to development. The land belonged to Padma Oil Company Limited, which is a
government entity, and no economic activities were being undertaken of the land. The ESIA report prepared in 1998
indicates that the land was free of human habitations. Other facilities on site included a storage tank and associated
pipelines and pump house. The project, thus, did not involve any kind of physical or economic displacement.
Based on the media search and discussions with the plant management it is also understood that there are no
litigations regarding the ownership of this land. The requirements of PS-5 are thus not triggered in this case.
3.6
Performance Standard (PS) 6: Biodiversity Conservation and Sustainable
Management of Living Natural Resources
3.6.1
Protection and Conservation of Biodiversity
Requirement 25
The risks and impacts identification process as set out in PS 1 should consider direct and indirect project-related
impacts on biodiversity and ecosystem services and identify any significant residual impacts. The client should seek
May 2016
KPCL, Khulna
51
to avoid impacts on biodiversity and ecosystem services. When avoidance of impacts is not possible, measures to
minimize impacts and restore biodiversity and ecosystem services should be implemented.
Observation 25
The project is located in an urban set up in Goalpara power plant complex of Khalispur area. The area also has other
industries with no identified significant natural vegetation. There are no legally protected areas or critical habitats
reported within 5km radius from the plant. The Environmental Assessment report mentions that Bhairab River does
not support commercial fishing activities possibly due to river pollution, though some subsistence fishing may occur.
The intake point has a screening system to ensure that small fishes are not trapped into the intake channel.
The cooling water requirement for the 110 MW unit is met through river water. Hot water is discharged back into the
3
Bhairab River, at a depth of 6 -7 m. About 10 m per hour of cooling water for both barges is reportedly drawn from
the river and the same quantity of heated water is discharged. The temperature of intake and discharged water is
monitored on continuous basis through temperature sensors installed at the intake and outfall points. A thermal
plume modelling, using CORMIX, was carried out as part of ESIA study. The modelling output predicted that the
temperature difference will be in the range of 10°C up to a distance of 100 m. The model also indicated that most
benthic organisms and fish will not be impacted since the heated discharge will form a surface plume that will have a
depth of only 1 m.
KPCL monitors the process temperature difference on real time basis from control room on the barges. On the day of
visit, a temperature difference of about 7°C between the intake and outfall points was observed for T-I while about
14°C temperature difference was observed for T-III. River water temperature measurements are taken on monthly
basis at both upstream location of intake point and downstream location of outfall point, at every 10 m distance up to
100 m. Records were reviewed for months of July 2014 and February 2016 and are presented below:
Table 3-10: Temperature Monitoring Records
S.
Monitoring period
No.
At
discharge
point (°C)
Upstream
Temperature
Downstream
Range
Temperature
Temperature
Range
Difference (°C)
(°C)
(°C)
1
July 2014
32.2
29.2 – 33.8
31.9 – 34.3
Up to 3.1°C
2
February 2016
26.2
26.0 – 26.9
26.0 – 26.8
Up to 0.8°C
The results of river water temperature downstream of outfall point indicate compliance with Bangladesh national
requirements of 40°C at 100 m from discharge point. The incremental temperature recorded for summer season is
3.1°C and winter season is 0.8°C in compliance with IFC-WB thermal discharge guidelines. The temperature
difference is also within the range as predicted in thermal plume modelling.
3.6.2
The project is in compliance with PS-6 requirements.
3.6.3
Recommendations
No recommendations have been provided.
3.6.4
Material Liability
No material liability issues have been identified within the context of PS6.
May 2016
KPCL, Khulna
3.7
52
Performance Standard (PS) 7: Indigenous People
Requirement 26
The client will identify, through an environmental and social risks and impacts assessment process, all communities
of Indigenous Peoples within the project area of influence who may be affected by the project, as well as the nature
and degree of the expected direct and indirect economic, social, cultural (including cultural heritage), and
environmental impacts on them.
Observation 26
Khalispur area of Khulna division has not reported presence of any indigenous community. Also, based on
information gathered on past land use of project site, it is understood that the project did not involve any impact on
indigenous peoples due to land procurement. Therefore, the requirements of PS-7 are not triggered in this case.
3.8
Performance Standard (PS) 8: Cultural Heritage
Requirement 27
Client will avoid removing cultural heritage unless there are no alternatives, and benefits outweigh costs. Client will
implement chance find procedures established through the ESA process wherever necessary. Client will consult with
the affected communities who use or have used the cultural heritage.
Observation 27
Secondary literature review and discussions with the site representatives and community suggest that there no
known archaeological structure of importance in or around the project site. The project operation does not affect any
structure of cultural significance. It may also be concluded that there is no possibility of chance find at the project
site, since the management does not have any proposed plans for expansion. Therefore, the requirements of PS-8
are not triggered in this case.
May 2016
Framework, HFO Based Power Plant, KPCL,
Khulna
53
This section delineates the list of actions required to be undertaken by the management to ensure closure of the gaps as identified in Section 3.0 of the report. The Corrective Action Plan is provided below with timelines, responsibilities and specific action items.
The CAP for the same has been furnished below:
The gaps are categorised as red, orange and yellow flag issues based on the severity of impact on the EHS and Social aspect:
Flags
Remarks
Red Flag Issues
These are observations which pose high impact on the environment, health, safety and social aspects and may have legal implications.
Orange Flag Issues
These are observations which pose moderate impact on the environment, health, safety and social aspects.
Yellow Flag Issues
These are observations which pose low or least impact on the environment, health, safety and social aspects.
Table 3-11: Summary of Key Observations and Recommendations – KPCL Khulna Facility
S. No.
1.
Applicable
Performance
Standard
PS-1
Issue Identified
Summary of Issues

ESMS

The IMS does not cover pre construction and
construction stage management.
IMS does not focus on social aspects.
Flag


2.
PS-1
Organisational
Capacity
and Competency


3.
PS-1
External Communication
and Grievance Redressal


4.
PS-2

Employment policy



5.
PS-2
Employment
Contractors
Policy
–

Budget and Resource
Develop a dedicated procedure for social aspects,
covering commitments made under the IMS
Policy.
Preconstruction
and
construction
stage
management procedures should also be outlined
as part of IMS.

Refresher courses and advanced training courses
to be provided to Environmental Officer
Formal short-term training on E&S requirements to
be imparted to IMS team
Responsibility
Timeline (from date
of finalization of this
report)
A third party consultant shall
be engaged to develop social
engagement
procedures
($3000)
Training Courses shall be part
of existing training budget

Plant Manager

Three
Months

Training Courses shall be part
of existing training budget

HR Manager

One month
Develop procedure on information disclosure to
community as part of IMS.
Disclose key information to community pertaining
to plant’s EHS performance, through display
boards, annual reports, etc.
Two tier grievance committee with representatives
from local community should be formed and
grievances to be recorded and resolved in formal
manner.

To be developed as part of
Social engagement aspect of
IMS as mentioned above.
resource

Liaison Officer

Two Month

No
dedicated
team
for
implementing
environmental and social management system.
Environmental
Officer
is
adequately
experienced but not formally qualified in the
subject.

No formal structure / procedures for information
disclosure to the local community on project’s
conformance with environmental compliance
requirements and plant’s EHS performance.
The existing Grievance redressal mechanism is
informal in nature and does not have well
defined escalation levels.

The Employment Policy Document of KPCL
does not adhere to certain requirements of
Bangladesh Labour Law (2006)
No policy on company’s willingness to collective
bargaining or formation of trade unions as per
the BLL and non-engagement of child/ forced
labour in its operations.
Absence of procedures to prevent and address
harassment, intimidation, and/or exploitation,
especially with regard to women.
The policy covers temporary and contract
workers, working for KJAPC, however
contractors engaged by the company i.e.
security agencies (Falcon Security limited) and
Canteen Operator are not covered by the Policy.

The Employment Policy Document to be revised to
accommodate the requirements of Bangladesh
Labour Law (2006) on:
o
Notice period for termination
o
Retirement age
o
Document the total weekly working
hours for an employee with overtime
hours
o
Calculation of Overtime including other
benefits
o
Develop policy on collective bargaining
or formation of trade unions
o
Anti-harassment procedures
o
Non-engagement of child/ forced labour

No additional
resource
budget
or

HR Manager

One Month
Mechanism to monitor the adherence of labour
laws on payment of minimum wages, child
labour verification and working hours for
contract workers engaged through contractors
does not exist.

Develop a mechanism to monitor following for
contract labour:
o
Payment of Minimum wages (review of
salary details)
o
o
Work Hours (review of attendance
records)

No additional
resource
budget
or

HR Manager

One Month




April 2016
Khulna
S. No.
Issue Identified
6.
Applicable
Performance
Standard
PS-2
Grievance Redressal for
employees

Grievances reported by employees are not
recorded, and in case of redressal of
grievances, the actions taken are not
documented in order to track satisfactory
closure of grievances raised.

Grievance received from employees should be
documented and record should be maintained for
all follow - ups and action taken

No additional
resource
or

HR Manager
7.
PS-2
Occupational
Safety

Monitoring of occupational health of employees
in terms of exposure to high noise levels, high
temperatures and EMF not undertaken

Monitoring of occupational noise should be
undertaken for plant staff working in engine room
and other high noise areas.
Duration of exposure and exposure levels of
workers to heat and EMF should be identified.
(Refer to Section 3.2.10 for details)

Occupation Noise, heat and
EMF monitoring through third
party ($ 15000)
Mechanical
Controls
depending on outcome of the
assessment

Safety Officer

One Month

One month
Health
Summary of Issues
&
Flag

Budget and Resource

Responsibility
54
budget
Timeline (from date
report)

One Month
8.
PS-2
Supply Chain

Existing supplier verification process does not
provide mechanism to verify labour aspects
including child labour in the primary supply
chain.

Mechanism to assess the labour related practices
of the supply chain to be developed through child
labour, minimum wages and working conditions
verification for suppliers

No additional
resource
or

Logistic/
manager
9.
PS-3
Resource efficiency

Groundwater extraction records are not being
maintained as the bore well at site is not
metered.
Cumulative impacts on groundwater resources
of the area not assessed.
Measures for water conservation are not being
practiced at site.


Installation of water meter on bore well at site
Maintain records pertaining to groundwater
extraction
Conduct study to evaluate the stress on existing
groundwater resources of the area. The study
should assess the existing levels of groundwater,
evaluate the water consumption due to project and
assess the impacts.
Based on outcome of study, rainwater harvesting
measures for water conservation should be
implemented at site.

Installation of water meter on
bore well (max. $ 400)
Groundwater
Resource
Assessment Study ($15,000)

Environment
Officer

Two months
Quantify energy conserved in terms of the heat
recovered through heat recovery boilers and
assess its CO2 reduction.
Monitoring of ambient air quality should follow the
monitoring periods as prescribed by Bangladesh
norms or WB-IFC guidelines.
Updated environmental standards of IFC-WB and
Bangladesh DoE to be followed in quarterly
reports to monitor compliance.
Fuel combustion of engine should be fine-tuned to
reduce unburnt carbon particles. Maintenance of
engines and stacks shall be done periodically and
stack emission recorded.
Noise monitoring to be undertaken on timeweighted average basis.
Noise levels at residential areas around the
southern boundary should be monitored for night
time noise levels and adequate control measures
should be planned.
Third party laboratory should be engaged to
monitor the noise levels in the plant and
surroundings on annual basis.
Water quality of Bhairab River downstream of
effluent discharge point to be monitored.
KJPAC plant shall quantify the discharge to river
as well as assess the quality of discharge to
ensure no impact on receiving waterbody

Changes
to
Monitoring
requirements;
Additional
monitoring ($ 5000)
Metering of discharge ($ 500)

Environment
Officer

Implement
from
next
monitoring
Two months
Lube oil storage area to be provided with
secondary containment or drains leading to oil
water separation sump

($ 50,000)





10.
PS-3








CO2 emission reduction due to heat recovery
not quantified
Monitoring periods of various parameters not in
accordance with the duration prescribed for
existing norms or guidelines to be comparable.
NOx levels monitored for the facility are
recorded for 24 hourly periods and therefore not
comparable to permissible standards
Particulate matter emissions from all stacks
exceed the permissible limits as stipulated by
IFC WB guidelines.
Noise level monitoring not instantaneous and
not conducted through third party
No noise monitoring have been undertaken at
the residential receptors outside the plant for
noise levels.
River water quality not monitored
No quantification of waste water discharge to
Bhairab River is maintained









11.
PS-3
Hazardous Material

No secondary containment or drain line to oil
sump was observed around the storage area of
lube oil



budget
Asset

Administration/
Logistics
Two months
April 2016
Khulna
S. No.
12.
Applicable
Performance
Standard
PS-4
Issue Identified
Community
Safety
Health
Summary of Issues
and


Quantitative risks associated with emergencies
due to tank fire and dyke fire scenario for the
storage area not done
No formal communication or dissemination of
information regarding ERP to the community
was observed
Flag


Quantitative Risk Assessment should be
undertaken for fuel storage and identify the zone
of risks in and around the plant vicinity
Emergency Response Plan to be disseminated
with the community and periodic discussions to be
organized
Budget and Resource

Engage third party for risk
modelling ($12000)
Responsibility

Safety officer
55
Timeline (from date
report)
Two months
April 2016
ESDD as per IFC Sustainability Framework for Projects under KPCL
1
4.0 Consolidated Corrective Action Plan for Projects under KPCL
Following key action items have been identified that require attention of KPCL.
Note: The following action items should be read in conjunction with the observations, gaps and detailed recommendations provided and summary table presented in Section 3 of both reports.
Sl. No.
Action Item
Budget and Resource
Responsibility and Timeline
Measurable Outcome
EHS&S Management procedures for Preconstruction and construction
A third party consultant shall be engaged to develop
Plant Manager (MR)
Documentation confirming implementation (i.e. procedures, related
stages
procedures ($3000)
Common CAP to both sites
1.
records, trainings, feedback from community, etc.)
Three Months
Social Management Procedures for operation phase, as part of IMS,
including Stakeholder Engagement Plan, Information disclosure and
Community grievance redressal procedure
2.
Update Employment Policy, in line with Bangladesh Labour Law, 2006
Through existing resources, no additional budget
HR Manager
required
Amended Employment Policy Document, documented grievance
records
One month
3.
Formal training courses on environment and social aspects
Through engagement of external agencies ($ 5000 per
HR Manager
Training records
course)
One month
4.
Information disclosure and Community grievance redressal procedure
A third party consultant shall be engaged to develop
Liaison Officer
procedures ($3000)
Documentation confirming implementation (i.e. procedures, related
records, trainings, feedback from community, etc.)
Two months
5.
Work exposure monitoring for occupational noise, heat and EMF on
Monitoring through third party ($ 15000)
Safety Officer
annual basis
Monitoring reports of site staff, implementation of mechanical controls
on the outcome of assessment
One month
6.
Updation of monitoring plan and additional monitoring, as provided in
Through external laboratory
Environment Officer
(Additional monitoring $ 5000)
Implement from next monitoring
Max. $ 50,000
Administration/ Logistics
Monitoring results
summary table of Section 3.0 of both reports.
7.
Secondary containment or drains for lube oil storage area
Department
Two months
8.
Quantitative Risk Assessment for fuel storage
Engage third party for risk modelling ($12000)
Safety Officer
Implementation of recommendations provided as part of study
Two months
9.
Adoption of operational controls for reduction of stack emissions, as
As part of existing maintenance schedule, no additional
provided in summary table of Section 3.0 of both reports.
budget required
Plant Manager
Subsequent stack emission monitoring reports
Immediate
10.
Installation of water meter on bore well
Max. $ 400
Environment Officer
Water consumption records on daily basis
May 2016
ESDD as per IFC Sustainability Framework for Projects under KPCL
Sl. No.
Action Item
Budget and Resource
Responsibility and Timeline
2
Measurable Outcome
Two months
11.
Metering of wastewater discharge point
Max. $ 500
Environment Officer
Wastewater discharge records on daily basis
Two months
KPCL Units, Khulna
12.
Groundwater Resource assessment study
Third party to be engaged ($ 15000)
Environment Officer
Study report and implementation of recommended actions
Two months
KjAPCL Units, Jessore
13.
Procurement of Oil Boom for jetty
Approx. $ 1000 for 30 m
Plant Manager
Procurement of Oil Boom for jetty
May 2016
Annexure A
ESDD Report as per IFC Sustainability Framework 40 MW
KhanJahana Ali Power Plant, Jessore
A-1
Photo No.
Date:
16-03-2016
Location Photo Taken:
From North East of Engine
Room
1
Description:
The picture shows the Engine
room and all 5 Stacks of the
KJAPC plant
Photo No.
Date:
16-03-2016
Inside the Engine room
2
Description:
The picture shows the
alignment of engines in the
engine room
April 2016
A-2
Photo No.
Date:
16-03-2016
South of the Tank Farm Area
3
Description: The
Photograph shows the tank
farm area with HFO
separation unit in the
foreground
Photo No.
Date:
16-03-2016
HFO Separation Room
4
Description:
A well-kept HFO separation
rook with no spills or
leakages, showing both the
separation units.
April 2016
A-3
Photo No.
Date:
16-03-2016
Inside water treatment unit
5
Description: Water
Treatment unit with ion
exchange filters and RO
Photo No.
Date:
16-03-2016
Lube Oil storage Area
6
Description:
The area showing storage of
lube oil on paved area and in
shade, however there is no
secondary containment or
spill collection drain.
April 2016
A-4
Photo No.
Date:
16-03-2016
Near Lube oil Storage area
7
Description: Oil –water
separation sump provided near
the tank farm area.
Photo No.
Date:
16-03-2016
South West of the Engine Room
8
Description: Lube oil storage
without adequate containment
close to storm water channel
April 2016
A-5
Photo No.
Date:
16-03-2016
Inside Engine Room
9
Description:
Foam Flooding Unit was not
found in the designated area
during the site visit
Photo No.
Date:
16-03-2016
From Jetty Area
10
Description:
Area near Jetty proposed for
dredging in Bhairab River
April 2016
A-6
Photo No.
Date:
16-03-2016
West of Engines room
11
Description:
Fire Water Tank
Photo No.
Date:
16-03-2016
Outside Engine room
12
Description: Drums kept for
collection waste within site
April 2016
A-7
Photo No.
Date:
16-03-2016
South West of Engine Room
13
Description:
Rain water Collection Tank,
which was observed to be
defunct
Photo No.
Date:
16-03-2016
East of the Engine Room
14
Description: Heat Recovery
boilers provided for recovering
heat for warming of HFO.
April 2016
A-1
Annexure A: Photo Log – KPCL Plant
Photo No.
Date:
th
1
16 Mar 2016
Spare Storage Room, 115 MW
Unit
Description:
Duly inspected fire extinguishers
Photo No.
Date:
th
16 Mar 2016
2
Admin Block, 115 MW Unit
Description:
Fire Plan displayed in Admin
Block
April 2016
A-2
Photo No.
Date:
th
16 Mar 2016
3
Near barges of 110 MW Unit
Description:
View of the two barges T-I and TIII and barge basin
Photo No.
Date:
th
16 Mar 2016
4
Control room -110 MW unit.
Description:
View of central monitoring
system in control room of 110
MW unit.
April 2016
A-3
Photo No.
Date:
th
16 Mar 2016
5
Control room, 110 MW unit
Description:
CO2 flooding system along with
pirate alarm in control room
Photo No.
Date:
th
16 Mar 2016
6
Jetty construction near 100 MW
unit
Description:
Cooling water discharge point for
110 MW unit
April 2016
Photo No.
Date:
th
16 Mar 2016
A-4
7
DM Plant at KPCL facility
Description:
View of the DM plant used for
demineralizing groundwater used in
the process.
Photo No.
Date:
th
16 Mar 2016
8
Admin Block, 115 MW unit
Description:
Safety statistics displayed for the
KPCL units
April 2016
A-5
Photo No.
Date:
th
16 Mar 2016
9
Lube oil storage yard
Description: Fresh lube oil
storage area, lube oil stored on
paved surface with rain shed
and labelling.
Photo No.
Date:
th
16 Mar 2016
10
Admin Block, 115 MW Unit
Description:
Consultations conducted with the
community members of
Khalispur.
April 2016
Sustainability Framework, 40 MW
HFO Based Power Plant, Jessore
Annexure B: Dispersion Modelling – Jessore Plant
1.1
Input Parameters
An air modelling exercise using AERMOD 8.1.0 was conducted for the operation of the 40MW HFO based Plant at
Jessore to ascertain the impact of air emissions from combustion of HFO at existing firing rate. The project is using
imported HFO with a sulphur content of 3.5% (max). The project has installed five stacks of 27m height with an
internal diameter of 1.1m. The average monitored normal flue gas flow is monitored as 50000 Nm 3/hr for each of the
stack. The stack emission data is presented in Table 1.
Table 1: Stack Emission Data
S. No.
Parameter
Value
Unit
1.
Stack Parameters
a)
Stack Height
27
M
b)
Stack Number
5
Number
c)
Stack diameter
1.1
m
d)
Exit Temperature
350
o
e)
Normal Flue Gas Flow
50000
Nm /hr
2.
Total Load of Stack Emissions
a)
SO2
950
mg/Nm
b)
NOX
1200
mg/Nm
c)
SPM
55
mg/Nm
3.
Rate of Emissions
d)
SO2
13.1
g/s
e)
NOX
16.6
g/s
f)
SPM
0.76
g/s
C
3
3
3
3
The inputs parameters for air dispersion modelling are summarized in Table 2.
Table 2: Input Parameters for Modelling
S.No.
Input
1
Control Pathway
2
Description

Dispersion Option
Non Default Option

Terrain
Flat

Dispersion Coefficient
Urban

Flagpole Receptors
No
Meteorology Input

Met Input Data
Meteorological data from 1 January 2013 to 31
December 2013 (Pre-processed Meteorological
Data)
May 2016
AII-1
S.No.
Input

Description
Wind Speed Categories
A: 1.54 m/s
B: 3.09 m/s
C: 5.14 m/s
D: 8.23 m/s
E: 10.8 m/s
F: No upper bound
4

Latitude
746507 E

Longitude
2548596N

Anemometer Height
15m

Base Elevation
7m
Receptor Pathway
Uniform Cartesian Grid

No. of X axis Receptors
51

No. of Y axis Receptors
51

Spacing for X axis
100m

Spacing for Y axis
100m
5
Source Pathway
Point Source
6
Output Pathway
Pollutants Ground Level Concentration
1.2

NOx
24 hourly and annual

SO2

SPM
Results of Predicted Ambient Air Quality from the Project
Based on inputs provided, predicted 24-hr and annual maximum ground level concentrations of Particulate Matter
(PM), SO2, and NOx due to the emissions from the project are provided in Table 3 to Table 8.
2.1.1
Sulphur Dioxide (SO2)
The predicted 24 hour and annual incremental ground level concentration of sulphur dioxide (SO2) monitored in the
project area is presented in Table 3 and Table 4.
Table 3: Predicted 24-hr Maximum Ground Level Concentration of - SO2
S. No.
Monitoring location
24
hourly
monitored
Baseline
for
SO2
3
Incremental SO2 GLC (g/m )
Total
SO2
Predictive
3
(max)
GLC (g/m )
124.9
135.9
3
(g/m )
1.
Noapara
11
The resultant concentration of 135.9 g/m is well within the acceptable limits for SO 2 for ambient air quality as per
3
Bangladesh national ambient air quality standard of 365 g/m , however it significantly exceeds the IFC guideline
3
May 2016
AII-2
value of 20 g/m 3. The maximum concentration is towards the North east across the river at distance of 200 m and
the maximum GLC for 24 hourly average is 124.9 g/m .
3
Table 4: Predicted Annual Maximum Ground Level Concentration of - SO2
S. No.
Monitoring location
24
hourly
monitored
Baseline
for
SO2
3
Total
SO2
Predictive
3
(max)
GLC (g/m )
27.5
38.5
3
(g/m )
1.
Noapara
11
The resultant concentration of 38.5 g/m is well within the acceptable limits for SO 2 for ambient air quality as per
3
Bangladesh national ambient air quality standard of 80 g/m3 (annual). There is no IFC guideline value for annual
average concentration of SO2. The maximum concentration is towards the North across the river and the maximum
GLC for annual average is 27.5 g/m3.
The corresponding isopleths for 24 hourly and annual SO2 emissions from the KJAPC plant operations is as given in
Figure 1 and Figure 2.
May 2016
AII-3
AII-4
Figure 1: Isopleths – SO2 (24 Hourly)
Description
Overall
Dispersion
Isopleth
of
emission
through the year. As the wind blows
from the south for most part of the
year. The key area of spread is
towards the North east at distance
of 200 m.
May 2016
Description
AII-5
Isopleth
Isopleth showing area towards the
North where the GLC is maximum
May 2016
AII-6
Figure 2: Isopleths – SO2 (Annual)
Description
Overall
Dispersion
Isopleth
of
emission
towards the North east at distance
of 200 m.
May 2016
Description
AII-7
Isopleth
North east where the GLC is
maximum
May 2016
2.1.2
Oxides of Nitrogen (NOx)
The predicted 24 hour and annual incremental ground level concentration of NOx at all the monitored locations for
ambient air quality is presented in Table 5 and Table 6.
Table 5: Predicted 24-hr Maximum Ground Level Concentration of - NOx
S. No
Monitoring location
1.
Noapara
24
hourly
Baseline Incremental
3
NOx
3
3
monitored for NOx (g/m ) (g/m ) (max)
(g/m )
158.33
27
GLC Total NOx Predictive GLC
185.33
The resultant 24 hourly concentration of NOx is observed to be quite high, though there are no standards available at
national level or IFC to compare the results. The maximum concentration is towards the south east, west and north
east at 400 m across the river and the maximum incremental GLC for 24 hourly average is 185.33 g/m . The
3
corresponding isopleth for NOx emissions from the KJAPC plant operations is as given in Figure 3.
Table 6: Predicted Annual Maximum Ground Level Concentration of - NOx
S. No
Monitoring location
1.
Noapara
24
hourly
3
3
34.9
27
NOx
3
(g/m )
61.9
The resultant concentration of 61.9 g/m3 for NOx is within the prescribed limits for ambient air quality as per
Bangladesh national ambient air quality standard of 100 g/m3 (annual) however exceeds the IFC guideline value of
40 g/m3 (annual). The maximum concentration is towards the North at 175 m across the river and the maximum
incremental GLC for annual average is 34.9 g/m .
3
The corresponding isopleths for 24 hourly and annual NOx emissions from the KJAPC plant operations is as given in
Figure 3 and Figure 4.
May 2016
AII-8
AII-9
Figure 3: Isopleths – NOx (24 hourly)
Description
Overall
Dispersion
Isopleth
of
NOx
emission through the year. As
the wind blows from the south
for most part of the year. The
key area of spread is towards
the south east, west and north
east at 400 m across the river
May 2016
Description
AII-10
Isopleth
Isopleth showing area towards
south east, west and north east
at 400 m across the river where
the GLC is maximum
May 2016
AII-11
Figure 4: Isopleths – NOx (annual)
Description
Overall
Dispersion
Isopleth
of
NOx
emission through the year. As
the wind blows from the south
for most part of the year. The
the north at 175 m across the
river
May 2016
Description
AII-12
Isopleth
Isopleth showing area towards
north east at 175 m across the
river
where
the
GLC
is
maximum
May 2016
2.1.3
Particulate Matter (PM)
The predicted 24 hour and annual incremental ground level concentration of particulate matter (PM) at all the
monitored locations for ambient air quality is presented in Table 7 and Table 8.
Table 7: Predicted 24-hr Maximum Ground Level Concentration of - PM
S. No
Monitoring location
1.
Noapara
24
hourly
3
NOx
3
3
monitored for PM (g/m )
(g/m ) (max)
(g/m )
171
7.24
128.24
The resultant 24 hourly concentration of PM is observed to be exceeding the IFC guideline value of 50 g/m3 but is
within the Bangladesh NAAQs standards of 150 g/m3. The maximum concentration is towards the North east across
the river and the maximum incremental GLC for 24 hourly average is 7.24 g/m3.
Table 8: Predicted Annual Maximum Ground Level Concentration of - PM
S. No.
Monitoring location
24
hourly
monitored
Baseline
for
PM
Incremental
PM
3
GLC (g/m )
Total
PM
Predictive
3
(max)
GLC (g/m )
1.6
172.6
3
(g/m )
1.
Noapara
171
The resultant concentration of 172.6 g/m3 is exceeding acceptable limits for PM for ambient air quality as per
Bangladesh national ambient air quality standard of 50 g/m (annual) and IFC guideline value of 20 g/m . The
3
3
maximum concentration is towards the North east across the river and the maximum GLC for annual average is 1.6
g/m 3.
The corresponding isopleth for PM emissions from the KJAPC plant operations is as given in Figure 5.
May 2016
AII13
AII-14
Figure 5: Isopleths – PM (24 hourly)
Description
Overall
Dispersion
Isopleth
of
emission
towards the North east
May 2016
Description
AII-15
Isopleth
North where the GLC is maximum
May 2016
1.3
Inference and Recommendation
The maximum incremental concentration is expected towards the North and north east of the Plant at a distance of
175 - 400 m. The maximum incremental Ground Level Concentration of PM, SO2 and NOx due to operation of
KJAPC is significantly high. Following observations have been made on the basis of results obtained:
Sulphur Dioxide: The modelled incremental values for SO 2 (both 24-hourly and annual) are observed to be more
than 25% of the national ambient air quality standards (NAAQS). The 24 hourly resultant concentration of SO 2
significantly exceeds the IFC guideline value but is within prescribed limits of Bangladesh NAAQS. The annual
average resultant also exceeds the Bangladesh NAAQS.
Oxides of Nitrogen: The modelled incremental values for NOx (annual) are observed to be more than 25% of the
NAAQS. The annual average resultant exceeds IFC guideline value but is within the Bangladesh NAAQS. The 24
hourly resultant concentration of NOx is significantly high though standards are not available for comparison.
Particulate matter: The modelled incremental values for PM (24-hourly) is observed to be more than 25% of the
national ambient air quality standards (NAAQS)m though annual average values are less than 25% of NAAQS. The
24 hourly resultant concentration of PM significantly exceeds the IFC guideline value but is within prescribed limits of
Bangladesh NAAQS. The annual average resultant exceeds both the Bangladesh NAAQS and IFC guideline value.
contribution of the plant is expected to make the air shed degraded. There is a need to collect robust baseline data
within 5km radius of the plant to understand the existing impact of the air emissions, as of now the information is
It was further observed that the existing height of stacks is adequate considering the scale of operations, however air
dispersion from the operation of the engines is observed to be significantly high. Following recommendations are
proposed for reducing stack emissions:

o
residence time. This can reduce the concentration of NOx that is generated by reducing peak
temperature.
o
Valve timing adjustments to reduce residence time at peak temperature to control NOx formation.
Shall be explored
o
In case the above two adjustment do not yield appropriate results Chemical reduction of NOx using
catalytic converters to reduce NOx to N2 shall be considered.

Use of fuel with even lower sulphur content i.e. less than 2%, to reduce SO 2 emissions is recommended.

In case, none of the above mentioned measures are effective, then raising stack height needs to be considered by
KJAPC.
May 2016
AII-16
Based Power Plant, KPCL, Khulna
Annexure B: Dispersion Modelling – KPCL Plant
1.1
Input Parameters
An air modelling exercise using AERMOD 8.1.0 was conducted for the operation of the 115 MW (Unit II) HFO based
Plant at Khulna to ascertain the impact of air emissions from combustion of HFO at existing firing rate. The project is
using imported HFO with a sulphur content of 3.5% (max). The project has installed seven stacks of 30 m height .
The average monitored normal flue gas flow is monitored as 77750 Nm3/hr for each of the stack Unit II. The stack
emission data is presented in Table 1.
Table 1: Stack Emission Data
S. No.
Parameter
Value
Unit
1.
Stack Parameters
a)
Stack Height
30
M
b)
Stack Number
7
Number
c)
Stack diameter
1.6
m
d)
Exit Temperature
350
o
e)
Normal Flue Gas Flow
105000
Nm /hr
2.
Total Load of Stack
C
3
Emissions
3
a)
SO2
381
mg/Nm
b)
NOX
360
mg/Nm
c)
SPM
17
mg/Nm
3.
Rate of Emissions
d)
SO2
7.7
g/s
e)
NOX
8.2
g/s
f)
SPM
0.367
g/s
3
3
The inputs parameters for air dispersion modelling are summarized in Table 2.
Table 2: Input Parameters for Modelling
S.No.
Input
1
Control Pathway
2
Description

Dispersion Option
Non Default Option

Terrain
Flat

Dispersion Coefficient
Urban

Flagpole Receptors
No
Meteorology Input

Met Input Data
Meteorological data from 1 January 2013 to 31
December 2013 (Pre-processed Meteorological
Data)
May 2016
AII-1
S.No.
Input

Description
Wind Speed Categories
A: 1.54 m/s
B: 3.09 m/s
C: 5.14 m/s
D: 8.23 m/s
E: 10.8 m/s
F: No upper bound
4

Latitude
23.013189 N

Longitude
89.388189 E

Anemometer Height
15m

Base Elevation
7m
Receptor Pathway
Uniform Cartesian Grid

No. of X axis Receptors
101

No. of Y axis Receptors
101

Spacing for X axis
100m

Spacing for Y axis
100m
5
Source Pathway
Point Source
6
Output Pathway
Pollutants Ground Level Concentration
1.2

NOx

SO2

PM
Results of Predicted Ambient Air Quality from the Project: 24 hourly
Based on inputs provided, predicted 24-hr maximum ground level concentrations of SO2, NOx and SPM due to the
emissions from the project are provided in Table 3 and Table 4.
2.1.1
The predicted 24 hour incremental ground level concentration of sulphur dioxide (SO2) monitored in the project area
is presented in Table 3.
Table 3: Predicted 24-hr Maximum Ground Level Concentration of - SO2
S. No.
Monitoring location
24
hourly
Baseline
3
1.
Daulatpur
Incremental
3
SO2
GLC
Total
SO2
Predictive
3
monitored for SO2 (g/m )
(g/m ) (max)
GLC (g/m )
14
72.27
86.27
The resultant 24 hourly concentration is within the acceptable limits for SO2 for ambient air quality as per Bangladesh
national ambient air quality standard of 365 g/m but exceeds IFC guideline value of 20 g/m . The maximum
3
3
concentration of SO2 is towards the North across the river and the maximum predicted incremental GLC for 24 hourly
May 2016
AII-2
average 72.27 g/m3. The corresponding isopleth for SO2 emissions from the KPCL plant operations is as given in
Figure 1.
May 2016
AII-3
AII-4
Figure 1: Isopleths – SO2 (24 hourly)
Description
Overall
Dispersion
Isopleth
of
emission
towards the North.
May 2016
Description
AII-5
Isopleth
North where the GLC is maximum ,
at about 200 m.
May 2016
2.1.2
The predicted 24 hour incremental ground level concentration of NOx at all the monitored locations for ambient air
quality is presented in Table 4.
Table 4: Predicted 24-hr Maximum Ground Level Concentration of - NOx
S. No
Monitoring location
1.
Daulatpur
24
hourly
3
3
NOx
3
(g/m )
29
106.01
77.01
The resultant 24 hourly concentration of NOx is observed to be significantly high, though there are no standards
available at national level or IFC guidelines to compare the results. The maximum incremental concentration is
observed towards North across the river and the maximum incremental GLC for 24 hourly average is 77.01 g/m3.
The corresponding isopleth for NOx emissions from the KPCL plant operations is as given in Figure 2.
May 2016
AII-6
AII-7
Figure 2: Isopleths – NOx (24 hourly)
Description
Isopleth
Overall Dispersion of NOx
emission through the year.
As the wind blows from the
south for most part of the
year. The key area of spread
is towards the North.
April 2016
Description
AII-8
Isopleth
Isopleth for NOx around the
Plant
, showing area of
maximum impact
200m to
the North.
April 2016
2.1.3
AII-9
Particulate Matter (SPM)
The predicted 24 hour incremental ground level concentration of SPM at all the monitored locations for ambient air
Table 5: Predicted 24-hr Maximum Ground Level Concentration of - SPM
24
S. No
Monitoring location
hourly
monitored
for
3
SPM (g/m ) (max)
3
(g/m )
1.
Daulatpur
77
3.44
SPM
GLC
Total SPM Predictive GLC
3
(g/m )
80.44
The resultant concentration is within the acceptable limits for SPM for ambient air quality as per Bangladesh national
ambient air quality standard (200 g/m 3) but IFC guideline value of 50 g/m 3 for particulate matter (PM10). The
maximum incremental concentration is observed towards North across the river and the maximum incremental GLC
for 24 hourly average is 3.44 g/m3. The corresponding isopleth for SPM emissions from the KPCL plant operations
is
as
given
in
Figure
3.
April 2016
AII-10
Figure 3: Isopleths – SPM (24 hourly)
Description
Overall
Dispersion
Isopleth
of
SPM
emission through the year. The
key area of spread in towards
north.
May 2016
Description
AII-11
Isopleth
Isopleth for SPM around the
Plant.
The
maximum
concentration is observed at
about 200 m to the North of the
plant.
May 2016
1.3
Results of Predicted Ambient Air Quality from the Project: Annual
Based on inputs provided, predicted annual maximum ground level concentrations of SO 2, NOx and SPM due to the
emissions from the project are provided in Table 3 and Table 4.
2.1.4
The predicted annual incremental ground level concentration of sulphur dioxide (SO2) monitored in the project area is
presented in Table 6.
Table 6: Predicted Annual Maximum Ground Level Concentration of - SO2
S. No.
Monitoring location
24
hourly
monitored
Baseline
for
SO2
3
Total
SO2
Predictive
3
(max)
GLC (g/m )
20.59
34.59
3
(g/m )
1.
Daulatpur
14
The annual resultant concentration is within acceptable limits for SO2 for ambient air quality as per Bangladesh
national ambient air quality standard of 80 g/m 3. There is no IFC guideline value for annual average concentration of
SO2. The maximum concentration is towards the North across the river and the maximum predicted incremental GLC
for annual average is 20.59 g/m 3. The corresponding isopleth for SO2 emissions from the KPCL plant operations is
as given in Figure 4.
May 2016
AII12
AII13
Figure 4: Isopleths – SO2 (Annual)
Description
Overall
Dispersion
Isopleth
of
emission
towards the North.
May 2016
Description
AII14
Isopleth
North at about 170 m from plant
where the GLC is maximum.
May 2016
2.1.5
The predicted annual incremental ground level concentration of NOx at all the monitored locations for ambient air
Table 7: Predicted Annual Maximum Ground Level Concentration of - NOx
S. No
Monitoring location
1.
Daulatpur
24
hourly
3
3
NOx
3
(g/m )
29
50.95
21.95
The resultant concentration is within the NOx value for ambient air quality as per Bangladesh national ambient air
quality standard of100g/m3 (annual) but exceeds IFC guideline value of 40 g/m 3 (annual). The maximum
incremental concentration is observed towards North across the river and the maximum incremental GLC for annual
average is 21.95 g/m3. The corresponding isopleth for NOx emissions from the KPCL plant operations is as given in
Figure 5.
May 2016
AII15
AII-16
Figure 5: Isopleths – NOx (Annual)
Description
Isopleth
Overall Dispersion of NOx
emission through the year.
As the wind blows from the
south for most part of the
year. The area of spread is
predominantly towards the
North.
April 2016
Description
AII-17
Isopleth
Isopleth for NOx around the
Plant,
showing
area
of
maximum impact 150 m to
the North.
April 2016
2.1.6
AII18
Particulate Matter (SPM)
The predicted annual incremental ground level concentration of SPM at all the monitored locations for ambient air
Table 8: Predicted Annual Maximum Ground Level Concentration of - SPM
24
S. No
Monitoring location
hourly
monitored
for
SPM
GLC
3
SPM (g/m ) (max)
3
(g/m )
3
(g/m )
1.
Daulatpur
77
Total SPM Predictive GLC
0.98
77.98
The resultant annual average concentration of SPM has been noted to be 77.98 g/m approximately at a distance of
3
160 m to the north of the plant. The maximum incremental GLC for SPM is 0.98 g/m3. Bangladesh national AAQ
standards for SPM over annual averaging period are not available, however the resultant exceeds the standard value
of 50 g/m3 for particulate matter (PM10). Similarly the resultant exceeds the IFC guideline values over annual
averaging period for particulate matter (PM10) i.e. 20 g/m3. The corresponding isopleth for SPM emissions from the
KPCL
plant
operations
is
as
given
in
Figure
6.
April 2016
AII-19
Figure 6: Isopleths – SPM (Annual)
Description
Overall
Dispersion
Isopleth
of
SPM
emission through the year. The
North.
May 2016
Description
AII-20
Isopleth
Isopleth for SPM around the
Plant.
The
maximum
concentration is observed at
about 160 m to the North.
May 2016
1.4
Inference and Recommendations
The maximum incremental concentration is expected towards the North of the Plant at a distance of 160 – 200 m.
The maximum incremental Ground Level Concentration of SO2, NOx and SPM due to operation of KPCL plant is
expected to be mostly within prescribed limits. Following observations have been made on the basis of results
obtained:
Sulphur Dioxide: The modelled incremental values for SO2 (both 24-hourly and annual) are observed to be less
than 25% of the national ambient air quality standards (NAAQS). The 24 hourly resultant concentration of SO2
significantly exceeds the acceptable IFC guideline value but is within prescribed limits of Bangladesh NAAQS. The
annual average resultant is within the Bangladesh NAAQS.
Oxides of Nitrogen: The modelled incremental values for NOx (annual) are observed to be less than 25% of the
Bangladesh NAAQS. The annual average resultant exceeds IFC guideline value but is within prescribed limits of
Bangladesh NAAQS. The 24 hourly resultant concentration of NOx is high though standards are not available for
direct comparison.
Particulate Matter: The modelled incremental values for SPM (24 hourly) are noted to be within 25% of the
Bangladesh NAAQS. The 24-hourly resultant concentration of SPM is within the prescribed limits of Bangladesh
NAAQS. The concentration exceeds the IFC guideline value of 50 g/m3 for particulate matter (PM10) by significant
levels. Prescribed limits or IFC guideline values are not available for comparison of SPM over annual averaging
periods. However the concentration was observed to be significantly high and exceeds the standards available for
particulate matter (PM10).
contribution of the plant is not expected to make the air shed degraded. There is a need to collect robust baseline
data within 5km radius of the plant to understand the existing impact of the air emissions, as of now the information is
Following recommendations could be utilized for further reducing stack emissions:

o
residence time. This can reduce the concentration of NOx that is generated by reducing peak
temperature.
o
Valve timing adjustments to reduce residence time at peak temperature to control NOx formation.
Shall be explored
o
In case the above two adjustment do not yield appropriate results Chemical reduction of NOx using
catalytic converters to reduce NOx to N2 shall be considered.

Use of fuel with even lower sulphur content i.e. less than 2%, to reduce SO 2 emissions is recommended.


Fuel combustion of engine should be fine-tuned to reduce unburnt carbon particles.

The facility should refer Annexure 1.1.2 of World Bank EHS guidelines to evaluate the prevention and
control technologies which may include various methods or mix of methods to control emission levels.
May 2016
AII-21
AECOM
www.aecom.com
About AECOM
AECOM (NYSE: ACM) is a global provider of
Professional technical and management support
services to a broad range of markets, including
transportation, facilities, environmental, energy, water
and government. With approximately 45,000 employees
around the world, AECOM is a leader in all of the key
markets that it serves. AECOM provides a blend of
global reach, local knowledge, innovation, and
collaborative technical excellence in delivering solutions
that enhance and sustain the world’s built, natural, and
social environments. A Fortune 500 company, AECOM
serves clients in more than 130 countries and has
annual revenue in excess of $8.0 billion.
More information on AECOM and its services can be
found at www.aecom.com.
AECOM
19th Floor, Tower C, Cyber Terraces, Building 5, DLF Phase 3
Gurgaon, 122002, India
T +91-124-4682800/-2700
aecom.com

Set V - ESDD report for pro

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