Bangladesh: Southwest Transmission Grid Expansion Project

Semi-annual Environmental Monitoring Report

Project No. 51137-001 June 2020

Bangladesh: Southwest Transmission Grid Expansion Project

This semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily represent those of ADB's Board of Directors, Management, or staff, and may be preliminary in nature.

In preparing any country program or strategy, financing any project, or by making any

designation of or reference to a particular territory or geographic area in this document, the

Asian Development Bank does not intend to make any judgments as to the legal or other status

of any territory or area.

Southwest Transmission Grid Expansion Project

Loan 3683-BAN | Grant No. 0589 | Component BAN & 0590-BAN

Semi-Annual Environmental Monitoring Report

Reporting Period

January to June 2020

Implementing Agency

Power Grid Company of Bangladesh Limited (PGCB)

Ministry of Power, Energy and Mineral Resources

(Power Division)

June 2020

Environmental Monitoring Report

Southwest Transmission Grid Expansion Project

Semi-Annual Environmental Monitoring Report

January to June 2020

June 2020

The environmental impact assessment report is a document of the borrower. The views expressed herein

do not necessarily represent those of ADB’s Board of Directors, Management, or staff, and may be

preliminary in nature.

Southwest Transmission Grid Expansion Project Semi-annual Environmental Monitoring Report (January – June 2020)

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Table of Contents

Executive Summary

I. Introduction 1 A. Background 1 B. The project 1

1. Brief project information 1 2. Impact and Outcome 4 3. Outputs 4

C. ADB and GoB categorization 4 D. Purpose of the Environmental Safeguards 5 E. PGCB safeguards policy 1

II. Status of Ongoing Contract Packages 3 A. Project status 3

1. Package No. 1Bangladesh: Southwest Transmission Grid Expansion Project 3 2. Package No. 2 3 3. Package No. 3 3 4. Package No. 4 4 5. Package No. 5 4

B. Contract requirements (Environment) 4 C. Financing Agreement 4

III. Environmental Status 5 A. Status of Environmental Safeguards Documents 5 B. Environmental safeguards monitoring 5

1. Gopalganj substation 5 2. Transmission line 6

C. Construction period environmental quality monitoring 8 1. Gopalganj substation 8 2. Transmission line subproject: Bogura-Rahanpur 400kV 8 3. Transmission line subproject: Chapainawabganj-Rahanpur 132kV 10

D. Training, awareness and workshop 13 E. Environmental issues of the current project 14 F. Performance of EMP implementation 14 G. Grievance Redress Mechanism 29

IV. Environmental Compliance (agreements) 30 A. Compliance with environmental related project covenants 30

1. National Covenant 30 2. The ADB Safeguards Policy Statement (2009) 33 3. ADB Safeguards Policy Statement (2009) compliance status 34 4. Compliance with loan Covenants 35

V. Performance Indicators 37 A. Overall performances 37 B. Health and Safety performance 41 C. COVID – 19 response performance 43

VI. Concluding Observations 45 VII. Appendix - I 47


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List of Tables

Table I-1 Brief project information 1 Table III-1 Summary Status of environmental safeguards documents prepared for the project 5 Table III-2 Noise testing results at TL sites 8 Table III-3 Water quality test results at the TL sites 9 Table III-4 Air quality test results at TL sites 9 Table III-5 Soil test results at TL sites (400kV TL Naogaon site) 10 Table III-6 Noise test results at TL sites (132kV) 10 Table III-7 Water quality test results at TL sites (132kV) 11 Table III-8 Air quality test results at TL sites (132kV) 12 Table III-9 Performance status of the EMP implementation processes in the project 15 Table IV-1 Summary of Environmental Legislations Applicable to the Proposed Project 30 Table IV-2 ADB Safeguards Policy environmental compliance Status for the STGEP subprojects (ADB

SPS 2009 Appendix 1 Safeguards Requirement: Environment) 34 Table IV-3 Compliance with Environmental Considerations of Loan Agreements 35 Table V-1 Overall performance in relation to environmental compliance (Gopalganj substation) 37 Table V-2 Overall performance in relation to environmental compliance (TL) 39 Table V-3 H&S Performance indicators of all subprojects 42 Table V-4 COVID-19 Performance indicators of all subprojects 43

List of Figures

Figure I-1 Project area of the southern part 3 Figure I-2 Project area of the northern part 3 Figure IV-1 Overall environmental monitoring checklist reported by Energypac (Sample June 2020) 6 Figure IV-2 Monitoring checklists used by KPTL (Sample June 2020) 7 Figure IV-3 Onsite water quality and air quality test at TL site 12 Figure IV-4 Onsite training and awareness materials at the project sites 13


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ABBREVIATIONS

ADB Asian Development Bank

APs affected persons

BDT Bangladesh Taka (Currency)

CAP Corrective Action Plan

CSMMP Construction Site Management and Monitoring Plan

DOE Department of Environment

DC Deputy Commissioner

EA Executing Agency

EIA Environmental Impact Assessment

EPC Engineering, Procurement and Construction

ESIA Environmental and Social Impact Assessment (ESIA)

ESMP Environmental and Social Management Plan

ECC Environmental Clearance Certificated

EMP Environmental Management Plan

ECR Environmental Conservation Rule

GoB Government of Bangladesh

GRC Grievance Redress Committee

GRM Grievance Redress Mechanism

HIV Human Immunodeficiency Virus

HSE Health Safety and Environment

IEE Initial Environmental Examination

KPTL Kalpataru Power Transmission Limited

PAP Project Affected Person

PMU Project Management Unit

PIU Project Implemented Unit

PPE Personal Protective Equipment

RAP Resettlement Action Plan

RP Resettlement Plan

ROW Right of Way

SMP Social Management Plan

SPS Safeguard Policy Statement

TL Transmission line


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Executive Summary

1 This report is the Semi-annual Environmental Monitoring Report (hereinafter refereed as EMR) of

the Asian Development Bank (ADB) financed Southwest Transmission Grid Expansion Project (STGEP) in

Bangladesh, which covers the period of January – June 2020.

2 The project will improve the operational performance of the power sector and contribute to the

Government of Bangladesh’s target to achieve electricity for all by 2021 through (i) constructing (a) a

400/132-kilovolt (kV) substation at Gopalganj; (b) a 230 kV transmission line in the southern zone, from

Barisal to Faridpur; and (c) a 400 kV transmission line in the western zone, from Bogra to Rohanpur; and

(ii) implementing a capacity development program in the electric utility industry to promote socially and

gender inclusive growth. The project will use state-of-the-art conductors with higher power transmission

capacity and lower energy loss in both the 230 kV and 400 kV transmission lines.

3 The Department of Environment is responsible for environmental issues while forest issues are

looked after by Department of Forests. Over the years, the MoEFCC has adopted number of legal

instruments in the form of Acts for the protection and conservation of the environment. Table IV-1

summarizes the Environmental Legislation applicable to the sub-projects. Refer to Table IV-2 for the status

of the respective component sub-projects with regard to environmental compliance status to ADB’s policy

statement (SPS 2009). Schedule 4 of the Agreements for Grant 0582-BAN includes covenants for

environmental issues. The Project’s compliance with the contractual environmental safeguards’ covenants

are shown in the Table IV-3

4 A GRC has been formed for mitigating any unavoidable circumstances during implementing the

compensation process. The committee consists of representatives from PGCB, EPC Contractor,

Consultant (IISPL), and local people. Any dispute regarding determination of compensation against the

losses, usage of land for tower construction and approach road, and other relevant issues during

construction will be solved through the GRC. No grievances have arisen during the reporting period January

2020 to June 2020 at the Transmission Line and Substation project.

5 At Gopalganj substation site Enegrypac is working as contractor and they have their HSE team at

site. The HSE team is lead my Mr. Moniruzzaman. The entire team with their phone number and

designation is listed at site and in their report. The HSE team is monitoring the site continuously and report

back to the contractor who shares with PGCB. To date Monthly environmental inspection report is the

lowest tier of environmental reporting. The latest report is available for June 2020.

6 Kalpataru Power Transmission Limited is the contractor for the transmission line project

(132kV/230kV). The HSE team of the contractor is led by Md. Nur E Alam Siddique, Environmental

Specialist. Environmental monitoring in the field is carried out by the Engineers and the task of actual

monitoring is undertaken by environmental specialists. The environmental specialist is mobilized on an

intermittent basis to undertake field audits and compilation of necessary periodic environmental report for

the PGCB and Financier (Asian Development Bank).

7 The IEE prepared for the project has estimated around 8900 plants to be affected during

construction of Transmission Line (TL). Records of compensation for trees are not well kept. During Midterm

Review Mission with ADB, the Project Director mentioned that the compensation has been paid and the

records will be provided to ADB in due course. The tree plantation plan has not been formulated yet.


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However, the contractor of the Subproject, KPTL mentioned that they have already distributed 2000

saplings to local schools and Madrasas. This record is also not well kept.

8 At both sites, toolbox meetings were found as commonly adopted instead of formal training for EMP

implementation. Both sites are equipped with a trained HSE team lead by specialist. It has been found that,

at Gopalganj substation site, the HSE team works at site with every activity are monitored by a specialist

who is staff of the company. The activities include toolbox meeting, monitoring and reporting, register

maintenance and check upon environmental checklists. On the other hand, at the TL worksite, the

contractor has hired an external environmental specialist to lead the HSE team. The team does regular

HSE meetings and report as monitoring checklists.

9 At TL worksite some awareness materials were also found to be displayed nearby, although the

awareness materials are not found to be adequate, especially in the time of COVID-19 Pandemic. In the

Gopalganj substation site, the site is closed and awareness poster or signboards were found. It is

recommended that, regarding the COVID-19 situation, signboards and posters suggested by ADB and

Health Department of GoB should be showing at the worksite.

10 Until date no significant environmental issue has been identified and reported. However, during

discussion at the Mid Term Review Mission of ADB, it was known that during construction of the substation

low land was sand filled and prepared for construction. No record for local waterlogging, drainage

congestion and grievance has been kept. It was advised that such record needed to be kept all the time

and should be shared with ADB. Since the worksites were in pause during the high outbreak of COVID-19,

not many environmental issues were identified and reported.

11 The concluding observations are as follows:

The Environmental Safeguards compliance performance of the EAs are in good shape except

a few things. The onsite training workshop and regular monitoring of PGCB and contractors

HSE team to sensitize the workers need to be continued for greater benefit.

Due to accessibility issues attributed to restrictions associated with COVID-19, implementation

of environmental safeguards is hindered. In addition, inadequate safety measures, especially

social distancing and frequent disinfection of equipment are still visible at work site.

Environmental quality data from periodic monitoring indicated that in reference to the

Bangladesh standard, the quality of ambient air and groundwater in the project area is within

the standard limit. The noise level is within the safe limit for mixed areas with intermittent spikes

due to proximity of the sites to the roads and human interference.

The labour shed and labour hygiene appear to be ignored by the contractors. This needs

immediate attention and frequent monitoring to improve the condition of labour sheds and

associated hygiene facilities.


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I. Introduction

A. Background

12 This report is the Semi-annual Environmental Monitoring Report (hereinafter refereed as EMR) of

the Asian Development Bank (ADB) financed Southwest Transmission Grid Expansion Project (STGEP) in

Bangladesh, which covers the period of January – June 2020. The report is produced to comply with the

environmental scope stipulated in the sub-projects’ Environmental Management Plans (EMPs)

implemented by Power Grid Company of Bangladesh Limited (PGCB), Ministry of power, Energy and

mineral resources, under the project. The report serves the mandatory monitoring report in the form of six-

monthly environmental safeguards monitoring as per the loan agreement between ADB and Bangladesh

Government and belongs to PGCB.

B. The project

13 The project will improve the operational performance of the power sector and contribute to the

Government of Bangladesh’s target to achieve electricity for all by 2021 through (i) constructing (a) a

400/132-kilovolt (kV) substation at Gopalganj; (b) a 230 kV transmission line in the southern zone, from

Barisal to Faridpur; and (c) a 400 kV transmission line in the western zone, from Bogra to Rohanpur; and

(ii) implementing a capacity development program in the electric utility industry to promote socially and

gender inclusive growth. The project will use state-of-the-art conductors with higher power transmission

capacity and lower energy loss in both the 230 kV and 400 kV transmission lines.

1. Brief project information

14 Power Grid Company of Bangladesh Limited (PGCB) is the implementing agency for Southwest of

Transmission Grid Expansion Project. The details project title, objectives, location, execution funding

provisions and signing of agreements etc is given in Table-1. The site map of southern part and northern

part of the project is given in Figure I-2 and Figure I-1.

Table I-1 Brief project information

Item Description

Project Title Southwest Transmission Grid Expansion Project

Ministry/Division Ministry of power, Energy and mineral resources/Power Division

Executing Agency Power Grid Company of Bangladesh Limited (PGCB)

Location of the project

Division District City corporation/Pouroshova/Upazila

Dhaka Faridpur Faridpur sadar, Nagarkanda, Bhanga

Gopalganj Maksudpur

Madaripur Madaripur Sadar, Rajoir, Kalkini

Barishal Barishal Gournadi, Babuganj,Wazirpur, Barishal Sadar

Rajshahi Chapainawabganj Gomastapur, Nachole, Nawabganj Sadar

Naogaon Naogaon Sadar, Manda, Niamatpur

Rajshahi Tanore

Bogura Kahaloo, Bagura Sadar, Nandigram, Adamdighi

Objectives of the project (Main)

To ensure adequate and reliable power supply for the upcoming Economic Zones in Barisal area as well as in Rajshahi area which is known as the largest agricultural production zone of Bangladesh and meet the rapidly growing demands of residential and commercial consumers in the southwest region of Bangladesh.


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Item Description

Specific Objectives

i. To construct 104 km Bagura(West) - Rahanpur (Chapainababganj) 400 kV Double Circuit transmission Line.

ii. To Construct 11 km LILO of Bagura- Barapukuria 230 kV Transmission Line to Bagura(West) 400/230 kV GIS Substation

iii. To Construct 126 km Barishal(N)-Gopalganj(N)-Faridpur 230 kV Double Circuit Transmission Line

iv. To Construct 26 km Chapainawabganj (old)-Rahanpur (Chapainawabganj) 132 kV Transmission Line

v. To Construct 400/230 kV Outdoor GIS at Bagura (West), 400/132 kV at Rahanpur (Chapainawabganj) & Upgradation of 400/132 kV Gopalganj Substation

vi. To Construct 230/132 kV GIS Substation at Faridpur & Extension of Barishal 230 kV SS vii. Two nos. 132 kV GIS bay extension at Chapainawabganj (Old)

Financing of Foreign component

Being financed by ADB under Loan Agreement No. 3683-BAN, Grant No. 0589-Component BAN & 0590-BAN signed between ADB & GOB

Financing of Local component

Being financed by ADB under Loan Agreement No. 3683-BAN, Grant No. 0589-Component BAN & 0590-BAN signed between ADB & GOB

Financing for Land Acquisition, Land Development, CD VAT & Right of Way

Being Financed from GoB

Financing for AIT & other official Expense

Being Financed from PGCB

Signing of Loan/Grant

Between GoB & ADB Loan No.: 3683-BAN = 350.00 mUSD, Date of signing: 10/09/2018 Grant No.: 0589-BAN = 7.00 mUSD. Date of signing: 10/09/2018 Grant No.: 0590-BAN = 0.50 mUSD. Date of signing: 10/09/2018

Signing of SLA/SGA

Between GoB & PGCB Loan on 07/05/2019 Grant on 06/08/2019


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Figure I-1 Project area of the southern part

Figure I-2 Project area of the northern part


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2. Impact and Outcome

15 The project is aligned with the following impacts: (i) national target of electricity for all achieved by

20211, and (ii) combined transmission and distribution losses reduced from 13% to 9% of generation, and

uninterrupted power supply provided to industries by 20202. The project will have the following outcome:

capacity of electricity supply in Bangladesh increased.

3. Outputs

16 Output 1: New substation at Gopalganj installed. The project will construct and commission the

Gopalganj (North) 400/132 kV substation comprising three 325 megavolt-ampere (MVA) transformers.

17 Output 2: Transmission network in southern Bangladesh expanded. The project will expand the

network by (i) constructing and commissioning a 126-kilometer (km) Barisal (North)– Gopalganj (North)–

Faridpur 230 kV double-circuit line, (ii) constructing and commissioning two 230 kV bay extensions at the

existing Barisal (North) substation and augmenting the existing Faridpur 132/33 kV substation with four 132

kV bays; five 230 kV bays; and 230/132 kV, 2x250 MVA transformers; and (iii) augmenting the Gopalganj

(North) substation with 400/230 kV, 2x750 MVA transformers.

18 Output 3: Transmission network in western Bangladesh expanded. The project will expand the

network by constructing and commissioning (i) a new 104 km Bogra (West)–Rohanpur 400 kV double-

circuit line; (ii) a new 400/230 kV, 2x750 MVA Bogra (West) substation; (iii) a new 400/132 kV, 2x325 MVA

Rohanpur substation; (iv) a new 26 km Chapainawabganj–Rohanpur 132 kV double-circuit transmission

line; (v) two 132 kV bay extensions at the existing Chapainawabganj substation; and (vi) an 11 km line-in,

line-out connection from the Barapukuria-Bogra (South) 230 kV transmission line to the Bogra (West)

substation, and a 1 km line-in, line-out connection from the Chowdala–Niamatpur 132 kV transmission line

to the Rohanpur substation.

19 Output 4: Socially inclusive capacity in the electric utility industry enhanced. The project will

enhance capacity, particularly emphasizing inclusive development and gender equality, through a university

program relevant to the energy sector, supporting (i) 50 university students, of which at least 40% are

women; and (ii) 30 staff from Power Grid Company of Bangladesh Limited (PGCB), of which at least 30%

are women.

C. ADB and GoB categorization

20 ADB categorization: In compliance with ADB’s Safeguard Policy Statement (2009), the project’s

safeguard category for environment is ‘B’. The project will not pass through any ecologically sensitive areas

and will not bring significant adverse environmental impacts. An initial environmental examination (IEE) has

been prepared in accordance with the Safeguard Policy Statement. The IEE and environmental

management plan propose mitigation measures to minimize effluent, noise, and waste from the project that

may impact the environment, health, and safety. PGCB will disclose any updates to the IEE resulting from

some changes in project scope. The project will utilize aluminum conductor composite core cable in the

transmission lines under outputs 2 and 3 as an advanced technology to reduce greenhouse gas emissions

1 Government of Bangladesh, Ministry of Planning, Planning Commission. 2012. Perspective Plan of Bangladesh, 2010– 2021:

Making Vision 2021 a Reality. Dhaka. 2 Government of Bangladesh; Ministry of Power, Energy and Mineral Resources. 2016. Power System Master Plan 2016. Dhaka.


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by 174,595 tons of carbon dioxide-equivalent per year. The project has been assessed for its risk and

vulnerability to climate change impacts, and design measures have been integrated to minimize these risks.

The draft IEE report was prepared from the technical due diligence and fact-finding mission. PGCB has

implemented several ADB projects and has adequate institutional capacity and experience to manage the

environmental risks through its project management unit. PGCB is committed to implementing the

environmental management plan and submitting environmental monitoring reports on a regular basis to

ADB.

21 GoB categorization: The Environment Conservation Act of 1995 establishes the requirement for an

environmental assessment in Bangladesh. Any proposed "industrial unit or project" must obtain prior

approval from the Department of Environment (DoE). The act has classified projects to be assessed by the

DoE in four categories (Green, Amber A, Amber B, and Red). Power development projects are allocated to

the Red category, which triggers an automatic requirement for an IEE followed by a full EIA.

D. Purpose of the Environmental Safeguards

22 According to the loan agreement, PGCB has to submit semi-annual safeguards monitoring report

to ADB and disclose relevant information from such reports to the project affected persons promptly upon

submission. The safeguards issues are guided by the ADB Safeguards Policy Statement (SPS) 2009. The

objectives of these ADB environmental safeguards are: (i) to ensure the environmental soundness and

sustainability of projects and (ii) to support the integration of environmental considerations into the project

decision-making process. ADB environmental safeguards are triggered if a project is likely to have potential

environmental risks and impacts.

23 The purpose of the Environmental Safeguards for a project are defined as:

Assist in determining adequacy of cost for EMP implementation;

Assist in addressing any concern related to IEEs and EMPs;

Assist in summarizing IEEs, translating to language understood by local people and disclosure

in public locations;

Oversee implementation of EMP including environmental monitoring of contractors;

Assist in implementing corrective actions when necessary to ensure no environmental impacts;

Review quarterly reports by contractors, assist PMU to submit environmental monitoring

reports on regular basis;

Assist in establishing the grievance mechanism for safeguards and addressing any grievances

brought about through the GRM in a timely manner as per IEE;

Submit semi-annual environmental safeguards monitoring report to ADB via PMU;

Be responsible for training the PMU/contactor safeguards officers on environmental awareness

and management in accordance with both ADB and government requirements and implement

the capacity building program for PMU and all staff involved in project implementation on (a)

ADB SPS, (b) Government of Bangladesh national and local environmental laws and

regulations, (c) core labor standards, (d) occupational health and safety monitoring given in the

environmental safeguards monitoring report and (e) EMP implementation especially spoil

management, working in congested areas, public relations and ongoing consultations,

grievance redress, etc.; and

Provide induction course for the training of contractors preparing them on EMP implementation.


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E. PGCB safeguards policy

24 The PGCB has its own policy and requirements for compliance relating to environment, health and

safety issues for its operations. The company is committed to managing its operations in a safe, efficient

and environmentally responsible manner. The PGCB's Health Environment and Safety (HES) manuals,

guidelines, procedures, and plans are important tools indicating their commitment. HES manuals include:

• Environmental Impact Assessment Module;

• Guideline on Integrated Impact Assessment;

• Health Impact Assessment Module; and

• Social Impact Assessment Module.

25 In addition, the requirement for impact assessment is affirmed in the PGCB's Statement of General

Business Principles. The PGCB is committed to:

• Pursuing the goal of no harm to people;

• Protecting the environment; and,

• Managing HES as any other critical business activity.

26 The mandatory company Operations Management System, Environmental Care Element/

Standards, issued in March 1997, refers to Environmental Assessment indicating that "EIA (including a

consideration of social impacts) shall be conducted prior to all new activities and facility developments, or

significant modifications of existing ones.”


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II. Status of Ongoing Contract Packages

A. Project status

28 The following paragraphs detail the package progress status:

1. Package No. 1

Project Title: Design, Supply, Installation, Testing & Commissioning of Barisal (N)-Gopalganj (N)-Faridpur

230 kV Double Circuit Transmission Line on Turnkey basis.

Contract was signed on 22/05/2019; Contract Effective date: 22.10.2019

Financial Progress from the contract effective date:

a. Foreign & Local portion against 10% Mobilization advance Paid to consultant.

b. Progress payment USD: 11,050721.66 BDT: 341099585.95

Physical Progress:

a. Route/Check Survey and route map are completed for Barishal Gopalganj Section and Gopalganj-

Faridpur portion

b. Piling of the line has been started on 05.09.2019.

c. Total Piling completed 213 towers out of 345

d. Total Pile cap completed 80 out of 345

e. Total Tower erection completed 47 out of 345

2. Package No. 2

Project title: Design, Supply, Installation, Testing & Commissioning of 230 kV Indoor GIS Substation with

132 kV AIS Substation at Faridpur and GIS Bay Extension in the existing 230/132 kV Barisal (North) AIS

Substation on turnkey basis

Contract was signed on 08/05/2019; Contract Effective date on 12.11.2019

Financial Progress from the contract effective date: Foreign & Local portion against 10% mobilization

advance Paid to consultant.

Physical progress:

a. Sub-station Layout has been finalized.

b. Piling of GIS Building at faridpur has been started.

c. Ansar barak building work is going on.

d. Design Drawing approval is going on.

3. Package No. 3

Project Title: Design, Supply, Installation, Testing & Commissioning of Bogura-Rahanpur 400kV Double

Circuit and Associated 230kV & 132kV Transmission Lines on Turnkey Basis.

Contract was signed on 20/11/2019; Contract Effective date: 10.02.2020

Financial Progress from the contract effective date:

a) Foreign & Local portion against 10% mobilization advance Paid to consultant.

b) Progress payment USD


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Physical progress:

132 kV Transmission Line

a) Route/Check Survey and route map have been completed 23 km out of 26 km

b) Piling of the line has been started on 10.01.2020.

c) Total Piling completed 55 towers out of 86

400 kV Transmission line

a) Route/Check Survey and route map has been completed 98 km out of 104 km.

b) Piling of the line has been started on 29.02.2019.

c) Total Piling completed 37 towers out of 278

4. Package No. 4

Project title: Design, Supply, Installation, Testing & Commissioning of 400kv Outdoor GIS Substation at

Bogura (West) & Rahanpur up gradation /Extension of Gopalganj and Chapainababganj (Old) Substation

on Turnkey Basis

Status: Financial evaluation has been completed & Report sent to ADB for their concurrence.

5. Package No. 5

Consultancy Services for the EMTP study, bid documentation preparation & clarification, design checking,

supervision for 400 kV substations of the project

Status: NOA Issued to consultant (WAPCOS) on 27.09.2020 & accepted it unconditionally on the same

day. Draft contract document sent to ministry for vetting on 05.08.2020.

B. Contract requirements (Environment)

29 The following documents, relating to the identified environmental safeguards, form part of the

Contract Package and are part of the monitoring requirements in ascertaining the degree of compliance:

a) Initial Environmental Examination (IEE)

b) Environmental Management Plan (EMP); and In addition to the foregoing, the Contractor is to

provide the Project Director with a written notice of any unanticipated environmental risks or

impacts that arise during construction, implementation or operation of the Plant or Works, which

were not considered in the IEE’s and the EMP’s.

30 The general anticipated impacts for all subprojects and their mitigation measures are summarized

in Error! Reference source not found. for reference of the later chapters which discuss the environmental

safeguard compliance in relation to the requirements set by subproject specific EMPs.

C. Financing Agreement

31 Financial cost provision for the Contractor to complete all the required Environmental mitigation

and monitoring requirements is given in the EMP cost stipulated with the subproject specific EMPs, along

with the stipulated frequency and extent of sample monitoring, in accordance with the respective

Environmental Management and Monitoring Plan, of the particular contract package.


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III. Environmental Status

A. Status of Environmental Safeguards Documents

32 The following safeguards documents have been prepared by PGCB and contractors for the project

(Table III-1):

Table III-1 Summary Status of environmental safeguards documents prepared for the project

Type of safeguards document Agency Package Latest version

Coverage

Semi Annual Environmental Monitoring Report PGCB All August 2019

April – June 2019

Semestral Environmental Monitoring report PGCB All June 2019 April – June 2019

COVID-19 Exposure Prevention, Preparedness & Response Plan Contractor (Energypac Engineering Ltd)

Gopalganj Substation

August 2020

Rest of the contract

Site specific Environmental Management Plan (SEMP) Contractor (Energypac Engineering Ltd)


August 2020


Monthly environmental inspection report Contractor (Energypac Engineering Ltd)


June 2020 June 2020

Complain and sick register report Contractor (Energypac Engineering Ltd)


August 2020

From beginning of construction

OHS Plan Contractor (Energypac Engineering Ltd)


August 2020


Monthly HSE meeting reports Contractor (Energypac Engineering Ltd)


June 2020 June 2020

Overall monitoring checklist Contractor (Energypac Engineering Ltd)


June 2020 June 2020

Environment test report (132kV): included environmental monitoring, checklist, HSE monitoring

Contractor (Kalpataru Power Transmission Limited (KPTL)

Transmission line

June 2020 January – June 2020

Environment test report (230kV): included environmental monitoring, checklist, HSE monitoring

Contractor (Kalpataru Power Transmission Limited (KPTL)

Transmission line

June 2020 January – June 2020

B. Environmental safeguards monitoring

1. Gopalganj substation

33 HSE Team: At Gopalganj substation site Enegrypac is working as contractor and they have their

HSE team at site. The HSE team is lead my Mr. Moniruzzaman. The entire team with their phone number

and designation is listed at site and in their report. The HSE team is monitoring the site continuously and

report back to the contractor who shares with PGCB. To date Monthly environmental inspection report is

the lowest tier of environmental reporting. The latest report is available for June 2020. Besides that, the


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team generates overall environmental monitoring checklist. The latest is available for June 2020 (Figure

IV-1).

34 Environmental testing: To date environmental testing was not done. At present only civil

construction is in progress without use of chemicals and without burning any fossil fuel. Therefore, gasses

detrimental to the environment are not generated and emitted to the environment. Contamination of surface

water and ground water due to construction work is also not expected. Only source of noise during

construction was piling work. In this project, piles of maximum 500 mm diameter and 12 m length have

been constructed. As the drilling was done by using earth auger without using any hammer, generated

noise was minimum, which did not affect the environment outside the substation boundary. Therefore, no

environmental monitoring has been carried out by the Contractor and therefore no monitoring data /

documents are available for review and comments.

2. Transmission line

35 HSE team: Kalpataru Power Transmission Limited is the contractor for the transmission line project

(132kV/230kV). The HSE team of the contractor is led by Md. Nur E Alam Siddique, Environmental

Specialist. The Executing Agency (EA) of PGCB, Kalpataru Power Transmission Limited (KPTL) has

established a Project Implementation Unit (PIU) including its regional specialists to manage day-to-day

coordination, implementation and environmental monitoring and administration activities of the 400kV and

Figure III-1 Overall environmental monitoring checklist reported by Energypac (Sample June 2020)


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230 kV transmission line project. The PIU of Kalpataru Power Transmission Limited (KPTL) is assisted by

PGCB. The Kalpataru Power Transmission Limited (KPTL) also has an Environmental Specialist dedicated

to the project, as mentioned earlier. Environmental monitoring in the field is carried out by the Engineers

and the task of actual monitoring is undertaken by environmental specialists. The environmental specialist

is mobilized on an intermittent basis to undertake field audits and compilation of necessary periodic

environmental report for the PGCB and Financier (Asian Development Bank). Likewise, the national

environmental and social safeguard specialist is engaged on a regular basis to support acquisition and

ensure validation of monitoring data. The HSE team of KPTL also do internal monitoring using checklist

and reporting and reflected in the quarterly progress report and environmental report that are submitted to

PGCB (Figure IV-2).

36 Environmental testing: Recent Environmental testing was done in July 2020. The contractor hired

an external monitoring company for water, soil, noise and air quality testing. The results are reported in the

later section of this report. All the parameters tested were found to be within the DoE limits set in ECR 1997

and its amendments.

Figure III-2 Monitoring checklists used by KPTL (Sample June 2020)


8

C. Construction period environmental quality monitoring

37 In order to ensure proper implementation of the environmental safeguard requirements during the

construction period, Contractors have appointed third party organizations for testing of required

environmental parameters (air quality, noise quality, surface water quality and groundwater quality). All

instruments used by the organization are maintained following International Standards and calibrated

regularly in accordance with the manufacturer’s instructions.

1. Gopalganj substation

38 No environmental testing was done at Gopalganj substation as discussed in the earlier sections.

2. Transmission line subproject: Bogura-Rahanpur 400kV

39 Noise quality: Noise samples were collected at pilling workplace and apart from 300-meter

distance (North & South) at Bil-palsha, Raninagor, Naogoan. According to the Environment Conservation

Rules (ECR, “SRO no 212-law/2006”), noise levels were within limits. The results are reported in the

Environmental report prepared by the contractor for PGCB for the period of January to July 2020.

40 Surface water: The surface water sample has been collected from adjacent area near the Bil-

palsha, Raninagor, Naogoan, Bogura-Rahanpur 400kV Double Circuit and associated 230kV Transmission

Lines. The parameters were determined by appropriate approved analytical method. However, the

concentration of above parameters was within the acceptable limit of DoE Standards for inland surface

water [Schedule-10 (Rule 13) & Standards for inland surface water Schedule-3 (Rule12)]. The results are

reported in the Environmental report prepared by the contractor for PGCB for the period of January to June

2020.

Table III-2 Noise testing results at TL sites


9

41 Air quality: As part of environmental management & monitoring guidelines, periodical

environmental air quality monitoring has been carried out by the high-volume sampler with gaseous

attachment which has been using for collecting air for a certain period of time from Bil-palsha, Raninagor,

Naogoan of Bogura-Rahanpur 400kV Double Circuit and associated 230kV Transmission Lines. The origin

of ambient air quality standard for Bangladesh has set at Environmental Conservation Rules, 1997, later

on, the standard limit ambient air quality has been revised since 2005 as National Ambient Air Quality

Standard for Bangladesh. The values of ambient air quality parameters are showed in the table below. It

has been observed that the concentrations of ambient air quality parameters are within the allowable

ambient limit as per DoE, Bangladesh Standard for air quality.

Table III-3 Water quality test results at the TL sites

Table III-4 Air quality test results at TL sites


10

42 Soil quality: The soil samples have been collected from Bil-palsha, Raninagor, Naogoan of

Rahanpur - Bogura- Barapukura 400 kV duble circuit TL and Polsha of Chapainawabganj Sadar from 132kV

double circuit TL. The test result of the parameters (Organic matter, Total CaCO3, soil pH and nitrogen

content) suggest that the parameters tested are within the recommended levels for crop land.

43 Comparative results: Since the results presented in the above section are the first batch of

environmental testing results, comparison with previous results cannot be made. Therefore, these results

should be used as the baseline results and should be compared with future results to investigate any

change in the environmental quality from the project.

3. Transmission line subproject: Chapainawabganj-Rahanpur 132kV

44 Noise quality: Noise samples are collected at pilling workplace and from 300-meter distance

(North & South) at Polsa, Chapainababgonj Sador of the 132kV Double Circuit TL from Chapainawabganj

(Old) substation to Rahanpur (Chapainawabganj) substation. Except at worksite, all the sites were

measured as noise being allowable limit set by ECR 1997 and its amendments.

Table III-6 Noise test results at TL sites (132kV)

Table III-5 Soil test results at TL sites (400kV TL Naogaon site)


11

45 Surface water quality: The surface water sample has been collected from adjacent area near the

Polsa, Chapainababgonj Sador 132kV Double Circuit TL from Chapainawabganj (Old) substation to

Rahanpur (Chapainawabganj) substation. The parameters were determined by appropriate approved

analytical method. However, the concentration of above parameters was within the acceptable limit of

Department of Environment Standards for inland surface water [Schedule-10 (Rule 13) & Standards for

inland surface water Schedule-3 (Rule 12)]

46 Air quality: As part of environmental management & monitoring guidelines, periodical

environmental air quality monitoring has been carried out by the high-volume sampler with gaseous

attachment which has been using for collecting air for a certain period of time from Polsa, Chapainababgonj

Sador (N 24039’ 2 E 88018’ 15) of 132kV Double Circuit TL from Chapainawabganj (Old) substation to

Rahanpur (Chapainawabganj) substation. Results suggest all the parameters are within the allowable limit

set by DoE.

Table III-7 Water quality test results at TL sites (132kV)


12

47 Tree Plantation Programme: The IEE prepared for the project has estimated around 8900 plants

to be affected during construction of Transmission Line (TL). Records of compensation for trees are not

well kept. During Midterm Review Mission with ADB, the Project Director mentioned that the compensation

has been paid and the records will be provided to ADD in due course. The tree plantation plan has not been

formulated yet. However, the contractor of the Subproject, KPTL mentioned that they have already

distributed 2000 saplings to local schools and Madrasas. This record is also not well kept. KPTL

representative mentioned that they will come up with the full tree plantation plan/distribution plan and will

keep hardcopy and visual records of plant distribution which will be shared with PGCB and ADB.

Table III-8 Air quality test results at TL sites (132kV)

Figure III-3 Onsite water quality and air quality test at TL site


13

D. Training, awareness and workshop

48 Training: At both sites, toolbox meetings were found as commonly adopted instead of formal

training for EMP implementation. Both sites are equipped with a trained HSE team lead by specialist. It has

been found that, at Gopalganj substation site, the HSE team works at site with every activity are monitored

by a specialist who is staff of the company. The activities include toolbox meeting, monitoring and reporting,

register maintenance and check upon environmental checklists. On the other hand, at the TL worksite, the

contractor has hired an external environmental specialist to lead the HSE team. The team does regular

HSE meetings and report as monitoring checklists.

49 Awareness: At TL worksite some awareness materials were also found to be displayed nearby,

although the awareness materials are not found to be adequate, especially in the time of COVI-19

Pandemic. In the Gopalganj substation site, the site is closed and awareness poster or signboards were

found. It is recommended that, regarding the COVID-19 situation, signboards and posters suggested by

ADB and Health Department of GoB should be showing at the worksite.

Figure III-4 Onsite training and awareness materials at the project sites


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E. Environmental issues of the current project

50 Until date no significant environmental issue has been identified and reported. However, during

discussion at the Mid Term Review Mission of ADB, it was known that during construction of the substation

low land was sand filled and prepared for construction. Not record for local waterlogging, drainage

congestion and grievance has been kept. It was advised that such record needed to be kept all the time

and should be shared with ADB. Since the worksites were in pause during the high outbreak of COVID-19,

not many environmental issues were identified and reported.

F. Performance of EMP implementation

51 Performance of the EMP implementation for the project has been presented in the following table:


15

Table III-9 Performance status of the EMP implementation processes in the project

Environmental issue

Mitigation measures suggested in EMP Observation during monitoring period Recommendation /comments

Gopalganj substation: Construction phase Topsoil Prior to start of filling of the site, collect and store top soils

(minimum 0.5 m thick) for using on the surface of the site boundary and access road side slopes for protection from side slope erosion. The topsoil, excavated from the proposed construction sites, should be re-spread in areas to be landscaped.

Land filling of Access Road and Substation Area has been completed in October 2019. More than 3 m land filling have been done in entire area by dredged sand directly transported from the reverbed to the site through pipeline. Therefore, the filled-up area is well compacted. Proper slope has been provided at the top of compacted filled up soil. Proper slopes have provided at the sides of the access road and covered with concrete slabs to protect from erosion.

Photo evidences needs to be kept

Vegetation clearing Prior to the start of clearing of vegetation, provide adequate compensation to the owners in good time.

Compensation has been given to the affected people. However, proper records are not kept.

PGCB has been advised to keep proper records and share with ADB

Fauna Prepare construction management plan (CMP, by the contractor) and follow it properly. Follow GoB rules and regulations on noise. Project workers should not disturb or kill any wildlife.

The Contractor for the Gopalganj sub-station project has prepared an Environmental and Social Management Plan for implementation during construction of the sub-station. The document is titled as ESMP. The ESMP document was submitted by Contractor on 8th May 2020 and awaiting PGCB approval.

The ESMP, however, needs to be aligned with the EMP contained in the IEE report as well as with the other conditions stipulated in the Contract documents with respect to management of environmental, health, safety and social aspects on the project. However, contractor confirmed that the revised ESMP has been sent to PGCB on 25 September 2020.

Construction waste Use of durable, long-lasting materials that will not need to be replaced as often, thereby reducing the amount of construction waste generated over time. Provision of facilities for proper handling and storage of construction materials to reduce the amount of waste caused by damage or exposure to the elements. Purchase of perishable construction materials such as paints incrementally to ensure reduced spoilage of unused materials. Use of building materials that have minimal packaging to avoid the generation of excessive packaging waste. Use of construction materials containing recycled content when possible and in accordance with accepted standards. Adequate collection, separation, and storage of waste on site and safe transportation to the disposal sites and disposal methods at designated area shall be provided.

As part of waste management system at site, garbage collection bins are located in numerous locations. Garbage collected in these bins are disposed of on daily basis.

In the situation of COVID-19 pandemic, waste need to regularly disinfected. Set waste bins dedicated to COVID-19 on site. Monitor for COVID-19 related waste being dumped and disposed in healthy manner and keep record in a register. Used mask, gloves are to be disposed in the COVID-19 designated waste bins. Assign the HSE officer on field to


16

Environmental issue


There is designated space with sign board at site to be used as scrapyard. Scrap material accumulated in this scrapyard are disposed of at regular intervals.

monitor such activities and record in a separate register.

Drainage construction and flooding

Provide culverts in the access road of the substation. Ensure adequate monitoring, especially if construction works are carried out during the monsoon period. Provision for pumping of congested water, if needed. Consideration of the HFL during design of substations, to avoid inundation.

Currently no drainage congestion has been found at site.

Noise Use of noise reducers in heavy construction equipment. It is recommended that no construction should be allowed during night time (9 PM to 6 AM). Avoid prolonged exposure to noise (produced by equipment) by workers. Use of noise reducers in heavy construction equipment. It is recommended that no construction should be allowed during night time (9 PM to 6 AM). Avoid prolonged exposure to noise (produced by equipment) by workers.

Only civil works are ongoing in the site. Noise level is slightly higher than accepted limit (~71dB) for industrial areas. However, this is common in worksite.

Site work should be limited with the stipulated time (9AM – 6PM). However, the construction site is away from residential area and noise pollution therefore is negligible.

Air quality and dust All vehicles (e.g., trucks, equipment, and other vehicles that support construction works) shall be well maintained and not emit dark or smoky emissions in excess of the limits described in the EQS. Specific training will be focused on minimizing dust and

Dust suppression measures are taken and the site was observed as dust free (photos later). Dust suppression activities are taken twice a day and more if required.

The entire site is filled with sand. Therefore, the dust suppression activities need to be frequent so that


17

Environmental issue


exhaust gas emissions from heavy construction vehicles. Drivers of vehicles used during construction will be under strict instructions to minimize unnecessary trips and minimize idling of engines. Dust suppression facilities (water sprayer) shall be available where earth and cement works are required. Spray water on dry and loose surfaces of the construction sites regularly. Maintain adequate moisture content of soil during transportation, compaction and handling. Construction materials (sand, gravel, and rocks) and spoil materials will be transported in trucks covered with tarpaulins. Sprinkle and cover stockpiles of loose construction materials (e.g., fine aggregates, sand). Avoid use of equipment such as stone crushers at the sites, which produce significant amount of particulate matter. Dust masks should be provided to all personnel in areas prone to dust emissions throughout the period of construction.

At the moment, civil construction is going on without using chemicals. Stockpiles were found covered and within designated places.

communities and workers are not affected.

Soil Laboratory analysis of the river bed materials to be confirmed prior to starting collection from the river. Prevention of spillage and leakage of hazardous liquids at construction sites and camp. Ensure no use of transformers containing PCB to avoid soil and air pollution.

Soil was collected from a local supplier certified by the local DC office. Soil was taken form nearby river. However, laboratory analysis of the riverbed material for PCBs has not been performed.

Soil/sand used for construction needs to be immediately tested for PCBs and report to PGCB.

Traffic congestion Follow Bangladesh Road Traffic Authority (BRTA) traffic rules and regulations. Schedule deliveries of materials/ equipment during off-peak hours. Engage flagmen especially at the entry of the substation sites and construction camps for traffic control. Engage experienced drivers to drive project vehicles. Arrange for signal lights at night. Prepare and follow proper traffic management. Avoid stockpiling of materials, especially at the road sides, that could disturb traffic movement.

Traffic congestion at the worksite is very low due its distance from the road ways. Traffic congestion, therefore was not observed at site.


18

Environmental issue


Community Health and Safety (H&S)

Safety barriers and warning signs surrounding the construction site. Generators should be placed in closed rooms. Formulate and implement an emergency risk management plan (by the contractor).

The Contractor have posted one HSE Engineer at site, who is responsible for implementation and monitoring of environmental, health, safety and social aspects of the project. Records relating to monitoring of HSE aspects at site are being maintained at site by the Contractor. A register for Grievance has been kept at site.

Occupational Health and Safety

An experienced Health & Safety (H&S) Manager must be engaged by the contractor prior to start of construction. Only permit trained and certified workers to work with any electrical equipment. Safety induction by the H&S Manager should be provided for the workers. Prior to starting work, a tool box meeting should be arranged by the H&S Manager for the workers. First Aid Box and personal protective equipment, PPE (such as safety helmets, safety shoes, eye protection glasses, ear plugs/muffs, waist belts, masks, hand gloves, body protective aprons and insulating boots) must be provided to the workers and ensure their use by the workers. Safety signs, health signs, prohibition signs, warning signs, mandatory signs, emergency escape signs, first-aid signs, information signs, signboards, supplementary signboards, safety collar, symbol, pictogram, illuminated signs, acoustic signals, verbal communication and hand signals must be fitted at the designated.

The Contractor have posted one HSE Engineer at site, who is responsible for implementation and monitoring of environmental, health, safety and social aspects of the project.

Records relating to monitoring of HSE aspects at site are being maintained at site by the Contractor. A register for Grievance has been kept at site. There is designated space with sign board at site to be used as scrapyard. Scrap material accumulated in this scrapyard are disposed of at regular intervals.


19

Environmental issue


Safety fencing was observed.

Regular toolbox meeting on site safety and COVID-19 situation are conducted

Workers were observed to be using PPEs.


20

Environmental issue


Proper housekeeping was observed in the store room forming a part of the site office complex. In the store room, materials of various kinds were observed to be stored in satisfactory way.

First Aid boxes are available and kept in the store room.


21

Environmental issue


The Vehicle is available at site for handling any emergency and for reaching the nearby hospital in case of an emergency. Emergency Contact numbers are displayed in the office area. Safety signage have been placed at numerous locations at site.

Fire extinguishers are kept inside store & generator room. As part of grievance redress mechanism, a complaint register is maintained at site. To maintain records of accidents and injuries a sick register maintained at site. Safe drinking water supply was found for workers.


22

Environmental issue


Extra precautions for COVID-19 situation has been observed.

Transmission line

Contractor’s CEMP/SEMP The contractor should develop a site-specific CEMP and approved by PCGB. The CEMP should be shared with ADB.

Environmental monitoring is overseen by PGCB. The responsible engineer of PGCB reviews the CESMMP and environmental report relating to the project and performs monitoring of compliance of Kalpataru Power Transmission Limited (KPTL)’s performance with the approved CESMMP, environmental standards and other environmental commitments of the Kalpataru Power Transmission Limited (KPTL). Environmental monitoring in the field is carried out by the Engineers and the task of

Once PGCB approves the SEMP/CEMP, in this CESMMP, the document should be shared with ADB for observation.


23

Environmental issue


actual monitoring is undertaken by environmental specialists. The environmental specialist is mobilized on an intermittent basis to undertake field audits and compilation of necessary periodic environmental report for the PGCB and Financier (Asian Development Bank). Likewise, the national environmental and social safeguard specialist is engaged on a regular basis to support acquisition and ensure validation of monitoring data.

Fauna Preparation of construction management plan by the contractor and follow it. Follow GoB rules and regulations on noise. Project workers should not disturb or kill birds or other animals.

The contractor has developed site specific CEMPs which prohibits the disturbances on the local fauna. To avoid wetlands which have potential fauna, tower footing has been changed.

However, the changes in tower footings and changes reflected in the CEMP has not been shared with PGCB and ADB. These changes should be recorded well and shared with PGCB and ADB to verify whether any changes in the IEE/EMP is required or not.

Construction waste and water pollution

Use of durable, long-lasting materials that will not need to be replaced as often, thereby reducing the amount of construction waste generated over time. Provision of facilities for proper handling and storage of construction materials to reduce the amount of waste caused by damage or exposure to the elements Purchase of perishable construction materials such as paints incrementally to ensure reduced spoilage of unused materials Use of building materials that have minimal packaging to avoid the generation of excessive packaging waste. Use of construction materials containing recycled content when possible and in accordance with accepted standards. Adequate collection and storage of waste on site and safe transportation to the disposal sites and disposal methods at designated area shall be provided.

Effluent from worksite are controlled and brough to a detention basin for settling. Once settled the soil is carried away to a designated place by city corporation/municipality.


24

Environmental issue


Effluent drainage is maintained and monitored at worksite all the time.

Noise It is recommended that no construction should be allowed during night

time (9 PM to 6 AM). Avoid using of construction equipment producing excessive noise at any time. Avoid prolonged exposure to noise (produced by equipment) by workers. Regulate use of horns and avoid use of hydraulic horns in project vehicles.

Measured noise at various site was high only at workplaces while the transmission line area was found to be within limits (see noise test results in the previous sections).

Construction works should be strictly limited to (9AM to 6PM) to avoid complains from surroundings. Spraying of water should be more frequent in the upcoming dry season.

Air quality and dust All vehicles (e.g., trucks, equipment, and other vehicles that support construction works) shall be well maintained and not emit dark or smoky emissions in excess of the limits described in the Environment Quality Standards (EQS). Specific training will be focused on minimizing dust and exhaust gas emissions from heavy construction vehicles. Drivers of vehicles used during construction will be under strict instructions to minimize unnecessary trips and minimize idling of engines. Dust suppression facilities (back pack water sprayer) shall be available where earth and cement works are required. Spray water on dry and loose surfaces of the construction sites regularly. Maintain adequate moisture content of soil during transportation, compaction and handling. Construction materials (sand, gravel, and rocks) and spoil materials will be transported in trucks covered with tarpaulins. Sprinkle and cover stockpiles of loose construction materials (e.g., fine aggregates, sand). Dust masks should be provided to all personnel in areas prone to dust emissions throughout the period of construction.

Water is spayed regularly to avoid dust concentration in air. It was found from the onsite EHS specialist that, water is sprayed twice a day.

Vehicle movements are also restricted with the site to avoid smoke and dust.

Traffic congestion Follow Bangladesh Road Transport Authority (BRTA) traffic rules and regulations. Schedule deliveries of material/ equipment during off-peak hours. Engage flagman where needed. Engage experienced drivers to drive project vehicles. Arrange for signal lights at night, for

Kalpataru has devised a traffic management plan to implement on worksites.

The traffic plan needs to be updated and align with the TL and submitted to PGCB and BRTA for approval.


25

Environmental issue


proper traffic management. Avoiding stockpiling of materials, especially at the road sides, that could hamper traffic movement.

Additionally, the following measures have been taken by the contractor: a) All deliveries of stocks have been carefully planned and suppliers should be advised as to the time and location at which these will have to be delivered to the Gopalgonj to Mongla. b) The frequent presence of trucks is added to increase traffic, sound (excessive noise) and smoke pollution through exhaust emission. c) Avoided as far as possible the peak traffic hours such as school hours in order to reduce the risk of any children/traffic accident/incidents. d) Ensured that allowable axel weight is not exceeded when the deliveries are brought by the suppliers using the Fort portal main highway.


26

Environmental issue


Community health and safety

Safety barriers and warning signs surrounding the tower construction site. Formulate and implement an emergency risk management plan (by the contractor).

Worksite safety fencing were found.

compliance register was found at site.

Proper signboards and posters on community safety should be posted along the TL and worksites. Before posting them, PGCB needs to approve the posters.

Occupational health and safety

An experienced H&S Manager must be engaged by the contractor prior to the start of construction of the towers. Only permitting trained and certified workers to work with any electrical equipment. First aid box and personal protective equipment, PPE (such as helmet, safety shoes, eye protection glass, ear plugs, waist belt, mask, hand gloves, body protective apron, ear muff and insulating boots, as needed) must be provided to the workers, and ensure their use by workers. Safety signs as needed at the tower sites.

Labors specially who will be climbing up and work at height are trained on safety matters including accident prevention, safe lifting practices, and proper control of all site machineries at TL project; and maintenance of equipment and facilities. Training is also included emergency response, including the location and proper use of emergency equipment, emergency contacts, PPE, health and hygiene procedures for raising the notifying emergency response teams and proper response actions for each foreseeable emergency situation for all labors and stakeholders of this TL project. Fire extinguisher was found at the project site.

Register or records of each training given and their outcomes should be kept at site for tracking progress and lacking. These records should be shared with PGCB and ADB via quarterly and semi-annual monitoring reports. Additionally, to tackle COVID-19 situation the contractor should develop its own guideline using the combined GoB and ADB guidelines and should use awareness posters around the works site. The contractor needs to pay immediate attention to the worker hygiene, toilet and labor shed. They are in pretty bad shape and unhygienic. A checklist is needed to be prepared by the contractor after taking care of the labour shed to ensure that the living condition of the labour shed


27

Environmental issue


Kalpataru Power Transmission Limited (KPTL) has given the basic training on environmental, social, safety, incident, PPE of all the workers who are newly engaged with TL tower installation project. Kalpataru Power Transmission Limited (KPTL) has been progressing work at the moment of COVID-19 Pandemic. At this moment workers and labors have been following all of the health and safety condition of COVID-19 pandemic. Regular site safety briefing is done.

In the situation of COVID-19, the contractor is using the GoB guideline to combat contamination.

meet the Bangladesh Government’s labour law compliance as well as ADB guideline. Contractor also must ensure that no effluent is discharged from labour shed to nearby wetland, cropland or any sensitive ecosystem.


28

Environmental issue


However, toilets and shelters provided for the workers were found in pretty bad shape.


29

G. Grievance Redress Mechanism

52 The objective of the grievance redress mechanism (GRM) is to resolve complaints as quickly as

possible and at the local level through a process of conciliation; and, if that is not possible, to provide clear

and transparent procedures for appeal. A well-defined grievance redress and resolution mechanism will be

established to resolve grievances and complaints in a timely and satisfactory manner. All affected persons

will be made fully aware of their rights, and the detailed grievance redress procedures will be publicized

through an effective public information campaign.

53 A GRC has been formed for mitigating any unavoidable circumstances during implementing the

compensation process. The committee consists of representatives from PGCB, EPC Contractor,

Consultant (IISPL), and local people. Any dispute regarding determination of compensation against the

losses, usage of land for tower construction and approach road, and other relevant issues during

construction will be solved through the GRC. According to GRM, affected people and communities would

place their claims/counterclaims to the GRC. The affected people may appeal to the GRC against any

disagreeable decision, practice, or activity arising from construction related activities especially in terms of

compensation against affected land and assets. The feature of GRM of the proposed project are mostly

similar to the features of another similar donor funded project in Bangladesh include:

a) An assigned focal person or grievance redress officer managed the grievance redress mechanism,

to whom people can appeal if they are unhappy with the decision made by the implementing

authority;

b) The provision and process of the grievance redress mechanism is well publicized;

c) Information about the complaint and its resolution is documented in registered book and

photography with others relevant soft copies are in DVDs as well as in electronic devices. This

information is generally supposed to be managed in safe and secured hand for using in this project

and sharing experience in other upcoming projects;

d) If the aggrieved person is female, they have been assisted in hearings by any favorable female

participants from her/proponent end, and if from a tribal community, by a tribal representative;

e) Complaints have been dealt with within a specific timeframe, generally around two weeks to four

weeks; The GRM does not interfere in a person’s right to seek redress in the courts of law.

54 No grievances have arisen during the reporting period January 2020 to June 2020 at the

Transmission Line and Substation project.


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IV. Environmental Compliance (agreements)

A. Compliance with environmental related project covenants

1. National Covenant

55 The National Environmental Policy (NEP) was adopted in 1992 and is now under revision. It

embraces different sectors related to agriculture, forest, power, health, transport, housing etc. The central

theme of policy is to ensure protection and improvement in environment. The policy supports sustainable

development and long-term use of natural resources. The National Environment Policy contains policy

statements and strategic options with regard to population and land-use management, management and

utilization of natural resources and other socio-economic sectors, as well as the necessary arrangements

for the implementation of the policy.

56 The main Ministry, Department, Institutions and Boards responsible for development of policy,

framing regulation, developing projects, monitoring and approval of issues related to environment protection

and conservation are presented in this section. The Department of Environment (DoE) was established in

1977 under the Environment Pollution Control Ordinance, 1977. During 1987-89, Forestry was a Division

of Agriculture Ministry with a Secretary to Government in charge of the Forestry Division. With the formation

of the new Ministry of Environment and Forests, in 1989, both the departments were transferred to this new

Ministry.

57 The DoE has been placed under the MoEFCC as its technical wing and is statutorily responsible

for the implementation of the Environment Conservation Act, 1995. Besides these two departments,

MoEFCC controls the Bangladesh Forest Industries Development Corporation (BFIDC), Bangladesh Forest

Research Institute (BFRI) and Bangladesh National Herbarium (BNH).

58 The Ministry of Environment and Forests and Climate Change (MoEFCC) prepare the

environmental policies. MoEFCC has also formulated regulation toward clearance of projects from

environmental angles based on environmental impact assessment report.

59 The Department of Environment is responsible for environmental issues while forest issues are

looked after by Department of Forests. Over the years, the MoEFCC has adopted number of legal

instruments in the form of Acts for the protection and conservation of the environment. Table IV-1

summarizes the Environmental Legislation applicable to the sub-projects.

Table IV-1 Summary of Environmental Legislations Applicable to the Proposed Project

No. Environmental Legislation / Act

Objective Relevance to the Project Responsible Institution

Compliance status

1 National Environmental Policy, 1992

Ensure that development components do not pollute the environment or degrade resources. It sets out the basic framework for environmental action together with a set of broad sectoral action guidelines.

Restriction on operations which cannot be initiated in ecological critical areas

Regulation on vehicles emitting smoke which is harmful to the environment

Follow standards on quality of air, water, noise and soil

Sets limits for discharging and emitting waste

Ministry of Environment and Forests, and Climate Change

The final design of the transmission alignment has been selected avoiding ECAs and PAs. The substations are also located avoided any ECA/PA nearby.


31



Compliance status

2 National Environmental Management Action Plan (NEMAP), 1995

An action plan to identify key environmental issues affecting Bangladesh, identifies actions for reducing the rate of environmental degradation and improve quality of life.

Sectoral agencies to coordinate with MoEFCC in preparing environmental guidelines


EC has been obtained from DoE for the transmission line (active unstill September 2020) project and has been applied for renewal. Additionally, EMP has been formulated in IEE indicating potential impacts and their remedies. Moreover, SEMPs have been formulated by the contractors and send to PGCB for approval

3 Environment Court Act, 2000 and subsequent amendments in 2003

Establishment of Environment Court for trial of an offence or for compensation under environmental law, such as environment pollution.

Option to affected persons for grievances related to environment safeguards.


GRC has been formulated to address the affected persons for grievance.

4 The Forest Act (1927) and Forest (Amendment) Act (2000)

An act to control trespassing, illegal resource extraction and provide a framework for the forestry revenue collection system;

Requires clearances for any project within forest areas and clearances for any felling, extraction, and transport of forest produce.

Department of Forests

The transmission line avoids forested areas.

5 National Forest Policy (1994)

To conserve existing forests and bring about 20% of the country’s land area under the Forestation Programme and increase reserved forests by 10% per year until 2015

Incorporate tree planting in the subproject

Clearance for any felling, extraction, and transport of forest produce


The transmission line avoids forested areas.

6 The Bangladesh Wildlife (Conservation & Security) Act, 2012

To conserve and protect wildlife in Bangladesh including designation of protected areas. Protection of wildlife is provided with lists of species with four schedules: first, second, third and fourth schedule. The fourth schedule species have the highest level of protection.

Consultation and necessary permits required if the project will pass through the wildlife sanctuaries and other protected areas.


The transmission line does not cross any wildlife sanctuaries.

7 Wetland Protection Act 2000

Advocates protection against degradation and resuscitation of natural water-bodies such as lakes, ponds, beels3, khals, tanks, etc. affected by man-made

There are some ponds and small wetlands on the way of transmission line that might affect the natural flow and size of the wetlands

Ministry of Water Resources

Site specific designs have been formulated by the contractor who have made some minor changes in the tower footings to

3 A beel is a billabong or a lake-like wetland with static water (as opposed to moving water in rivers and canals - typically called

khaals), in the Ganges - Brahmaputra flood plains of the Eastern Indian states of West Bengal, and Assam and in the country of Bangladesh.


32



Compliance status

interventions or other causes. Prevents the filling of publicly-owned water bodies and depressions in urban areas for preservation of the natural aquifers and environment. Prevents unplanned construction on riverbanks and indiscriminate clearance of vegetation on newly accreted land.

avoid wetlands on the way.

8 Bangladesh Labor Law, 2006

It is a comprehensive law covering labour issues such as: conditions of service and employment, youth employment, benefits including maternal benefits, compensation for injuries, trade unions and industrial relations, disputes, participation of workers in company’s profits, regulation of safety of dock workers, penalty procedures, administration and inspection.

This Act pertains to the occupational rights and safety of factory workers and the provision of a comfortable environment for working. It also includes rules on registration of labourers, misconduct rules, income and benefits, health and fire safety, factory plan

Compliance to provisions on employment standards, occupational health and safety, welfare and social protection, labor relations and social dialogue, and enforcement.

Prohibition of employment of children and adolescents.

Ministry of Labor and Employment

OHS and COVID-19 guidelines have been formulated for the project by PGCB and Contractors.

9 Bangladesh Labor Rules, 2015

Includes rules on registration of laborers, misconduct rules, income and benefits, health and fire safety, factory plan

Contractors to implement occupational health and safety measures

Contractor will be liable for compensation for work-related injuries

Department of Labor

OHS and COVID-19 guidelines have been formulated for the project by PGCB and Contractors.

10 Bangladesh Climate Change Strategy and Action Plan of 2009

Enhances the capacity of government ministries, civil society and private sector to meet the challenges of climate change

Integrate adaptation measures for buildings in consideration of extreme climatic events

Ministry of Environment, Forests and Climate Change

The design includes climate enhancement. Climate mitigation is estimated to cost estimated as $93 million.

11 Building Construction (Amendment) Act and Building Construction Rules, Bangladesh

Regulates technical details of building construction and to maintain standards of building construction

Follow specifications to ensure structural integrity of buildings

Ministry of Housing and Public Works

The design of the building construction (Gopalganj substation) followed all the specifications required.


33



Compliance status

National Building Code

12 Electricity Act, 1910 and Electricity Rules 1937

Requires compensation for any damage, detriment or inconvenience caused by the project; Requires precautionary measures in laying down electricity supply lines near or where any metallic substance or line crosses to avoid electrocution

Secure permission to supply energy and lay down or place electricity supply lines for the conveyance and transmission of electricity from respective authorities prior to any works

Give full compensation for any damage, detriment or inconvenience caused by him or by anyone employed by him

Take precautions in laying down electricity supply lines near or where any metallic

substance or line crosses in order to avoid electrocution


GRC has been formed and compensation lists is with the GRC.

13 The National Energy Policy (1996 and Updated 2004)

Ensures environmentally sound sustainable energy development programs causing minimum damage to the environment, to encourage public and private sector participation in the development and management of the energy sector and to bring the entire country under electrification.

Public and private sector participation in the development and management of the energy subprojects.

Provides guidelines for renewable energy subprojects


This project does not consider renewable energy; however, the climate mitigation measures have been included in the project design.

14 National Disaster Management Act of 2012

Establishes a framework for managing disasters in a comprehensive way.

Setting-up emergency response procedures

Ministry of Disaster and Relief

Site specific measures have been developed by the contractors in the form of SEMP.

2. The ADB Safeguards Policy Statement (2009)

60 The ADB SPS (2009) provides the guiding principles of the environmental safeguards monitoring

of a project. The ADB Safeguard Policy Statement (SPS), 2009 (ADB, 2009) defines, generally, the actions

that should be undertaken to avoid, minimise, or mitigate adverse environmental and social impacts,

including protecting the rights of those likely to be affected or marginalised by the development process.

The three operational components of the safeguard policy are: protection of the environment, protection of

vulnerable (indigenous) people, and preventing/minimizing involuntary resettlement. These three safeguard

policies involve a structured process of impact assessment, planning, and mitigation to address the adverse

effects of projects throughout the project cycle. The safeguard policies require (i) identifying and assessing

impacts early in the Project cycle; (ii) developing and implementing plans to avoid, minimise, mitigate, or

compensate for the potential adverse impacts; and (iii) informing and consulting affected people during the

Project preparation and implementation.


34

61 ADB’s safeguard policies have provisions for compliance monitoring throughout the Project cycle

and an accountability mechanism whereby people adversely affected by ADB-financed projects can

express their grievances and seek solutions. The procedure referred to as the Grievance Redress

Mechanism (GRM) must be defined in every IEE and EIA.

62 SPS 2009 has also provisions for identify measures to avoid, minimize, or mitigate potentially

adverse impacts on and risks to biodiversity, natural resources, safety of both workers and affected

community and physical cultural resources during the design, construction, operation, and

decommissioning of the project.

3. ADB Safeguards Policy Statement (2009) compliance status

63 Refer to Table IV-2 for the status of the respective component sub-projects with regard to

environmental compliance status to ADB’s policy statement (SPS 2009).

Table IV-2 ADB Safeguards Policy environmental compliance Status for the STGEP subprojects (ADB SPS 2009 Appendix 1 Safeguards Requirement: Environment)

ADB Safeguard Policy Statement Contract Package Status

Package 1 Package 2 Package 3 Package 4 Package 5

(i) Environmental Assessment

(Category B: Requires IEE) done

and disclosed

Complied Complied Complied Complied Complied

IEE done for all packages, available at: https://www.adb.org/projects/documents/ban-51137-

001-iee

(ii) Environmental Management Plan

drafted

Complied Complied Complied Partially

complied

Partially

complied

EMP drafted along with IEE, sperate site specific CEMPs for each site has been developed by

contractors, Package 4 and 5 are still under processing. No CEMP has been done since no

contractor is engaged.

(iii) Information disclosed


IEE done for all packages, available at: https://www.adb.org/projects/documents/ban-51137-

001-iee

(iv) Consultation and participation have

been done and public opinion has

been used in project design phase.


Consultations were done during IEE development. GRC has been establish to consult public

grievance during project implementation.

(v) Establishment of GRC and notes of

grievances

Complied Complied Complied Yet to start Yet to start

GRCs have been establish for each package and are active. No grievance has been noted till

date.

(vi) Monitoring and reporting: client will

document regular monitoring

results, in case of adverse

significant affects external NGO will

be involved as third party monitoring


Biannual environmental monitoring report submitted by PGCB. External NGO will be engaged

in October 2020.

(vii) Unanticipated environmental

impacts


Site specific CEMPs have been prepared by the contractors and have been approved by

PGCB. Due to the unanticipated COVID-19 pandemic, the project activities were stopped to

avoid contamination. Sites were reopened in June 2020 with contractors forming their own

COVID-19 guidelines for workspace reopening based on ADB COVID-19 guidelines and GoB

COVID-19 guidelines. The guidelines have been approved by PGCB.

(viii) Biodiversity Conservation and

Sustainable Natural Resource

Management: The borrower/client

will assess the significance of

project impacts and risks on


The assessment was done during the development of IEE and has been disclosed on ADB’s

website. The project does not impact any critical habitat. The tree plantation programme does

not include any invasive alien species. Contractors have distributed 2000 native tree saplings to

local schools and Madrasas.


35

ADB Safeguard Policy Statement Contract Package Status

Package 1 Package 2 Package 3 Package 4 Package 5

biodiversity and natural resources

as an integral part of the

environmental assessment process

(ix) Pollution presentation: During the

design, construction, and operation

of the project the borrower/client will

apply pollution prevention and

control technologies and practices

consistent with international good

practice, as reflected in

internationally recognized standards

such as the World Bank Group’s

Environment, Health and Safety

Guidelines.


Both contractors drafted their own site-specific CEMPs and that has been approved by PGCB.

No hazardous materials of toxic properties have been found at site. All nonhazardous wastes

are being dumped to the municipalities’ designated area. The project itself has invested for

climate mitigation. Therefore, GHG emissions is expected to be marginalized. Environmental

tests were done for 400kV and 132kV transmission lines and no parameter exceeded DoE

recommended guidelines.

(x) Health and safety: The

borrower/client will provide workers

with a safe and healthy working

environment, taking into account

risks inherent to the particular

sector and specific classes of

hazards in the borrower’s/client’s

work areas, including physical,

chemical, biological, and

radiological hazards.


Both contractors have their own OHS rules which are effective in field. Additionally, PGCB has

its own rules regarding OHS. During the COVID-19 pandemic spread in March – June, the

project activities were stopped to avoid contamination. Upon reopening the contractors drafted

their COVID-19 response plan that are approved by PGCB. ADB has also provided its COVID-

19 guidelines for contractors following which contractors prepared, updated and implemented

the plan at site

(xi) Physical and cultural resources:

The borrower/client is responsible

for siting and designing the project

to avoid significant damage to

physical cultural resources


The project design considered the important cultural and physical resources in the project sites

4. Compliance with loan Covenants

64 Schedule 4 of the Agreements for Grant 0582-BAN includes covenants for environmental issues.

The Project’s compliance with the contractual environmental safeguards’ covenants are shown in the Table

IV-3

Table IV-3 Compliance with Environmental Considerations of Loan Agreements

Covenant Reference in the Grant Agreement

Compliance Status

Environment

PGCB shall ensure that the preparation, design, construction, implementation, operation and decommissioning of each Subproject comply with: (i) all applicable laws and regulations of the Recipient relating to environment, health, and safety; (ii) the Environmental Safeguards; the EARF; and (iii) all measures and requirements set forth in the respective IEE and EMP, and any corrective or preventative actions set forth in a Safeguards Monitoring Report.

Schedule 4, Para. 5 Complied. All requirements addressed in preparation and design stages including contract documentation.


36

Covenant Reference in the Grant Agreement

Compliance Status

Safeguards – Related Provisions in Bidding Documents and Works Contracts

The Recipient shall ensure, or cause the EAs to ensure, that all bidding documents and contracts for Works contain provisions that require contractors to:

Schedule 4, Para. 9 Complied.

(a) comply with the measures and requirements relevant to the contractor set forth in the relevant IEE, EMP and RP (to the extent they concern impacts on affected people during construction), and any corrective or preventative actions set out in a Safeguards Monitoring Report;

Complied. All Bidding Documents and Contracts contain the required provisions

(b) make available a budget for all such environmental and social measures; Complied.

(c) provide the Recipient with a written notice of any unanticipated environmental, resettlement or indigenous peoples risks or impacts that arise during construction, implementation or operation of the Subproject that were not considered in the relevant IEE, EMP and RP;

Complied.

(d) adequately record the condition of roads, agricultural land and other infrastructure prior to starting to transport materials and construction.

Complied.

(e) reinstate pathways, other local infrastructure, and agricultural land to at least to their pre project condition upon completion of construction

Yet to comply

Safeguards Monitoring and Reporting

The Recipient shall do the following, or shall cause the EAs to do the following: (a) submit semi-annual Safeguards Monitoring Reports to ADB and disclose relevant information from such reports to affected persons promptly upon submission.

Schedule 4, Para. 10 Complied.


37

V. Performance Indicators

A. Overall performances

65 Overall performances of the project in the perspective of environmental compliance has been

analysed based on monitoring reports and site visit impressions are presented in Table V-1 and Table V-2.

Table V-1 Overall performance in relation to environmental compliance (Gopalganj substation)

No. Aspects of

Environmental issues

Compliance Status

Remarks

FC PC NC

A. General

1. Legal working hours approval

The workers work 10 hours a day at site including 1.5-hour lunch break. Sometimes worker taking rest if they feel bored due to work which is maximum 30 min.

2. Employment Record keeping arrangement

The employment records are kept in a register book manually every day in the field.

3. Payment Record keeping arrangement

The payment records are kept in a register book manually every day in the field.

4. Environment, Health and Safety Officer designated

Appointed from the beginning. The contractor has inhouse HSE team

5. Provision for monthly meeting for inspection of site activities

Meetings are held on working progress, environmental compliance and future planning periodically during mission. However, it is strongly advised that the meeting minutes need to be reported to PGCB and compilation of the monthly meeting reports needed to be included in the Semi-annual report prepared by PGCB which is disclosed at ADB website.

B. Health and Sanitation

Occupational Health

1. First-Aid Box availability at work sites

A well-equipped first aid box is available at the site.

2. Provision of personal protection equipment’s (PPEs)

Site Engineers, supervisors and workers are provided with PPEs including vests, helmets, safety boots etc. However, it was found that not all workers are wearing the appropriate PPEs, neither they are aware of the COVID-19 situation. During monthly meeting and COVID-19 awareness programmes arranged by the contractor, it found that both the workers and communities receiving training are not maintaining social distancing and not wearing mask. It is strongly advised that COVID-19 measures as drafted by the contractor and ADB guidelines should be strictly followed at site and awareness trainings should be arranged on monthly basis which needs to be reported back to PGCB. Additionally, toolbox meetings everyday should feature PPE and COVID-19 awareness and should be recorded as meeting memos at site.

3. Handling of cement and other hazardous materials by workers

Hazardous and Non-Hazardous materials were collected by a separate waste bin. Fuel drums are stored in the designated area. However, no chemical handling plan was not found at site. It is recommended that, contractor should draft a chemical handling plan for the site.

4. Workers’ complains taken care of by the supervisor

Planning to appoint a supervisor for the workers is appointed to take care of the worker’s problems and receiving complaints from the workers and solving those problems accordingly.

5. Children below 18 employment

There are no below 18 children working in the site


38

No. Aspects of


Compliance Status

Remarks

FC PC NC

C. Environmental Pollution Dust and emission control

1.

Construction vehicles and machineries maintained properly to reduce emissions

Try to maintain the vehicles and machineries with least pollution.

2. Proper storage of materials and regular watering.

The materials are stored in proper manner and watering is done when required to mitigate air pollution. Removal of dust fully is quite difficult but the project team is trying to remove by water spraying in an environmentally friendly manner. As suggested earlier, a chemical handling plan should be drafted and followed by the contractor. The plan needs to be approved by PGCB.

Noise Pollution

1. Movement of vehicles at desired hours

Heavy vehicles movements are done mostly from morning to afternoon.

2. Noise control measures at sites

Noise created due to construction and heavy machineries affects less on the surrounding household because the construction site is away from the residential area.

Water Pollution

1. Land filling During land filling no proper record were kept to observe waterlogging and drainage congestion.

2. Wastes, cement, effluents and junks not disposed in water

Settling ponds were dug for effluent discharge. The dried sand/soil is excavated and carried away to a municipality designated area.

Flora and Fauna

1.

Trees and bushes outside the construction area preserved from damages

Trees and bushes in the construction area is cleared during pre-construction phase. Vegetation outside of the working area is not affected. However, plantation programme will be commenced during site reinstatement as part of environmental enhancement.

2. Disturbance to terrestrial fauna minimized

The camp site has no significant terrestrial fauna; few birds, mouse, snake etc. are identified there which are not affected by the project works. Workers are instructed not to hurt any wildlife if they encountered in the construction site.

Waste Management

1. Construction wastes are removed off site regularly

The wastes are kept in a specific place and they are removed off site regularly in and environmentally friendly manner. The contractor needs to draft a waste management plan and follow the plan accordingly with reports to PGCB.

2. Chemical wastes, if any, collected and disposed of properly

Chemical used for water purification is stored offsite in the chemical storage safely. During the monitoring period, no incident of chemical spills is seen. As advised earlier, the contractor needs to devise a chemical handling plan approved by PGCB.

D. Environmental documents at Field Office and Project sites

1.

Field Office possesses copies of EMP, contract document and Technical Specifications

All the documents are kept in the field office.

2. Heavy equipment maintenance records

In the mini pipe packages, no heavy equipment is required except mechanical drilling rig which is checked regularly. The maintenance records are yet to kept at site.

TOTAL 18 3 1


39

Table V-2 Overall performance in relation to environmental compliance (TL)

No. Aspects of


Compliance Status

Remarks

FC PC NC

A. General

1. Legal working hours approval

The workers work 10 hours a day at site including 1.5-hour lunch break. Sometimes worker taking rest if they feel bored due to work. This break is maximum 30 min which is known to the workers as tea break.

2. Employment Record keeping arrangement

The employment records are kept in a register book manually every day in the field.

3. Payment Record keeping arrangement

The payment records are kept in a register book manually every day in the field.

4. Environment, Health and Safety Officer designated

Appointed from the beginning. The contractor has inhouse HSE team

5. Provision for monthly meeting for inspection of site activities

Meetings are held on working progress, environmental compliance and future planning periodically during mission. The meeting memos are kept by contractor, but they should be submitted to PGCB to report back to ADB.

B. Health and Sanitation

Occupational Health

1. First-Aid Box availability at work sites

A well-equipped first aid box is available at the site

2. Provision of personal protection equipment’s (PPEs)

Site Engineers, supervisors and workers are provided with PPEs including vests, helmets, safety boots etc. However, it was found that not all workers are wearing the appropriate PPEs, neither they are aware of the COVID-19 situation. During monthly meeting and COVID-19 awareness programmes arranged by the contractor, it found that both the workers and communities receiving training are not maintaining social distancing and not wearing mask. It is strongly advised that COVID-19 measures as drafted by the contractor and ADB guidelines should be strictly followed at site and awareness trainings should be arranged on monthly basis which needs to be reported back to PGCB. Additionally, toolbox meetings everyday should feature PPE and COVID-19 awareness and should be recorded as meeting memos at site.

3. Handling of cement and other hazardous materials by workers

Hazardous and Non-Hazardous materials were collected by a separate waste bin. Fuel drums are stored in the designated area.

4. Workers health and sanitation

Worker labour shed and toilets were found unhygienic. The contractors need to immediately improve the labour shed condition and report back to PGCB. The contractor also should prepare a compliance sheet stating the current condition and conditions being provided for the workers. PGCB will check the compliance sheet and inspect site to observe the condition. The contractor also shall report to the PGCB team on worker conditions including labour shed and hygiene facilities.

5. Children below 18 employment

There are no below 18 children working in the site

C. Environmental Pollution Dust and emission control

1.

Construction vehicles and machineries maintained properly to reduce emissions

Try to maintain the vehicles and machineries with least pollution.


40

No. Aspects of


Compliance Status

Remarks

FC PC NC

2. Proper storage of materials and regular watering.

The materials are stored in proper manner and watering is done when required to mitigate air pollution. Removal of dust fully is quite difficult but the project team is trying to remove by water spraying in an environmentally friendly manner. However, it was found the water spray needs to be more frequent. Therefore, records of water spray and complains should be registered.

Noise Pollution

1. Movement of vehicles at desired hours

Heavy vehicles movements are done mostly from morning to afternoon.

2. Noise control measures at sites

Noise created due to construction and heavy machineries affects less on the surrounding household because the construction site is away from the residential area.

Water Pollution

1. Wastes, cement, effluents and junks not disposed in water

Settling ponds were dug for effluent discharge. The dried sand/soil is excavated and carried away to a municipality designated area. This needs to be under strict monitoring. Therefore, the contractor needs to develop a waste management plan in the light of waste management guidelines provided in the IEE and submit to PGCB for approval. The compliance of the waste management plan should be recorded in a register.

Flora and Fauna

1. Compensatory tree plantation

2000 Tree saplings were distributed to local schools and madrasas. No proper record kept.

2.

Trees and bushes outside the construction area preserved from damages

Trees and bushes in the construction area is cleared during pre-construction phase. Vegetation outside of the working area is not affected. However, plantation programme will be commenced during site reinstatement as part of environmental enhancement.

3. Disturbance to terrestrial fauna minimized

The camp site has no significant terrestrial fauna; few birds, mouse, snake etc. are identified there which are not affected by the project works. Workers are instructed not to hurt any wildlife if they encountered in the construction site.

Waste Management

1. Construction wastes are removed off site regularly

The wastes are kept in a specific place and they are removed off site regularly in and environmentally friendly manner. The contractor needs to develop a waste management plan in the light of waste management guidelines provided in the IEE and submit to PGCB for approval. The compliance of the waste management plan should be recorded in a register.

2. Chemical wastes, if any, collected and disposed of properly

Chemical used for water purification is stored offsite in the chemical storage safely. During the monitoring period, no incident of chemical spills is seen. The contractor needs to develop a waste management plan in the light of waste management guidelines provided in the IEE and submit to PGCB for approval. The compliance of the waste management plan should be recorded in a register.

D. Environmental documents at Field Office and Project sites

1.

Field Office possesses copies of EMP, contract document and Technical Specifications

All the documents are kept in the field office.

2. Heavy equipment maintenance records

In the mini pipe packages, no heavy equipment is required except mechanical drilling rig which is checked regularly. The maintenance records are yet to kept at site.


41

No. Aspects of


Compliance Status

Remarks

FC PC NC

TOTAL 14 6 1

B. Health and Safety performance

66 This section presents some site-based H&S performance indicators for all running subprojects at

a glance. The performance indicators are based on field observations from each subproject. The

performance indicators are presented in Table V-3.


42

Table V-3 H&S Performance indicators of all subprojects

Environmental Safeguards Questions Package 1 Package 2 Package 3 Package 4 Package 5

1. Sensitive receptors adjacent to the site? (i.e. residential, schools/learning center, health care center, daycare...)

N Y Y - -

2. Are the workers aware of the EMP? Y Y Y - -

3. Occupational Health and Safety: 3.1 Is there a designated person responsible for ensuring safe working practices? Are the workers aware?

Y Y Y - -

3.2 Have the workers received appropriate OHS training to perform their jobs? How often are they briefed on OHS requirements? *

Y Y Y - -

3.3 Do the workers use personal protective equipment (PPE - hats, glasses, boots etc.)? ** Y Y Y - -

3.4 Are working areas clear of slipping and tripping hazards? Y PC PC - -

3.5 Are health and safety warning and information signs visible and understandable to workers? PC PC PC - -

3.6 Are there any hazardous materials? Are they stored and handled appropriately? Y Y Y - -

3.7 Are workers exposed to risks from working at height? If yes, are the workers using harnesses (fall protection equipment)?

N Y Y - -

3.8 Are workers exposed to risk from confined spaces? (i.e. storage areas for hazardous materials) N N N - -

3.9 Is there a record of occupational injuries and diseases? N N N - -

3.10 Do workers receive health checks? Y Y Y - -

3.11 What medical facilities are made available for the workers? First aid First aid First aid - -

Labor Camps: 3.12 What toilet and washing facilities are provided?

Y PC PC - -

3.13 Do workers have access to clean drinking water? Y Y Y - -

3.14 Is the workers accommodation provided by the contractor? Y Y Y - -

Emergency Procedures: 3.15 Are any procedures in place in case of an injury on site?

N N N - -

3.16 Is there a first aid kit available on site? Y Y Y - -

3.17 Are any procedures in place for chlorine leak, oil spills? Y N N - -

3.18 Is firefighting equipment available on site? Is servicing up to date? Y Y Y - -

4. Grievance Redress Mechanism {GRM): 4.1 Are the names and contact information posted for possible complaints?

Y Y Y - -

4.2 Is there a log book available on site? Y Y Y - -

5. House Keeping: 5.1 Did you observe examples of poor housekeeping? (i.e. empty containers scattered, stagnation of water from improper disposal of solid waste?)

N N N - -

Y = Yes; N = No: PC = partially complied


43

C. COVID – 19 response performance

67 This section presents some site-based performance indicators COVID-19 for all running

subprojects at a glance. The performance indicators are based on field observations from each subproject

and compared with ADB and Bangladesh Government guideline. The performances indicators are

presented in Table V-3.

Table V-4 COVID-19 Performance indicators of all subprojects

COVID-19 Response questions

Pac

kag

e 1

Pac

kag

e 2

Pac

kag

e 3

Pac

kag

e 4

Pac

kag

e 5

Comments

Site re-opening and entry protocol Locate the closest medical establishment equipped with COVID -19 response facilities.

C C C - -

Engage a full time EHS professional at site C C C - - Purchase thermometer gun, soap, hand sanitizer, disinfectants and PPEs (mask, hand gloves, hard shoes etc.) and keep it at worksite office.

PC PC PC - - Workers are not always using the safety cautions. Need frequent awareness training

Establish site entrance protocol. Redesign the site safety notices/signboards/protocol according to the ADB guidelines NC NC NC - -

Entry protocol has been established, but not satisfactory. Site signboards are not visible.

Arrange washbasin, soap and clean water at the entrance of every worksite/campsite. Also keep either a disinfectant tub for shoes or keep disinfectant spray that must be sprayed under the boots/hard shoes of the persons entering worksite.

PC PC PC - -

Wash basin, soap, clean water etc. has been arranged. However, enforcement of the entry protocol is poor

Provide every personnel working in the site with mask, hand gloves and hard shoes for their personal use.

C C C - -

Everyone entering the worksite must wear a mask, gloves and hard shoes

PC PC PC - - Enforcement of entry protocol is poor

Daily worksite protocol A designated EHS and medical person should stay all time during work. The EHS/Medical person should also monitor campsite. He/she will be in charge of ensuring physical distances (minimum 1m) among workers, disinfecting surfaces that are commonly used and investigate workers/site personnel health and safety.

PC PC PC - -

Fulltime ESH officer is present at site. However, enforcement of physical distancing and frequent disinfection is poor.

At the start and end of the day disinfect the total worksite.

NC NC NC - -

No prove of disinfection at start and end of work. Need to start immediately and monitoring from EHS officer and PGCBB needs to improve.

Encourage site personnel/camp dwellers to not touch their eyes, mouth or nose if not washed thoroughly with soap recently. Also discourage hand shaking or hugs.

PC PC PC - -

Daily toolbox meetings are done and records are kept. But implementation has not been up to the mark.

Arrange a mandatory site brief on COVID awareness in the morning. The session must be conducted by the EHS/medical professional.

PC PC PC - - Same as above.

While worksites are commonly well ventilated (if not make sure the work sites are well ventilated), ensure that the camp sites including the rooms designated for the camp dwellers are well ventilated and spacious.

NC NC NC - -

Labor shed has been found as in pretty bad shape with lack of hygiene facilities. Mitigation measures are reported elsewhere in this report (EMP performance section).


44

COVID-19 Response questions

Pac

kag

e 1

Pac

kag

e 2

Pac

kag

e 3

Pac

kag

e 4

Pac

kag

e 5

Comments

Before sharing common tools/machines at worksite, ensure to disinfect.

NC NC NC - - Need to start immediately and monitoring from EHS officer and PGCBB needs to improve.

Discourage site personnel to gather and gossip at any time, rather encourage physical distance while chatting/discussing.

PC PC PC - -

Workers are not enough sensitized on COVID issues. Also, enforcement of site rules appeared to be weak. The ESH officer needs to be much strict on this issue.

Restrict worksite personnel to go outside unnecessarily. Also restrict campsite personnel to go outside without any valid cause.

C C C - -

If any person related at worksite/campsite fall victim to COVID-19 or being kept isolated for pre-caution, consider paid leave with no exception allowed.

- - - - -

No incident has recorded to date.

Every day training Train workers on how to properly put on, use/wear, and take off protective clothing and equipment. The on-site EHS/Medical person should be in-charge of these trainings. These trainings must maintain the WHO’s social distancing protocol. Make these trainings mandatory at worksites. Provide 10-15 minutes of a workday for such ‘training and encouragement’ activities.

PC PC PC - -

Toolbox meetings are done. But the workers seem not enough sensitized. Therefore, effective training and enforcement of site rules is needed.

*C = Complied, NC = Non complied; PC = Partially complied.


45

VI. Concluding Observations

68 Current environmental conditions of 3 ongoing subprojects are presented through some site

photographs in Appendix I of this report.

69 The concluding observations are as follows:

The Environmental Safeguards compliance performance of the EAs are in good shape except

a few things. The onsite training workshop and regular monitoring of PGCB and contractors

HSE team to sensitize the workers need to be continued for greater benefit. However, it was

found that despite of the trainings and awareness programmes, onsite photos (Appendix I)

suggest the workers and community people are not maintaining proper PPEs and COVID-19

guidelines. This needs to be strictly monitored and HSE guidelines including COVID-19

guidelines needs to be enforced at site. The reports need to be submitted to PGCB. PGCB

also shall increase the number of monitoring visits and enforce the guidelines.

Due to accessibility issues attributed to restrictions associated with Covid-19, implementation

of environmental safeguards is hindered. In addition, inadequate safety measures, especially

social distancing and frequent disinfection of equipment are still visible at work site.

Environmental quality data from periodic monitoring indicated that in reference to the

Bangladesh standard, the quality of ambient air and groundwater in the project area is within

the standard limit. The noise level is within the safe limit for mixed areas with intermittent spikes

due to proximity of the sites to the roads and human interference.

The labour shed and labour hygiene appear to be ignored by the contractors. This needs

immediate attention and frequent monitoring to improve the condition of labour sheds and

associated hygiene facilities.

70 Recommended actions: The following actions with timeframe is recommended:

Sl. no Recommended action Time frame to

achieve

1 Immediate improvement of the labour shed conditions. The contractor will prepare a

compliance checklist of the labour shed’s present condition and submit to PGCB for

approval. The PGCB team will visit site for checking and approve the compliance checklist.

Then the contractor will take immediate action to improve the prevailing condition using the

checklist and submit to PGCB. The PGCB team will again visit site and inspect using the

checklist whether the situation has improved or not. Then PGCB will make a report on the

improvement and share with ADB

November 30, 2020

2 Contractor must devise On-site waste management plan and submit to PGCB for approval.

The contractor should also develop a onsite checklist for monthly reporting and should report

back to PGCB on monthly basis.

November 30, 2020


46

Sl. no Recommended action Time frame to

achieve

3 The PPE and COVID-19 guidelines are not in full compliance. Contractor needs to strictly

monitor the PPE and COVID-19 compliance on site and report back to PGCB. Contractor

shall arrange a general PPE awareness and COVID-19 awareness training workshop at site

with all workers and report to PGCB as compliance reporting. Monthly reports on PPE and

COVID compliance should be submitted to PGCB.

General workshop

by November 15,

2020

4 Tree plantation plan shall be submitted by the contractor to PGCB immediately. Proper

records of tree plantation need to be kept and submitted to PGCB

November 15, 2020


47

VII. Appendix - I

Community awareness programme at TL site: People are without mask and not maintaining social

distancing as per COVID-19 awareness guideline. Recommended actions are stipulated in the text.

Posters shown in worksite on COVID-19 awareness:


48

Health awareness campaign near the TL area on COVID-19. Participants are not wearing mask and not

maintaining social distancing, which is not acceptable. Recommended measures are stipulated in the report

Tree plantation activities around the TL area:


49

Traffic safety management at the TL area:

Hand washing facilities at site: as seen in photo, workers are not maintaining proper OHS guideline.

Recommended measures are stipulated in the report.

Bangladesh: Southwest Transmission Grid Expansion Project

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