Annual Environment & Social Monitoring Report (July 2013 to June 2014)

Environmental and Social Performance Report October 2014

Pakistan: Electric Supply Company Post Privatization Rehabilitation, Upgrade and Expansion

Prepared by K-Electric Limited (formerly Karachi Electric Supply Company) Karachi,

The Environmental and Social Performance Report is a document of the borrower. The views expressed herein do not necessarily represent those of ADB’s Board of Directors, Management, or staff, and may be preliminary in nature. Your attention is directed to the “Terms of Use” section of this website.

ANNEXURE ‘E’ K-Electric (IFC LOAN DOCUMENT)

ANNUAL MONITORING REPORT (AMR)

REPORTING PERIOD: 1st JULY 2013 – 30th JUNE 2014

8th Yearly Report

K-Electric Certification

IFC Project Identification: KESC (Pakistan) IFC Number # 25396 AMR reporting period: 1st July 2013 – 30th June 2014

KE PHYSICAL ADDRESS: K-Electric Limited KE House, 39 – B, Sunset Boulevard Defence Housing Authority (DHA) Phase - II, Karachi Pakistan.

Telephone: +9221-32637133 Fax: +9221-35647155 Web: www.ke.com.pk

We certify that to the best of our knowledge and belief the data contained in this AMR completely and accurately represents the environmental and social aspects of KE’s activities during this reporting period i.e. 1st July 2013 to 30th June 2014.

Acronyms and Abbreviations

AMR Annual Monitoring Report

BDL Below Detectable Limits

EHSS Environmental, Health, Social and Sustainability

EHT Extra High Tension

EIA Environmental Impact Assessment

GoS Government of Sindh

GT Gas Turbine

HSEQ Health, Safety, Environment & Quality

IBC Integrated Business Centre

IEE Initial Environmental Examination Report

IFC International Finance Corporation

KE K-Electric Limited

KESC Karachi Electric Supply Company

NEQS National Environmental Quality Standards

NFEH National Forum for Environment and Health

NGO Non-Governmental Organisation

NMS Non Management Staff

PEPA’97 Pakistan Environmental Protection Act 1997

PS Performance Standards

SEPA Sindh Environmental Protection Agency

SEPA’14 Sindh Environmental Protection Act 2014

T&D Transmission and Distribution

Contents

1. Introduction 1

2. Scope and Timing 1

3. K-Electric: Energy that moves Life 2

4. KE’s Environmental, Health, Social and Sustainability (EHSS) Initiatives 4

4.1. Compliance Evaluation 4

4.2. Environmental Management and Assessment 6

4.3. Health and Safety 10

4.4. Corporate Social Responsibility 16

4.5. Energy Conservation Initiatives 18

4.6. New and Renewable Energy Projects 18

4.7. Stakeholders Engagement 21

5. Compliance with IFC Performance Standards 23

5.1. Social and Environmental Assessment and Management System (PS1) 23

5.2. Labour and Working Conditions (PS2) 26

5.3. Pollution Prevention and Abatement (PS3) 31

5.4. Community Health, Safety and Security (PS4) 37

5.5. Land Acquisition and Involuntary Resettlement (PS5) 38

5.6. Biodiversity Conservation and Natural Resource Management (PS 6) 38

5.7. Indigenous People (PS 7) 38

5.8. Cultural Heritage (PS 8) 38

6. Challenges and the Way Forward 39

Annexes

Annex – A: List of KE Awards during FY 2013 - 14 Annex – B: IFC’s Social and Environmental Management Plan (April – June 2014) Annex – C: KE’s HSEQ Policy Annex – D: Executive Summaries of IEE of 03 projects Annex – E: Executive Summary of EIA - 132 kV Baldia Valika Transmission Line Annex – F: Public Hearing Notice of 132 kV Baldia Valika Transmission Line project Annex – G: Non-Objection Certificates of KE’s projects by SEPA Annex – H: Generation Plants Monitoring Results for Second Quarter 2014 Annex – I: ISO 14001:2004 certificates of Two Generation Plants Annex – J: PCBs summary sheet Annex – K: Waste Management Procedure Annex – L: Asbestos Management Procedure

Annex – M: SF6 Management Procedure Annex – N: Trainings on Environmental Management Annex – O: Safety Inspection Report Annex – P: Energy Conservation Activities Annex – Q: Breakdown of Customers Complaints Annex – R: Descriptions of accidents

1. Introduction

The Annual Monitoring Report (AMR) for FY 2013 – 2014 has been prepared by the K- Electric Limited (KE – the company) as part of its reporting commitments to the International Finance Corporation (IFC). This is Eighth Year post-financing report and describes the degree to which the requirements specified in the Action Plan and Annexure ‘E’, specified in section 5.03(d) of the Loan Agreement document, have been met and to describe non-compliance and what is being done to address such non-compliance.

This report is not only KE’s disclosure of its environmental, health, social and sustainability (EHSS) initiatives to the stakeholders but, also, is a performance benchmarking document. Thus, the AMR will enable the company to reflect back and improve on its various ESS initiatives undertaken to incorporate the element of sustainability in its business functions and operations.

2. Scope and Timing

The AMR encompasses all the activities associated with KE, including operations, generation, transmission and distribution, capacity enhancement projects and social and environmental initiatives from 1st July 2013 to 30th June 2014. The report has been independently verified to ensure that the reporting is factual and accurate and that a fair description of KE’s overall performance in meeting the loan agreement requirements has been provided.

The AMR 2013-14 is built upon IFC’s Performance Standards (PS). IFC’s PS have been designed and developed to assist its clients in rolling out their respective business functions and operations in a sustainable way. Together, the eight (08) PS provide guidance and direction on EHSS aspects, that the client is to meet throughout the lifecycle of a project financed by IFC. Therefore, at KE, these PS are used as a benchmark to manage company’s environmental and social risks, which may arise as a result of its operations. In this report, first, a brief snapshot of KE, as a utility company, is presented. Second, the overview of KE’s EHSS regime and activities carried out during the FY 2013 -14 is presented. This is followed by KE’s EHSS initiatives benchmarking against each of the IFC’s PS. Page | 1

3. K-Electric: Energy that moves Life

K-Electric Limited (KE), formerly known as Karachi Electric Supply Company (KESC), is the only remaining vertically integrated power utility in Pakistan with exclusive licensing rights for Karachi, a customer base of 2.4 million. The city of Karachi is central to Pakistan’s economy. Around 90 percent of the head offices of the banks, financial institutions and multinationals operate from Karachi. In addition, 40 percent of large scale manufacturing employment is Karachi based. Against this background and as the sole electricity provider to the city, KE is of strategic importance not only to Karachi but also to the country, Pakistan.

KE was incorporated in 1913 (pre-independence) as a public utility company. However in 2005, KE was privatized. Outlook of KE’s entire power value chain is;

Presence Across the Entire Power Value Chain Generation Transmission Distribution All power units and grid station are monitored by a centralized Load Dispatch Centre using state of the art SCADA system Own Generation

Grid Stations End User Power Purchase

Generation Capacity MW Capacity: Capacity: KE Internal 2,422 62 grid station KE Coverage area: 6,500 sq km IPPs and others 365 128 power transformers 11kV distribution capacity of 4,973 MVA NTDC (National 650 Network of 220, 132, and 66 kV circuits through 15,588 PMTs and sub stations Grid) 1,249 KM of overhead and underground 11kV: 7,900 KM cables (67% underground) Total 3,437 cables 0.4kV: 12,044 KM (90% overhead) Figure 1: K-Electric Presence across the Entire Power Value Chain

KE has shown a noticeable improvement in its business operations and services since the takeover by the current management back in April/May 2009. Since then, KE’s generation capacity has increased by 1,000 Megawatts (MW). Through improved system, KE has witnessed 22 percent efficiency gain in FY 2013 – 14 since 2009.

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Average Fleet Efficiency (%)

22% 36.70% 37.00% 34.40% 33.10% 33.50% 30.40%

FY-09 FY-10 FY-11 FY-12 FY-13 FY-14

Graph 1: Average Fleet Efficiency

Moreover, KE increased the reliability of its transmission network, with 189km of old Extra High Tension (EHT) line rehabilitated and an additional 62km of EHT lines added. Similarly, the company turned around its ‘Transmission and Distribution (T&D)’ system and managed to reduce its T&D losses by ten percent since FY 2009. Currently T&D losses stand at 25.30 percent as compared to 35.9 percent in FY 2009. T&D Losses (%) – Rolling Average

35.90% 34.90% 32.20% 29.70% 27.80% 25.30%

FY 09 FY 10 FY 11 FY 12 FY 13 FY 14 Graph 2: Transmission & Distribution Losses (%)

IFC Award: The success of KE’s transformation was appreciated by the Financial Times and IFC. KE, in June 2014, was honored with the prestigious FT/IFC Transformational Business Award for exceptional achievement in Project Finance – Energy. During the period KE won Picture 1: KE won Financial Times and IFC Award

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various other awards in the field of occupational health and safety, fire safety and environment (for details refer to attached Annex – A).

New Identity: The FY 2013-14, amongst other things was important as K-Electric completed its 100 years of continued existence. Therefore, while entering the new century, a renewed pledge to realign the company’s identity with the company’s vision, a new corporate identity was established. On January 20, 2014, KESC evolved into KE.

Figure 2: KE’s New Brand Identity The three feathers in KE’s new identity have been inspired by Pakistan’s national bird ‘Partridge’. The yellow feather represents ‘energy’, blue ‘community’ and the green is for the ‘environment’. The new corporate identity underpins the company’s resolve to carry out its operations in a sustainable way to meet the energy demands of current and future generations.

4. KE’s Environmental, Health, Social and Sustainability (EHSS) Initiatives

This section presents the highlights of KE’s EHSS initiatives during the FY 2013 -14.

4.1. Compliance Evaluation

KE’s infrastructure and operations were in compliance with the IFC Performance Standards (PS) during the reporting period. As mentioned above, IFC PS assists the clients to adopt a more socially and environmentally inclusive business model. Based on this, the summary of KE’s compliance status vis-a-vis IFC Performance Standards is given below in Table - 1;

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SNo IFC Performance Standards KE’s status Remarks PS1: Social and Environmental 1 Compliant - Assessment and Management Systems 2 PS2: Labour and Working Conditions Compliant - PS3: Pollution Prevention and Partially Continuous Improvement 3 Abatement Compliant Process* PS4: Community Health, Safety and Partially Continuous Improvement 4 Security Compliant Process* PS5: Land Acquisition and Involuntary 5 Compliant - Resettlement PS6: Biodiversity Conservation and 6 Sustainable Natural Resource Compliant - Management 7 PS7: Indigenous Peoples Compliant - 8 PS8: Cultural Heritage Compliant - Table 1: KE’s compliance status against IFC Performance Standards

* Although KE is in compliance with the PS # 3 and 4, however since these are continuous improvement processes therefore they have been graded as ‘Partially Compliant’.

Additionally, KE has complied with the major actions and interventions required under IFC’s Action Plan (Revised: October 2009). Remaining actions have been revised through a mutually agreed Action Plan October 23, 2009 and are ongoing and at various stages of compliances. The up-dated status on IFC’s Social and Environmental Management Plan for April – June 2014 is attached as Annex – B.

Moreover, KE is conducting all of its business operations as per National and Provincial regulations to which it subscribes. As a result of company’s strong emphasis on adopting and following best available health, safety and environment (HSE) regime across the board, there were no fines and/or penalties levied against the company during the reporting period (FY 2013 – 14). Summary of company’s compliance status with applicable and relevant National and Provincial regulations is given below in Table - 2;

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SNo National/Provincial Regulations KE’s status Remarks Pakistan Environmental Protection 1 Compliant - Act (PEPA), 1997 (EIA/IEE) PEPA – Review of IEE and EIA KE submitted three IEE and one 2 Compliant Regulations 2000 EIA report during FY 2013-14. National Environmental Quality KE carried out third monitoring, 3 Standards (NEQS) for emissions & Compliant that established compliance Effluents 2009 with the NEQS. Project Implementation and 4 resettlement of affected persons Compliant - Ordinance 2002 Partially 5 Hazardous Substances Rules, 1999 Continuous Process Compliant 6 Sindh Cultural Heritage Act 1994 Compliant - Table 2: Summary of National / Provincial Regulations

4.2. Environmental Management and Assessment

KE, in accordance with its HSEQ Policy (Annex – C), has carried out its business functions and operations as per applicable National/Provincial environmental laws and regulations to which it subscribes. In this regard, KE follows Pakistan Environmental Protection Act of 1997, to benchmark and report its environmental performance and compliance. However, it is important, to highlight the enactment of Sindh Environmental Protection Act 2014 (SEPA’14) by the Provincial Assembly (Parliament) of Sindh in March 2014. Against the backdrop of 18th Constitutional Amendment, the subject of ‘environment’ stands devolved. Therefore, Government of Sindh (GoS) approved SEPA’14. However GoS has yet to notify Sindh Environmental Quality Standards (SEQS).

4.2.1. Environmental Studies – IEE/EIA

KE rolled out four new projects, during the reporting period. For three projects, KE submitted individual Initial Environmental Examination (IEE) reports to the Sindh Environmental Protection Agency (SEPA) (Executive Summaries attached as Annex –D). For the fourth project, based on its scope, an Environmental Impact Assessment (EIA) report was submitted (Executive Summary attached as Annex – E). For this EIA study, as per PEPA’97/SEPA’14 policy on stakeholder participation and public disclosure, project’s public hearing was arranged on August 20, 2013 at Karachi. In this regard, the EIA’s public

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hearing notices were published in local language as well as English newspapers (Notices attached as Annex – F).

SEPA approved all four projects and accorded ‘Non-Objection Certificate (NoC)’ to the projects (NoCs of all the four projects attached as Annex – G).

Submission SNo Project Name Category NoC Date 1. 132 kV Baldia Valika Transmission Line EIA 12.03.13 09.01.14 2. SGTPS Up-gradation IEE 21.11.13 24.02.14 3. KGTPS Up-gradation IEE 21.11.13 24.02.14 4. Extension of 220 MW Combine Cycle IEE 09.01.14 24.02.14 Power Plant, Gas Engine Table: 3 – Detail of IEEs and EIA submitted during FY 2013 – 14

4.2.2. Emission and Effluent Monitoring

KE, on monthly basis, has been monitoring air emissions and effluent discharges from its five generation plants in compliance of National Environmental Quality Standards (NEQS) of PEPA’97, during FY 2013 -14. This activity was carried out, by an approved third party environmental laboratory/Consultant. Quarterly reports were shared with SEPA as per reporting/compliance commitments. Based on the monitoring results, KE’s (five) generation plants were in compliance with the NEQS during the reporting period. No fines and/or penalties were served to the company by SEPA on the basis of nonconformity with the environmental standards during the FY 2013 - 14.

Monitoring results of all the five generation plants for 2nd Quarter of 2014 are attached as Annex – H (monitoring reports for previous quarter have already been shared).

4.2.3. EMS: ISO 14001 and OHSAS: 18001 Certifications and Hazardous Waste Management

KE while improving upon its environmental management systems was successful in acquiring EMS ISO 14001:2004 certifications for two of its generation plants in the FY 2013 – 14 (Certificates attached as Annex – I). Therefore, now, all of KE’s generation plants are ISO 14001 certified, which resonate company’s resolve to pursue its business operations in an environmentally friendly manner.

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In addition, during the reporting period, one of KE’s generation plant ( Town Gas Turbine Power Station) got its OHSAS 18001:2007 certification. Another generation plant (Korangi Combine Cycle Power Plant) renewed its OHSAS 18001 certification. Thus, all of KE’s generation plants are OHSAS 18001 certified by the end of FY 2013 – 14.

The overview of KE’s ISO 14001 and OHSAS 18001 certifications is presented below;

Certification Date SNo Plant Name ISO 14001 OHSAS 18001 1260 MW Bin Qasim Power 1 (BQPS-I) 26th Aug, 2013 28th Nov, 2011 Station 560 MW Bin Qasim Combine (BQCCPP- 2 05th Aug, 2012 22nd Oct, 2012 Cycle Power Plant BQPS-II) 25th July 2010 and 220 MW Korangi Combine 3 (KCCPP) 2th Oct, 2012 26th July 2013 Cycle Power Plant (Renewal) 90 MW GE JB Gas Engines 4 Gas Turbine (KTGTPS) 30th Sept, 2012 27th Nov, 2013 Power Station 90 MW GE JB Gas Engines 5 SITE Gas Turbine Power (SGTPS) 31st Dec, 2013 30th Sept, 2012 Station Table: 4 – Overview of KE’s Generation Plants ISO 14001 and OHSAS 18001 certifications

Moreover, KE as per the findings of an independently carried out Environmental, Health and Safety audit (2010) of its Transmission and Distribution assets has rolled out a ‘Hazardous Waste Management’ programme. Main features of this programme were; to identify the presence of hazardous chemicals and materials in KE’s operations, and propose corrective actions for the same. In this regard, use of Polychlorinated biphenyls (PCBs) and asbestos were found to be of primary concern. Based on these recommendations, the company has adopted a phase wise approach to address the environmental, health and safety challenges posed by PCBs and the asbestos.

Addressing PCBs issue, a representative samples of oil from 132/11 KV step-down transformers, capacitor banks and surrounding soil from eleven Grid Stations were collected for laboratory analysis to find out the presence of PCBs. As per the laboratory analysis report, only, one oil sample out of twenty samples contained PCBs traces (Summary Report attached as Annex – J). The PCB contaminated equipment was isolated

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and disposed off as per KE’s waste management procedures (attached as Annex – K). Also, to eliminate the risk of PCB contamination in future, KE has been using mineral oil – which is PCBs free oil. Furthermore, in June 2014, KE entered into a partnership with the United Nations

Development Programme (UNDP) and Picture 2: PCB Sampling for Laboratory Analysis Global Environment Facility (GEF) for a project which aims to reduce and eliminate Persistent Organic Pollutants (POPs) in Pakistan. This, international, collaboration is a testimony of KE’s endeavours vis-a-vis environmental protection.

For asbestos management, the company issued a corporate level Asbestos Management Procedure on April 1, 2014 (Procedure attached as Annex- L). This provides a set of guidelines for preparing Site Asbestos Management Plan (SAMP) and to standardise asbestos management practices across the company. Further, in order to ensure coordinated and consistent approach in asbestos management, a company-wide training was organized for more than 200 employees during the reporting period.

Similarly, KE in line with its Climate Change policy, developed and issued a corporate level management procedure for Sulphur Hexafluoride (SF6) – 23,900 times more potent

Greenhouse Gas (GHG) in comparison to Carbon Dioxide (CO2) on June 25, 2014 (attached as Annex - M). KE uses SF6 at high voltage interface between the generation and transmission systems for insulation, arc quenching and current interruption in gas- insulated switchgear and circuit breakers. By developing these management procedures, it is envisaged to establish and maintain a system for minimising the risks of releasing SF6 gas into the environment as a result of KE’s operations. Implementation on procedure has commenced and baseline records / SF6 inventories were under development by the relevant departments.

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4.2.4. Earth Day Celebrations at KE

KE, building upon its environmental initiatives, celebrated the ‘Earth Day’ in April 2014. Around 1000 trees were planted across KE’s various offices and at different tertiary level education institutions in Karachi. An awareness raising session to protect environment and natural resources was also held at BQPP – II. In addition to above mentioned environment management initiatives, following trainings were held across KE during the reporting period to promote environmental consciousness amongst the employees (Details attached as Annex – N).

1. Awareness Session on Environmental Incidents and Impacts 2. Awareness Session on EHS Audit Compliance for Distribution 3. Waste Management 4. Implementation of Environmental Management Plan 5. Awareness Session on EIA and IEE

4.2.5. Environmental Award

KE’s vision towards Environment and Sustainability, and its pursuit towards the achievement of sustainable development were recognized at the national level, when for the fifth consecutive year, KE was awarded the “10th Annual Environment Excellence Award 2013”. This award was presented by the National Forum for Environment and Health (NFEH), affiliated with the United Nations Environmental Program (UNEP) and jointly supported by the Sindh Environmental Protection Agency. The award ceremony was held on July 5, 2013 Picture 3: Environmental Excellence Award 2013 at Karachi and a total of 170 companies from the country participated.

4.3. Health and Safety

KE, under the present management since 2009, has initiated the implementation of a comprehensive Health and Safety (H&S) regime across the company. KE’s Corporate Page | 10

Health, Safety, Environment and Quality department (Corp. HSEQ) since its inception has been instrumental in deploying multipronged strategies to address H&S challenges in an organisation, where previously, the H&S culture was nonexistent. The Corp. HSEQ department has a team of 43 dedicated professionals to assist, guide and educate other departments/business units on H&S aspects. In addition, the Corp. HSEQ team has been facilitated by departmental safety coordinators.

4.3.1. Health – ‘We Care’ Programme

KE gives priority to matters related to its employees’ health and general well-being. Against this backdrop, KE initiated ‘We Care’ Programme to provide, its employees, preventive vaccination and medication against the leading causes of diseases in Pakistan. This programme, also, compliments Government of Pakistan’s immunisation drive.

KE, under its health programme, organised a medical camp in collaboration with Pfizer Limited (Pharmaceutical Company) in November 2013. 100 of company’s employees went through different medical tests during that session. Moreover, KE in April 2014 entered into an agreement with UNICEF to raise awareness of vaccines for preventable diseases. This, particular, initiative aims to disseminate a series of motivational awareness messages, about diseases such as Polio on the monthly electricity bills reaching to 2.3 million households across Karachi and some areas of Sindh and Baluchistan.

In addition, a total of 1066 vaccinations of staff and families were carried out in FY 2013 -14. Also, 349 hygiene inspections were carried out during the reporting year. This was coupled by 92 training sessions on ‘First Aid and Cardiopulmonary resuscitation (CPR)’ covering 3090

employees. These interventions Picture 4: Karachi (April 2014): Agreement Signing Ceremony for Polio Awareness Campaign resulted in 73% reduction in Hepatitis B registered cases.

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4.3.2. Safety Programme – Inspections, Trainings and Activities

KE’s safety philosophy is ‘Nobody Gets Hurt’. Primary focus, of this, is to provide safe working conditions to the employees and secure power network to the consumers. To ensure this, KE has developed an overreaching Safety Management System. Main features of SMS are;

- Safety Trainings for the employees, - Using Personal Protective Equipments (PPEs), - Promoting the ownership of safety responsibilities and accountabilities at all management levels through Annual Performance Appraisals, safety awards/rewards and reprimand system, - Lessons learnt through formal investigations of accidents, - Regular safety audits, and - Risk management etc.

To benchmark the Safety Management Safety Trainings System, special emphasis was laid on Employees Trained Training Hours 27,732 safety trainings and awareness 22,767 programmes during the reporting 16,801 11,415 period. As a result of this around 16,801 employees went through

different safety trainings for 27,732 2012-13 2013-14 training hours on a whole spectrum of Graph 3: Safety Trainings FY 2012-13 vs FY 2013-14 topics related to H&S. As compared to last year, FY 2013 – 14 witnessed an increase in safety training regime.

In this regard, to align company’s safety drive with internationally accepted best practices, KE celebrated ‘World Safety Day’ on April 28, 2014. To mark and highlight the significance of safety practices in work space, weeklong activities across the company were carried out. This includes, awareness raising sessions on safety topics, safety parades and distribution of Pamphlets containing safety messages against electrical risks and protection against field hazards.

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Moreover, the Corp. HSEQ team along with its safety coordinators carried around 1,029 safety inspections in FY 2013 - 14 of KE’s installations, establishments and assets across the city of Karachi. The aim of these safety surveys and inspections was to map and check nonconformity of different departments against company’s HSEQ policy and applicable national and/or international regulations/standards. Timely actions were taken to address and rectify the points/observations raised through these inspection reports (A Safety Inspection Report is attached as Annex – O).

Reinforcing safety culture, KE’s business units and departments were apprised on the usefulness of incorporating safety initiatives like near miss reporting, tool box talks, evacuation drills, job specific trainings, internal audits and safety walks into their daily official operations and functions. As a result, to illustrate, T&D department carried

323,539 tool box talks and 43,926 safety walks during the reporting period.

As a result of these actions, KE’s 90 Megawatts (MW) Korangi Town Gas Turbine Power Station acquired its OHSAS 18001:2007 certification on November 27, 2013. Another Power Plant (220 MW Korangi Combine Cycle Power Plant) got its renewal certificate of OHSAS 18001 on July 26, 2013 (Refer Table – 4). Thus by the end of FY 2013 – 14, all of the five generation plants were OHSAS 18001 certificated which underpins company’s thorough H&S regime.

The steps taken to improve safe working conditions at KE resulted in the reduction of employee accidents by 32 percent while public accidents reduced by 67 percent as compared to the previous year. Although, KE has been able to demonstrate improvement on its health and safety portfolio, nevertheless the company appreciates the room for further improvement. Therefore, KE has rolled out different initiatives to improve its safety performance.

4.3.3. Safety Improvement Initiatives

Learning from incidents and accidents by carrying root cause analysis and investigations is important for improving operations and business procedures. Therefore, KE has rolled out various safety improvement initiatives to address the gaps and refine company’s existing safety procedures.

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 ‘Safe Card’ - Hazard Reporting: KE is the first and only power utility in Pakistan to offer a 24/7 on-line reporting medium to its customers and general public to raise safety and electric hazards alarms/reports (http://www.safecard.kesc.com.pk/bill/safecard.aspx). During FY 2013 – 14, KE received 546 ‘Safe Card’ alarms/reports on safety hazards like broken conductors, tilted poles, exposed cables, tree branches touching conductors etc. The analysis of the observed trend is given in Graph: 4. Graph 4: Safe Card trend analysis 59 percent observations were addressed and closed within three hours of their reporting. 82 percent reduction in public accidents was noticed during FY 2013-14 compared to the FY 2010 – 11: the launch year of ‘Safe Card’ reporting system. This reflects ‘Safe Card’ effectiveness to improve company’s systems’ safety. This initiative, also, reflects on KE’s openness to take a step further in improving its safety performance by engaging with the stakeholders (consumers and general public).

Picture 5: Before and After – Pillar Box

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 PMT & Pole Grounding: As a part of public safety enhancement, during FY 2013 -14, a total of 1,145 Pole Mounted Transformers (PMTs), 213 Substation and 26 Ring Main Units were grounded. The campaign was, specially, targeted to congested low income areas prone to accidents. This initiative has also contributed in improving company’s safety performance.

 Promoting the use of PPEs: Considering the safety of employees, KE is continuously increasing its focus on the use of PPEs. Company Employees and OSP (third Party employees), as per policy, need to wear proper PPE before executing their job on site. In this regard, the company ensured to provide standardized personal protective equipment to its employees by spending Rs. 37 million on PPEs in FY 2013-14. Violators go through strict disciplinary action.

4.3.4. Recognition of KE’s Occupational Health and Safety Regime – Awards

For the third year running, KE in December 2013 was awarded the National Fire and Safety Award for having an effective Fire and Safety Management System. The award was an acknowledgement of the progress made by KE in promoting and implementing “Fire Safety” initiatives throughout the organisation. The award was jointly sponsored by the National Forum for Environment and Health (NFEH) which is supported by the United Nations Environmental Program (UNEP) and Fire Protection Association of Pakistan (FPAP), a member of the Confederation of Fire Protection Associations International (CFPA-I) and CFPA-Asia.

Moreover, the Employers Federation of Pakistan (EFP) in collaboration with International Labour Organisation (ILO) awarded KE the ‘Third Prize’ in the category of Oil, Gas and Energy, at its Ninth Occupational Health, Safety and Environment Award ceremony held in April 2014. This prestigious award has been won for the first time by KE. This award is a recognition of the company’s best safety practices for its employees’ and its management’s commitment for continual improvement in the field of Occupational Health, Safety & Environment (OHS&E).

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4.4. Corporate Social Responsibility

The concept of Corporate Social Responsibility (CSR) is based on the notion that society and businesses are mutually dependent. KE appreciates this and has been playing its part to give back to the society through incorporation of ethical, social and environmental values in its systems and operations. Main focus of KE’s CSR activities during FY 2013 – 14, was to strengthen projects/institutions that were delivering social and health care services to the vulnerable people (especially women and children) / low income groups in the city of Karachi. Under its CSR programme, the company during the reporting period, signed five Memorandum of Understandings (MoUs) with the following social and health care institutions;

a) The Kidney Centre, Karachi: The Kidney Centre provides renal care, mainly, to the poor patients for free or minimal charges. Since the center is providing necessary medical care to the vulnerable segments of the society, KE in September 2013 signed an MoU with the

Kidney Center to share the costs of its electricity expenses. b) Behbud Association – Karachi: KE, in December 2013, signed another MoU under its CSR programme with ‘Behbud Association’ to provide free of cost electricity to the charitable organization providing multi-faceted services to the needy and underprivileged sections of society particularly women and children since 1970. Behbud Association runs programmes that are focused on community development through an integrated approach so as to alleviate poverty, illiteracy, ill-health and economic deprivation of the lower-income groups. Their projects reached close to 125,000 people in the last year while indirectly

benefiting to over a million people. c) Bait-ul-Sukoon Cancer Hospital: KE in January 2014 signed an MoU with Bait-ul-Sukoon Cancer Hospital to provide free electricity for the benefit of its patients. The 50-bed benevolent institution provides complete treatment, laboratory assistance, medicines and lodging facilities to all its patients without any charges. The hospital treats over 5,000

patients a year. d) SOS Children’s Villages, Karachi: SOS village is a children’s orphanage, working in Karachi since 1987. It reaches out to over 8,000 children a year. KE, through an MoU has pledged

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free electricity to the village to facilitate the organisation working for the vulnerable and orphan children. e) Lady Dufferin Hospital, Karachi: The Lady Dufferin Hospital serves over 90,000 patients, especially women, per year providing services at subsidized rates. KE in second quarter of 2014 partnered with the hospital to share the costs of its electricity expenses.

In addition, KE ensured provision of uninterrupted supply of electricity to 23 major hospitals and educational institutions in the city. KE provided free of cost feeders and PMTs along with the system enhancements required to allow smooth running of the operations. Provision of generators was also ensured where uninterrupted power is not feasible due to system limitations. Main beneficiaries that received system upgrades include: • Indus Hospital, Karachi • Sindh Institute of Urology and Transplantation, Karachi • Edhi Foundation, Karachi • Karachi Institute of Heart Diseases • The Hub School Thus on the back of these initiatives, KE’s endorsements amounting to Pak Rs. 34 million reached out to over 7 million individuals during the reporting period.

In addition, KE during FY 2013 - 14 sponsored the National Academy of Performing Arts’ International Theatre Festival and the All Pakistan Music Conference at Karachi. The company has also been in constant contact with the Heritage Foundation of Karachi City and Karachi Metropolitan Corporation to work towards a trilateral mechanism where the focus was to preserve and uplift key heritage sites throughout the city of Karachi.

Apart from helping and assisting different organisations, KE has been encouraging its employees to volunteer for different community support initiatives and career counselling programmes. In this regard, over 2,000 hours have been volunteered over the reporting period.

Recognising KE’s CSR endeavors, National Forum for Environment and Health (NFEH) awarded the ‘National Corporate Social Responsibility Award 2014’ to the company on

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February 20, 2014. Also, in April 2014, the volunteerism activities of KE’s employees were recognized by INJAZ Pakistan. INJAZ Pakistan is a member of Junior Achievement Worldwide, the world’s largest non-profit business education organization.

4.5. Energy Conservation Initiatives

KE, against the backdrop of Changing climate and rising power demand, has initiated a pragmatic energy conservation drive. The aim is to engage with different tiers of stakeholders coming from varied socio-economical backgrounds to raise awareness and demonstrate tangible energy conservation solutions. In this regard, KE during the reporting period has been;

 Facilitating industrial and large scale commercial customers to adapt energy efficient operations,  Pursuing power factor improvement projects, and  Carrying out energy audits and suggesting energy conservation solutions.

As a result of these initiatives particularly the power factor improvement initiative and energy audits, KE has contributed to the reduction of around 57,739 Metric Tons of carbon emissions and saving of approximately Pak Rs. 1 billion (distributed amongst different stakeholders). Detailed list of energy conservation activities, involving various stakeholders and community members that were carried out during FY2013 – 14 is attached as Annex – P.

KE’s role in promoting and contributing to energy conservation was appreciated at a national energy leaders’ summit in May 2014. Wherein, KE was awarded the Energy Leaders Award 2014 by the National Forum for Environment and Health (NFEH) in collaboration with Government of Sindh, Federation of Pakistan Chambers of Commerce and Industry (FPCCI) and Karachi Chamber of Commerce and Industry (KCCI).

4.6. New and Renewable Energy Projects

KE has initiated different projects during the reporting period with the aim to increase its generation capacity, diversify its generation portfolio, sourcing cheap electricity for the

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consumers and reducing its environmental footprint by venturing into the renewable sources of energy production. The highlight of such initiatives/projects is;

4.6.1. Coal Conversion Project:

KE is in the process of converting two of its units (2 x 210 MW) of its 1260 MW BQPS-1 (6 X 210 MW) into coal in a phased approach. For this purpose, KE has an agreement with Bright Eagle Enterprises Group and Investments Limited (BEEGIL) to develop the Project under an IPP structure. BEEGIL has already formed the local project company/IPP by the name of ‘K-Energy’.

KE has already received approval on its Licensee Proposed Modification (LPM) from NEPRA – Government’s Regulatory body, as it will be leasing out its two units to K-Energy. K-Energy, while, will be responsible for the construction of new boilers and ancillaries and coal handling equipment (that shall be connected to KE’s existing units after their overhaul). It is important to mention that K-Energy submitted an EIA report to Sindh Environmental Protection Agency and acquired NOC for the project during the reporting period.

4.6.2. Biogas Project

KE and the Aman Foundation have signed a Joint Development Agreement with the International Finance Corporation (IFC) for the co-development of Karachi Bio Waste to Energy Project (KOEL) in the vicinity of the Landhi (LCC). KOEL has been brought on its footing to drive the project forward. KOEL has engaged an international firm ARUP to conduct feedstock survey and waste logistics study. Moreover, the company is engaged in the process of hiring consultants for technical design and other ancillary studies.

4.6.3. Solid Waste to Energy Project:

KE is working on an opportunity to develop a ‘Waste to Energy’ power plant based on bio- combustible waste being produced in one of the largest urban cities of the world, Karachi. It is estimated that, Karachi generates more than 10,000 tons of solid waste per day and less than 50 percent is disposed off to land fill sites. Municipal Solid waste is an environmental hazard and a social problem in Karachi. This environmental liability Page | 19

however has great potential to generate electricity through combustion of municipal solid waste if it can be collected and processed. KE has sent an RFP to relevant consultants for waste categorization study. KE is currently in the process of evaluating consultants’ proposals and identifying suitable piece of land for the project.

4.6.4. Wind Power Projects

KE’s licensed area strategically overlaps Gharo’s wind corridor. In order to meet its Climate Change policy goals and diversify its energy mix, KE has been discussing the prospects of the development of green field wind projects with reputable foreign parties. In this regard, initial project teasers and financial models have been shared with the potential investors and developers.

In addition, Burj Power Limited (BPL) is developing two wind projects in the vicinity of KE’s licensed area. KE has provided a Letter of Intent (LOI) to Burj Power expressing KE’s desire to enter into an Energy Purchase Agreement (EPA) for off take of power from the 10 MW project in Gharo. Burj is currently in the process of conducting project studies and negotiating with EPC Contractor.

4.6.5. Hydro Power Projects

KE has been working on the prospects of adding hydel based power to its overall generation. In this regard, the company has signed two MoUs with Laraib Group (LG) to procure affordable power from Azad Pattan project and Ashkot hydropower project, which are currently in development phase.

4.6.6. Solar Power Project

KE is actively engaged in seeking out potential partners and sponsors to promote the development, construction, operation and maintenance of solar power plants within its franchise area. KE is actively working upon an on-grid solar power option of approximately 30MW Photovoltaic (PV) power project located within the KE’s franchise area. KE is in discussions with reputable international solar PV manufacturers and developers to set up solar IPPS in KE’s licensed area and have issued two LOIs for setting up 10 MW solar-based IPP. KE is also facilitating prospective IPPs in identifying suitable land for the project.

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4.7. Stakeholders Engagement

KE being a socially responsible corporate entity has laid special focus on stakeholder engagement. For this, the company has unveiled different initiatives and programmes. Disclosure of company’s activities is an important parameter of stakeholders’ engagement process. As a result, KE has been regularly sharing information regarding its business performance, environmental, social initiatives and CSR programme through various mediums like internet, mobile phones and publication of various corporate reports which comply with various local and international frameworks. This includes;

 Annual Reports: In compliance with the Security Exchange Commission of Pakistan, the Code of Corporate Governance and different Accounting Bodies.  GRI Sustainability Reports: GRI’s Self Reporting Standards under the G3.1 Standards, having received Level “A” rating for KE’s submission in 2012. Having committed to releasing an updated report in 2014, preparation are well under way with data collection and compliance checks.  Annual Monitoring Reports (Social and Environmental): Periodic updates were provided to various stakeholder including investors, governmental and corporate bodies.

Openness and transparency have been the hallmark of KE’s stakeholders’ engagement programme that has played an effective and pivotal role in bridging communication gaps. KE published 12 monthly editions of ‘AZM’ – internal newsletter and 4 quarterly editions of ‘UMEED’ – external stakeholders. Estimated 3.5 million external stakeholders have been reached through UMEED newsletter, sharing company’s various business related activities during the period.

KE has provided different means to the consumers and stakeholders to get in touch with it on issues and matters relevant to the company. This include; KE’s website, emails, Short Messaging Service (sms), 118 – a 24/7 telephone helpline and social media. Taking advantage of these, KE proactively engages with stakeholders (including consumers) to share alerts on scheduled maintenance works, awareness material with respect to safety, hazards and energy conservation etc. Over 6 million sms were sent directly to the

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consumers over the FY 2013 - 14, addressing issues pertaining to public concern. In this regard, the option to use ‘Safe Card’ has already been discussed, above, in section 4.3. Making use of these channels, consumers (stakeholders) raised around 1.9 million observations vis-a-vis KE’s various operations during FY 2013 – 14. The breakdown of these complaints is attached as Annex – Q. The company ensured swift actions to address the issues raised through these complaints and addressed all of them.

FY 2013 -14 was important from the view that KE’s main corporate website was totally revamped to make it user friendly and approachable. As mentioned above, different options were made available to the customers and stakeholders to touch base with KE on operational and business related matters. Additionally, KE rolled out ‘I power Karachi’ campaign – an initiative for energy conservation during this year. Energy conservation department of KE spearheaded this campaign and reached out to more than 15,000 consumers through engagement activities carried out throughout the city.

In addition to this, KE has effectively used the medium of sports to connect with different segments of the society (stakeholders). Sports’ have been quite instrumental in reaching out to the marginalised community members like the people living in the slum area of - Karachi’s poor neighbourhood. The people of Lyari are famous all over Pakistan for their love of soccer (football). Capitalising on Lyari’s fondness towards football, KE in association with UNICEF and the Antinarcotics Force (ANF), Government of Pakistan organised ‘Youth Football league’ at Lyari from May 16 – 25, 2014. Collaboration with UNICEF and ANF was sorted to raise awareness on the importance of vaccination and ill- effects of drugs on people and social fibre of this community.

Similarly, KE while being an integral part of Karachi’s development, acknowledged the services and efforts of 25 individuals who have helped the city in different capacities. In this regard the ‘Pride of Karachi Awards’ ceremony was held in January 2014 wherein the services of the distinguished citizens of Karachi were not only recognised but they were given free life-time electricity benefits from the company. Mr. Abdul Sattar Edhi of Edhi Foundation was one of the award winners. His foundation is running the highest number of ambulances outside the public sector in the world. This event also underpins the efforts put-in by the company to reach out to the stakeholders.

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Not to overlook company’s own employees, KE organised a family fun gala for all of its employees in the reporting year. The two day event which included free games, food and entertainment provided a casual opportunity to the employees to come together and interact outside formal office environment. Moreover, KE in FY 2013 – 14 as a part of its stakeholder engagement process has hosted a number of official visits representing various extended stakeholder groups like; Asian Development Bank, USAID, WAPDA & PEPCO and National Institute of Management.

5. Compliance with IFC Performance Standards

In the following section, KE’s HSE performance has been evaluated and reported against the backdrop of IFC Performance standards.

5.1. Social and Environmental Assessment and Management System (PS1)

5.1.1. HSE Organization, Budget and Reporting Line:

KE has an effective HSEQ Management System functioning across the company. A decentralized approach has been implemented which empower business unit of the company to plan, organise and control its HSEQ practices. At corporate level, Corporate HSEQ provides corporate level guidelines, procedures, trainings, audits, inspections and drives HSEQ systems throughout the company. The Chief HSEQ Officer reports directly to KE’s CEO on HSEQ performance and serves as a member along with all the other Business Units’ (BU) Heads in Executive HSEQ committee chaired by the CEO. Breakdown of costs incurred on social and environmental assessment and the number of employees directly related to the implementation of HSEQ management system is given below;

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S&E Assessment and Item Total of KE Management (% of the Total) Financial Capital Investment; US$ 1.21 Million (0.4%) Resources US$ 85.83 million Operating Cost; US$ 303.52 million Human Employee – Officers Number of Employees 228 Resources Male: 5,085 (1.64%) Female: 192 Total: 5,277 Employees – Staff Male: 4,960 Female: 05 Total: 4,965 Sub-total (1+2): 10,242 Contractors: 3,640 Total (3+4): 13882 Table 5: Resources Used for S&E Assessment and Management System during FY 2013-14

5.1.2. Social and Environmental Assessments:

KE in accordance with the National/Provincial environmental laws (PEPA’97/SEPA’14) conducts IEE and / or EIA of new projects in Generation, Transmission and Grid developments. The list of such projects during the reporting period is;

Submission SNo Project Name Category NoC Date 1. 132 kV Baldia Valika Transmission Line EIA 12.03.13 09.01.14 2. SGTPS Up-gradation IEE 21.11.13 24.02.14 3. KGTPS Up-gradation IEE 21.11.13 24.02.14 Extension of 220 MW Combine Cycle 4. IEE 09.01.14 24.02.14 Power Plant, Gas Engine Table 6: Details of S&E Assessment Prepared during FY 2013-14

5.1.3. S & E Internal Audits and External Risk Assessment:

Annual HSEQ audits are planned and executed under the umbrella of Safety Leaders Award (SLA) program. Each department goes through a rigorous audit exercise twice each year. Fourth “Annual Safety Leader” award ceremony was held on January 30, 2014 after 25 departments went through audit exercise. This ceremony was held to acknowledge departments H&S initiatives.

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Under this, Bin Qasim Combined Cycle Power Plant – II (BQPS-II), Region IV (Distribution), LDC Department, Engineering & Construction and Administration were declared Safety Leaders - 2013 in their respective categories, and were awarded with “Safety Trophies”, “Safety Certificates” and cash awards respectively.

To promote a safe and hygienic workplace environment across the company, “Fire Safety & Housekeeping Award” was also introduced for the first time during FY 2013 - 14. The winners of KE’s first “Fire Safety & Housekeeping Award” were “Civic Centre Building” amongst Category-I buildings (occupancy > 250 employees) and IBC – KIMZ amongst Category-II buildings (occupancy < 250 employees) for their best housekeeping and fire safety practices.

Moreover, around 1029 safety and hygiene inspections and 50 HSEQ, Safety Leader Award’s Audits were conducted covering all facilities of KE. Main objectives of these Audit / Inspections were to record un-safe acts and conditions and suggest corrective actions, raise awareness regarding the use of PPE’s and communicate finding and recommendation to the concerned managers to prevent reoccurrence.

5.1.4. S & E and Emergency Response Trainings (Employee / Contractors):

Different trade and technical trainings for the field staffs were conducted during the reporting period. In total 9,457 employees were trained through these trainings. S&E trainings to raise environmental awareness, pollution prevention and abetment, work process safety, material handling and safety management in field were imparted to the employees. Table – 7, presents the overview of company’s training regime during FY 2013 – 14.

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Month Sessions Participants Training Hours August 13 16 529 19,796 September 13 11 269 30,916 October 13 18 571 17,624 November 13 25 877 33,659 December 13 19 849 32,500 January 14 19 649 26,620 February 14 18 541 12,666 March 14 32 974 8,660 April 14 69 2,789 17,322 May 14 18 685 10,370 June 14 21 724 14,444 Grand Total 266 9,457 224,577 Table 7: Summary of Technical Training across KE

During these trainings particular focus was given to the training needs of the employees in Distribution network division. A multi-tier program for lineman, supervisors, safety coordinators and mangers was initiated to provide safe and hazard free work place. 27,732 man-hours were spent on training of more than 16,801 employees (Refer Graph: 3). KE’s HSEQ Training philosophy not only encompasses training of KE’s own employees but extends to third party workers. 59 percent of total employees trained were KE’s non- management employees while more than 36 percent of total employees were third party non-management employees.

5.1.5. S & E Performance (Sustainability Report):

As, already, mentioned above in Section 4.7, KE has published various reports that highlight company’s S&E performance. The flagship report in this regard has been KE’s last year Global Reporting Initiative (GRI) report. The company is well underway to submit the new report in next FY 2014 – 15. In addition, AMR is an annual feature of KE that encompasses company’s health, safety and environment related initiatives and achievements.

5.2. Labour and Working Conditions (PS2)

5.2.1. Internal Grievance Mechanism and Workers Issues:

Workers at KE have full statutory facilities. KE has transparent system of promotions/increments/enrichment of jobs. A sound grievance handling system like direct

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approach system prevails that consists of a team of more than 170 AZM volunteers across KE and 6 welfare officers’, area wise; this team redress the petty grievances of workers at their workplaces. There was no any involuntary retrenchment during the reporting year.

Moreover, at work all the workers are fully equipped with the safety equipments (PPEs) and uniforms. Welfare Officers are assigned to ensure hygienically prepared food is served through the canteens across KE. Due to these measures, there was no labour unrest or any formal dispute aroused during the reporting year. Summary of KE’s welfare activities for its workers during FY 2013 – 14 is;

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No. of SNo Description Employees Amount (Rs.) Facilitated Welfare Loan @ Rs.36,000/= & Rs.18,000/= per employee and 1 Welfare Loan enhanced @ Rs.48,000/= & Rs.24,000/= Per 2,513 83,328,000 employee w. e. f. 01-10-2013 respectively. Delivery Cases @ Rs.5,000/= at hospital & Rs.4,000/= for delivery 2 96 564,667 at home per case(Enhanced Rs.8000/= & 5000/= respectively). Grant of Financial Aid being Cost of Blood and Granting Full Cost 3 1 3,900 of Blood Transfused during Delivery. IOL Aid Cases @ Rs.4,125/= Per Case (One IOL) (Ceiling Enhanced 4 42 235,875 Rs.6,000/=) 5 Financial Aid Grant @ 75 % of Actual Cost of Artificial Limbs. 2 58,800 Sewing Machines delivered to widows of K-Electric employees 6 18 113,200 from KSWF. 7 Hearing Aid Cases @ Rs.7,500/= Per Case. (One pair) 1 12,000 8 Dependant's Death Cases @ Rs.2,000/= Per Case. 38 76,000 Marriage Grant Cases @ Rs15,000/= Per Case. (Enhanced 9 71 1,475,000 Rs.25,000/=) 10 Retirement Grant @ Rs.10,000/= Per Case. 229 2,290,000 11 Funeral Expenses @ Rs.20,000/= Per Case. 20 400,000 12 Widow Grant @ Rs.20,000/= Per Case. 18 360,000 Transportation of Dead Body (from Karachi to Native Places) in 13 0 0 case of Industrial Fatal Accident. Post Funeral Expenses @ Rs.50,000/= to the family of the 14 2 100,000 Deceased NMS (In case of Fatal Accident) 15 Educational Scholarship @ Rs.7,200/= per Case (Per year). 8 57,600 Immediate Cash Payment to Serious / Major Injured employee 16 due to Industrial Accident @ Rs.20,000/= Per 5 100,000 Case. Payment of monthly stipend to Pesh Imam / Moazzan of K- 17 108 1,092,000 Electric Mosque @ Rs.9,000/= & Rs.7,000/= respectively. Grant of Financial Aid for the Education of Mentally Retarded 18 Children of KE NMS @ Rs.3,000/= Per Month (Initially for 6 1 18,000 months). If an employee has borrowed House Building Loan from K-Electric and he passes away during the course of employment then the 19 0 0 Recovery of Outstanding HB Loan with interest against him may be paid from KESWF. If an employee has borrowed Welfare Loan from KESWF and he 20 expires during the course of employment, then the outstanding 2 50,880 Loan with service charges against him may be waived off. Total Rs. 90,335,922 Table 8: Labour Welfare Activities

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5.2.2. Status of Collective Bargaining Agent (CBA) In KE:

There is no binding on workers from KE to join any workers’ organization and they are free to do so. There is positive relationship between management and its staff. Friendly culture and conducive work environment has been the hall mark besides facilitating non management staff through offering variety of prospects. These opportunities not only include the compensation but scholarship to the staff’s children, medical facility for self and dependents even after retirement, opportunity to perform Hajj, welfare loan facility, subsidized food, various welfare grants, Residence and many more. These encouraging opportunities constitute industrial peace which also motivates the staff to perform their duties in true spirit and pride. There also lies strong bond and commitment to work among staff which could be gauged through the improved results of the company.

Even though post 18th Amendment in the Constitution of Islamic republic of Pakistan the legality of federally constituted unions has a question mark but the following data is being provided never the less as an approximation.

Description of Number of Name of the Organizations Member Category Members KESC Ltd. Labour Union Regular 1400 KESC Ltd. Democratic Mazdoor Union Regular 1200 KESC Ltd. Peoples Workers Union Regular 1000 KESC Ltd. United Workers Front Regular 900 KESC Ltd. Employees Power League Regular 100 KESC Employees Unity (KESUTY) Regular 300 Table 9: Summary of Staff participation in Labour Unions

The actual figures are available with the National Industrial Relations Commission (NIRC) Islamabad (post 18th Amendment, the question of the legality of NIRC is pending adjudication in Superior Courts) otherwise every union submits its membership in thousands and if it is calculated then it comes to manifolds than the actual strength of KE’s employees.

5.2.3. National Laws and Workers Organizations:

KE was in compliance with the National Labour laws and industrial relation ordinances / Acts during the reporting period.

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5.2.4. Involuntary Retrenchment:

No involuntary retrenchment was made during the reporting period in the FY 2013 -14.

5.2.5. Child Labour and Forced Labour Requirements:

No child / forced labour exist in KE. Minimum age of employment at KE is 18 years or above. Company’s HR directives are clear on this.

5.2.6. Occupational Health and Safety Performance of the Company:

KE’s safety performance during FY 2013 -14 was;

Indicator FY 2013 - 14 Total Number of Workforce A 5,127 Total Number of Man-Hour Worked B 12,796,992 Total Number of Fatalities C 2 Total Number of Lost Time Accidents D 12 Total Lost Time Accidents (Man-Day) E 802 Lost Day Rate (E*200,0001) / B 12.53 Fatality Rate (C*200,0001) / B 0.031 Table 10: KE’s safety performance during FY 2013 -14 1Factor 200,000 is derived from 50 working weeks @ 40 hours per 100 employees based on OHSA and GRI practices of rate calculations.

5.2.7. Descriptions of Accidents (Including Fatal Accidents):

KE safety management system been driven by a continual improvement philosophy has shown the results, where employee’s accidents have reduced by 32 percent during FY 2013 -14 as compared to the previous year.

With regard to KE’s employees, in total fourteen (14) incidents were recorded during the reporting period. Out of which two (02) were fatal, eight (08) were major, four (04) were minor. Short description of incidents is attached as Annex - R. The families of the two deceased KE’s employees were paid insurance of Pak Rs. 500,000/- each as per company’s policy. In addition, the families of the deceased employees were paid Pak Rs. 20,000/- each for funeral expenses and Pak Rs. 50,000/- each for post funeral expenses. Also there was one fatality of a third party contract staff. His family was paid Pak. Rs. 400,000/- as per KE’s insurance policy for third party workers.

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Accidents KE (Staff & 3rd Party)

FY 2012-13 FY 2013-14 34

23

13 9 10 9 7 5 3 1

Fatal Major Minor Asset Total

Graph 5: Accidents KE Staff (Non Management) and OSP (Third Party)

5.3. Pollution Prevention and Abatement (PS3)

5.3.1. Environmental Compliance, Accidental release of pollutants, Violations notices, Penalties and Fines:

KE’s operations (including its five generation plants) were in compliance with the National Environmental Quality standards (NEQS). No fine, penalty was enforced on the company during the reporting period. Additionally, KE regularly (as per agreed reporting commitments) share its emissions and effluent monitoring results with the Sindh Environment Protection Agency.

5.3.2. Waste Management:

A Waste Disposal department functions at KE that is responsible to collect and dispose-off wastes generated at different business units / locations. A scrap yard at , Karachi is a central place for waste collection. The scrap accumulated there has mostly been recycled / reused by auctioning it. The summary of disposed-off waste in FY 2013-14 is provided below (Refer Table – 11).

In addition, oil used in transformers was recycled at KE’s indigenous transformer workshop. This workshop also reclaims different parts from the transformers that were not useable.

Furthermore, the ‘Reduce, Reuse and Recycle’ practices have been incorporated as part of EMS: ISO-14001 system implemented at KE’s Generation Plants. Engineering solutions and best maintenance practices have been explored and implemented to minimize the waste.

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Disposal Quantities/Units for the year FY 2013-14 Scrap LT Transformers (Distribution) 52 Nos Old Vehicles 52 Nos Scrap Meters 122 Tons Scrap Copper Conductor/Wire 234 Tons Scrap Aluminium Cable 170 Tons Scrap Aluminium Conductor 120 Tons Used Tyres 275 Nos Used Tubes 300 Nos Scrap Iron 866 Tons Scrap Batteries 662 Nos Used Oil 90,583 Litres Scrap Plastic Drums 240 Nos Scrap Wood 218 Tons Scrap Empty Steel Drums 889 Nos Scrap Copper Cable 147 Tons Scrap Waste Paper 108 Tons Scrap 132 KVA Air Circuit Breaker 25 Tons Table 11: Summary of waste management by the company during the reporting period

5.3.3. Emergency Preparedness and Response Plans:

KE’s approach towards emergency management is decentralized where each department is responsible for Emergency Planning adequate to its area of business operation. At local level, Emergency Response Teams (ERTs) mechanism was put in place to respond to building emergencies.

Emergency Response Teams are trained in handling all kind of isolated emergencies like fire and earthquake through formal training programs and regular refreshers. Periodic drills were arranged at all KE locations (at least twice per year) and drill record was maintained. Each location has its own Emergency Response Plan which acts as guidance document.

Catering to disaster level emergencies which require a corporate level action, a Disaster Management Procedure dated May 3, 2013 has been issued which provides KE’s Disaster Management Organization, formation of Disaster Control Centre, outlines responsibilities and steps to be taken in case of emergency. KE’s Head Office, being the central hub of company’s communication, command and control centre and equipment (SCADA, Telecom & LDC) remains under 24/7 monitoring of Corporate HSEQ’s fire safety team.

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5.3.4. Energy Efficiency and GHG Emissions Performance:

KE’s CO2 emission factor (emission factor is emission intensity in g/kWhr) has decreased from 627.98 g/kWhr (FY 2010 - 11) to 547.36 g/kWhr (FY 2013 - 14) which is a decrease of 13 percent. Whereas, KE's generation efficiency has increased from 33.5 percent (FY 2010-11) to 37 percent (FY 2013-14) with the introduction of new efficient generation plants and rehabilitation of old plants. Overall efficiency has increased by 3.5 percent

(FY2010-11 vs FY 2013-14) which is the primary reason of reduction in CO2 emission

factor. Total CO2 emissions have decrease by 3 percent (FY 2010-11 vs FY 2013-14) although the power generation has increased by 11 percent over the same period (FY 2010-11 vs FY 2013-14).

Generation Efficiency Vs CO2 Emission Intensity

Generation Efficiency CO2 Emissions Intensity

640.00 627.98 38.00% 37.00% 36.70% 620.00 37.00% 599.09

600.00 36.00%

34.40% 580.00 562.54 35.00% 560.00 33.50% 547.36 34.00%

540.00 33.00% Efficiency (%) Emission Emission (g/kWhr)Rate

2

CO 520.00 32.00%

500.00 31.00% FY 2011 FY 2012 FY 2013 FY 2014

Graph 6: Generation Efficiency Vs CO2 Emission Intensity

This reduction was primarily due to the addition of new and efficient combine cycle power plants (220 MW Korangi and 560 MW Bin Qasim Power Plants, total generation capacity 780 MW). Also the replacement of old gas turbines with new and efficient 180 MW GE Jenbacher Gas Engines at twin Korangi Town (90 MW) and SITE (90 MW) Power Plants, resulted in improving the efficiency.

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Natural Gas Furnace Oil

FY 2013-14 57226 20115

FY 2012-13 53140 23748

FY 2011-12 54490 22651

FY 2010-11 49591 27552

0 10000 20000 30000 40000 50000 60000 70000 Fuel Consumed in Tera Joules

Graph 7: Generation Fuel Mix

Secondary reasons include preference to the use of gas and minimizing the use of furnace oil. Oil has approx 28 percent greater CO2 emission factor. During FY 2012-13, KE faced gas supply decline, due to which a slight increase in the use of furnace oil was observed. However owing to the fact that highly efficient, 560 MW BQCCP was commissioned, efficient use of available gas allowed KE not only to maintain, but improve environmental performance of its generation plants. Over the past four years, use of furnace oil has reduced by 28 percent (FY 2010-11 vs FY 2013-14) whereas preference has been given to natural gas whose consumption went up by 15 percent (FY 2010-11 vs FY 2013-14).

CO2 Emission Vs Net Generation

CO2Emissions (Million Tons) Net Generation (TWh)

4.95 4.91 8.50 4.90 8.05 8.00 7.90 4.85 4.81 4.82 4.80 4.77 7.50 7.39 4.75 7.24 TWhr

Million Million Tons 7.00 4.70 4.65 6.50 FY 2010-11 FY 2011-12 FY 2012-13 FY 2013-14

Graph 8: CO2 Emission Vs Net Generation

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Although overall fuel consumption has increased only by 0.26 percent (FY 2011 vs FY 2014), energy produced by KE has increase by 11 percent (FY 2011 vs FY 2014). On the

whole, KE’s total CO2 emission have decreased from 4.91 million tons annual to 4.71 million tons, despite the energy generated has increase from 7.24 TWh to 8.05 TWh.

Item Formula Unit FY 2013 - 14 KE Thermal Power Station – Fuel

Consumption Natural Gas – HHV A TJ 63,584 Natural Gas – LHV B TJ 57,226 Furnace Oil – HHV C TJ 21,173 Furnace Oil – LHV D TJ 20,115 Total - HHV E = A + C TJ 84,757 Total - LHV F = B + D TJ 77,340 KE Thermal Power Station – Electricity

Generation Gross Generation G GWh 8,709 Auxiliary Consumption H GWh 660 Net Generation I = G – H GWh 8,050 KE Thermal Power Station – Generation

Efficiency J = G/(Ex0.278) KE Generation Efficiency, HHV, Gross % 37.0 x100 K = I/(E x KE Generation Efficiency, HHV, Net % 34.2 0.278)x100 L = G/(F x KE Generation Efficiency, LHV, Gross % 40.5 0.278)x100 M = I/(F x KE Generation Efficiency, LHV, Net % 37.4 0.278)x100 CO2 Emissions Factor – Natural Gas, LHV N = 56,100 kgCO2/TJ basis CO2 Emissions Factor – Furnace Oil, LHV O = 77,400 kgCO2/TJ basis P = KE Generation: CO2 Emissions tCO2 4,767,230 (BxN+DxO)/1,000 KE Generation: CO2 Emissions Rate, Q = P/G gCO2/kWh 547 Gross Table 12: Energy Efficiency and GHG Performance of KE for FY 2013-14

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5.3.5. Air Emissions Performance of the Company:

Summary of Air Emissions Performance of KE during the reporting period 2013-14:

: D *

Plant Name (%) kWh): Content of Fuel Oil Gas Consumed kWh): E = D / A NOx Emissions Fuel Oil Consumed Installed CapacityInstalled (MW) Sulfur SOx EmissionsSOx (ton SO2): B NOx Emission Rate (gNOx / Gross Generation (GWh): A SOx EmissionsSOx Rate (gSO2 / BQPS-I 1,260 3,765 19,348,567 20,068,334 3% 29845 7.9 3,379 0.90 KTGPS 88 393 3,724,225 - - - - 138 0.35 SGTPS 88 113 1,084,746 - - - - 19 0.17 Korangi CCPP 220 799 6,821,840 - - - - 115 0.14 BQCCPP (BQPS-II) 560 3,639 29,286,760 - - - - 236 0.06 KE Total 2,381 8,709 60,266,140 20,068,334 3% 29845 3.4 3,887 0.45 Table 12: Air Emission Performance of KE for FY 2013-14 *NOx emissions have been best estimated by theoretical calculation based on Average NOx Emission (mg/Nm3), Air to Fuel Ratio (AFR=20), Fuel Consumed, Energy Produced and Calorific Value of Fuel.

Air Emissions Performance of KE – Yearly Performance:

SO2 and NOx Intensities

SO2 Emission Intensity NOx Emission Intensity

5.0 4.3 4.5 4.1 4.0 3.4 3.5

3.0 2.5

g/kWh 2.0 1.5 0.77 1.0 0.58 0.45 0.5 0.0 FY 2011-12 FY 2012-13 FY 2013-14

Graph 9: SO2 and NOx Intensities

SO2 emissions reduced by 21 percent during FY 2013 – 14 as compared to last year due the use of natural gas. Previously furnace oil with high sulphur content (3 percent) was

being used resulting in slightly higher SO2 emissions.

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KE’s new, state of art and efficient combine cycle and gas engine power plants are equipped with necessary NOx reduction technologies and therefore have reduced NOx emission intensity by 42 percent (FY 2011-12 vs FY 2013-14).

Total SO2 and NOx Emissions

Total SO2 Emissions Total NOx Emissions

40,000 34,444 35,240 35,000 29,845 30,000 25,000

20,000 tons 15,000 10,000 5,202 4,933 3,887 5,000 - FY 2011-12 FY 2012-13 FY 2013-14

Graph 10: Total SO2 and NOx Emissions

On the whole KE’s total SO2 and NOx emission have reduced by 13 percent and 25 percent (FY 2011-12 vs FY 2013-14) respectively.

5.4. Community Health, Safety and Security (PS4)

5.4.1. Local Population Disruption

There was no such activity during the reporting period that has caused local population disruption.

5.4.2. General Public Injuries and Fatalities:

The company witnessed 67 percent reduction in Public accidents as compared to the previous year; six public fatalities were reported during FY 2013 - 14. Three of these accidents were due to illegal hook connections; two were due to coming in contact with broken wire whereas one was due to leakage current in LT pole. KE has initiated various corrective measures to ensure its employees and public safety, discussed above in section 4.3.2.1.

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Pulic Fatal Accidents

Pulic Fatal Accidents 30

18

6

FY 2011-12 FY 2012-13 FY 2013-14

Graph 11: Public Fatal Accidents

5.4.3. Emergency Preparedness, Response Plans and Community Participation: KE has established emergency preparedness and response plan at its facilities and business operation centre. Emergency evacuation drills were conducted on regular basis at KE’s business units and facilities.

5.5. Land Acquisition and Involuntary Resettlement (PS5)

No Involuntary Resettlement took place for the purpose of land acquisition for KE during the reporting period.

5.6. Biodiversity Conservation and Natural Resource Management (PS 6)

There were no projects constructed during the reporting period that resulted in ecological damage or destruction. Also no event occurred that has resulted in loss of biodiversity and harm to natural environment.

5.7. Indigenous People (PS 7)

There are no indigenous people as such in the vicinity of KE’s operations, as defined for the purpose of IFC Performance Standard 7.

5.8. Cultural Heritage (PS 8)

KE appreciates the importance of maintaining and preserving culture heritage. Company has not taken any activity that caused harm / damage to city’s cultural heritage. It is worth mentioning that KE has partnered with Karachi Metropolitan Corporation and the

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Heritage Foundation of Pakistan to work on different initiatives that aims to protect city’s architectural heritage and cultural identity.

6. Challenges and the Way Forward

KE has come a long way with respect to improving its EHSS performance. The company is meeting with the applicable EHSS regulatory parameters and no fines were incurred by KE during the reporting period. In addition, the trend of employee and public fatalities is also decreasing. That said there remain some key challenges.

a) Liquidity Crunch-Circular Debt: The total outstanding receivables of KE have mounted to over 78 billion rupees in receivables from Government and related sovereign entities (i.e. Strategic Customers, federal and provincial bodies).This has resulted in a serious liquidity crisis at KE, inhibiting company’s potential to undertake business improvement and enhancement schemes. On its part, KE remains in continuous negotiations to get at least some amount released on time to time basis. b) Gas Supply Issues: KE has repeatedly demanded from the Government of Pakistan the regular supply of gas to provide affordable electricity to its consumers. The company appreciates that the electricity produced from expensive fuel (Furnace Oil is four times higher than gas) results in electricity theft and non-payment of the electricity bills by the people. After persistent efforts, now an MoU have been signed with the Sui Southern Gas Company Limited to ensure a minimum level of uninterrupted gas supply. c) Poor Law and Order Situation: Although city’s security situation improved during the year, but still areas like Town, Korangi, Baldia, , Landhi, Lyari, SITE, Malir, Shah Faisal, Korangi etc remained as hot spots causing long delays in rectification of faults, installation of new connections & system improvement work. This can lead to any untoward accident. Therefore, KE is engaging the people from such areas/communities to win their respect and confidence to work in their areas for systems’ improvement. d) Theft and Illegal Connections: Theft of extra high tension overhead conductors’ wires and cable leads from substations, especially in rural and coastal areas is not only illegal

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but also a life hazard. In addition, people in low income areas restore to take illegal connections. These practices make them vulnerable and expose them to electrical hazards. Cognizant of this, KE has initiated a public awareness campaign to educate masses about the dangers involved in stealing company’s assets. e) Employees’ Mindset: KE has a comprehensive reward and reprimand policy vis-a-vis the use of PPEs and adhering to the laid down safety procedures. Nevertheless, keeping in view the educational background of company’s Non Management Staff (NMS) and the overall non-existent safety culture prevailing in the society, casualness on part of NMS at times has been observed. To address this, company is ensuring regular refresher trainings for NMS and increasing the frequency of spot checks. In addition, considering the safety of employees, KE is continuously increasing the budget to provide world-class PPEs/SPEs to its employees. KE spend Pak Rs. 37 million on PPEs in FY 2013-14. This PPE budget has been increased to Pak Rs. 58.4 million for FY 2014-15, showing an increment of 58 percent.

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K-Electric Wins the Global Transformational Business Award for its Exceptional Performance

K-Electric (KE) has been honored with the prestigious FT/IFC Transformational Business Award for exceptional achievement in Project Finance – Energy. KE became the only company in the energy sector to have won the international award recognizing KE’s financial achievements in the field. KE CFO, Mr. Moonis Alvi received the award at the award ceremony held at a hotel in London.

The Financial Times and IFC (a member of the World Bank Group) Transformational Business Awards, an expansion of the FT/IFC Sustainable Finance Awards highlighted innovative, commercially viable, and replicable products and services that can create long-term, transformative solutions to development needs. Such needs lie in areas such as infrastructure, energy, food, water, affordable housing and health. The awards also recognized the use of technology to empower the poor, initiatives to reverse environmental and social degradation, and efforts to promote gender diversity. The program in its first year attracted 237 entries from 214 institutions in 61 countries.

Speaking on the occasion, Mr. Alvi said, “I am greatly overwhelmed to receive this esteemed award from IFC and grateful to the jury for recognizing KE’s achievement in the energy sector. KE has come a long way from being a loss making institution to a privatized profitable venture that has become one of the most successful turnarounds in the history of Pakistan. The company transformed itself competently by not only becoming profitable but also increasing the capacity of electricity generation and establishing a more efficient electricity transmission system.”

"The winners list shows us that businesses in developing countries are driving innovation and that the private sector is increasingly focused on projects that can have a long-term impact," said IFC Executive Vice President and CEO Jin-Yong Cai. "The awards give companies a global platform to showcase their work, expand into new markets, and demonstrate that the toughest issues in developing countries can be addressed in sustainable and profitable ways.”

The award winning by KE is not something to be proud of only for KE, but for Pakistan. The award was organized by the leading international financial institutes highlighting the credibility of the recognition. Awarded on its merits as a transaction with truly transformational social, economic, environmental and corporate governance benefits, KE continues to transform Pakistan’s energy sector while positively enriching lives of over 23 million citizens of Karachi. K-Electric wins OSH&E Award 2013 - EFP

KE’s AZM towards introducing and inculcating a safe corporate culture within the organization has been appreciated and acknowledged both at national and international levels. It is a matter of great pride to announce that a renowned body like Employers Federation of Pakistan (in collaboration with ILO) has awarded 9th EFP – OSH&E award-2013 to K-Electric in the category of Oil, Gas & Energy Sector. Employers’ Federation of Pakistan (EFP) is a member of International Organization of Employers, Geneva and was established in 1950 to protect and promote employers’ interest.

Fire & Safety Award - NFEH

For the third year in a row, KE has been awarded the National “Fire and Safety Award - 2013” for demonstrating an effective Fire and Safety Management system in line with the Company’s vision. The assessment was also based on the company’s Emergency response planning, recently introduced Location Fire Safety Program & fire inspections / drills. This prestigious award is an acknowledgement of the advances made by KE in promoting and implementing “Fire Safety” initiatives throughout the organization.

National Environment Excellence Award Once again, KE’s vision towards Environment & Sustainability, contribution in the field of environment and safety and its pursuit towards the achievement of its vision of sustained development by playing its role in social and environmental aspects was recognized at national level, when for the fifth running year KE was awarded with “10th Annual Environment Excellence Award 2013” The award ceremony was held on 5th July 2013, and a total of 170 companies from across the country participated.

Action Plan – Compliance Status (April – June 2014)

January 30, 2007 Revised October 2, 2009

Action Plan by K-Electric Ltd. (Formerly: Karachi Electric Supply Company Ltd) - Environmental and Social Aspects –

Implementation No Action Verified by Compliance Status Schedule 1 Follow up on the Social and Complied Environmental Impact Assessment (SEIA), dated January 2007 for the Capacity Enhancement Project (Bin Qasim):  Present the Environmental For operational Copies of the Complied Management Plan and the Social phase EMP for (See Annexure “A1”) Management Plan with concrete operational specifications phases. 2 Prepare SEIAs and conduct consultation In accordance Copies of the Complied for new investment projects (e.g. with the Executive (Any project requiring development of new transmission lines, development Summary of the environmental study development of new grid stations) which schedule of the studies. was not initiated are subject to Pakistan EIA regulations projects during the quarter) 3 Conduct Environmental, Health and Copies of Complied Safety (EHS) Audit for the Transmission quarterly (See Annexure “B1”) and Distribution (T&D) Assets (or “EHS reports on T&D Audit”) to identify areas of Implementation concerns and propose corrective actions Status. on the following fields: A. Hazardous waste management (such as PCBs, used oil, etc.) B. Health and safety management:  Minimum clearance distance from transmission lines / high voltage equipment  Appropriate fencing, appropriate safety signs

 Reporting / awareness

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promotion C. Electromagnetic field management (e.g. compliance with ICNIRP Guidelines for occupational and general public exposure to EMF). D. Transmission lines right-of-way regulation compliance. 4 Implement recommended corrective Quarterly report Complied actions by the EHS T&D Audit on (See Annexure “B1”) implementation status to be submitted. 5 Conduct asbestos audit for existing Copies of Complied thermal power stations (except for asbestos audit Korangi Thermal Power Station of which report audit was completed and the certificate dated December 14, 2006 has been obtained by KE). 6 Implement recommended corrective actions by ECTECH’s Environmental Audit that was conducted for the generation assets in the area of ambient air quality, wastewater treatment, and noise. Actions include: A. Conduct regular monitoring of 2009 and Copy of the Complied ambient air quality around annually monitoring (See Annexure “C1”) existing thermal power stations. results to be included in the Annual Monitoring Reports B. Conduct treatment of Completion Copy of the Complied wastewater at existing thermal date: March 31, progress report. Liquid effluent power stations or send 2011. monitoring is being wastewater to a collective conducted for all treatment plant. power plants through third party (See Annexure “C1”)

7 Strengthen the Company’s Environmental, Health and Safety, and Social Management System to ensure that the Company will conduct business in accordance with IFC’s Performance Standards on Social and Environmental Sustainability (April 30, 2006). Actions proposed by KE include: A. Establishment of Health, Safety Integrated HSE Copy of the Complied and Environment (HSE) Policy Policy to be Integrated HSEQ (See Annexure “D1”) established by Policy.

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June 30, 2010 B. Preparation of HSE manuals Copy of the list Complied of HSE manuals. List of Corporate HSEQ Manuals & Procedures is attached. Corporate HSEQ Manual has been shared in earlier updates (See Annexure “E1”) C. Establishment of cultural Copies of the Complied property protection policy / policy / (See Annexure “F1”) procedures procedures. 8 Update and implement the Environmental Management Plan and Social Management Plan described in Section 7 of the Social and Environmental Impact Assessment (SEIAs) for the 220MW Korangi Capacity Enhancement Project and for the 575MW Bin Qasim Capacity Enhancement Project, including: A. Air Emissions – Bin Qasim: Stack Copies of the Complied height has been kept at 45 operational meters, Dry Low NOx Combustor phase EMP. to achieve 9 ppm (at 15%O2) on gas, and water injection to achieve 42 ppm (at 15%O2) on non-gaseous fuels. B. Thermal Effluent – Bin Qasim: Copies of the Complied Design cooling water intake operational structure to minimize phase EMP. entrainment and impingement of marine organisms including limiting the through slot velocities of the screen to less than 0.5 feet per second. C. Install wastewater treatment to Copies of the Complied ensure that liquid effluents from operational (Waste water the expansion projects will meet phase EMP and Treatment plant is the effluent limits provided in the relevant design installed and in Thermal Power: Guidelines for specifications operation at new Plants, World Bank Group used for BQPS-II) Pollution Prevention and construction of Abatement Handbook 1998 the plant. including: TSS 50 mg/l, Oil and grease 10 mg/l, Total residual chlorine 0.2 mg/l, Chromium

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(total) 0.5 mg/l, Copper 0.5 mg/l, Iron 1.0 mg/l, Zinc 1.0 mg/l, and pH 6-9.

9 Make operable the Continuous Emission CEMS Complied Monitoring System (CEMS) installed at monitoring (Third Party Bin Qasim Thermal Power Station results to be Monitoring is being included in carried out regularly) Annual Monitoring Reports 10 Prepare and implement KE’s Community Copy of the Complied Development Plan for communities completion identified in the SEIAs of the Korangi report (Ibrahim Expansion Project and Bin Qasim Expansion Project Community Development Project).

Copy of the completion Report.

List of Annexure Page Annexure Title number Annexure “A1”: Implementation Status of Environmental Management Plan for BQPS-II & KCCPP------05 Annexure “B1”: Update on Compliance Status of EHS Audit of T&D Assets------10 Annexure “C1”: Environmental Monitoring Report for Quarter April-June 2014------17 Annexure “D1”: KE’s HSEQ Policy------50 Annexure “E1”: List of Corporate HSEQ Manuals & Procedures------51 Annexure “F1”: Heritage and Culture Protection Policy------52

Saeed-ur-Rehman GM – Performance Evaluation & QA Corporate HSEQ

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Annexure “A1”

ENVIRONMENTAL MANAGEMENT PLAN DURING OPERATION PHASE

560 MW BIN QASIM, CCPP, BQPS-2

For Period Apr-June 2014

POTENTIAL STATUS REMARKS SNO MITIGATION MEASURE IMPACT Enhance more plantations across the facility, roads 1 Landscape and other open spaces, to create to some extent a Complied 13000 trees planted at site. natural landscape. Continuous water injection to be carried in gas For NOx control water injection is used turbines for NOx control. Maintain 125 mg/Nm3 at Complied Ambient Air continuously 2 15% oxygen limit. Quality Height of the stacks to be maintained at 150 Complied Height of the stack is 150, meters for enhanced dispersion of pollutants in air. Waste water treatment plant is installed at plant site. Waste water treatment to be carried out Third party monitoring of waste water is 3 Surface Water continuously and monitoring before mixing with Complied carried out on monthly basis for return sea water. independent performance analysis. Treated waste water monitoring results are below the prescribed standards Oily waste water treatment is available at Regular inspection is carried out throughout facility plant and after analysis in chemical lab as 4 Ground Water Complied for intercepting leaking and spilled liquids. per NEQS requirement it is discharged in to the sea.

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POTENTIAL STATUS REMARKS SNO MITIGATION MEASURE IMPACT Hazardous chemicals are handled in Hazardous chemicals shall be handled only in separate areas. appropriate segregated, sealed and bundled areas Complied MSDS are available for all chemicals at site. with trained personals at site. Besides safety instructions and CoSHH assessments are available at all dosing skids Record of scrap disposed is maintained Separate Bins are available at plant for All solid wastes shall be disposed off according to a disposal. The scrap then transfer in to the set procedure and all relevant records of sales will Complied scrap yard where it will be kept separately. be kept to track at any time when it is required. Facility has also implemented 3R concept to minimize the waste generation. 5 Solid Waste The contractors to whom any waste is to be sold Electronic cards, batteries when scraped, it shall be fully made aware of the environmental is clearly mention on SDF (Scrap Disposal impacts and health effects of the waste to be sold form) that such items shall be disposed off Complied to him. He shall be provided instructions for reuse / in an environment friendly way. The SDF handling of such wastes in environmentally then sent to disposal department for sustainable way. further action.

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POTENTIAL STATUS REMARKS SNO MITIGATION MEASURE IMPACT Dry deposition has been assessed as low impact environmental parameter in SEIA of project. Air dispersion modeling for stack emission was carried out for the plant and maximum values were found to be well below World Bank Guidelines. Dispersion calculation for stack emissions should Moreover monthly stack and ambient air 6 Soil Complied likewise consider dry deposition of NOx monitoring is being performed. Stack emissions are well below the NEQS limits. Ambient air NOx is below detectable limits. If ambient air NOx is found on the higher side in our regular monitoring, soil monitoring and modeling would be considered. All high noise areas are properly identified and marked with sign boards. Hearing Equipment will be acoustically shielded as far as Complied protection is mandatory while working at possible. high noise areas. Gas turbines, chillers, steam turbines are shielded. A noise measurement campaign during full 7 Noise Monitoring of noise is incorporate in operation at operation start should be Complied Preventive Maintenance Plan. Third party implemented to verify the real noise levels are in also measures the noise around the plant line with NEQS. Workers should be obliged to carry ear protection It is mandatory and mentioned on permit to in areas within the plant and for specific work that Complied use PPE’s where applicable. exceed the tolerable maximum noise values.

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ENVIRONMENTAL MANAGEMENT PLAN DURING OPERATION PHASE

220 MW KORANGI COMBINED CYCLE POWER PLANT

For Period Apr-June 2014

POTENTIAL SNO MITIGATION MEASURE STATUS REMARKS IMPACT In front of Management office green belt is Develop a green belt along the facilities boundary developed. However due to project work it 1 Landscape area and other open spaces, to create to some Complied is not possible to develop inside plant extent a natural landscape. premises Continuous water injection to be carried in gas Complied yes Ambient Air turbines for NOx control. 2 Quality Height of the stacks to be maintained at 25 meters Complied 25 m for enhanced dispersion of pollutants. Yes water treatment is carried out Waste water treatment to be carried out fortnightly by plant itself. Besides through 3 Surface Water continuously and monitored before mixing with Complied third party it will be carried out on monthly return sea water. basis. Regular inspection of facilities for intercepting Complied Yes leaking and spilled liquids. 4 Ground Water Hazardous chemicals shall be handled only in appropriate segregated, sealed and bundled areas Complied Yes at site. All solid wastes shall be disposed off according to a Procedure exist regarding solid waste 5 Solid Waste set procedure and record of sales will be kept to Complied management track at any time when it is required.

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POTENTIAL SNO MITIGATION MEASURE STATUS REMARKS IMPACT The contractors to whom any waste is to be sold shall be fully made aware of the environmental In SDf (scrap disposal form it is mentioned impacts and health effects of the waste to be sold that scrap to be disposed off in a Complied to him. He shall be provided instructions for reuse / environment friendly manner and send it handling of such wastes in environmentally to procurement sustainable way. Dispersion calculation for stack emissions should 6 Soil likewise consider dry deposition of NO . Complied x Equipment will be acoustically shielded as far as Complied Yes possible. A noise measurement campaign during full Noise monitoring is carried out monthly by operation at operation start should be third party and plant itself conducted on Complied 7 Noise implemented to verify the real noise levels are in yearly basis. All high noise areas are clearly line with NEQS. marked with sign boards. Workers should be obliged to carry ear protection All workers are well aware and used proper in areas within the plant and for specific work that Complied PPE’s exceed the tolerable maximum noise values.

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Annexure “B1” EHS Audit of T&D Assets (Findings and Recommended Actions)

As per point ‘3’ of IFC action plan, dated October 23, 2009, external audit was required to be undertaken. External auditors were selected, who conducted an EHS audit of our T&D assets. All stakeholders are being provided relevant audits findings for implementation of recommendations. Major findings, action required and responsibilities along with implementation schedule are enumerated below:

SNO Findings Status Actions Taken 1. Identification and On-  Oil and Soil Sampling was carried out at 11 (pre-selected) Management of PCB going grids based on pre-sampling survey through document Contaminated review. (Report Attached as “Annexure G”) Substance  Out of 61 Samples of oil and soil only one sample has PCB

Contamination (PCB Content Above 50 ppm but below 500 ppm)  PCB contaminated oil has been phased out and only mineral oil is used 2. Handling & Storage Closed  MSDS has been made available, translated & displayed of hazardous  Secondary containments have been established where substance other essential than PCB (Acid,  Awareness training with translation in is also Chemicals, cleaners, thinners, surfactants arranged & displayed in concerned areas etc) 3. Soil Contamination Closed  Trays and stands are being used at centrifuging areas to contain oil spillage  Record of contaminated spots are maintained 4. Hazardous Waste Closed  Corporate procedure for waste management has been Management issued. Procedure also covers hazardous waste management  Scrap record is maintained and waste is transferred to an isolated location and segregation is maintained. This practice is continuous 5. Non- Hazardous Closed  Record of waste disposed is maintained. Waste Management:  Scrap is transferred to a Baldia scrap yard. All the waste at Baldia scrap yard is stored with segregation.

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SNO Findings Status Actions Taken 6. Health Risks of On  Asbestos management being performed with Asbestos: going collaboration of civil & safety departments of KE

 Companywide awareness sessions were organized on hazards of asbestos and asbestos management practices. Nine sessions of two hour each, were organized covering 204 participants during 2013 (One session in Feb, One in April, Two in May, Three in June and Two in Oct)  Corporate Asbestos Management Procedure has been implemented to have consistency is management practices company-wide. Procedure Attached as “Annexure H” 7. Waste water On  Operational control of oil separation has been adopted discharge from going through practice of reuse and recycle of used oil Transformer  Environmental monitoring through third party has been workshop arranged to establish waste water treatment requirement

8. Birds & Plants Closed  Flora and Fauna is considered in environmental studies of Biodiversity the projects

 Record of bushes/herbs cutting is maintained

9. SF6 Management to On-  Release of SF6 is identified as an important area in our minimize fugitive going Climate Change Policy emissions:  All the efforts are being made to prevent leakages through

preventive maintenance of equipment  Any leakages reported are timely attended and record maintained

 SF6 management procedure has been issued in June 2014 in line with our climate change initiative to record and

manage SF6 emissions. Procedure Attached as “Annexure I” 10. CFCs Closed  No new equipment is procured containing CFCs as per (Chlorofluorocarbon) climate change policy of KE. Climate Change Policy is Management to attached as “Annexure J” minimize fugitive  Leakages are attended promptly and phase out is planned emissions for old equipment

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SNO Findings Status Actions Taken 11. EMF Management Closed  EMF Measurement is a continuous process and is part of operational activities  EMF of more than 364 equipments & lines have been measured, which include 11 kV switches, 132 kV lines , Power / Auto Transformers, 132 kV breakers, 220 kV lines, 220 kV circuit breaker  Record is maintained 12. HSE Representatives Closed  HSEQ Coordinators from each department have been of BU’s nominated

 Trainings are conducted on the regular basis for knowledge improvement and capacity enhancement  Record of TBT, Safety walk and other activities is being maintained  Roles and responsibilities have been defined in Manuals and SOPs 13. Leadership Closed  HSEQ policy is issued by CEO and Corporate HSEQ Commitment & Department is formed to provide HSEQ oversight and Accountability implementation guidance.

 HSEQ performance is continuously reviewed by leadership and timely decisions made for improvement in systems  Departmental Accident prevention plans have been prepared and reviewed by Corporate HSEQ department  Clear goal and objects for the HSEQ implementation have been established  Roles, responsibilities, authorities and accountabilities have been communicated through circulation of HSEQ manuals and policies

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SNO Findings Status Actions Taken 14. Communications Closed  Monthly meeting on the HSEQ affairs are being conducted chaired by HoDs at all levels of management  Continuous coordination with coordinators and HoDs is ensured for effective implementation of policies and procedures  Trainings are organized on regular basis for communication of policies and procedures  Incident investigation reports are wide circulated for information dissemination.  Reporting mechanism is in place for reporting of near miss and hazards.  Safety signs have been displayed in workplaces and continuously enhanced.  Record and forms are reviewed and gaps communicated 15. EHS Trainings Closed  Trainings plan is in place and trainings are being conducted round the year duly approved by HSEQ Department and recorded in line with procedure spelled out by HSEQ 16. Work Procedures / Closed  SOPs/ Work Instruction already exist and new SOPs are SOP’s being developed as and when needed 17. Ergonomics On-  Continuous efforts are being made to identify and record going ergonomic issues  Industrial Health Unit and Medical department are in process of identifying medical cases pertaining to hazardous working conditions 18. Format Preparation Closed  Logs and sheets have been implemented and are being / (Paper tools) updated accordingly  SOPs are regularly developed & updated 19. Hazard Analysis Closed  Workplace hazards are analyzed and recorded  Actions are taken to control and minimize risk  Documents are periodically reviewed for changes and enhancement 20. Safety Instructions Closed  Work Instructions are in place and reviewed periodically Preparation &  HSEQ Manual has been prepared which fulfills these Implementation requirements

 Trainings are conducted for all the staff & officers  Site inspections being performed for verifying the implementation

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SNO Findings Status Actions Taken 21. Provision of PPE’s Closed  The PPEs are procured & supplied on regular intervals as per company policy  Special Protection Equipment like live line testers for 11 KV and 132 KV have been provided for safe operation and working by staff  Proper network isolation is ensured and grounded for safe working conditions  No officer & staff are allowed to attend the site without proper PPEs 22. Emergency Closed  Emergency Plans of all the locations have been prepared Preparedness and and tested through Emergency Drills Response Plan 23. Formation of safety Closed  Formal Structure duly approved by HSEQ in place and Committees effectively operated  Departmental HSEQ Committees have been also been formed and monthly meetings are being held 24. Self Inspection and Closed  Safety walks are conducted by line managers and check Auditing sheets are used  Bi-annual systems of HSEQ audits is in place  Compliance is being recorded and monitored 25. Incident Reporting Closed  Formal occurrence reporting system is in practice and System documented and trend reviewed on monthly basis by top management 26. Approaching Closed  Vaccination by IHU is done periodically and as and when Physician needed.  Hygiene card systems for employee assessment is in place  Industrial Health Unit doctors are available 24 hours on call to provide emergency support 27. Chemical Inventories Closed  MSDS of chemicals are made available in workplace and translated in Urdu where required  Inventory of chemical is maintained as operational requirement. 28. Machine Closed  Safe guards for machines are maintained Safeguarding

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Annexure “C1” Environmental Monitoring Results

Table of Contents

BQPS-I Page # Liquid Effluent ------19 Air Quality ------20 Noise ------22 Gaseous Emission ------23

BQPS-II Liquid Effluent ------25 Air Quality ------26 Noise ------27 Gaseous Emission ------28

KCCPP Liquid Effluent ------30 Air Quality ------31 Noise ------32 Gaseous Emission ------33

KTGTPS Liquid Effluent ------35 Air Quality ------36 Noise ------37 Gaseous Emission ------38

SGTPS Liquid Effluent ------43 Air Quality ------44 Noise ------45 Gaseous Emission ------46

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BQPS-I ENVIRONMENTAL MONITORING REPORT April-June 2014

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BQPS-II ENVIRONMENTAL MONITORING REPORT April-June 2014

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KCCPP ENVIRONMENTAL MONITORING REPORT April-June 2014

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KTGTPS ENVIRONMENTAL MONITORING REPORT April-June 2014

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SGTPS ENVIRONMENTAL MONITORING REPORT April-June 2014

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Annexure “D1”

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Annexure “E1” List of Corporate HSEQ Manuals & Procedures

Document Revision Revision SNO Document Title Number # Date 1 Corporate HSEQ Manual Jul-10

HSEQ Policy KE-HSEQ 2 4 Jan-14 Policy-001 3 Emergency Response Plan – KE House KE-ERP-002 0 Aug-10 4 Accidents / Incidents, Reporting Procedure KE-SP-002 0 Jul-09 5 Safety Reward and Reprimand Procedure KE-SP-003 2 Jan-12 6 HSE Committee Procedure KE-SP-004 0 Nov-09 7 HSE Management System Audit Procedure KE-SP-005 0 Nov-09 8 HSE Risk Management Procedure KE-SP-006 0 Feb-10 9 Corporate HSEQ Training Manual KE-SP-008 0 Nov-12 10 Documents and Record Control Procedure KE-SP-009 0 May-11 11 Tool Box Talk Procedure KE-SP-010 1 Jul-12 12 Waste Management Procedure KE-SP-012 0 Jan-11 13 Health & Hygiene Management Procedure KE-SP-013 0 Mar-14 14 Manual Handling Procedure KE-SP-014 0 Mar-14 Environmental Management / Monitoring 15 KE-SP-015 0 Jul-13 Procedure 16 Environmental Emissions Monitoring Procedure KE-SP-016 0 Jul-13 17 Spill Prevention Procedure KE-SP-017 0 Jul-13 18 Confidential Reporting Procedure KE-SP-019 0 Feb-11 19 Accident / Incident Investigation- Procedure KE-SP-020 1 Oct-11 20 Fire Prevention and Management System KE-SP-021 0 May-10 21 Contractor HSEQ Management Procedure KE-SP-022 0 Aug-10 Procedure For Obtaining Safety 22 KE-SP-023 0 Sep-11 Exemption/Deviation During Operations 23 Fire Safety Inspection Procedure KE-SP-024 0 Jan-13 24 Fire Safety Reward and Reprimand Procedure KE-SP-025 1 May-14 25 KE Disaster Management Procedure KE-SP-026 0 May-13 26 Asbestos Management Procedure KE-SP-027 0 Jan-14 27 SF6 Monitoring and Management Procedure KE-SP-028 0 Jun-14

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Annexure “F1” KE’s Heritage & Cultural Protection Policy

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Initial Environmental Examination of

Extension of 220 MW Korangi Combine Cycle Power Plant (KCCPP)

Executive Summary

K-Electric (formerly known as Karachi Electric Supply Company) was incorporated on 13th September 1913 under the Indian Companies Act, 1882 as amended to date vide the Companies Ordinance 1984. The Company is listed on Karachi, Lahore and Islamabad Stock Exchanges. The Government of Pakistan took control of the Company by acquiring majority shareholding in 1952. The Ministry of Water and Power had looked after the affairs of The Company at federal level since 1952 until its privatization in 2005.

The new management’s objective is to make the Company a Customer centric entity. In this regard the new privatized management is in the process of updating and modernizing the infrastructure and operations of the Company. To sort out the current power crisis, the KE Management has planned a comprehensive program for the enhancement of its generating capacity, which is being implemented by adding clean and more energy efficient combined cycle units at existing thermal power stations on a fast track basis and allow the reputed global companies to install and connect their power generation with KE system on rental basis.

This proposed project is for the installation of extension of the combine cycle power plant-II at KTPS.

Existing Project capacity is 220MW at the Korangi Thermal Power Station. After Completion of project extension plant capacity will be 248 MW.

The proposed project’s sole purpose is to utilize the heat generated from the plant and produce more electricity from the heat which is being lost at the present plant. It will be a cost effective technique to produce electricity from potential energy means. The system would work in such a way, that the initial plant will generate electricity from its engines and release excessive heat, this heat will be channeled into a closed cycle system where this heat will represent potential energy and it will be converted into electrical energy, thereby the name Combined Cycle Power Plant.

In compliance with the government’s regulatory requirements, and following its own Corporate Policy and Climate Change Policy, KE has engaged the services of Global Environmental Management Services (GEMS) Pakistan to conduct an Initial Environmental Examination (IEE) of the proposed project.

The whole plant is located along the coast of Arabian Sea. A thorough baseline survey had been conducted which included the biological, physical and socio-economic surveys. However, the proposed project lies within the vicinity of an already existing power plant and it has been carefully examined that it will not cause any major impact on the environment. A human settlement, namely Ibrahim Hydri goth, is located adjacent to the area which represents fishermen and it is observed that the community might be influenced by KE activities especially by socio-economic perspective. There are some minor impacts which will be temporary during the construction phase and can be easily mitigated.

The operational phase is considered to have almost no environmental impact functionality. However, safe working practices are highlighted at all times within the proposed project area. KE itself represents strong Environmental, Health and Safety policies and regulations within its plants and moreover they work for improvement as suggested by the Environmental Management Plan (EMP).

After assessing the proposed project activities and investigating the project area, the environmental consultants, Global Environmental Management Services (Pvt.) Limited (GEMS) have concluded that:

“If the activities are undertaken as proposed and described in this report, and the recommended mitigation and environmental management measures are adopted, the project will not result in any long‐term or significant impacts on the local community or the environment. In fact once the project is operational it will have a positive social impact as it will help in reducing the gap in electricity demand and supply which has become a major social problem in the current scenario”. Initial Environmental Examination of

Site Gas Turbine Station Upgradation Project

Executive Summary

Electricity plays a pivotal role in fulfilling the needs of everyday life. There has been an enormous increase in the demand of energy in recent years as a result of industrial development and population growth, in comparison to enhancement in energy production. Supply of energy is, therefore, far less than the actual demand, resultantly crisis has emerged. The acute power shortage in Karachi is because of a considerable gap between demand and supply of electricity in the city. Keeping in view the power crisis in Karachi, K- Electric (formerly known as Karachi Electric Supply Company) has started working to add power generation capacity to the existing KE’s generation infrastructure and minimizing the losses by revamping of transmission lines and grids.

KE intends to convert SITE Gas Turbine Power Station “SGTPS” from open cycle to combined cycle power plant in order to increase the plant capacity as well as to make power generation more environmental friendly manner. Power plant upgradation component involves; installation of 32 Heat Recovery Steam Generators on all 32 Gas powered Generator Sets and installation of one Steam Turbine Generator with associated components. On completion, the project shall be able to add 10 MW to the national grid by utilizing the waste heat of flue gasses, in addition to existing 88 MW capacities. Revamping of grid component involves conversion of existing Air Insulated Switchgear system to Gas Insulated Switchgear system. After the completion of power plant component, the power station shall be classified as a combined cycle power plant.

In order to get environmental approval, KE has planned to conduct Initial Environmental Examination (IEE) study for the proposed project prior to start of construction activities. The study has taken into consideration all the relevant national legislations, regulations and guidelines related to the power generation plants. The study was followed by site visits, details of construction activities and operations of sites. Environmental and socio-economic baseline has been taken from different journals, books and other literature available related to the project site.

Impact of the proposed project has been assessed for construction and operations which will be controlled through mitigation measures. Mitigation measures are proposed mitigation through environmental management and clean practices. The exposure of noise generated during operations will be controlled through providing PPEs to the workers. All vehicles, generators and other equipment used during the construction will be properly tuned and maintained in good working condition in order to minimize emission of pollutants.

Environmental management plan (EMP) has been proposed in order to ensure that the measures are practically implemented during the construction and operation of the project. Responsibilities of the project proponent and the contractor has been clearly defined and allocated to ensure effectiveness of the plan. EMP will serve as a tool for effective communication of environmental issues between the proponent and the contractor during the construction and operations phase of the project. Project proponent will undertake overall responsibility for compliance with EMP and will carry out verification checks to ensure that the contractors are effectively implementing mitigation measures.

KE and their subsequent contractors are required to follow the EMP strictly. It is also recommended that where necessary, KE’s management shall amend this EMP as per gaps arise. Initial Environmental Examination of

Korangi Gas Turbine Station Upgradation Project

Executive Summary

Electricity plays a pivotal role in fulfilling the needs of everyday life. There has been an enormous increase in the demand of energy in recent years as a result of industrial development and population growth, in comparison to enhancement in energy production. Supply of energy is, therefore, far less than the actual demand, resultantly crisis has emerged. The acute power shortage in Karachi is because of a considerable gap between demand and supply of electricity in the city. Keeping in view the power crisis in Karachi, K- Electric (formerly known as Karachi Electric Supply Company) has started working to add power generation capacity to the existing KE’s generation infrastructure and minimizing the losses by revamping of transmission lines and grids.

KE intends to convert Korangi Gas Turbine Power Station “KGTPS” from open cycle to combined cycle power plant in order to increase the plant capacity as well as to make power generation more environmental friendly manner. Power plant upgradation component involves; installation of 32 Heat Recovery Steam Generators on all 32 Gas powered Generator Sets and installation of one Steam Turbine Generator with associated components. On completion, the project shall be able to add 10 MW to the national grid by utilizing the waste heat of flue gasses, in addition to existing 88 MW capacity. Revamping of grid component involves conversion of existing Air Insulated Switchgear system to Gas Insulated Switchgear system. After the completion of power plant component, the power station shall be classified as a combined cycle power plant.

In order to get environmental approval, KE has planned to conduct Initial Environmental Examination (IEE) study for the proposed project prior to start of construction activities. The study has taken into consideration all the relevant national legislations, regulations and guidelines related to the power generation plants. The study was followed by site visits, details of construction activities and operations of sites. Environmental and socio-economic baseline has been taken from different journals, books and other literature available related to the project site.

Impact of the proposed project has been assessed for construction and operations which will be controlled through mitigation measures. Mitigation measures are proposed mitigation through environmental management and clean practices. The exposure of noise generated during operations will be controlled through providing PPEs to the workers. All vehicles, generators and other equipment used during the construction will be properly tuned and maintained in good working condition in order to minimize emission of pollutants.

Environmental management plan (EMP) has been proposed in order to ensure that the measures are practically implemented during the construction and operation of the project. Responsibilities of the project proponent and the contractor has been clearly defined and allocated to ensure effectiveness of the plan. EMP will serve as a tool for effective communication of environmental issues between the proponent and the contractor during the construction and operations phase of the project. Project proponent will undertake overall responsibility for compliance with EMP and will carry out verification checks to ensure that the contractors are effectively implementing mitigation measures.

KE and their subsequent contractors are required to follow the EMP strictly. It is also recommended that where necessary, KE’s management shall amend this EMP as per gaps arise.

EIA for Project: 132 KV Overhead / Underground Baldia Valika Transmission Line & Diversion of Jacob Line Transmission Line.

EXECUTIVE SUMMARY

This report discusses the Environmental Impact Assessment of Proposed sites. Baldia to Valika Transmission line and existing Jacob line grid line diversion project.

The proposed project of 132kV Single Circuit Power transmission (overhead & underground) network of KESC of about 9.5km will be constructed from Baldia to Valika.

The proposed project is the diversion of existing 132kV Single Core Oil Filled Underground Cable from Grid to the Jacob line grid station.

Aim of the project is to manage overloading on the existing transmission lines/ Network and to improve electric supply quality of the adjoining areas as well as to cater the future load growth

PROPONENT INTRODUCTION

KESC is one of the city's largest employers: around 11,600 people currently working for the company. It is also one of the oldest companies in Karachi and was established in the city even before the creation of Pakistan in 1947. Incorporated on September 13, 1913, under the Indian Companies Act of 1882, the company was nationalized in 1952 but was re-privatized on November 29, 2005. KESC came under a new management in September, 2008; a significant number of professional managers with experience in running utility and other large companies have joined and will be running it until the company is turned into a best practice utility. KESC is listed on all three of Pakistan's stock exchanges: the Karachi Stock Exchange, Lahore Stock Exchange and Islamabad Stock Exchange.

At present, KESC is the only vertically-integrated power utility in Pakistan and manages the generation, transmission and distribution of electricity. KESC covers a vast area of 6,000 square kilometers and supplies electricity to all the industrial, commercial, agricultural and residential areas that fall under its network.

KESC believes that it have a responsibility to offset carbon emissions and to conserve national energy resources. KESC have recently launched the AZM tree plantation drive and the Graffiti-free Karachi project.

NEED OF THE PROJECT

Site A

The project is prepared to reduce overloading of the existing transmission line/Network and to improve electric supply quality of the adjoining areas as well as to cater the future load growth in the area namely Ittihad town, , Saeedabad, , and .

Site B

The project is prepared to improve the reliability of Garden Grid Station and further to utilize the vacant Bay for future extension of transformer at Jacob line Grid Station to cater the load growth.

PROJECT AREA

Site A (power Transmission line) found in Badia town adjacent Gulshan e Ghazi Block C to Valika grid station adjacent Allah Bachayo Goth Manghopir.

Site B (Line Diversion) found in Jacobline of adjacent CDGK parking plaza at New M.A. Jinnah road.

PROJECT DESCRIPTION

The EIA study consists of two Sites which are describe below into two sections in same chapter.

Section A

The proposed project of 132kV Single Circuit Power transmission (overhead & underground) network of KESC of about 9.5km will be constructed from Baldia to Valika grid station. Approximate Underground length is 5.9km and Overhead portion is 3.4km. The Detail of this project is given the following sections. Transmission line will be installed (underground and overhead) parallel towards existing transmission line from Baldia Grid Station to Valika Grid Station. Transmission line routes can be seen in Exhibit: 2.1

Section B

The proposed Lines diversion project is the diversion of existing 132kV Single Core Oil Filled Underground Cable from Garden East Grid to the Jacob Line Grid Station with necessary jointing / terminations for connection to the existing 132kV Underground Circuit after isolation from its 132kV Gas Insulated Switchgear (GIS) Bay with Copper Tubular Bus-Bars in open air.

UNDERGROUND TRANSMISSION

Electric power will be transmitted through Baldia grid station by underground power cables because project site is unplanned, residential setup with less right-of- way to install overhead transmission. Underground Transmission line of 132kV single core oil filled cable of 5.9km (5900m) will cover Gulshan-e-Ghazi Road (Baldia Town) to Orangi Town Area. All construction, commissioning and installation of cables will be done according to KESC Technical Procedure (TP) 6, 7, 8, 11, 12, 13 & 14.

An overhead power line is an electric power transmission line suspended by towers or utility poles. Since most of the insulation is provided by air, overhead power lines are generally the lowest- cost method of transmission for large quantities of electric energy. Towers for support of the lines are made of steel (either lattice structures or tubular poles). The bare wire conductors on the line are generally made of aluminum (either plain or reinforced with steel, or sometimes composite materials), though some copper wires are used in medium-voltage distribution and low-voltage connections to customer premises.

An overhead transmission power line about 3.4km will be installed and jointed from the end point of Underground Cable to Valika Grid Station. It will be installed along with old Overhead Transmission line. Overhead transmission work will be done according to KESC Technical Procedure (TP) TP 9.9 to 9.11.9.

LEGISLATIVE REQUIREMENT

The EIA of the proposed KESC Project activity will be subjected to the pertinent legislative and regulatory requirements of the Government of Pakistan including State laws. Legislation presents a synopsis of environmental policies, legislation and other guidelines that have relevance to the proposed project.

The proposed project falls under the project category of SCHEDULE II “Transmission lines (11KV and above) and Grid Stations1” as per the guidelines issued by the Environmental Protection Agency (EPA) under the Pakistan Environmental Protection Act 1997 (PEPA 1997). According to these guidelines, projects under this category require an EIA to be conducted.

The Pakistan Environmental Protection Act, 1997 (PEPA 1997) is the basic legislative tool empowering the government to frame regulations for the protection of the environment. The PEPA 1997 is broadly applicable to air, water, soil, marine and noise pollution. Penalties have been prescribed for those contravening the provisions of the Act. Under the provisions of the Act, federal and provincial EPAs have been formed which ensure enforcement of the Act in their respective areas of power.

The two primary deliberations of the Act are the conduct of projects only after approval of environmental assessments from the relevant EPA and adherence with National Environmental Quality Standards (NEQS).

Under section 12 of PEPA, no project involving construction activities or any change in the physical environment can be taken unless an IEE or EIA as required is conducted and a report submitted to the federal or provincial EPA.

PHYSICAL ENVIRONMENT

The appraised land cover of Karachi city indicated that the major share by area is comprised of mountains / barren land and seawater (79.9%); urban land use (15%) and vegetation canopy (4.9%). However, urban land cover is growing day by day.

The district of Karachi South lies between the low land of Lyari river and Malir River. Karachi may be broadly divided into two parts; the hilly areas in the north and west and an undulating plain and coastal area in the south-east. The hills in Karachi are the off-shoots of the Kirthar Range. The highest point of these hills in Karachi is about 528m in the extreme north. All these hills are devoid of vegetation and have wide intervening plains, dry river beds and water channels. Karachi has a long coastline in the south. The famous sea beaches include Hawks Bay, Paradise Point, Sands Pit, and Clifton. China Creek and Korangi Creek provide excellent calm water channels for rowing and other water activities. Away from the shoreline are small islands including Shamsh Pir, Baba Bhit, Bunker, Salehabad and Manora.

The Manghopir zone forms the highest terrain of the area. The highest peak is 233 above mean sea level and located at north of paradise point in jhill. The range is cut by numerous faults with horizontal displacement. These displacements have provided natural asses and have made accessibility easy across the rage at sona, lal bakhar, gloamani, etc. the dips of the bed are gentle and climb is not difficult except due to growth of thorny bushes and cactus. These hills aligned northeast- southwest from mangho pir to cape monze from water shed of the study area.

Geology of the local area is underlain a lower Indus basin described as Indus river alluvial early Eoicene early deposition of sediments includes silt, sand stone, conglomerate, limestone with low compact and cementing materials. Surface feature describe as syncline delta and valley region and anticline ridges exposed. As stratigraphic description there are two formations Gazij and Manchar formation dip gently northeast to southeast in offshore.

The exposed geological material in the area (Manghopir) is generally silty sand, sandy gravel and silty clay which is either product of in-situ weathering or deposited by the action of gravity and water. Below this over burden of silty sandy gravel soil, alternating layer of sedimentary rock comprising of sandstone, shell mudstone, siltstone and limestone are present. The rock formation of this area (Manghopir) is from Nari Formation of Oligocene age and partially from Gaj Formation of Miocene age. The Nari Formation consists mainly of sandstone, siltstone and shale with subordinate limestone while the Gaj Formation consists of shale with subordinate limestone. Both of these Formations were deposited in shallow marine environment. The shallow marine dispositional conditions in evidenced in the area by the presence of reefal limestone in in different members of the Nari and Gaj formations and by the presence of well developed cross bedding and ripple marks in some rocks of Nari and Gaj formation. Preliminary soil investigation will be carried out by the contractor after award of contract at design stage.

The area’s climate is broadly classed as hot and arid. The yearly (1992-2001) maximum average temperature in the area remains approximately 32.3°C. Hottest months of the year are May, June and July; coldest, are December, January and February. Humidity levels in the project area are high in the mornings as compared to the evenings Maximum humidity occurs in the month of August whereas minimum occurs in the month of April.

Average annual rainfall in the district is about 166mm. The rain fall is scanty and is un- predictable. The rainy season stretches between July, August & September.

There is no significant natural freshwater source in the project area. The Indus River about 120km to the east of Karachi city and the Hub River, a perennial stream that originates in Balochistan and marks the boundary between Karachi Division and Balochistan are the sources of fresh water in Karachi.

Groundwater resources in Karachi Division are limited. The aquifers close to the coastal belt are mostly saline and unusable for domestic purposes. Proposed Site A of Jacob line Grid station is near the sea and therefore the groundwater is estimated to be at a depth of 15-20 ft in this area. Site B Baldia-Valika Grid at Manghopir, there is GARAM CHUSHMA (Hot Spring) in which groundwater is heated by geothermal forces and brought to the surface.

BIOLOGICAL ENVIRONMENT

Data for the EIA was gathered from both primary and secondary sources. Baseline field survey was conducted in July 2012. Sampling locations for the identification of floral and faunal assemblages has carefully been selected so that maximum number of species can be observed within the project area. The summary of biodiversity found during the site visit is Present in form of table.

SOCIO ECONOMIC ENVIRONMENT

The Proposed Project spread our three towns of Karachi. Underground and Overhead Transmission line will be constructed to connect Baldia-Valika Grid.The route of power line will starts from Baldia KESC Grid Station situated in UC 1 Gulshan e Ghazi of Baldia Town, following Gulshan-e-ghazi road lies between UC 3 Hanifabad & UC 4 Muhammad Nagar and also crossed UC 10 of Orangi Town to reach Valika Grid Station situated at UC 8 Mangopir of by crossing Orangi town. The major places in the vicinity of Underground Transmission line from KESC Baldia- Valika Grid station Project area are Police training college Saeedabad, 19-D, G-7 & N-5 Last stop, Memon Market, Madina Excellent High School, Bangla Bazar, Government Girls College, Aziz-e- Millat School, Sindh Qatar Hospital and Jamia Masjid Subhani. Major Places at the vicinity of Overhead Transmission line are People Steel Mill, Ijtama Gah, Javedan Cement Factory, Naya , Maghopir Shrine Sindh and Qatar Government Hospital.

The Jacob line KESC Grid Station adjacent to CDGK Parking Plaza situated on New M. A. Jinnah Road, considered in Jamshed Town but it lies between Jamshed Town, Town and back side of the Grid station is the Karachi area “A”

Karachi is one of the world's largest populated cities, spread over 3,530 square kilometers. The city credits its growth to the mixed populations of economic and political migrants and refugees from different national, provincial, linguistic and religious origins largely come to settle here permanently.

Site A

The beginning of Underground Transmission line is from Baldia Grid Station situated at UC-1 (Gulshan-e-Ghazi) Baldia Town then following Underground transmission route is the intersection of UC-3 (Hanifabad) , UC-4 Muhammad Nagar and UC-10 (Gabol Colony). These are dense populated areas with the population (forecast in 2008) of UC-1 (Gulshan-e-Ghazi) 89,813, UC-3 (Hanifabad)

95,571, UC-4 () 112,060 and UC-10 (Gabol Colony) 98,645 respectively. Hazara, Pakhtun, Urdu and other communities are living in this vicinity The Overhead Transmission line route starts from Transition Station (where it will be connected to Underground Transmission line) to Valika Grid Station.

The proposed Overhead Transmission line is situated at UC-8 (Mangopir) Gadap Town which has the population of about 62,197. The Average household size is 5-7 members per family. Almost medium and lower class families are living in these areas.

Baldia, Orangi and Gadap town are very busy residential and commercial areas of Karachi. These are the residential areas but also know as Commercial at low scale with a number of markets or other business activities. There are some markets, bangla and memon market in the close vicinity of the proposed project area.

The educational facilities in Karachi at present are over and above the National Standards of Educational Facilities. Educational facilities in Karachi Metropolitan areas including are in excess due to commercialization of education and active role of private sector. Private organizations NGOs, autonomous bodies have all taken part in providing private educational facilities, so the measure should be taken to improve standard & quality of education. Major popular school of project area Khyber Muslim School, Millat Excellent High School, Aziz-e-Millat School, Sunrise English Secondary School, Government Monotechnic Institute, government degree Girls College, City District Government School and Government Girls Intermediate College.

The adequate health facilities are also visible in project area, again mainly with private set up. There are some 5-15 main health facilities available in Baldia and Jacobline, out of which some are very near to the proposed project area.

Site B

The proposed project site is located at the intersection of UC 8 (Jacob line) of Jamshed town and UC 9 (Saddar) of , back side of the project is . The population (forecast in 2008) of UC 9 (Jacob line) is approximately 114,887; UC 8 (Saddar) is 114,802 and Karachi cantonment is 58000 respectively. Average household size is 5-7 members per family. Almost medium and lower class families (Mix communities) are living in these areas.

Jamshed and Saddar Town are very busy residential and commercial areas of Karachi. This is a commercial area with a number of shopping malls. There are some shopping malls in the close vicinity of the proposed project area. However if we calculate all the shopping malls of Saddar, the nearest major shopping mall is Gul Plaza, Murshid Bazar, Bohri Bazaar, Regal Market, Zaibunisa Street, Rainbow Centre, Mobile & Electronic Market etc which is one of the most famous shopping mall of Karachi. Famous Saddar DHOBI GHAT is at the back side of Grid Station.

The livelihood of the people in the project area is mixture of elite, middle and lower class population, hence very diverse. The livelihood of elite people mainly depends on business, private and Government jobs, however medium and lower class people on shops, jobs and labor.

The major source of drinking water in the project area is the KWSB. People of this area also use water supply line and underground water, for drinking purpose but mostly for gardening, sanitary or cleaning purposes. According to the people of this area, there is shortage of water. The water through KWSB in most of the areas comes daily or on alternative days for around one hour. If there is load shedding at that time, people cannot store the water. In this case people have to purchase water through tankers. The underground water of the area is brackish and hard in nature.

Educational facilities in Karachi Metropolitan area including Saddar & Jacobline are in abundance to commercialization of education and active role of private sector. Private organizations NGOs, autonomous bodies have all taken part in providing private school educational facilities, so the measure should be taken to improve standard & quality of education. St Patrick’s, St Paul’s, St Joseph & BVS are the famous private schools situated in this area. Government Islamia Girls College is near to Jacobline grid station.

PUBLIC CONSULTATION

The consultants organized meetings with primary and secondary stakeholders of targeted areas including local residents, business community and civil servants. The team visited various prominent places in the project area to meet with the targeted audience.

The public consultation meetings were arranged at shops, outside house / flat or on roads. In a metropolitan city like Karachi and due to current law and order situation none of the residents allowed the team to enter inside their house, neither it was possible to arrange a Focus Group Discussion at some central place with a group of 6-8 people together. Individual meetings were arranged at shops, tea hotels, outside the house or on the street / market, or in the office / working premises individually or in small groups of 3-4 persons.

Participants in general raised some common concerns regarding the project and pointed out few common problems which Karachi people are already facing. Some of them also appreciated the project by saying that this project will be beneficial in catering the load problem in designated areas. Neither Non- governmental organization nor Community Based Organization was found in the area.

CONCLUSION

The EIA of the proposed Baldia-Valika Transmission Line and Jacobline-Garden east diversion line in Karachi area has achieved the following goals:

 Identification of national environmental regulatory requirements that apply to the proposed project activities;  Identification of the environmental features of the project area including the physical ,biological and social disturbance and likely impact of the project on the environment;  Recommendation of appropriate mitigation measures that KESC will incorporate and ensure as per this EIA into the project to minimize the adverse environmental impacts.

"If the activities are undertaken as proposed and described in this report, and the recommended mitigation measures and environmental management plan is adopted, the project will not result in any long-term or significant impacts on the local community or the physical and biological environment of the project area in Karachi. (Baldia,Orangi, Gadap, Saddar & Jamshed town).”

Notice of Public Hearing for 132 kV Baldia Valika Transmission Line Project

NOC for 132 kV Baldia Valika Transmission Line & Diversion of Jacob Line/Garden Circuit to Gizri Grid Station

NOC for Up-gradation of Korgani Gas Turbine Power Station

NOC for Up-gradation of SITE Gas Turbine Power Station

NOC for Extension on Korangi Combine Cycle Power Plant

Environmental Monitoring Results

For 2nd Quarter 2014 (Apr – June 2014)

Table of Contents

BQPS-I Liquid Effluent ------3 Air Quality ------4 Noise ------5 Gaseous Emission ------6

BQPS-II Liquid Effluent ------9 Air Quality ------10 Noise ------11 Gaseous Emission ------12

KCCPP Liquid Effluent ------14 Air Quality ------15 Noise ------16 Gaseous Emission ------17

KTGTPS Liquid Effluent ------19 Air Quality ------20 Noise ------21 Gaseous Emission ------22

SGTPS Liquid Effluent ------27 Air Quality ------28 Noise ------29 Gaseous Emission ------30

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BQPS-I ENVIRONMENTAL MONITORING REPORT April-June 2014

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BQPS-II ENVIRONMENTAL MONITORING REPORT April-June 2014

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KCCPP ENVIRONMENTAL MONITORING REPORT April-June 2014

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KTGTPS ENVIRONMENTAL MONITORING REPORT April-June 2014

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SGTPS ENVIRONMENTAL MONITORING REPORT April-June 2014

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ISO 14001:2004 Certificate for Site Gas Turbine Power Stations (SGTPS)

ISO 14001:2004 Certificate for Korangi Town Gas Turbine Power Stations (KTGTPS)

WASTE MANAGEMENT PROCEDURE

KESC-SP-12 0 28th Jan, 2011 1 of 17 HSEQ Document No. Version Date of Version Page Issuing department

1.0 PURPOSE:

The purpose of this procedure is to define the processes by which waste is managed throughout KESC. Waste management procedures and practices are designed to;

· Assign an appropriate regulatory classification or standard according to best international practices.

· Effectively segregate to encourage the proactive development of waste reduction, reuse and recycling initiatives.

· Appropriately containerize, labeled and stored in accordance with all regulatory requirements.

· Disposal of hazardous waste as per EPA rule 2003, and all other wastes should be disposed off through proper third party contractors.

2.0 SCOPE:

This procedure relates to the production, handling, keeping, safe storage, transport, collection and disposal of all waste generated at KESC sites.

3.0 DISTRIBUTION:

All employees and contractor staff – KESC

4.0 DEFINITIONS: Waste: (also referred to as rubbish, trash, refuse, garbage, or junk) is unwanted or unusable materials. There are many types of waste defined by modern systems of waste management, notably including:

· Municipal Solid waste (MSW)

· Construction waste and Demolition waste (C&D)

· Institutional waste, Commercial waste, and Industrial waste (IC&I)

· Medical waste (also known as clinical waste)

· Hazardous waste, Radioactive waste and Electronic waste

· Liquid waste Waste Management: administration of activities that provide for the collection, source separation, storage, transportation, transfer, processing, treatment, re use (recycle) and disposal of waste.

WASTE MANAGEMENT PROCEDURE

KESC-SP-12 0 28th Jan, 2011 2 of 17 HSEQ Document No. Version Date of Version Page Issuing department

Waste Minimization: includes reducing waste before it is even generated and environmentally sound recycling.

Municipal Solid Waste: wastes such as durable goods, disposable goods and packaging, food stuffs, yard trimmings, trees and miscellaneous inorganic wastes from households, commercial establishments (e.g., businesses or restaurants), institutions (e.g., schools or hospitals), and industrial sources. It does not

Include non hazardous industrial wastes, sewage, agricultural waste, hazardous waste, or construction and demolition waste.

Hazardous Waste: waste that is often produced in large quantities by businesses and industrial facilities that can be defined as toxic, ignitable, corrosive, or reactive. This type of waste is regulated by a law called the Resource Conservation and Recovery Act (RCRA) erected by US regarding Solid waste disposal 1965 to minimize risks to human health and the environment. Hazardous wastes produced by the Organization may include:

· Infectious clinical wastes: certain waste medicines, infected sharps and sharps contaminated with medicines

· Waste chemicals

· Batteries (e.g. lead acid batteries or significant volumes of batteries containing mercury or cadmium)

· Lamps, fluorescent tubes containing mercury (in significant quantities)

· Refrigerants (such as CFCs, HCFCs)

Clinical Waste: waste from human or animal tissue, blood, excretion, body fluids, pharmaceutical products, swabs, dressings, syringes, needles, sharps, or any other waste that may cause the infections of persons coming into contact with it.

Liquid Waste: in a facility may include grease trap waste and used lubricating oils. It also includes other untreated effluent that is normally discarded in the sewer.

BOD (Biological Oxygen Demand): Standard method for indirect measurement of the amount of organic pollution (that can be oxidized biologically) in a sample of wastewater.

COD (Chemical Oxygen Demand): Standard method for indirect measurement of the amount of organic pollution (that cannot be oxidized biologically) in a sample of wastewater.

Characterization: Determination of concentration of contaminant levels in the waste material

WASTE MANAGEMENT PROCEDURE

KESC-SP-12 0 28th Jan, 2011 3 of 17 HSEQ Document No. Version Date of Version Page Issuing department

Classification of Industrial Units: PEPA classifies industrial units into three categories, generally based on their pollution levels (A, B & C).

NEQS: National Environmental Quality Standards means standards established by the Federal Agency, Government of Pakistan under PEPA (Pakistan Environmental Protection Act) 1997.

PH: Measure of the acidity or alkalinity of a substance

Pollution: The contamination of air, land or water by the discharge or emission of effluents or wastes or air pollutants or noise or other matter which either directly or indirectly or in combination with other discharges or substances alters unfavorably the chemical, physical, biological, radiation, thermal or

Radiological or aesthetic properties of the air, land or water or which may, or is likely to make the air, land or water unclean, noxious or impure or injurious, disagreeable or detrimental to health, safety, welfare or property of persons or harmful to biodiversity.

Prescribed Waste: Solid, liquid, or gaseous substance which because of its source or measurable characteristic is classified under state of federal law as potentially dangerous and in subject to special handling, shipping and disposal requirement.

Municipal Landfill: Landfill designed to accept municipal wastes, which are of low environmental hazard.

Secured Landfill: An engineered landfill containing impervious barriers to prevent the migration of contaminants to the surrounding environment. This type of landfill is termed “secured” and is licensed to accept solid Prescribed Wastes.

Incineration: The controlled combustion of waste to reduce its volume or toxicity.

MSDS (Material Safety Data Sheet): Formal document containing information about the characteristics and actual or potential hazards of a substance.

5.0 HEALTH, SAFETY AND ENVIRONMENT REQUIREMENT: It is the responsibility of the BU/Divisions to protect human health and the environment by meeting applicable regulatory requirements including air emissions, solid/hazardous waste and water discharge. The BU/Divisions adopts reasonable measures to mitigate negative operational impacts on the environment and strives to continuously improve environmental performance.

Develop and implement processes and procedures for the minimization and management of waste.

5.1 Waste Monitoring and Reporting: All the waste generated shall be segregated, quantified and recorded prior to storage and disposal. A record should state storage location and disposal, the quantity disposed off and the name of end disposal contractor/ source. The quantity shall also be reported to HSEQ department on half yearly basis. WASTE MANAGEMENT PROCEDURE

KESC-SP-12 0 28th Jan, 2011 4 of 17 HSEQ Document No. Version Date of Version Page Issuing department 5.2 Waste Characterization: Any recordable emission or waste shall be characterized, handled and disposed off as: · Advised in the National or Local Regulations (PEPA 1997 / NEQS) from time to time. · According to site procedures (where applicable).

5.3 Use of PPE: PPE must be worn (depending upon the type of hazards) while handling waste. Refer to MSDS or contact HSEQ Department where special PPE is required to minimize the risk level e.g. handling of hazardous contaminated material, asbestos etc. It should be noted that solid waste could have physical as well as chemical or biological hazards. All PPE should be in good condition, fit for purpose and maintained where required in accordance with manufacturer and/ or legislative requirements.

5.4 Training: All employees must receive awareness training. Training must include:

· Descriptions of all solid waste streams.

· General techniques for waste minimization. Employees whose work involves solid waste handling, such as maintenance and custodial staff, will receive the same training as outlined above, as well as training in:

· Proper handling, storage and disposal techniques and procedures.

· Specific operational procedures for waste minimization.

· The use of personal protective equipment.

5.5 Documentation / Records:

· Employee training records must be available and retained for at least 3 years.

· Incident Records must be kept of all incidents for a minimum of 5 years.

· All waste record as per KESC-SP- 12 -F01

· Regulatory permits as required.

· Solid waste disposal documentation for a minimum of 5 years.

WASTE MANAGEMENT PROCEDURE

KESC-SP-12 0 28th Jan, 2011 5 of 17 HSEQ Document No. Version Date of Version Page Issuing department 5.6 Safety Precautions for workers dealing Hazardous Wastes (EPA - Hazardous Substance Rule 2003): A waste disposal form licensee shall ensure that the following safety precautions are taken in respect of workers employed by him for handling hazardous substances –

· No worker aged below 18 years or over 60 years shall be employed for any job involving physical handling of hazardous substances.

· All workers shall be thoroughly trained in safety precautions for handling hazardous substances and shall be supervised by qualified supervisors.

· Protective clothing and equipment comprising helmet or cloth cap, safety spectacles or goggles, respirators or masks, rubber or plastic gloves and work boots shall be available for all workers who may be exposed to any hazardous substance, and no worker shall be permitted on job unless and until he is wearing such protective clothing and equipment.

· Adequate supply of water shall be made available to the workers for personal washing as well as for washing their protective clothing and equipment.

· Protective clothing and equipment of the workers shall be washed and cleaned as often as may be required to ensure their efficacy.

· No worker shall be permitted to eat, drink or smoke till he has removed his protective clothing and equipment, washed his hands and face, and left the place of work.

· All fire-fighting, emergency and safety equipment shall be frequently checked and properly maintained.

· First-aid medical facility equipped with required antidotes shall be available in the premises, supervised by trained staff.

· Medical check-up of all workers shall be carried out at the time of employment and at least once a year thereafter.

· A record of every worker shall be maintained containing, amongst other details, his name and address, his medical check-up history, and the hazardous substances handled by him.

5.7 Emergency Response Plan: Refer to procedure KESC-ERP-02. All emergencies during Handling, Storage, and transportation shall be followed as per the procedure and MSDS.

WASTE MANAGEMENT PROCEDURE

KESC-SP-12 0 28th Jan, 2011 6 of 17 HSEQ Document No. Version Date of Version Page Issuing department

6.0 RESPONSIBILITIES:

6.1 Director HSEQ:

· Shall ensure that the procedure developed, rollout among all Division and BUs.

· Shall ensure the procedures shall be revised if there is any change in regulatory requirements.

· Shall ensure by conducting audit and inspection that procedures are being followed throughout KESC.

· Shall ensure to facilitate appropriate training and awareness to all staff.

6.2 HOD / Director / BU Head:

· Shall ensure that the procedure implemented to their respective department.

· Shall Ensure that all wastes are identified, segregated, disposed off and all records are maintained as per the attached form (KESC-SP- 12 -F01) of their respective departments.

· Shall ensure all staffs are trained in dealing with the waste material especially hazardous wastes.

· Shall ensure that records are communicated to Corporate HSEQ Department on timely basis (six monthly) as mentioned in the procedure.

· Shall ensure timely reporting of potential HSE impacts, risks and potential liabilities arising from wastes and hazardous materials to Corporate HSEQ Department.

· Shall ensure development and implementation of safe handling procedures

6.3 Director – Inventory Management:

· Shall ensure that waste is managed in accordance with legislative requirements.

· Shall hire third party contractors / vendors for proper disposal of all waste material including hazardous waste material in a safe manner.

· Shall maintain the monthly record of waste transfer to third party contractor. Records shall be maintained for minimum three years.

· Shall get certificate from third party contractor that their waste disposal activity is in accordance with our local legislation.

WASTE MANAGEMENT PROCEDURE

KESC-SP-12 0 28th Jan, 2011 7 of 17 HSEQ Document No. Version Date of Version Page Issuing department 6.4 Contractor:

· Comply with the requirements of KESC procedures wherever applicable.

· Control, handle and dispose of wastes in a responsible manner and in compliance with contractual agreements.

· Maintain auditable records.

6.5 All Personnel:

· Effective control of wastes. This is particularly important in the areas, which are close to communities.

· Compliance with safe handling procedures.

7.0 PROCEDURE:

7.1 Waste classification: KESC classifies waste into three categories: 1. Domestic and municipal waste 2. Non-hazardous industrial and commercial waste 3. Hazardous waste

· Radioactive waste (a special category of hazardous waste)

· Medical Waste (a special category of hazardous waste)

7.1.1 Domestic and Municipal Waste:

This includes household, commercial, agricultural, governmental, industrial and institutional wastes, which have chemical and physical characteristics similar to those of household such as garbage, paper, cardboard, plastic, cans, etc. Disposal of such waste normally presents little difficulty and it can often be routed to municipal recycling or disposal facilities.

7.1.2 Non- Hazardous Industrial and Commercial Waste:

This includes any non-hazardous wastes that have physical and chemical characteristics, or both, that are different from domestic wastes such as construction wastes, glass, scrap metal, wood, used containers, tires etc. These materials generally pose little risk to the environment and can be disposed of via approved and authorized contractors as per the local legislations.

WASTE MANAGEMENT PROCEDURE

KESC-SP-12 0 28th Jan, 2011 8 of 17 HSEQ Document No. Version Date of Version Page Issuing department 7.1.3 Hazardous Waste:

Waste is classified as being hazardous because of its quantity, concentration, or physical, chemical or infectious characteristics which:

· May cause or significantly contribute to an increase in mortality,

· May cause an increase in serious irreversible or incapacitating reversible illness,

· May pose threat to human health or the environment.

KESC defines hazardous wastes in accordance with the EPA Hazardous Substance Rule 2003, as any waste (i.e. solid, liquid or gaseous) having the following properties:

· Explosive.

· Radioactive (which includes X Rays Films).

· Ignitable or flammable liquids and solids.

· Substances liable to spontaneous combustion.

· Substances which, by interaction with water, are liable to become spontaneously flammable or give off flammable gases.

· Poisons with acute and chronic (delayed) toxicity.

· Substances and preparations which release toxic gases, including those that are harmless on their own but release toxic gases upon contact with air or water.

· Infectious substances (biohazards).

· Teratogenic and/or mutagenic

· Carcinogenic.

· Corrosives and oxidizing agents.

· Organic peroxides.

· Ecotoxicity.

· Capable after disposal of producing another material (e.g. leach ate) which exhibits any of the above characteristics.

WASTE MANAGEMENT PROCEDURE

KESC-SP-12 0 28th Jan, 2011 9 of 17 HSEQ Document No. Version Date of Version Page Issuing department 7.2 Unknown Wastes:

7.2.1 Sampling: Where:

· The classification of waste relies upon characterization results; or

· The waste is a ‘cocktail’ generated via an operational or maintenance activity (e.g. sludge from collection pits etc); and

· Treatment and/or disposal locations have still to be established; Departmental Heads shall take assistance from Corporate HSEQ department who shall advise and ensure a waste sample is taken to determine contaminant (as appropriate).

7.2.2 Analytical Parameters for ‘Unknown’ Waste: Waste materials requiring classification or the determination of a treatment and/or disposal options and locations shall be analyzed for contaminants. The following guidelines apply to analytical testing of waste materials:

· Liquid Wastes shall be analyzed for contaminant concentrations according to NEQS guidelines. However, if NEQS does not provide any guidelines than refer to WHO or US EPA guidelines (where appropriate).

· Solid Prescribed Wastes shall be analyzed if the details are not available for contaminant concentrations (e.g. solidified sediments from pits etc.) and for elutriates to determine the potential for leach-ability to the surrounding environment.

WASTE MANAGEMENT PROCEDURE

KESC-SP-12 0 28th Jan, 2011 10 of 17 HSEQ Document No. Version Date of Version Page Issuing department 7.3 Waste Management Strategy:

WASTE MANAGEMENT PROCEDURE

KESC-SP-12 0 28th Jan, 2011 11 of 17 HSEQ Document No. Version Date of Version Page Issuing department 7.3.1 Waste Segregation, Packaging & Labeling: Wide ranges of solid wastes are generated by the activities undertaken at KESC Premises. These wastes require different disposal options, from basic land filling to reprocessing for recycling or specialized waste disposal such as incineration.

7.3.1.1 Segregation: By effectively segregating waste types on site we can:

· Avoid contaminating “clean” waste with contaminated or hazardous materials.

· Minimize the quantities (and hence cost) of waste requiring specialized disposal.

· Ensure that the waste disposal option is suited to the waste type.

· Minimize the potential for environmental damage at the waste disposal site.

· Minimize the potential for safety incidents.

· Have more scope for developing on-site management systems.

· Waste should be segregated at the generation source.

7.3.1.2 Packaging & Labeling: A container of a hazardous substance shall be of such size, material and design as to ensure that –

· It can be stored, transported and used without leakage, and safely;

· The hazardous substance therein does not deteriorate in a manner as to render it more likely to cause, directly or in combination with other substances, an adverse environmental effect. The following information shall be printed conspicuously, legibly and indelibly on every container of a hazardous substance –

· Name of the hazardous substance;

· Name, address and license number of the licensee;

· Net contents (volume or weight);

· Date of manufacture and date of expiry, if any;

· A warning statement comprising – (i) The word “DANGER!” in red on a contrasting background; (ii) A picture of a skull and cross-bones; WASTE MANAGEMENT PROCEDURE

KESC-SP-12 0 28th Jan, 2011 12 of 17 HSEQ Document No. Version Date of Version Page Issuing department (iii) Pertinent instructions for use, storage and handling and safety precautions relating thereto.

7.3.2 Waste Elimination and Reduction: The volume of waste produced should be reduced through:

· Material elimination

· Inventory control and management

· Material substitution

· Reduction in the consumption of natural resources.

· Process modification

· Improved housekeeping

· Purchase of materials in bulk.

· Use of reusable rather than disposable containers.

· Avoiding purchase of goods with excessive packaging.

· Avoiding wastage of materials.

· Better handling and storage practices to prevent damage.

7.3.3 Re-use: Wherever possible items should be reused rather than discarded, eg:

· Reuse of containers such as bins and barrels.

· Recovery and reuse of refrigerants during maintenance.

· Handle and store packaging material in way so that it can be reused either at site or by others if sold.

· office waste (printing toner, paper) Materials that can be reused should be segregated from the waste stream, cleaned and repaired prior to storage for future reuse. However, containers of hazardous chemicals (e.g. fumigation chemicals) if not required at site – may be damaged prior to disposal or as advised in the MSDS or as per procedure (if any).

WASTE MANAGEMENT PROCEDURE

KESC-SP-12 0 28th Jan, 2011 13 of 17 HSEQ Document No. Version Date of Version Page Issuing department 7.3.4 Recycling / Recovery: This is the conversion of waste into usable materials and/or the extraction of energy or materials from waste including:

· Paper, cardboard, aluminum cans, wood, glass/plastic bottles

· scrap material

· Waste oil i.e., recovery of oil from vehicle, produced water, tank bottoms and oil based mud.

· All metals.

7.3.5 Treatment and Disposal:

7.3.5.1 Treatment: In situations where source reduction, reuse and recycling/recovery options have been fully explored and cannot be implemented feasibly, treatment of the waste must be considered as an alternative option to minimize waste volumes and/or toxicity. Potential treatment options to destroy, detoxify and/or neutralize waste residues include processes such as:

· Physical methods e.g. gravity separation, filtration, centrifugation, soil washing, solidification, stabilization, encapsulation.

· Biological methods e.g. waste water treatment, composting, tank-based reactors, land farming via bio-remediation and/or phytoremediation.

· Thermal methods e.g. destruction via incineration, burning, thermal desorption, detoxification.

· Chemical reaction e.g. neutralization, stabilization, extraction, precipitation.

7.3.5.2 Disposal: Disposal must be seen as the last resort and should be practiced only when the hierarchy of waste management methods has been fully evaluated (see Figure 1). Depositing of waste on land, in water or other means must use appropriate methods such as:

· Surface Discharge

· Deep Well Injection

· Landfill

· Fuel Blending WASTE MANAGEMENT PROCEDURE

KESC-SP-12 0 28th Jan, 2011 14 of 17 HSEQ Document No. Version Date of Version Page Issuing department · Waste Pits

7.4 Handling, Storage and Transport of Waste

7.4.1 Handling: Refer to section 5.0 (Health, Safety and Environment Requirements) and following sub sections;

5.3 Use of PPE

5.4 Training

5.5 Safety precaution for workers dealing with Hazardous Substances

5.6 Emergency Response Plan

7.4.2 Storage:

· All waste will be stored in a safe and secure manner pending collection by third party contractors for recovery, recycling or disposal.

· All waste will be stored in a manner that prevents its escape.

· Wherever possible, access to waste containers will be restricted to the Organization’s designated employees, contractors and contracted waste collection contractors.

· Ensure that only appropriate general solid wastes are added to the solid waste container. Certain wastes such as hazardous wastes, appliances, fluorescent lamps, pesticides, liquid waste etc. may not be disposed of in solid waste containers

· Separate recyclable waste (i.e. paper, plastic, empty glass bottles, tins, metals scrap etc.) from other waste. Do not mix wastes; this can make recycling impossible and complicate disposal.

· Where possible boxes and other containers should be flattened to save space inside containers.

· All waste containers and bins should have lids and these should be kept closed at all times in order to minimize odor and prevent wastes being blown out.

· The containers should be watertight, with the use of lids being essential during periods of rainfall.

· Lubricant waste can be recycled, therefore care should be taken for its storage and handling, so that it does not get contaminated or mix with water or other materials e.g. paper, cardboard etc. Filled barrels should be stored with lid closed. Lubricants should be stored separately according to its type/ specification. WASTE MANAGEMENT PROCEDURE

KESC-SP-12 0 28th Jan, 2011 15 of 17 HSEQ Document No. Version Date of Version Page Issuing department 7.4.2.1 Secondary Containment:

· All waste receptacles containing liquid waste materials shall be stored in a suitable spill containment facility.

· Where possible, receptacles (e.g. 205 lits. drums, etc) should be stored undercover to prevent the ingress of storm water and the deterioration of the waste receptacle.

7.4.3 Transport:

7.4.3.1 Non Hazardous Waste:

In most cases, transport for disposal of non hazardous waste will be to a designated municipal facility and the majority of such waste will go for recycling. The collection and transport of such waste will generally be arranged through IM. It is necessary to establish disposal facilities locally where every type of waste should be segregated. Onsite burning or disposal of solid waste will only is allowed with approval and a permit from the applicable regulatory agencies.

7.4.3.2 Hazardous Waste: An application for grant of license for transport of a hazardous substance shall be as per the requirements of EPA- Hazardous Substance Rules 2003, and shall provide the following details –

· Name and address of the person from whom the hazardous substance is to be collected; · Name and address of the person to whom the hazardous substance is to be delivered; · Quantity of hazardous substance to be transported; · Mode of transport, including full particulars and specifications of the motor vehicles or Other conveyance; · Route to be adopted between the origin and destination; and · Date and time of proposed transportation. · Marking and signs as per MSDS.

WASTE MANAGEMENT PROCEDURE

KESC-SP-12 0 28th Jan, 2011 16 of 17 HSEQ Document No. Version Date of Version Page Issuing department 7.5 Duty of Care:

WASTE MANAGEMENT PROCEDURE

KESC-SP-12 0 28th Jan, 2011 17 of 17 HSEQ Document No. Version Date of Version Page Issuing department

8.0 REFRENCES:

· Environment Protection Act 1997 · Hazardous Substance Rule 2003 · US EPA / EU EPA

9.0 APPLICABILITY:

· All Management and non‐management staff – KESC. · 3rd Party contractual.

10.0 FORMS / DOCUMENTS:

KESC-SP-12-F01 - Waste Record Form.

______

Prepared By; Approved B;

Corporate HSEQ Department CEO

Waste Record Form

Title KESC-SP-12-F01 0 1 of 1 CORPORATE HSEQ Document No. Version Date of Version Page Issuing department

LOCATION: ______DEPARTMENT / DIVISION / BU:______

MONTH: ______INCHARGE / HOD:______

Operation / Frequency Quantity Equipment / Waste Disposal Date Waste of (No. / KG / Disposal Location Remarks Generating Characterization Method Generation Liters, etc) Source

ANNEXURE “A”

LIST OF PRESCRIBED HAZARDOUS SUBSTANCES OR ANY OTHER SYNTHETICALLY CHEMICAL

S. NO. NAME OF CHEMICALS CAS. No 1 Acetaldehyde 75-07-0 2 Acetic acid 64-19-7 3 Acetic anhydride 108-24-7 4 Acetone 67-64-1 5 Acetone cyanohydrin 75-86-5 6 Acetone Thiosemicarbazide

7 Acetylene 74-86-2 8 Acetyl chloride 75-36-5 9 Acrolein 107-02-8 10 Acrylamide 11 Acrylonitrile 107-13-1 12 Adiponitrile 111-69-3 ? 13 Aldicarb 116-06-3 ? 14 Aldrin 309-00-2 15 Allyl alcohol 107-18-6 16 Allyl amine 107-11-9 ? 17 Allyl chloride 107-05-1 18 Amino biphenyl 92-67-1 19 3-Amino-1, 2,4 triazole 61-82-5 20 Aminopterin ? 21 Amiton 78-83-5 ? 22 Amiton dialate ? 23 Ammonia 7664-41-7 24 Ammonium chloride 12125-02-9 25 Ammonium sulphamate 7773-06-0 26 Aniline 62-53-3 27 Aniline 2,4,6-Trimethyl

28 Anthraquinone 84-65-1 ? 29 Antimony & Compounds 7440-36-0 30 Arsenic & Compounds 7440-38-2 31 Arsine 7784-42-1 32 Asbestos 1332-21-4 33 Azinpho-ethyl ? 34 Azinphos methyl 86-50-0 35 Bacitracin ? 36 Barium and Compounds 513-77-9 37 Benzal chloride 98-87-3 38 Benzenamine 3-Trifluoromethyl

39 Benzene 71-43-2 40 Benzene sulfonyl chloride 98-09-9 41 Benzene 1- (chloromethyl) –4 Nitro

42 Benzene arsenic acid

43 Benzidine and Salt 92-87-5

44 Benzimidazole, 4,5-dichloro-2 (Trifluoromethyl)

45 Benzyl chloride 100-44-7 46 Beryllium and Compounds 7440-41-7 47 Bis (2-chloroehyl) Sulphide ? 48 Bis (chloroethyl) ketone ? 49 Bis (Tert-butyl peroxy) cyclohexane ? 50 Bis (Tert-butyl peroxy) butane ? 51 Bis (2,4,6-Trinitrophenylamine) ? 52 Bromo chloro methane 74-97-5 53 Bromoform 75-25-2 54 Butyl amine tert 75-64-9 55 Butvl-n-mercaptan 109-79-5 56 Cadmium and Compounds 7440-43-9 57 Calcium arsenate 7778-44-1 58 Calcium Cyanamide 156-62-7 59 Camphechlor Toxaphene) 8001-35-2 60 Cantharidin ? 61 Captan 133-06-2 62 Carbachol chloride ? 63 Carbaryl 63-25-2 64 Carbofuran 1563-66-2 65 Carbon tetrachloride 56-23-5 66 Carbon disulphide 75-15-0 67 Carbon monoxide 630-08-0 68 Cellulose nitrate 9004-70-0 ? 69 Chlordane 12789-03-6 70 Chlorinated benzene 108-90-7 71 Chlorine 7782-50-5 72 Chlorine oxide 10049-04-4 73 Chlorine trifluoride 7790-9102 74 Chloroacetaldehyde 107-20-0 75 Chlorobenzene 108-90-7 76 Chloroform 67-66-3 77 Chloromethyl methylether 107-30-2 78 Chloronitrobenzene 88-73-3 79 Chloroethyle Vinyl ether 110-75-8 80 Chromium and Compounds 7440-47-3 81 Cobalt and Compounds 7440-48-4 82 Copper and compounds 7440-50-8 83 Crotonaldehyde 123-73-9 84 Cumene 98-82-8 85 Cyanides and Compounds 151-50-8 86 Cyclohexane 110-82-7 87 DDT 50-29-3 88 Demeton 298-03-3 89 Dichlorobenzene 95-50-1 90 Dichloroethyl ether 111-44-4 91 Dichlorophenol-2.6 87-65-0 92 Dichlorophenol-2.4 120-83-2 93 Dichloropropene-1,3 142-28-9 94 Dichloroproponic acid 127-20-8 95 Dichlorvos 62-73-7 96 Dieldrin 60-57-1 97 Dimethyl hydrazine 57-14-7 98 Dimethyl phenol 2,4 105-67-9 99 Dimethylamine 109-89-7 100 Dimethylaniline 121-69-7 101 Dinitrophenol 2-4 51-28-5 102 Dinitrotoluenes 121-14-2 103 Dinoseb 88-85-7 104 Dinitrobenzene 528-29-0 105 Dioxane-p 123-91-1 106 Dioxathion 78-34-2 107 Diquat 85-00-7 108 Endosulfan 115-29-7 109 Endrin 72-20-8 110 Epichlorohydrine 106-89-8 111 Ethion 563-12-2 112 Ethyl acetate 141-78-6 113 Ethyl benzene 100-41-4 114 Ethyl amine 75-04-7 115 Ethyl ether 60-29-7 116 Ethyl methacrylate 97-63-2 117 Ethylene dichloride 107-06-2 118 Ethylene dibromide 106-93-4 119 Ethylene diamine 107-15-3 120 Ethylene oxide 75-21-8 121 Ethylenimine 151-56-4 122 Fluorine 7782-41-4 123 Formaldehyde 50-00-0 124 Formic acid 64-18-6 125 Furfural 98-01-1 126 Heptachlor 76-44-8 127 Hexachlorobenzene 118-74-1 128 Hexachlorocyclohexan (Lindane) 608-73-1 129 Hexachlorocyclopentadiene 77-47-4 130 Hydrochloric acid 7647-01-0 131 Hydrogen sulphide 7783-06-4 132 Hydrogen cyanide 74-90-8 133 Hydrogen fluoride 7664-39-3 134 Iridium tetrachloride ? 135 Isobutyl alcohol ? 136 Lead (Inorganic) 7439-92-1 137 Lead arsenate 7784-40-9 138 Lindane 58-89-9 139 Magnesium powder or ribbon 7439-95-4 ? 140 Malathion 121-75-5 141 Maleic anhydride 108-31-6 142 Malononitrile 109-77-3 143 Mercury and Compounds 502-39-6 144 Methoxy chloride

145 Methyl alcohol 67-56-1 146 Methyl amine 74-89-5 147 Methyl bromide (Bromomethane) 74-83-9 148 Methyl chloride 74-87-3 149 M ethyl chloroform (1,1,1-Trichloroethane) 137-5-3 150 Methyl ethyl ketone peroxide 1338-23-4 151 Methyl isocyanate 624-83-9 152 Methyl methacrylate monomer 80-62-6 153 Methyl Parathion 298-00-0 154 Mevinphos 7786-34-7 155 Molybdenum and Compounds 7439-98-7 156 Monocrotophos 6973-22-4 157 Butyl acetate 123-86-4 158 Butyl alcohol 71-36-3 159 Naled 300-76-5 160 Naphthalene 91-20-3 161 Naphthyl amine 91-51-8 162 Nickel salts 7440-02-0 163 Nicotine 54-11-5 164 Nitric acid 7697-37-2 165 Nitric oxide 10102-43-9 166 Nitro benzene 98-95-3 167 Nitrocholorobenzene 100-00-5 168 Nitrocyclohexane

169 Nitrogen dioxide 10102-44-0 170 Nitrogen trifluride 7783-54-2 171 Nitrophenols 88-75-5 172 Nitropropane-2 79-46-9 173 Nitroso dimethyl amine 62-75-9 174 Cresol 1319-77-3 175 Nitroaniline 100-01-6 176 Osmium tetroxide 20816-12-0 177 Oxygen (Liquid) 7727-37-9 178 Oxygen difluoride 7783-41-7 179 Ozone 10028-15-6 180 Paraoxon (diethyl-4 nitrophenyphosphate)

181 Parathion 56-38-2 182 Pentaborane 19624-22-7 183 Pentachlorobenzene 608-93-5 184 Pentachlorophenol 87-86-5 185 Pentabromophenol

186 Phenol 108-95-2 187 Phenol,2,2-thiobis (4,6-dichloro)

188 Phenol,2,2-thiobis (4 chioro 6 methyl phenol)

189 Phenol, 3- (1- methyl-ethyl)- methylcarbamate

190 Phorate 298-02-2 191 Phosgene 75-44-5 192 Phosphoric acid 7664-38-2 193 Phosphorus 7723-14-0 194 Phosphorus oxychloride 10025-87-3 195 Phosphorus pentasulphide 1314-80-3 196 Phosphorus trichloride 7719-12-2 197 Phthalic anhydride 85-44-9 198 Picric acid (2,4,6-trnitrophenol) 88-89-1 199 Polychlorinated biphenyls (PCBs) 1336-36-3 200 Propionic acid 79-09-4 201 Propargyl alcohol 107-19-7 202 Propylene oxide 75-56-9 203 Pyrethrins 8003-34-71 204 Pyridine 110-86-1 205 Quinone 106-51-4 206 Sodium azide 26628-22-8 207 Sodium fluoro-acetate 62-74-8 208 Sodium hydroxide 1310-73-2 209 Strychnine 57-24-9 210 Styrene 100-42-5 211 Sulfuric acid 7664-93-9 212 Tert- Butyl peroxyacetate

213 Tetra ethyl pyrophosphate 107-49-3 214 Tetra nitromethane (Rocket Industry) 509-14-8

215 Tetra-chlorodibenzo-p-dioxin, 1,2,3,7,8 (TCDD) 1746-01-6

216 Tetraethyl lead 78-00-2 217 Thallic oxide

218 Titanium powder 7440-32-6 219 Toluene 108-88-3 220 Toluene 2,4-diisocyanate 584-84-9 221 Toxaphene 8001-35-2 222 Trans-1,4-dichloro-butene

223 Trichloroethylene 79-01-6 224 Trichlorophenols 95-95-4

225 Trichlorophenoxy acetic acid 2,4,5 triethylamine 93-76-5

226 Trichlorophenol 2,3,6 933-75-5 227 Trichlorophenol 2,4,5 95-95-4 228 Triethylamine 121-44-8 229 Triethylene melamine

230 Trinitrobenzene 99-35-4 231 Trinitrotoluene (TNT) 118-96-7 232 Turpentine 8006-64-2 233 Uranium and compounds 7440-61-1 234 Vanadium and compounds 7440-62-2 235 Vinyl acetate 108-05-4 236 Vinyl chloride 75-01-4 237 Vinyledene chloride 75-35-4 238 Warfarin 81-81-2 239 Xylene 1330-20-7 240 Xylidine 1300-73-8 241 Zinc chloride 7646-85-7 242 Zirconium and compounds 7440-67-7

243 Any other substance declared hazardous by Pak-EPA

ASBESTOS MANAGEMENT PROCEDURE

Title

KE-SP-027 00 1 of 18 Corporate HSEQ Date of Issuing Document No. Version Page Version department

1.0 PURPOSE The purpose of Asbestos Management Procedure is to provide guidelines for preparing Site Asbestos Management Plan (SAMP) for employees with control of premises to comply with the asbestos prohibitions and prevent exposure to airborne asbestos fibers while Asbestos Containing Materials (ACMs) remain in the workplace. 2.0 SCOPE

This Asbestos Management Procedure applies to locations where asbestos containing materials are present. 3.0 DEFINITIONS

Asbestos means the fibrous form of mineral silicates belonging to the serpentine and amphibole groups of rock-forming minerals, including amosite (brown asbestos), anthophyllite, chrysotile (white asbestos), crocidolite (blue asbestos), tremolite, or any mixture containing one or more of the mineral silicates

Asbestos-Containing Material (ACM) means any material, object, product or debris that contains asbestos.

Asbestos Waste means all removed ACM and disposable items used during the asbestos work, such as plastic sheeting used to cover surfaces in the asbestos work area, disposable coveralls, disposable respirators, and rags used for cleaning.

Friable (Asbestos) means asbestos-containing material which, when dry, is or may become crumbled, pulverized or reduced to powder by hand pressure.

Airborne Asbestos Fibers means any fibers of asbestos small enough to be made airborne. For the purposes of monitoring airborne asbestos fibers, only respirable asbestos fibers.

Respirable Asbestos Fiber means a fiber of asbestos small enough to penetrate into the gas exchange regions of the lungs.

Air Monitoring means airborne asbestos fiber sampling to assist in assessing exposures and the effectiveness of control measures.

TWA means Time Weighted Average calculated over 8 hours per day and 40 hours a week

PEL means Permissible Exposure Limit

HEPA Filter means High Efficiency Particulate Air Filter. HEPA Filter is described as a filter which is up to 99.97% efficient to remove 0.3 m size or larger particle from the air passing through filter.

ASBESTOS MANAGEMENT PROCEDURE

Title

KE-SP-027 00 2 of 18 Corporate HSEQ Date of Issuing Document No. Version Page Version department

4.0 AIRBORNE ASBESTOS FIBERS EXPOSURE HEALTH RISKS

Asbestos Containing Materials (ACMs) can release asbestos fibers into the air whenever they are disturbed, and especially during the following activities:

• Any direct action on ACM, such as drilling, boring, cutting, filing, brushing, grinding, sanding, breaking, smashing or blowing with compressed air. • The inspection or removal of ACM from workplaces (including vehicles, plant and equipment); • The maintenance or servicing of materials from vehicles, plant, equipment or workplaces; • The renovation or demolition of buildings containing ACM. Non-friable ACM that has been subjected to extensive weathering or deterioration also has a higher potential to release asbestos fibers into the air.

Asbestos is a carcinogen and the inhalation of asbestos fibers is known to cause mesothelioma, lung cancer and asbestosis.

4.1 MESOTHELIOMA

Mesothelioma is a cancer of the outer covering of the lung (the pleura) or the abdominal cavity (the peritoneum) and is usually fatal. Mesothelioma is caused by the inhalation of needle-like asbestos fibers deep into the lungs where they can damage mesothelial cells, potentially resulting in cancer. The latency period is generally between 35 and 40 years, but it may be longer, and the disease is very difficult to detect prior to the onset of illness. Mesothelioma was once rare, but its incidence is increasing throughout the industrial world as a result of past exposures to asbestos.

4.2 LUNG CANCER

Lung Cancer has been shown to be caused by all types of asbestos. Average latency period of the disease, from the first exposure to asbestos, ranges from 20 to 30 years. Lung cancer symptoms are rarely felt until the disease has developed to an advanced stage.

4.3 ASBESTOSIS

A form of lung disease (pneumoconiosis) directly caused by inhaling asbestos fibers, causing a scarring (fibrosis) of the lung tissue, which decreases the ability of the lungs to transfer oxygen to the blood. The latency period of asbestosis is generally between 15 and 25 years. Asbestos poses a risk to health by inhalation whenever asbestos fibers become airborne and people are exposed to these fibers. Accordingly, exposure should be prevented. 5.0 RESPONSIBILITIES

5.1 CHIEF HSEQ OFFICER

Ensure effective training programs are planned and implemented for asbestos awareness trainings ASBESTOS MANAGEMENT PROCEDURE

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5.2 BU HEADS

• Approve and Implement Site Asbestos Management Plans (SAMPs) • Ensure appropriate resources (human & financial) are allocated to enable thorough application of SAMPs. • Ensure Site Asbestos Management Plans are prepared in line with Asbestos Management Procedure

5.3 CHIEF MEDICAL OFFICER

Arrange for health surveillance of employees exposed to asbestos according to the information conveyed by respective HSEQ Managers / Coordinators

5.4 GENERAL MANAGER CORPORATE COMPLIANCE, CHSEQ

• Coordinate with HSEQ Managers / Coordinators for their Site Asbestos Management Plans • Coordinate site surveys and audits for effective asbestos management 5.5 HSEQ MANAGERS / COORDINATORS

• Ensure a Site Asbestos Management Plan is prepared and implemented. • Ensure the inventory of ACM and Products Register is maintained for the site. • Ensure the Asbestos Exposure Register is maintained for the site. • Ensure persons involved with asbestos work have attended asbestos training • Ensure Contractor HSEQ Management Procedure (KE-SP-022) and Contractors Responsibilities for Asbestos Management are duly followed in their respective areas.

5.6 CONTRACTORS

• Submit risk assessment and HSE plans when performing asbestos removal work • Develop a site-specific asbestos removal control plan prior to performing the asbestos removal work • Undergo site induction • Refer to KE’s Asbestos Management Procedure, Site Asbestos Management Plan and Site Asbestos Materials and Products Register for guidance to identify, manage and remove asbestos • Ensure no asbestos is removed or disturbed without prior notification to their site HSEQ Manager / Coordinator • Follow site safe work guidelines • Upon job completion ensure all products are labeled using the correct identification stickers • Report immediately to supervisor any perceived asbestos risk 5.7 EMPLOYEES

• Comply with the Site Asbestos Management Plan and any associated procedures • Attend and comply with associated Asbestos Awareness training ASBESTOS MANAGEMENT PROCEDURE

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• Ensure no asbestos is removed without prior notification to their HSEQ Managers / Coordinators • Report asbestos related hazards to the HSEQ Managers / Coordinators 6.0 PROCEDURE

6.1 SITE ASBESTOS MANAGEMENT PLANS (SAMP)

Site Asbestos Management Plans (SAMPs) are prepared to manage asbestos. SAMPs are essentially required where;

• Asbestos removal work is to be carried out • High and Medium Risk of asbestos exposure is present • Routine Activities involve dealing with ACMs • Medium and Large quantities of friable asbestos are present on site • Need to control the human-asbestos interaction is deemed necessary

A SAMP may be a separate independent document prepared in light of Asbestos Managements Procedure or to be used in conjunction with the procedure. In addition to the guidelines highlighted in this procedure, a SAMP may address site specific details, elaborate methodologies and further define the aspects of Asbestos Management.

SAMP may contain details of;

• Allowed safe and prohibited work practices • Specifications of the PPEs • Details of PELs and Excursion Limits • Details of controls and monitoring plans and site specific forms • Requirement of permit to work. Any site which is going under asbestos removal through third party / hired contractor or self (to be performed by competent and trained personnel only) should prepare an Asbestos Removal Control Plan which defines the removal procedure, quantity and type of asbestos being removed. An asbestos removal control plan is prepared by the competent person defining the following:

6.1.11 Identification

Details of the ACM to be removed (e.g. the location(s), whether it is friable or non-friable, type, condition and the quantity to be removed)

6.1.12 Preparation

• Consultation Plan • Responsibilities for the removal ASBESTOS MANAGEMENT PROCEDURE

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• Program of commencement and completion dates • Emergency Plans • Asbestos removal boundaries, including the type and extent of isolation required and the location of any signs and barriers. • Personal Protective Equipment (PPE) to be used, including Respiratory Protective Equipment (RPE) • Details of air monitoring program • Waste storage and disposal program

6.1.13 Removal

• Methods for removing the ACM (wet or dry methods) • Asbestos removal equipment (spray equipment, asbestos vacuum cleaners, cutting tools, etc) • Details of enclosures, including details on their size, shape structure, etc. and the location of negative pressure exhaust units • Details on temporary buildings required (e.g. decontamination units) including details on water, lighting and power requirements, negative air pressure exhaust units and the locations of decontamination units • Other control measures to be used to contain asbestos within the asbestos work area 6.1.14 Decontamination

Detailed procedures for workplace decontamination, the decontamination of tools and equipment, personal decontamination and the decontamination of non-disposable PPE and RPE.

6.1.15 Waste Disposal

Methods of disposing of asbestos wastes, including details on the disposal of Disposable protective clothing and equipment, and the structure(s) used to enclose the removal area.

6.1.16 Air Monitoring

• Location, types and methods, for monitoring airborne fibers and dusts. • Ways of communicating monitoring results to workers 6.1.7 Communications

The removal of ACM on site requires certain people to be informed of the processes involved. Communication shall ensure those involved and impacted upon will have a better understanding of the process.

6.2 RISK ASSESSMENT

The asbestos risk assessment process, in line with company’s Risk Management Procedure (KE-SP-006) involves identifying, analyzing, evaluating, controlling and monitoring sources of asbestos within ASBESTOS MANAGEMENT PROCEDURE

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buildings/plants, equipment or other structures. The presence of asbestos within a building is considered a hazard, but the level of risk associated with the hazard is related to the presence of airborne fibers. The identification of asbestos within a building doesn’t automatically necessitate its immediate removal. Asbestos that is in a stable matrix, or effectively encapsulated or sealed, and remains in a sound condition while left undisturbed, represents low risk to health.

If materials of unknown composition, or materials suspected of containing asbestos, are encountered on site, and are not documented in the existing asbestos register, such materials are to be sampled and treated as asbestos until sample analysis confirms otherwise.

A qualitative risk assessment is undertaken each time an asbestos survey of buildings or structures is conducted. Each asbestos situation is allocated a high/ significant, medium or low risk rating. These ratings are defined as follows:

Significant / High risk: Friable ACM that has deteriorated significantly. The material is readily accessible and prone to further disturbance, or unsealed friable asbestos material located in air conditioning systems.

Moderate risk: minor deterioration of the ACM is evident and/or the ACM is prone to mechanical disturbance due to routine activity and/or maintenance.

Low risk: ACM shows no signs or very minor signs of damage/deterioration. Regular access to the ACM is unlikely to cause significant deterioration, if the material is adequately sealed.

Factors which may be included in risk assessment are Friability of the material, its present Condition, Surface-treatment, Likelihood for Disturbance and concentration of Asbestos Fibers in air. For Asbestos Risk Assessment, risk assessment form of HSEQ Risk Management Procedure (F-SP-006-1) is modified and annexed as KE-SP-027-F01 for future use and reference. A quantitative analysis method to analyze risk is defined below;

Friability (F) Score Example Low 1 Strong products such as floor tiles, artex and cement. Medium 2 Non-cement boards (like AIB), ropes, gaskets, millboard and paper. High 3 Insulation products (other than boards i.e pipe lagging), sprayed asbestos, packing.

Condition (C) Score Example No damage 0 Low damage 1 Slight damage, scrapes, damaged edges. Medium 2 Broken with fibrous areas reveled. The majority still being intact. High 3 Badly damaged with debris.

Surface Treatment (ST) Score Example Composites 0 Floor tiles and cement ASBESTOS MANAGEMENT PROCEDURE

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Enclosed/sealed 1 Enclosed highly friable materials (sprays, lagging), sealed (painted or papered) medium friable materials (insulation boards), unsealed low friable materials (cement boards, artex) Bare (medium) 2 Unsealed medium friability materials (insulation boards) Bare (high) 3 Unsealed high friability materials (sprays, laggings)

Disturbance Likelihood (L) Score Example Unlikely 0 Not likely to any manmade or natural disturbance (indoor) Moderate 1 Less accessed and prone to manmade or natural disturbance Likely 2 Frequently accessed but does not involve working with ACM Certain 3 Frequently accessed and involves working with ACM

Exposure (P) Score Example PEL & Below PEL 1 TWA 8 hour or less Above PEL but below 2 TWA 30 minutes or less Excursion Limit Above excursion limit or 3 Frequently accessed but does not involve working with ACM above PEL and TWA not less than 30 minutes

RISK (R) LOW MEDIUM HIGH R = P X (F+C+ST+L)

RISK SCORE 1-4 5-16 17-36

The risk assessment of ACM is to be reviewed when:

• There is evidence that the risk assessment is no longer valid • There is evidence that control methods are not effective • A significant change is proposed for the workplace or work practices or procedures relevant to the risk assessment • There is a change in condition of the ACM • The ACM have been removed, enclosed or sealed. • Otherwise risk assessment reviews should be conducted every 12 months. For detailed risk management procedure consult Risk Management Procedure (KE-SP-006)

6.3 CONTROLLING ASBESTOS HAZARDS

Control measures shall be implemented based on the level of risk of exposure to asbestos containing materials at sites / locations. The control measures must be aimed at eliminating risk arising from ACM and prevent exposure to airborne asbestos fibers. After elimination, the methods adopted should follow ASBESTOS MANAGEMENT PROCEDURE

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the remaining levels within the hierarchy of controls. The following information should be used to determine the correct control method for effective ACM management.

• If ACM is friable and not in a stable condition, and there is a risk to health, it must be removed by an EPA certified third party contractor, capable of handling asbestos in a safe manner as soon as practicable. • If ACM is friable but is in a stable condition and is accessible, consideration should be given to its removal. If removal is not immediately practicable, short term control measures, such as sealing and enclosure, may be used until removal is possible. • If ACM is not friable and is in a good stable condition, minimizing disturbance and encapsulation may be appropriate controls. • Any remaining ACM is to be clearly labeled where possible and regularly inspected to ensure it is not deteriorating or otherwise contributing to an unacceptable health risk. • ACM needs to be removed before demolition, partial demolition, renovation or refurbishment if it is likely to be disturbed by those works.

6.3.1 ELIMINATION / REMOVAL

Removal is the preferred control option because it removes the hazard from the workplace. The removal process does pose an increased risk to personnel engaged in the removal. Asbestos Removal work is to be performed by an EPA certified third party contractor, capable of handling asbestos in a safe manner.

Asbestos removal work must be conducted in accordance with the best industrial practices complying minimum requirement established in this procedure or site Asbestos Management Plan whichever more stringent.

6.3.2 ENCAPSULATION / SEALING

Encapsulation refers to the coating of the outer surface of the ACM by the application of some form of sealant compound that usually penetrates to the substrate and hardens the material. Sealing is the process of covering the surface of the material with a protective coating impermeable to asbestos. Either of these options helps protects the asbestos from mechanical damage and is designed to reduce the risk of exposure by preventing the release of asbestos fibers into the airborne environment. This control method is not considered to be an acceptable alternative to repairing or removing severely damaged asbestos materials.

6.3.3 ENCLOSURE / ISOLATION

This method involves installing a barrier between the ACM and adjacent areas. This inhibits further mechanical damage to the asbestos and some friable products may be candidates for enclosure if removal is not an option. The type of barrier installed may include plywood or sheet metal constructed as boxing a cladding around the asbestos.

ASBESTOS MANAGEMENT PROCEDURE

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6.3.4 SAFE WORK PRACTICES

The asbestos register for the site must be maintained and consulted prior to commencing work, if that work could result in the generation of airborne asbestos fibers. If, after consultation with the register and conducting a risk assessment, it is determined that the type of work and the location of work to be performed would result in an unacceptable level of risk, other controls are required to be implemented.

Maintenance tasks that may involve ACM at sites are to be addressed under controlled conditions, to prevent and minimize the risk of exposure of the maintenance personnel or any other person to airborne asbestos fibers. Safe work practices should be established according to the nature of job and work area.

6.3.5 PERSONAL PROTECTIVE EQUIPMENT (PPE) AND SAFETY SIGNS

The PPE requirements for work involving ACM at sites are to be based on the relevant risk assessment conducted by a suitably qualified person. Protective clothing and equipment is to be worn at all times during work in the asbestos work area. Any PPE worn during asbestos disposal is to be treated as asbestos waste and disposed of in the approved waste bags.

6.3.5.1 Overalls

• Disposable overalls. Type 5 (BS EN ISO 13982-1) are suitable. Cotton overalls hold dust and need specialist laundering • You may need waterproof overalls for outdoor work • If the cuffs are loose, seal them with tape • Avoid wearing a long-sleeved shirt - these are difficult to cover properly • Wear the overall legs over footwear. Tucking them in lets dust into footwear • Wear the hood over the RPE straps • Dispose of used overalls as asbestos waste Caution: Never take used overalls home. The laundering of contaminated protective clothing in workers’ homes is strictly prohibited.

6.3.5.2 Gloves

• If you wear protective gloves, use single-use disposable gloves. If you must use latex gloves, use only ‘low protein powder-free’ gloves. • Dispose of used gloves as asbestos waste. 6.3.5.3 Footwear

Boots are preferable to disposable overshoes which cause a slipping risk. Caution: Never use laced boots; these are very difficult to clean properly.

6.3.5.4 Respiratory Protective Equipment (RPE) ASBESTOS MANAGEMENT PROCEDURE

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• Disposable respirator to standards EN149 (type FFP3) or EN1827 (type FMP3) • Half mask respirator (to standard EN140) with P3 filter • Semi-disposable respirators (to EN405) with P3 filter 6.3.5.5 Safety Signs

Below safety signs may be used;

6.4 SITE ASBESTOS CONTAINING MATERIALS AND PRODUCTS REGISTER

Each site shall establish and maintain a Site Asbestos Containing Materials and Products Register on Form KE-SP-027-F02, recording the specific location, condition and exposure risk of each asbestos area. The accuracy and currency of the Register shall be confirmed and updated on an annual basis by conducting site inspections of each asbestos area, or areas where asbestos removal or damage has occurred.

Register should be located at each site and managed by the HSEQ Manager / Coordinator. It should provide following information on asbestos identified or presumed in the workplace, as well as items confirmed as asbestos-free:

• Description of the building / plant • Date of assessment and name of evaluator • Register data input date • Location of ACM within the building • Form of material (tiles, gaskets, sheeting, etc) • Asbestos Type (based on analysis) • Present condition of material • Data source • Potential risk to occupants (low, medium or high) ASBESTOS MANAGEMENT PROCEDURE

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• Modifications to items • Responsible officer for modifications • Date of modification Site Asbestos Materials and Products Register shall be made available to all concerned employees upon request and made clear by the competent person / team leader / supervisor to any maintenance personnel or contractor, prior to their commencing work on buildings or items of plant containing asbestos. The competent person / supervisor must advise workers of the register and if there is asbestos present, or if any other activity may cause exposure to the asbestos.

6.5 ASBESTOS MONITORING

Monitoring shall be undertaken on sites where asbestos materials are present to determine asbestos fiber concentrations. Monitoring is to occur before, during and after planned asbestos removal work in accordance with the asbestos removal control plan.

Each site shall undertake air and dust sample monitoring at strategic points – adjacent to areas with asbestos materials or products present at suitable intervals. Test results are to be assessed and actions taken to reduce the fiber concentration in the atmosphere or dust to control levels. The test results are put on the Site Asbestos Materials and Products Register.

6.6 RECORD KEEPING

All KE sites shall maintain a complete record of all activities and work permits relating to asbestos works, which have been undertaken at the individual sites. The records that are to be kept include:

• Copies of all asbestos survey reports, including updates and amendments • Copies of all permit to works • Site induction records pertaining to the information disseminated to contractors prior to conducting work onsite • Induction records pertaining to the information disseminated to employees regarding the presence of asbestos onsite • Records of any removal or other asbestos related works onsite • Clearance certificates indicating areas are safe to reoccupy after asbestos removal works • Asbestos fiber air monitoring results • All versions of the asbestos register Re-inspections of all ACMs remaining on site are to be conducted by a suitably qualified person. The re- inspection process shall involve a visual assessment of the materials to determine if there has been any deterioration since the last inspection and, if so, what course of action should be taken i.e. temporary encapsulation, isolation or immediate removal. The re-inspections are to be conducted every 12 months.

Once re-inspection has been completed, Site Asbestos Containing Materials and Products Register are to be updated accordingly by the HSEQ Coordinator / Manager. ASBESTOS MANAGEMENT PROCEDURE

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6.7 PROHIBITED PRACTICES

Work practices that are prohibited include:

• Work practices in the vicinity of asbestos materials that may disturb or, damage the material, cladding, enclosure, and sealant or containment barrier. • Workers using high pressure water process to clean an asbestos product or to clean up debris from an asbestos product. • Workers using compressed air to clean an asbestos product or a surface where debris from an asbestos product is present.

6.8 AWARENESS TRAINING

Any employee and others who may come into contact with ACM on a site, either directly or indirectly, must be provided with adequate information and training.

• Depending on the circumstances the asbestos awareness training may include: • Purpose of the training • Types, uses and likely occurrence of ACM in buildings, plant and/or equipment at the specific site • Health risks of asbestos • Trainees’ roles and responsibilities under the asbestos management plan • Where each site-specific register of ACM is located and how it can be accessed • Timetable for removal of ACM from the particular site / area • Processes and procedures to be followed to prevent exposure, including exposure from any accidental release of asbestos dust into the workplace • Where applicable, correct use of maintenance and control measures, protective equipment and work methods to minimize the risks from asbestos, limit the exposure of workers and limit the spread of asbestos fibers outside any asbestos work area • Control levels for asbestos and • Purpose of any air monitoring or health surveillance that may occur 6.9 WASTE REMOVAL AND DISPOSAL

6.9.1 WASTE REMOVAL AND CONTAINMENT

Asbestos waste, including contaminated PPE and cleaning materials (e.g. cleaning rags and plastic sheeting used to cover surfaces in the asbestos work area) are to be removed and disposed of into bags. Loose asbestos waste is not to be allowed to accumulate within the asbestos work area. It must be collected and disposed of in asbestos waste bags and/or in a solid, sealable asbestos waste container, such as a bin or drum, if storage is required. ASBESTOS MANAGEMENT PROCEDURE

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Controlled wetting of asbestos waste is to be done to reduce the possibility of dust emissions during the bagging or other containment of the waste. If asbestos waste cannot be disposed of immediately (e.g. because of volume requirements for disposal), it is to be stored in a solid waste drum, bin or container or skip and sealed and secured upon the completion of each day’s work so that unauthorized access is prevented.

6.9.1.1 Waste Bags

Asbestos waste is to be collected and double bagged in heavy-duty 200 μm (minimum thickness) polythene bags. The bags are to be labeled with an appropriate warning, clearly stating that they contain asbestos and that dust creation and inhalation should be avoided.

6.9.1.2 Waste drums and bins

All drums or bins used for the storage and disposal of asbestos waste must be in a good condition, with lids and rims in good working order, and free of hazardous residues.

The drums or bins must be lined with plastic (minimum 200 μm thickness), and labels warning of the asbestos waste are to be placed on the top and side of each drum or bin, with the safety warnings and signs.

6.9.2 WASTE DISPOSAL

Transport and final disposal of asbestos waste material shall be carried out only by a competent person (EPA approved contractor) who carries license / certification as a transporter of hazardous materials in hazardous waste and in a manner that will prevent the liberation of asbestos dust to the atmosphere.

Asbestos is a hazardous substance and should be disposed off as per company’s Waste Management Procedure (KE-SP-12). All waste disposals shall be recorded (date, quantity, disposal contract etc) accordingly.

6.10 ASBESTOS EXPOSURE REGISTER

Asbestos exposure record of persons that have been exposed, have potentially been exposed or have worked in close proximity to asbestos materials shall be maintained by HSEQ Coordinator / Manager and the information shall be timely communicated to Chief Medical Officer for Health Surveillance.

6.11 HEALTH SURVEILLANCE

Health surveillance is an important part of the monitoring of exposure to hazardous substances, including asbestos to ensure the health and safety of people in workplaces. One of its main purposes is to ensure that control measures are effective and provide an opportunity to reinforce specific preventive measure and safe work practices. Assessments shall be conducted in accordance with the instruction of IHU medical practitioners. Medical records are to be held with the workers personnel file and be protected by the relevant procedures for Privacy and Confidentiality. ASBESTOS MANAGEMENT PROCEDURE

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7.0 EXPOSURE LIMITS

Exposure limits are set accordingly to worldwide best practices;

Air borne concentration of asbestos Exposure (fiber / cubic centimeter) PEL 8 hour-TWA 0.1 Excursion Limit Not in excess 1 of 30 minutes

Compliance to the exposure limits must be evaluated through Asbestos Air Monitoring and if required necessary changes be made to controls. Record of air borne concentration of asbestos must be maintained and communicated to related employees on form KE-SP-027-F03.

8.0 APPLICABILITY:

• Permanent / Contract employees of KE • Third party contractor / sub contractor

9.0 FORMS / DOCUMENTS:

KE-SP-027-F01 ASBESTOS RISK ASSESSMENT FORM Annex A KE-SP-027-F02 SITE ASBESTOS CONTAINING MATERIALS AND PRODUCTS REGISTER Annex B KE-SP-027-F03 ASBESTOS AIR BORNE CONCENTRATION Annex C ASBESTOS MANAGEMENT PROCEDURE Annex “A” Title

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ASBESTOS RISK ASSESSMENT FORM SECTION 1

Risk Assessment # Rev #

Location: Date: DISTINCTIVE HAZARD ORIGINAL RESIDUAL SNO HAZARD EXISTING CONTROL ADDITIONAL CONTROL LOCATION EFFECT RISK RISK Eg. Welding Shop Asbestos Health Surface Treatment / Low / Removal / Access Low / Medium Effects Access Control / PPEs Medium / Control / RPEs / Training / High Or Risk (Long Etc High Or Risk Etc Score (1-36) Term) Score (1-36)

ASBESTOS MANAGEMENT PROCEDURE Annex “A” Title

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SECTION 2 (FOLLOW-UP SHEET):

SNO ACTION IDENTIFIED RESPONSIBILITY TARGET DATE

Team Leader Member Member Name Name Name

Signature Signature Signature ASBESTOS MANAGEMENT PROCEDURE Annex “B” Title

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SITE ASBESTOS CONTAINING MATERIALS AND PRODUCTS REGISTER

WORKPLACE CONDUCTED Date: LOCATION: BY: Likely To Activities That Risk Product Friable Or Surface Sustain Location Accessibility Condition May Disturb Assessment # Type Non-Friable? treatment Damage Or The Asbestos : Rev # Deteriorate?

ASBESTOS MANAGEMENT PROCEDURE Annex “C” Title

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ASBESTOS AIR BORNE CONCENTRATION

Asbestos Permissible Concentration In Ref. Risk SNO Workplace Area Exposure Time Precautions Air (fibers/cubic Assessment # Per Day centimeter)

Eg. Boiler 15 m 0.35 20 minutes Use RPEs 15

SF6 Monitoring & Management Procedure

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1.0 PURPOSE

The purpose of this procedure is to establish and maintain a system for minimizing the risk of

releasing SF6 gas into the environment, and specify safe practices for handling, removal, transportation and disposal of hazardous by-products of SF6 gas. This procedure establishes minimum requirements that must be followed while using, handling and inventory of Sulfur

Hexafluoride (SF6) gas.

2.0 BACKGROUND

KE uses Sulfur hexafluoride (SF6) at high voltage interface between the generation and transmission systems for insulation, arc quenching, and current interruption in gas-insulated switchgear (GIS) and circuit breakers.

Sulfur hexafluoride gas (SF6) is a fully fluorinated compound (FFC) which is recognized as being a particularly potent greenhouse gas. It is known that SF6 has up to 23,900 times the global warming potential in comparison to carbon dioxide (CO2). SF6 has atmospheric lifetimes of up to 3200 years, thereby significantly and permanently contributing to global warming.

KE is committed to its Climate Change Policy, an initiative to minimize greenhouse gas; effective management of SF6 gas is one of the key steps in this regard. KE accounts for all SF6 gas in its system, and also the amount of gas that has been lost to the atmosphere.

3.0 SCOPE

This procedure applies to the KE sites, staff, and third party contractors/suppliers working within the company’s jurisdiction, where SF6 is purchased, stored, used, transferred, transported, or handled.

4.0 REQUIREMENT

In developing the procedure, following considerations and strategies have been applied: • KE’s Climate Change Policy; • IFC requirements (IFC’s Environmental, Health, and Safety Guidelines for Electric Power Transmission and Distribution); • KE’s Waste Management Procedure (KE-SP-12); • Internationally accepted best practices.

5.0 DEFINITIONS

CPR: Cardiopulmonary Resuscitation is an emergency procedure for manually preserving brain function until further measures to restore spontaneous blood circulation and breathing in a person who is in cardiac arrest.

EAR: EAR (Expired Air Resuscitation) is an emergency procedure, used when a person has stopped breathing (respiratory arrest).

Environment: Surroundings in which an organization operates including air, water, land, natural resources, flora fauna, humans and their interactions.

SF6 Monitoring & Management Procedure

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Global Warming: It is the rise in the average temperature of Earth's atmosphere and oceans since the late 19th century and its projected continuation.

IEC 60376: International Standard specification applies to new and unused sulfur hexafluoride and gives the properties and methods of test applicable to sulfur hexafluoride when this substance is supplied for use in connection with any electrical equipment.

Measurement: A systematic method for estimating, testing, or otherwise evaluating key parameters and characteristics of a department’s activities to determine conformance with a specific standard and/or other performance requirements.

Monitoring: A systematic process of checking, observing, inspecting, regulating or otherwise controlling key parameters and characteristics of the department’s activities to determine conformance with a specific standard or other performance requirement, or to measure progress toward its environmental objectives and targets.

MSDS: Material Safety Data Sheet; documents that provide the information necessary for the safe handling of chemicals including Dangerous Goods and Hazardous Substances.

Personal Protective Equipment (PPE): Any equipment, device or clothing worn by a person to protect against all variety of hazards which may be found in worksites such as water, noise, chemicals, falls, lack of oxygen, presence of harmful gases/chemicals, etc.

Threshold limit value (TLV): It is defined as the time weighted average concentration for a normal eight hour work day and a 40 hour work week, to which nearly all workers may be exposed repeatedly, day after day, without adverse effect and is expressed in parts per million (ppm).

Transfer: Transfer is the deliberate moving of SF6 from one containing vessel to another.

Transport: Transport is the movement of SF6 from one site to another.

6.0 RESPONSIBILITY

Chief HSEQ Officer

• Shall ensure that SF6 Gas is managed as per requirement. • Shall ensure that effective training programs are planned and implemented for SF6 gas management.

BU Heads / Directors

• Shall approve and implement site specific SF6 gas Management Plans. • Shall ensure appropriate resources (human and financial) are allocated to enable the implementation of SF6 gas management plan. • Shall ensure that site specific SF6 gas management plan is prepared in line with corporate SF6 management procedure.

General Manager Corporate Compliance CHSEQ

• Coordinate with HSEQ Managers / Coordinators for their site SF6 Management Plans. • Coordinate site surveys and audits for effective implementation of SF6 Management Plans.

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HSEQ Managers / Coordinators

• Shall ensure that site SF6 Management Plan is prepared and implemented in consultation with GM Corporate Compliance, Corporate HSEQ.

• Shall ensure the inventory of SF6 is maintained for the site. • Shall ensure and verify that SF6 gas pressure is kept within the prescribed limits. • Shall be responsible for monitoring of SF6 as specified in this procedure. • Shall introduce controls and manage risks against incidental release. • Shall take corrective and preventive measures to reduce risk of sudden release. • Shall provide environmental related information. • Shall organize SF6 monitoring program through certified environmental laboratory or internal resources. • Shall prepare work instructions and local procedures and collect data with the assistance of technical team and maintenance in-charge.

• Shall ensure that relevant staff has attended training on SF6 management. • Shall submit report to Corporate HSEQ on regular basis.

Process In-charge / Product Manager

• Shall be responsible for process control, record keeping, proper identification and keeping good working condition in their Units. • Shall monitor the process, maintain record and in case of non-conformance, report to the HSEQ Manager/Coordinator.

Contractors

• Shall develop site specific plan prior to performing the SF6 handling, removal, transportation or disposal work.

• Shall refer to SF6 management procedure and site specific plan for guidance. • Shall ensure that SF6 gas equipment is managed in consultation with the site HSEQ Manager / Coordinator.

7.0 OVERVIEW - SULFUR HEXAFLUORIDE GAS

Sulfur Hexafluoride (SF6) gas is inert, colorless, tasteless, odorless, non-flammable, non-toxic, 5.5 (approximately) times heavier than air and chemically stable in the normal conditions. The gas is liquefied at -62oC under atmospheric pressure and 0oC under pressure of 12 kg/cm2 respectively. It is

used within electrical equipment as an insulant. SF6 gas in high concentrations acts as a simple asphyxiant and oxygen levels should be kept above 18% at normal atmospheric pressure. A threshold limit value (TLV) of 1000 ppm volume has been established for places of work in which personnel spend up to eight hours per day, five days a week.

7.1 EFFECTS OF SULFUR HEXAFLUORIDE GAS

High concentrations of SF6 gas can occur in non-ventilated open SF6 installations and at ground level of narrow compact rooms, as well as in spaces below ground level (e.g. basements, cable ducts). If

SF6 gas escapes without being able to mix turbulently with ambient air, it may, because of its high density, accumulate at floor level and enter lower located rooms. Ventilation is required to readily mix the gas with ambient air and achieve the threshold limit value (TLV) of 1000 ppm volume.

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7.2 EFFECTS OF SULFUR HEXAFLUORIDE BYPRODUCTS

At high temperatures (above 500°C), i.e. when exposed to an electric arc, some decomposition of SF6 takes place, producing compounds that may be toxic. The solid products resulting from the

decomposition of metals subjected to electric arcs in the presence of SF6 gas exist in form of whitish powder that hydrolyses in the presence of moisture to form a sticky grey deposit that is normally

acidic. Solid byproducts such as Aluminum fluoride (AlF3) and Copper fluoride (CuF2) dusts have an irritating action on the skin, eyes, respiratory and mucous membranes. If copper salts are inhaled in sufficient concentration so that it reaches the gastrointestinal tract (via cough and mucociliary mechanisms), they act as irritants producing salivation, nausea, vomiting, gastric pain, hemorrhagic gastritis, and diarrhea.

Gaseous Sulfur hexafluoride (SF6) byproducts such as Sulfur tetra fluoride (SF4), Silicon tetra fluoride (SiF4), Sulfuryl fluoride (SO2F2), Sulfur dioxide (SO2), and Hydrogen fluoride (HF) are extremely irritating to the eyes, nose, and throat. Other human health effects of these gases include pulmonary edema, skin and eye burns, nasal congestion, and bronchitis due to their corrosive characteristics. In the rare event of any SF6 decomposition products being present in the atmosphere, warning indications are apparent at very low concentrations, in the form of a pungent and nauseous odor. This is evident well before any toxic effects can take place.

8.0 MANAGEMENT OF SULFUR HEXAFLUORIDE GAS

8.1 PLANNING

In planning maintenance strategies for sites containing SF6 gas, the type of site, age of site, and prior incidents must be considered. The gas must be monitored via routine site inspections. The gas

pressure for every site containing SF6 must be recorded on the inspection sheet.

All new sites containing SF6 gas must be fitted with low pressure alarms, and where required, lockout circuitry. As part of the maintenance procedures for the site, the alarm systems must be checked to ensure that they are in working order. Gas pressure gauges must also be checked for functionality when maintenance on the site is performed.

8.2 IMPLEMENTATION

The monitoring of SF6 gas shall be performed as per the maintenance instruction. Any gas instrument (gauge, test equipment) that needs to be calibrated will be done so in accordance with manufacturer’s instructions.

The monitoring report will be maintained by the Process In-charge who will also update the site management records. He must notify the HSEQ Manager / Coordinator of any problems found, and must complete an SF6 Incident Reporting Form (KE-SP-028-F01).

8.3 MANAGING IDENTIFIED PROBLEMS

8.3.1 Registering event, necessary actions and implementation

Based on the monitoring activities and reports, the Process In-charge shall determine what action is necessary and register an event. He will be responsible for issuing a Request for Works specifying what action should be taken. The HSEQ Manager / Coordinator shall implement actions to provide the specified result.

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8.3.2 Need to drain

If there is a need to drain the SF6 gas, this shall be done in accordance with the procedure. If there is no need to drain the SF6 gas, Section 8.3.4 applies.

8.3.3 Testing of recovered Sulfur Hexafluoride gas

Based on the history of the site and the urgency of the existing situation, the HSEQ Manager /

Coordinator may decide to arrange testing of the recovered SF6 gas before reinstallation. Testing is primarily for moisture and arcing products. A suitably qualified technical person must be given the

task of testing the SF6 gas.

8.3.4 Repairing, inspecting and testing

The HSEQ Manager / Coordinator will issue a maintenance instruction to the Process In-charge

specifying the repair, inspection, and testing of cylinders/equipments that contain SF6 gas. The Process In-charge shall remedy any problems encountered, and notify the HSEQ Manager / Coordinator of the results obtained.

9.0 SAFETY REQUIREMENTS

This section details the general requirements and safety precautions to be taken for the safe use and

handling of SF6 gas. Table below summarizes the safety requirements for tasks involving SF6.

Requirements Work in the vicinity Filling and recovery Opening of SF6 gas of SF6 of SF6 gas compartments MSDS and operating manuals Mandatory Mandatory Mandatory Training As required Mandatory Mandatory Gas handling equipment N/A Mandatory Mandatory Cleaning/neutralising equipment N/A As required Mandatory Personal Protective Equipment Mandatory Mandatory Mandatory Tasks Flames/Welding/Smoking Not recommended Not permitted Not permitted Eating/Drinking Permitted Not recommended Not permitted

9.1 EQUIPMENT ISOLATION

All activities involving filling or extracting gas must be performed with the equipment isolated and de-energized in accordance with the Safety Rules. General inspections, pressure gauge reading and the use of imaging equipment for leak detection may be performed whilst the equipment is in service.

9.2 SAFETY PRECAUTIONS

If personnel close to a Gas Insulated Switchgear (GIS) installation hear an explosion, escaping gas sound, smell an odor like rotten eggs or in any other way get an indication of a sudden exhaust of gas, they should immediately protect themselves against the inhalation of dust by covering the face with clothing, and leave the vicinity of the installation.

Once in clear air, he must inform the HSEQ Manager / Coordinator, so that affected equipment is removed from the service. In the case of indoor installations, the switchgear room shall be

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abandoned as soon as possible to enable the initiation of further actions to make the area safe.

Safety information will be displayed whenever used SF6 gas is being handled.

Warnings prohibiting open fires, smoking, heating to more than 200°C, welding without special precautions and first aid instructions must be communicated.

Work shall not be commenced until: a) Personnel are wearing protective clothing as specified in Section 9.3; b) All safety equipments necessary to handle SF6 and its decomposition products, as detailed in the relevant sections of this document, are ready for use; and c) Appropriate first aid equipment is on site.

Maximum permissible concentration limit values of SF6 gas are given below for different situations: (Respiratory equipment is to be worn when maximum permissible concentrations of new and used

SF6 in air are exceeded). a) New SF6 in air - 1000 ppm volume. b) Used SF6 during maintenance and extension of high voltage equipment or abnormal leakage - 200 ppm volume. c) Used SF6 following an internal fault or external fire provoking opening of the gas enclosure - 20 ppm volume.

The following safety precautions shall be adhered to before any work involving SF6 gas: a) Where leaks are suspected, as indicated by the pressure gauges, the SF6 concentration should be measured with an appropriate SF6 detector to ensure compliance. b) Switchgear enclosures must not be entered without full protective clothing and breathing apparatus until they have been cleaned, ventilated and confirmed within the prescribed limits of

SF6 gas. c) When working on switchgear gas enclosures after internal arc faults or repeated switching, care must be taken in removing or opening hollow bus conductor sections or any other components that contain hollow spaces. Solid or gaseous decomposition products may be trapped inside such spaces. d) While work is being performed inside switchgear gas enclosures with known contaminated SF6 decomposition products, a safety observer, wearing appropriate protective clothing, must be in attendance. e) Safety requirements for work in confined spaces shall also be observed. f) Should skin irritation, eye irritation or nose irritation occur during work on previously decontaminated equipment, the work area must be vacated and force ventilated. The source of irritation or contamination must be identified and removed. g) Where the supply of water is limited, a neutralizing solution must be prepared before commencement of work for washing the skin, as per sub-section 16.7. h) Persons working with SF6 equipments, especially with SF6 decomposition products, must observe a high personal hygiene standard. Specifically, wiping eyes, mouth and nose should only be performed with disposable tissues. i) Protective clothing must be removed before leaving the work area. j) Processes such as welding, that create high temperatures, must not be carried out where the presence of SF6 and its decomposed products are suspected. k) No smoking in the vicinity of any SF6 equipment is allowed.

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9.3 PERSONAL PROTECTIVE EQUIPMENT

Personnel engaged in handling used SF6, its decomposed products and contaminants, should avoid direct contact by wearing appropriate personal protective equipment (PPE). The following equipments should be provided and made available in quantities sufficient for maintenance and special operational requirements as follows: a) Hooded overalls, overlapping the footwear and gloves b) Protective footwear c) Disposable plastic gloves or reusable industrial type rubber gloves d) Respiratory equipment: • For work in an enclosed area where decomposed SF6 has been discharged, or work inside an SF6 switchgear gas enclosure, a full face mask respirator with air supply is recommended. • For short term inspection and work where ventilation can be provided but where the concentration of used SF6 may exceed the appropriate maximum level, a full face mask with cartridge filter is recommended. • Respirators are not required when the appropriate maximum permissible concentrations of used SF6 gas have not been exceeded as quoted in Section 9.2.

9.4 FIRST AID

First-aid equipment, including eyewash equipment containing a saline solution, must be present at the work site. Means for contacting emergency services and guidance for medical doctors must also be available. First aid treatment is described below.

9.4.1 EYE IRRITATION

Remove the person from the work area. Wash the eye with a liberal quantity of clean water or saline solution. This may best be done using an eyewash basin or by holding the eye open and dipping the head into a basin of water. Seek medical attention following this treatment.

9.4.2 SKIN IRRITATION

Remove the person from the work area. Contaminated clothing should be removed and the affected area of skin washed with soap and water to neutralise and remove the contamination, or where the supply of clean fresh water is limited, rinse the affected area of the skin with the weak sodium bicarbonate neutralising solution. Seek medical advice if the irritation persists.

9.4.3 BREATHING DIFFICULTIES

If breathing is affected by lack of oxygen due to excessive concentration of SF6 or by SF6 decomposition products: • Move the person to fresh air immediately and remove any contaminated clothing • Treat for shock as required and keep under observation • If breathing has stopped, begin EAR and CPR • Call an ambulance or seek urgent medical attention

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9.5 INVESTIGATION KITS

Investigation kits are to be used when investigating possible SF6 gas release due to abnormal condition. The investigation kits must be maintained and kept in a container marked accordingly. The investigation kits should include as a minimum: a) Respiratory protection: Respiratory devices include dust masks, cartridge filter masks, supplied air respirators, and self-contained breathing apparatuses (SCBA). SCBA should only be worn by personnel trained in their use and only for special emergency conditions - Minimum need if the local exhaust ventilation is adequate. b) Hand protection: Chemical resistant protective gloves: Recommended materials: PVC, Neoprene, natural rubber, disposable plastic. c) Eye protection: Chemical resistant protective goggles. d) Skin protection: Chemical resistant overalls. e) Other precautions: Gloves, overalls and boots have to be double layered. f) Sealable plastic bags for holding contaminated items awaiting treatment or disposal or both. g) Shower and eye wash stations h) Sodium bicarbonate i) Warning signs j) Container (10 Litre minimum) for mixing neutralising solution All investigation kits should be inspected during the regular substation inspections, and in particular, consumable items must be sufficiently maintained.

10.0 HANDLING OF NEW SULFUR HEXAFLUORIDE GAS

This section covers the filling of switchgear compartments with new SF6 gas from a cylinder when the equipment is already partially full of gas or following erection or maintenance when the

equipment is at atmospheric pressure without SF6 gas. This section, however does not give full details for specific makes of switchgear as this is covered in detail in the manufacturer’s instructions issued for the particular make and type of switchgear.

When filling switchgear with SF6, precautions to avoid injury to the workforce must be taken. The precautions include, without limitation: a) The concentration of SF6 in an indoor environment is below the maximum permissible concentration of 1000 ppm volume. If concentration exceeds, the area should be ventilated

to restore the concentration to below 1000 ppm volume. The SF6 concentration should be periodically measured with an appropriate SF6 detector. b) The remaining workforce is removed from the immediate area in case fragmentation of porcelain on the switchgear occurs on filling. This may occur due to transport damage or damage caused during erection or maintenance activities.

10.1 EQUIPMENT REQUIRED

The following items will be required during the filling operation: a) Cylinders of SF6 gas; b) Manual handling equipment for gas cylinder; c) SF6 regulator; d) 20 metres (Minimum) of flexible hose with special fittings; e) SF6 detection device; f) Dew point meter; and g) Relevant manufacturers’ instruction for make and type of equipment.

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10.2 CERTIFICATION OF SULFUR HEXAFLUORIDE GAS

Gas supplied with new equipment, must be accompanied with a test certificate to confirm that the

purity complies with IEC 60376 Specification and Acceptance of New SF6, providing maximum acceptable purity levels of new gas. If no test certificate is available, the gas must be tested prior to acceptance into store. When cylinders are likely to be held for lengthy periods in store, there should not be any deterioration of the gas and it can be used without any further tests being necessary.

11.0 HANDLING OF USED SULFUR HEXAFLUORIDE GAS

This section deals with handling of SF6 gas that has been inside a switchgear gas enclosure. The SF6 gas may have become decomposed through arcing during operation or by contamination. The need

to handle used SF6 gas arises where: a) The gas has to be topped up in closed pressure systems; b) The gas has to be removed from the gas enclosure to allow maintenance, repair or extensions to be carried out; c) The gas has been wholly or partially expelled due to an abnormal release; or d) The gas has to be removed at the end of the life of an item of equipment.

Care should be taken to minimize the amount of used SF6 gas released into the atmosphere. Personnel working on or around an installation where used SF6 is being handled should not be exposed to the gas by its release.

11.1 EQUIPMENT REQUIRED

11.1.1 Gas Reclamation Equipment (OPTIONAL): Reclamation of contaminated SF6 should be carried out by gas handling plant in combination with a filter assembly comprising a drier section (molecular sieve), absorbing filter section and a dust trap as illustrated below:

Gas Contaminated Drier Gas Filter Dust Trap Gas Handling Plant Molecular Sieve

NOTE: Refer to Manufacturer’s Instructions for gas recovery equipment to determine the type of gas filter material to be used and type of dust trap. The gas handling plant should be clear of remaining

SF6 to prevent mixing with contaminated gas. Use of cryogenic cleaning processes will enable flushing of contaminants. The gas must be drawn out of the SF6 compartment and passed through the filter of the gas handling plant prior to storage. It is preferable to remove as much gas as possible by reducing the pressure in the compartment to as low as practicable in order to minimize the amount of residue-contaminated gas discharged into the surrounding atmosphere.

The contaminated gas should then be circulated through the filter until the acidity is below 2 ppm HF equivalent. Assistance from a chemical laboratory will be required in measurement of acidity. The molecular sieve and other filtering material may need to be changed during the recycling process to

achieve the required acidity level depending on the level of contamination, or the amount of SF6 gas that has been filtered. (Refer to manufacturer’s instructions) All contaminated filtering material shall be treated and disposed of as described in Section 13.2. The gas handling plant should be flushed clean with dry nitrogen after the treated gas has been either

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transferred back to the SF6 compartment or other storage facility. If there is any doubt about the effectiveness of the flushing, test the acidity of the nitrogen gas to ensure adequate removal of

decomposed SF6.

It is also acceptable to transfer contaminated gas from the gas compartment into temporary storage containers and carry out gas treatment when time permits.

11.1.2 Sulfur Hexafluoride detection equipment: An SF6 detector capable of detecting 20 ppm volume, 200 ppm volume and 1000 ppm volume SF6 in air will be used.

11.1.3 Ventilation equipment: Equipment for forced ventilation of enclosed and inaccessible areas shall be of adequate capacity to provide satisfactory working conditions. The working conditions

relate to the maximum concentrations for used SF6 gas after maintenance or abnormal leakage (200 ppm volume) or internal fault or external fire (20 ppm volume).

11.1.4 Vacuum equipment: A high efficiency dedicated vacuum cleaner, equipped with a disposable HEPA filter capable of trapping particles in the micron range, and a non-metallic open- ended nozzle.

11.1.5 Cleaning materials: Disposable cleaning material, agents and/or solvents as recommended by the manufacturer. As a guide, the following items should generally be used:

. Water supply: A water supply for preparing neutralising solutions . Neutralising Agent: Sodium Bicarbonate or Sodium Carbonate . Solvent: For insulator surfaces: 95% ethyl alcohol & For gas enclosure surfaces and other metal surfaces: Voltz, Citrisol solvents or equivalent . Cleaning material: Lint free cloth or paper . Plastic bags: Sealable plastic bags are to be used for holding contaminated items awaiting treatment or disposal or both.

11.1.6 Facilities and services: When handling used SF6, it is recommended that the following facilities be provided:

a) A clear space, for the period of work on the SF6 gas-filled equipment, designated for the purpose of changing and storing protective clothing, having cold water supplies and containers for the storage of soiled protective clothing. The purpose of this space is to facilitate adequate hygiene by minimizing the spread of decomposition products and also to

assist in obtaining the high standard of cleanliness required during maintenance of SF6 equipment. It is important that this space is not used for eating, drinking or smoking or for the storage of outdoor clothing or other materials not associated with the maintenance of

contaminated SF6 equipment. The size of the space and its facilities will be dependent on the size of the installation and the mass of gas involved.

b) A cold water supply for the preparation of neutralising solutions.

c) A second area, with cold water supply and drainage, for cleansing of clothing, any filter materials and disposable cleaning materials. This area may be at a different location to the designated space in Item (a) above.

11.1.7 Filling procedures: All filling procedures are included as sub-sections 16.1 to 16.7 of this document.

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12.0 DISPOSAL OF SULPHUR HEXAFLUORIDE EQUIPMENT

This section describes procedure for the disposal and/or recycling of SF6 equipment that has been removed from service. The equipment required will be as per Section 11.0 for handling of used SF6 gas. The procedure for the end of life of equipment is in sub-section 16.6. Disposal of empty gas cylinders is described in section 15.0 of this document.

13.0 WASTE MANAGEMENT

Any waste produced must be managed in accordance with Waste Management Procedure (KE-SP- 12). Under no circumstances should treated or untreated filter material or contaminated waste material be burnt, as it may cause the emission of toxic gases. Gloves should be worn at all times when handling contaminated SF6 waste.

13.1 PACKAGING OF CONTAMINATED WASTE MATERIAL

All disposable clothing, rags, internal filters from serviced equipment, vacuum cleaner filters, filters

from the SF6 treatment plant and spent micro sieves should be placed in double layer plastic bags that can be sealed. The bags are to be clearly labelled with their contents.

Contaminated equipment that requires disposal should firstly be placed in double layer plastic bags that have been sealed and then within a rigid container, e.g. metal drum or wooden box. The empty area around the bags should be filled with a suitable material, e.g. newspaper, to prevent the equipment moving during transport and possibly puncturing the plastic.

If the equipment is too large to be placed in bags, then a container shall be prepared. The container shall be impermeable, e.g. large plastic or metal drums, or a wooden crate lined with heavy duty plastic. The equipment shall be secured or packed in such a way as to prevent excessive movement that could puncture the container. The containers are to be labelled with their contents.

All material for disposal should be sent to Sindh Environmental Protection Agency (SEPA) approved contractors with personnel appropriately trained in disposal procedures.

13.2 TREATMENT AND DISPOSAL OF CONTAMINATED WASTE SF6

a) Prepare a neutralising solution of sodium carbonate (ordinary washing soda) in clean water, 3kg per 100 litres, by dissolving it in a suitable container, e.g. bare steel or plastics, and stirring to ensure that all crystals are dissolved. b) Place disposable vacuum cleaner filter bags or cartridges and all contaminated disposable materials, other than filter units or their contents taken from SF6 gas-filled compartments, into the neutralising solution. c) When filter units or their contents have been taken from SF6 gas-filled compartments for disposal, unless otherwise instructed by the manufacturer, prepare a second neutralising solution as above, with a volume five times that of the filter material, and place the filter units into the neutralising solution. d) Stir the neutralising solution(s) and contents of the container(s) for sufficient time to neutralise the arc decomposition products (approximately 15 minutes) checking that the solution remains alkaline (pH>7). e) If the solution is not alkaline add more sodium carbonate and continue the above neutralisation procedure. f) Pour the liquid portion of the used neutralising solution from the waste material in the container(s) into a foul water or sanitary sewer drain and flush it down with water.

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g) Remove the remaining solid materials from the containers (steps (b) and (c) above) and dispose of them according to local regulations or through a waste management contractor. Dispose of any remaining neutralising solution with entrained particles.

13.3 TREATMENT OF REUSABLE PROTECTIVE CLOTHING AND TOOLS

Items of reusable protective clothing may be laundered in the usual manner. If it is considered that the clothing is appreciably contaminated, a small quantity of sodium carbonate (ordinary washing soda) should be added to the wash water to ensure it is alkaline and to assist in the neutralisation of the arc decomposition products.

Boots, rubber gloves and tools, not suitable for laundering, should be wiped free of visible contamination using rags or clean paper tissues and then wiped over with a soft cloth moistened with sodium bicarbonate neutralising solution, as per sub-section 16.7, to neutralise any remaining contamination.

14.0 INVENTORY CONTROL

An inventory control system overcomes the need to monitor the existing gas in equipment by

controlling the gas movements to and from store. The loss of SF6 gas must be avoided and all gas used from store must be verifiable. The HSEQ Manager / Coordinator is responsible for ensuring that

SF6 Inventory Reporting Form (KE-SP-028-02) is completed at the end of each financial year.

14.1 INVENTORY RECORDS: Ongoing records must be maintained to show: a) Quantity of cylinders in stock b) Sequence numbering of cylinders c) Quantity of gas in each cylinder d) Quantity of empty cylinders returned to store e) Quantity of cylinders sent for disposal f) Retired gas cylinder sequence numbers g) Total quantity of gas in store h) Total quantity of gas dispensed from store i) Total gas in installed equipment

14.2 MAINTAINING SPARE GAS: The maximum quantity of gas maintained in a local store must be sufficient to refill the two largest devices in service only at any given Grid Station. Maintaining excess gas is a high environmental risk and is also unnecessarily cumbersome in store.

15.0 GAS CYLINDER STORAGE

All gas cylinders shall be painted with an identifying colour to identify them as being a controlled stock item and assigned an identifying number. Once the contents of a cylinder are used then the cylinder with the next sequential number is to be used.

Cylinders must be handled carefully and stored in a cool, dry, well-ventilated area away from flammable or explosive material. They should be protected from direct sunlight, mounted clear of wet ground and secured to prevent falling over, with their outlet valves upwards. Cylinders should be clearly labelled to identify their contents and should be physically separated into cylinders containing New Gas, Used Gas Ready for Reuse, and Used Gas Not Ready for Reuse.

As with any pressurised gas, there is risk of explosion of cylinders if they are excessively heated as might occur in a fire. Storage outdoors with suitable protection from weather and intense solar

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radiation is recommended. SF6 cylinders must be stored at least three metres from hazardous materials.

16.0 SAFETY PRECAUTIONS

16.1 FILLING A COMPARTMENT CONTAINING AIR

Prior to any activities involving filling or extracting gas, the equipment must be isolated and de- energised in accordance with the Safety Rules. If the compartment has been open to the atmosphere for less than eight hours, proceed with sub-section 16.2.

If the compartment has been open to the atmosphere for more than eight hours, it will be necessary first to dry out the compartment using dry nitrogen as follows: a) Apply a reduced pressure of about 260 Pa (2.6 millibar) for two hours to the compartment using the vacuum pump on the gas handling plant or a separate vacuum pump. b) Fill with dry nitrogen of moisture content less than 120 ppm vol. (15 ppm weight) to a pressure of 120-150 kPa and let stand for five to six hours. c) Measure the moisture level of the nitrogen after five to six hours. If the moisture level is less than 300 ppm vol., exhaust the nitrogen. If the moisture level is greater than 300 ppm vol., repeat items (a) and (b). d) Apply a reduced pressure of 65 Pa to the compartment for 15 minutes. e) Fill with SF6 in accordance with 16.2.

16.2 FILLING A COMPARTMENT PARTIALLY FILLED WITH SF6

Prior to any activities involving filling or extracting gas, the equipment must be isolated and de- energised in accordance with the Safety Rules. The dew point should be checked to confirm acceptability of the gas prior to any topping up. As a minimum, the ambient temperature, the (as) found pressure and the (as) left pressure should be recorded.

a) Remove plug from the valve on the gas cylinder and clear any foreign material from the valve using high pressure air. Make sure the valve is not pointing towards anyone during this procedure. b) Apply a reduced pressure of about 260 Pa (2.6 millibar) for two hours to the compartment using the vacuum pump on the gas handling plant or a separate vacuum pump. c) Connect SF6 regulator to the gas cylinder valve and a purged flexible gas hose to the regulator. d) With regulator closed, open the valve on the cylinder and check the pressure in the cylinder. e) Open the regulator and pressurize the hose to about the same pressure as in the switchgear. f) Connect the hose to the filling point on the switchgear and open the valve on the hose to allow SF6 gas to flow into the switchgear. Slowly open the valve and fill the equipment. (Note: The wider open the regulator, the quicker the gas flow, but also the quicker the temperature of the liquid will fall due to loss of heat with evaporation and a temperature will be reached where no further evaporation will occur without addition of heat to the cylinder). g) If the gas pressure in the bottle drops to the same pressure as in the compartment but it has not filled to the required pressure, it will be necessary to check if there is still liquid in the cylinder by weighing the cylinder. h) If there is no liquid remaining in the cylinder, it will be necessary to extract the remaining gas from the cylinder using a gas handling plant. Obtain a new cylinder of SF6 gas and continue filling, repeating the procedure until the switchgear is filled to the required pressure.

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i) When the required pressure has been reached as read on the gauge on the switchgear compartment, close the regulator. The required pressure for the ambient temperature should be read from the appropriate pressure or temperature graph for the compartment. (Refer to manufacturer’s instructions.) j) Check for gas leakage using one of the following methods appropriate to the particular gas compartment. o Record pressure and temperature at appropriate intervals (as per manufacturer’s instructions or when otherwise instructed by the HSEQ Coordinator) and make necessary temperature corrections to pressure readings. o Using a leak detector, check flanges, couplings, plugs, etc. for gas leakage. o Apply a leak detecting (soap) solution to flanges, joints, couplings, plugs, etc. to check gas leakage. k) Close the valve on the hose and disconnect the hose from the filling point on the switchgear. l) Close the valves on the regulator and on the cylinder.

16.3 TOPPING UP SULFUR HEXAFLUORIDE IN CLOSED PRESSURE SYSTEMS

Prior to any activities involving filling or extracting gas, the equipment must be isolated and de- energised in accordance with the Safety Rules. Topping up SF6 in closed pressure systems should be carried out following manufacturer's instructions.

Gas obtained for topping up of SF6 equipment should be from a known storage facility with test certificates for purity of the gas. The manufacturer’s instructions should give permitted concentration limits for used gas before allowing the gas to be used again after storage. Concentration limits should be obtained for Moisture content; Oxygen content; Acidity; and Hydrolysable fluoride content, expressed as hf.

Top up SF6 equipment as per sub-section 16.2. If the gas is known to be used, handling precautions apply. Personal protective equipment must be worn.

16.4 REMOVAL OF SULFUR HEXAFLUORIDE FROM CLOSED PRESSURE SYSTEMS

Prior to any activities involving filling or extracting gas, the equipment must be isolated and de- energised in accordance with the Safety Rules. Personal protective equipment must be worn.

Removal of SF6 gas from within closed pressure systems should be carried out in accordance with the manufacturer’s instructions.

Removal of SF6 should be carried out through a gas handling plant to allow the gas to be stored. The gas handling plant should be used in combination with a filter assembly comprising a drier section (molecular sieve), absorbing filter section and a dust trap to remove any gaseous and solid decomposition products. The Process In-charge should record the ambient temperature, and atmospheric pressure. The records must be forwarded to the HSEQ Manager / Coordinator.

16.5 FOLLOWING ABNORMAL RELEASES

Prior to activities involving filling or extracting gas, the equipment must be isolated and de-energised in accordance with the Safety Rules. Abnormal release can occur due to leakage, internal fault or external fire.

16.5.1 Due to leakage: Leakage from SF6 equipment will be indicated by low gas pressure indicators and an alarm. During abnormal leakage where no abnormal arcing has occurred, the amount of

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decomposed products released into the air would be minimal. Before work commences, ensure that

the SF6 concentrations are below maximum permissible concentration for used SF6. Personal protective equipment (PPE) must be worn.

16.5.2 Due to internal fault: In the unlikely event of internal flashover in SF6 equipment gas enclosures, arcing will result in a rise of internal pressure that may cause rupture of any fitted pressure-relief devices and, with a reduced probability, may also result in burn-through of the gas enclosure. In these cases, SF6 gas and its arc decomposition products are released to the surrounding air, and the following actions should be taken depending on the particular environment.

16.5.3 Indoor installations or enclosed areas: No entry to the room or enclosed area shall be permitted without protective clothing and breathing apparatus until the decomposition products

have been removed, the area has been ventilated and the concentration of SF6 in air is tested to be less than 20 ppm volume. The presence of the pungent odour of decomposition products will be immediately evident and will provide a warning that rupture of a gas enclosure may have occurred. Personnel entering the room or enclosed area shall proceed as follows:

a) Wear personnel protective equipment (PPE). b) Display warning signs at all entrances. c) Enter and locate the point(s) of burn-through or rupture of the gas enclosure. d) Visually determine the location and extent of arc decomposition product deposits. e) Clean up the deposits, if still in powder form using an industrial vacuum cleaner; otherwise use lint-free rags to wipe off deposits. f) Following the removal of the deposits, force ventilate the room or enclosed area with a fresh-air blower. Areas below where the release occurred should also be ventilated as high

density SF6 may have accumulated at and below floor level. g) Using an SF6 detector, ensure that the concentration of SF6 in air is less than 20 ppm volume before allowing other personnel into the area. Areas below where the release occurred should also be tested. h) Place contaminated protective clothing, contaminated cleaning rags, and if used, the vacuum cleaner filter bags or cartridges in double plastic bags for disposal.

16.5.4 Outdoor installations: The SF6 gas, its decomposition products and much of the entrained solid arc decomposition product particles will normally disperse in air, but the area surrounding the release may be contaminated with solid arc decomposition products in the form of a whitish powder or an acidic sticky grey deposit. Personnel entering this area to inspect the damage or to determine the location and extent of any remaining arc decomposition products shall don protective clothing. When evidence has been found of arc decomposition products:

a) Cordon off the affected area if possible. Display warning signs at the approaches to the contaminated area. b) Clean up the deposits, if still in powder form, using an industrial vacuum. Use lint-free rags to wipe off excess deposits where possible. c) The contaminated areas should preferably be sprayed or wetted down with a neutralising agent as specified in sub-section 16.7. d) The area should be washed down with an ample amount of clean water.

16.5.5 Due to external fire: For persons fighting a fire, precautions normally adopted for protection against vapours from burning plastics will be adequate if equipment has to be approached. Following a fire in an indoor installation, precautions detailed in sub-section 16.5.3 are adopted.

SF6 Monitoring & Management Procedure

KE-SP-028 00 25th June, 2014 16 of 20 Corporate HSEQ Document No. Version Date of Version Page Issuing department

16.6 TREATMENT AT END OF LIFE OF SF6 EQUIPMENT

Prior to any activities involving filling or extracting gas, the equipment must be isolated and de- energised in accordance with the Safety Rules.

16.6.1 Removal and treatment of Sulfur hexafluoride gas: The SF6 gas is to be removed as per sub- section 16.4. The gas may be re-processed for re-use or submitted to a manufacturer of SF6 for re- processing to new condition.

16.6.2 Treatment of the gas enclosure: The number of high-current interruptions by the equipment will determine the amount of decomposition products to be found in the gas enclosure. PPE must be worn as appropriate for the given situation to avoid injury. Outdoor equipment to be removed is to be roped off if possible. Warning signs will be displayed at approaches to the equipment to be removed. If working indoors, ensure that the working area is well ventilated.

Clean up the solid decomposition products from inside the gas enclosure using an industrial vacuum cleaner. Use lint-free rags to wipe off excess deposits where possible. The gas enclosures should be, where practical, filled with a neutralising agent. The gas enclosure is then to be washed down with an ample amount of clean water. All neutralising solutions and rinsing water should be disposed of according to local regulations. The equipment may then be dismantled, removed and handed over to SEPA (Sindh Environmental Protection Agency) certified contractor for ultimate disposal.

16.7 PREPARING A NEUTRALISING SOLUTION

Sodium bicarbonate is recommended for washing the skin. The neutralising solution should be mixed at a rate of 1 kilogram of Sodium bicarbonate to 100 litres of water. It can also be used as a neutralising solution for wetting down of outdoor equipment when mixed at a rate of 1 kilogram of Sodium bicarbonate to 10 litres of water.

Sodium carbonate is recommended for use as a neutralising solution for wetting down of outdoor equipment or for treatment of clothing, reusable PPE or tools and equipments that have been contaminated with decomposition products. The rate of mixture is 3 kilogram of Sodium carbonate to 100 litres of water.

17.0 REPORTING FORMS

• KE-SP-28-F01 - SF6 Incident Reporting Form • KE-SP-28-F02 - SF6 Inventory Reporting Form

SF6 Incident Reporting Form

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PART A (To be completed and signed by the person reporting the event) 1. Full Name: 2. Job Title: 3. Employee #: KE or Contractor: 4. Were you directly involved in the incident? YES/NO

If no, state capacity in completing this form CAPACITY: 5. Date of Incident: 6. Time of Incident:

7. Location: 8. Category  Incident Near miss Non-compliance with relevant legal and other requirements 9. Nature of Incident Equipment Damage Leakage of SF6 Sudden release of SF6 Emission of gaseous products into atmosphere Formation of solid byproducts Improper storage/disposal Observed human health effects o Inhalation Exposure o Suffocation o Irritation o Nausea/ vomiting o Any other Act of Nature (lightning, earthquake etc) 10. Cause of Incident Fire and explosion Inadequate ventilation Inadequate maintenance Lack of skill/training Any other

11. Further details:

Signature: Date of completing this form:

*Send the ORIGINAL form to the HSEQ Manager/Coordinator & Retain one COPY for record

SF6 Incident Reporting Form

KE-SP-028-F01 00 25th June, 2014 18 of 20 Corporate HSEQ Document No. Version Date of Version Page Issuing department

PART B (To be completed and signed by the HSEQ Manager/ Coordinator)

1. Immediate Corrective Actions:

Preventive Measures Identified:

Responsibility: Deadline for Implementation:

Signature: Position: Date of Implementation:

VERIFICATION*

2. Comments:

Signature:

Position: Date of Verification:

CLOSURE (To be signed and closed by the GM - HSEQ) 3. Signature:

Position: Date of Closure:

*(Give information on the verification process, including details of any checks carried out, and reference any audit checklists used)

SF6 Inventory Reporting Form

KE-SP-028-F02 00 25th June, 2014 19 of 20 Corporate HSEQ Document No. Version Date of Version Page Issuing department

INSTRUCTIONS FOR FILLING:

a) Report Annual SF6 Emissions based on Annual Changes in SF6 Inventory

This form will be used to report the annual SF6 emissions based on the annual changes in SF6 Inventory.

Following data is required to complete the SF6 Inventory Reporting Form:

• SF6 gas in inventory at the beginning of the reporting year • SF6 gas in inventory at the end of the reporting year • SF6 gas additions to the inventory (e.g. purchases) • SF6 gas subtractions from the inventory (e.g. sales or returns) • Changes in installed capacity

Gas in inventory refers to SF6 gas contained in storage cylinders, and other storage containers. It 1 does not refer to SF6 gas held in operating equipment.

Gas additions and subtractions refer to SF6 gas placed in or removed from the stored inventory, respectively. Gas additions also include SF6 provided by equipment manufacturers with or inside new equipment.

Complete Tables 1 and 2 to estimate annual emissions. Use the Comments box to describe the means used to obtain a specific quantitative value (e.g. measured, estimated using rough data, or other comments including perceived accuracy of the form entries). Add additional comment sheets if necessary.

b) Accounting for Acts of Nature and Other Non-Preventable Events

An act of nature (e.g. lightning or earthquake) or other non-preventable event of equipment failure (e.g. from a severe electrical fault) that destroys or damages a piece of equipment might result in a 2 sudden, ‘catastrophic’ loss of SF6 to the atmosphere . If SF6 loss to the atmosphere occurs as a result of an act of nature or other non-preventable event, this loss should be reported on the form kept separate from normal annual emissions.

1 Reporting is required only on the change in inventory, not the absolute value. This method assumes gas is being added to equipment as needed to ensure adequate insulation. 2 The term ‘non-preventable’ does not include releases from properly functioning equipment (caused by static and dynamic operation) or leakage (e.g., caused by deteriorated and leaking gaskets or seals)

SF6 Inventory Reporting Form

KE-SP-028-F02 00 25th June, 2014 20 of 20 Corporate HSEQ Document No. Version Date of Version Page Issuing department

Date Office Contact Table 1 Inventory Amount (lbs) Comments A Beginning of year B End of year

Table 2 Additions to Inventory

1. Purchases of SF6 (including SF6 provided by Amount (lbs) Comments equipment manufacturers with or inside new equipment)

2. SF6 returned to the site after off-site recycling

C: Total Additions (add items 1 and 2) Subtractions from Inventory

3. Sales of SF6 (to other entities, including gas left Amount (lbs) Comments in retired equipment)

4. SF6 returned to supplier

5. SF6 taken from storage or equipment and disposed of

6. SF6 taken from storage or equipment and sent off site for recycling D: Total Subtractions (add items 3-6)

Change in Installed Capacity 7. Total installed capacity of new equipment Amount (lbs) Comments

8. Total installed capacity of retiring equipment

E: Change in Installed Capacity (subtract item 8 from item 7)

Total Annual Emissions = A – B + C – D – E

Table 3 Release from Act of Nature or Other Unpreventable Event Type of Event3 Equipment damaged Amount released (lbs) Comments

3 Lightning, earthquake, electrical fault, vandalism, etc

Training Report

Awareness on Asbestos Management

The issue of Asbestos Management has repeatedly been raised by Corporate Compliance and Environment Section (CHSEQ) through EHS Audit actions points and SLA criteria at all BUs

At beginning of this year GSM decided to go for asbestos removal and a survey, where it was assessed that prior to any such action they must be given a basic asbestos management training to effectively and efficiently perform the required task. Henceforth, nominations were acquired from Grids (GSM & GSP) and first session of two hour interactive training was imparted to management and non-management staff of the department.

Moving onwards with the program, Supply Chain departments which can come in contact with Asbestos and Asbestos Containing Materials that are Inventory Management, Transformer Workshop, Fleet Management and Real Estate were given due importance and a two hour interactive session was organized after revising the previous module in accordance with the audience.

A third revision of module was performed to address the audience of BU Generation. Two hour interactive sessions were organized covering management staff at BQPS-I, BQCCP, KCCPP, KTGTPS & SGTPS.

In the last phase, nominations from BU Distribution and previously left out supply chain department that is Procurement were invited. In the similar fashion fourth revision of the module was performed to address the electrical engineers. Two highly interactive sessions were organized for managers performing additional roles of HSEQ.

Apart from the specific issues of the areas related to Asbestos varying from BU Supply Chain, Generation, Grid and Distribution main components of the module were;

1. Identification of Asbestos, Industrial Terms and Uses

2. Risk Assessment, Identification and Implementation of Controls

3. Handling and Disposal of Asbestos

The modules used during the training have been shared with the participant through emails however to further formalize and strengthen the Asbestos management culture whose base is developed in these sessions, a corporate level Asbestos Management Procedure shall soon follow.

A summary of sessions is below;

Number of SNO Date Time Location Participants Training Room, Elander 1 22nd Feb, 2013 1000 to 1200 Hours 25 Road 12th Floor, Technology 2 3rd April, 2013 1000 to 1200 Hours 19 Park Conference Room 3 29th May, 2013 1030 to 1230 Hours SGTPS 22 4 30th May, 2013 1030 to 1230 Hours KTGTPS 22 5 3rd June, 2013 1030 to 1230 Hours Bin Qasim - I 21 6 4th June, 2013 1030 to 1230 hours Bin Qasim II 18

7 5th June, 2013 1030 to 1230 hours KCCPP 30 12th Floor, Technology 8 2nd Oct, 2013 1000 to 1200 hours 22 Park Conference Room 12th Floor, Technology 9 3rd Oct, 2013 1500 to 1800 hours 25 Park Conference Room 204 Total Participants

Training Report Awareness Sessions on EIA/IEE

An awareness session was organized for the departments of KESC which perform or are somehow related to new project activities. Purpose of the training was, to aware the target audience on applicable environmental regulation of Initial Environmental Examination & Environmental Impact Assessment.

Manager to Deputy Director from departments PID, Engineering & Construction, Works & Real Estate, Strategy & Business Development, Generation (Planning) and Grid & Transmission were nominated for the session. All HSEQ coordinator across the KESC from departments Medical, Fleet Management, Inventory Management, Generation, Distribution, New Connection, Transformer Workshop, PSC, Grids, LDC, Transmission and Administration were also invited to attend the session.

Three batches of highly interactive two hour sessions were organized at AZM Learning Institute by General Manager Corporate Compliance & Environment (CHSEQ) Chander Perkash, during which following topics were discussed in detail;

 Environmental Laws & Regulations In Pakistan

 EIA/IEE Regulations & Requirements

 Non Compliance and Penalties as per Pakistan Environment Protection Act 1997

 KESC Activities and IEE / EIA

At the end of session, participants were encouraged to communicate and coordinate with Corporate Compliance & Environment Section, Corp. HSEQ to ensure compliance to all applicable environmental laws and regulations. Copies of following documents have been dispatched via emails to all the participants.

 Copy of the training module for ready reference

 Extract of Schedule I & II of IEE/EIA Regulation 2000

A brief summary of attendees and pictures of sessions follows;

LIST OF EMPLOYEES TRAINED SNO NAME DESIGNATION DEPARTMENT EMP NO 1 Asif Mateen GM BQPS-1 80009195 2 Aijaz Ul Haque GM KTPS 80009526 3 Sirajuddin Ahmed Khan GM Grids 7202 4 Khozema Shabbir DGM Grids 9950 5 Ejaz Rashid GM Grids 7183 6 Shujauddin M. Anwar Manager Grids 7656 7 Abdul Saleem GM Grids 80009751 8 Ghulam Mujtaba Manager Grids 80000107 9 Faiq Murtaz DGM Grids 80009759 10 Muhammed Adil DGM Grids 80009760 11 Muhammad Bilal Ahmed Mirza HOD PID 80009628 12 Ghayoor Ahmed Qureshi DGM PID 7563 13 Syeda Saman Shakeb Rizvi Manager PID 80008845 14 Faraz Ali Manager PID 80009707 15 Allauddin Ahsan Farooqui GM E&C 80009775 16 Nazir Ahmed DGM E&C 7347 17 Sultan Ahmed DGM E&C 7414 18 Adnan Adeel Memon Manager E&C 80000492 19 Naveed Memon Manager E&C 80000460 20 Ismail Jatoi DGM E&C 80009755 21 Aliuddin Hassan DGM Transmission 90009857 22 Alam Sher DGM Transmission 7454 23 Nasir Masoom GM Real Estate 80012136 24 Muhammad Anwar Malick HOD Real Estate 80012075 25 Jahanzeb Khan Manager BQPS-2 80012164 26 Syed Zulfiqar Ali Manager Real Estate 80009102 27 Riaz Ahmed Nizaman DGM R-I HT 80009731 28 Ashfaquddin Ahmed GM R-II LT 8011647 29 Masood Alam Bajwa Manager R-I LT 80000172 30 Imran Shaikh Manager R-IV LT & HT 80009224 31 Athar Ali Shah Banoor DGM FM 80009133 32 Mr. Azdiar Mobed GM FM 80012067 33 Ali Ejaz Syed DGM PSC 80009253 34 Muhammad Aslam DGM Grids 80009916 35 Ravi Laxman Manager Grids 80000246 36 Jamil Ahmed. DGM Grids 7647 37 Zahir Ahmed Shaikh DGM Grids 7334 38 Fahad Waheed Manager Grids 80008846 39 Ishtiaq Manager Grids 9881 40 Noman Zaidi Manager Grids 7630 41 Hassnain Shah Manager Grids 80000498 42 Omeal Ahmed. GM PID 7568 43 Syed Anwarul Haq Manager PID 8009516

44 Aurangzeb Zainul Abdin Manager PID 7408 45 Syed Muhammad Asif Ali Manager PID 8009742 46 Syed Naveed Ur Rehman DGM E&C 7382 47 Nasir Iqbal Manager E&C 80008608 Abdul Razzaq 48 Shaikh Manager E&C 80008413 49 Mohammad Memon DGM E&C 80009699 50 Talha Zia Manager Transmission 80008868 51 Mohammad Iqbal Ahmad DGM Transmission 80009506 52 Ramesh Kumar DM R-I 80008831 53 Dilawar Khan Manager BQPS-2 80012053 54 Dr. Tofique Ahmed Soomro Manager Medical 80012484 55 Sohail Hussain Manager Transformer Workshop 7597 56 Sajid Ali Manager Grids 80000384 57 Muhammad Taimoor Manager Grids 80008852 58 Muhammad Mehmood Elahi DM Grids 80010259 59 Shahid Mehmood DGM PID 7241 60 Syed Inam Mehdi Manager PID 7412 61 Abid Khokar Manager PID 80000503 62 Mohammad Muzaffar Khan Manager PID 7579 63 Muhamad Arif Khan Manager PID 7672 64 Shahnaz Ali DGM E&C 7353 65 Muhammad Zuhaib Manager E&C 80011846 66 K.D Khatri DGM Transmission 80009681 67 Zahid Ahmed Khan DGM Transmission 80009680 68 Tanveer Rana Manager Transmission 7258 69 Umar Mashkoor Makhdumi GM Real Estate 80012151 70 Raj Kumar Manager Real Estate 7476 71 Muhammad Mazhar Alam Manager Real Estate 7553 72 Jalil Ahsan Syed DGM LDC 7641 73 Murtaza Qamari Manager R-III HT 7529 74 Hira Rehman DM R-III LT 80009162 75 Mola Bux GM R-III LT 7455 76 Kashif Iqbal Ghazi DGM New Connection 80009604 77 Moinuddin Mannan AM SGTPS 7956 78 Zakiuddin, Syed Manager KTGTPS 80009181 79 Syed Zeeshan Mumtaz Manager KTGTPS 80009841 80 Muhammad Saad Hafeez DGM KTGTPS 8001182 81 Jahanzeb Khan Manager BQPS-2 80011736 82 Rashid Kareem DM BQPS-1 83 M. Amir Iqbal DGM KCCPP-II 80011720 84 Muhammad Khurram DM IM 80012107 85 Syed Asif Ali DGM Transmission 80009748 86 Abdul Hamid AM LDC 2483 87 Agha Wajeehuddin Shah GM SGTPS 80011993

Training Report

Implementation of Environmental Management Plan

A comprehensive training module on “Environmental Management Plan” was prepared focusing on effective implementation of EMP for legal compliance.

In this regard a training session was organized at KE House (Cafeteria) on 21st of February for PID department. Mr. Chander Perkash, GM (CC&E), the lead trainer for the session initiated by highlighting the learning objectives as;

 Increase knowledge level and awareness of EMP developed for the proposed project sites  Increase skills for undertaking activities related to EMP implementation  Increase capacity for initiating the process of EMP implementation

Through his vast experience in K-Electric, background in Environmental Sciences and relevant exposure in the field, he kept audience indulged and passed on the knowledge required to understand the various facets of EMP. He was assisted by Ms. Beena Riaz, Manager (CC&E) in presenting slides and answering the queries raised by the participants.

From the very beginning, participants were encouraged to interact and ask questions. Through this process of interaction, vital knowledge and skills for implementing environmental management plan were transferred to the audience. PID team is already submitting EMP at set frequency for AKU Grid Station Project – Construction Phase and thus had some basic knowledge of the subject. The training is expected to further enhance the quality and ensure efficient and timely delivery of these reports for onward submission to the regulatory authorities.

At the end of the session, a short quiz was conducted, duly filled by all. The overall results show that the participants were able to understand the topic well. A copy of the presentation was given to the department. The feedback forms were also gathered for further improvement in presentation content and delivery style as suggested by the participants.

In phase one of the training, 40 employees (AM-GM) from PID department were trained. More such sessions would be arranged for managerial staff of BU Distribution, Generation and Supply Chain etc to ensure same level of environmental awareness throughout the company.

DISTRIBUTION OF PARTICIPANTS

ATTENDANCE SHEET

TOPIC IMPLEMENTATION OF ENVIRONMENTAL MANAGEMENT PLAN

BOC Building, KE House 39-B, Sunset Boulevard DATE 21-02-2014 LOCATION DHA II, Karachi TIME 1000 - 1200

SNO NAME DESIGNATION DEPARTMENT EMP NO

1 BILAL A MIRZA Dy. Director PID 8009628

2 OMEAL AHMED General Manager PID 7568

3 GHAYOOR A. QURESHI Deputy General Manager PID 7563

4 SOHAIL RAIS SIDDIQUI Deputy General Manager PID 80009516

5 AURANGZEB ZAIN Deputy General Manager PID 80009742

6 SHAHID MEHMOOD Deputy General Manager PID 7241

7 FARAZ ALI Deputy General Manager PID 80009797

8 SHABBIR CHAND Manager PID 80013026 9 MUZAFFAR KHAN Manager PID 7579 10 M. ARIF KHAN Manager PID 7672 11 ABID KHOKHAR Manager PID 80000503 12 SYEDA SAMAN SHAKEB RIZVI Manager PID 80008845 13 SYED INAM MEHDI Manager PID 7412 14 KAMRAN MUHAMMAD KHALIL Manager PID 80012542 15 AHSAN FAWAD Manager PID 80012742 16 MUHAMMAD KHURRAM SHEHZAD Dy. Manager PID 80013012 17 SHARJEEL AHMED Dy. Manager PID 80000487

18 MUHAMMAD NAEEM Assistant Manager PID 80000385 19 ABDUL SAMAD ANWER Assistant Manager PID 80012210

20 ABDUL MANAN CHACHAR Assistant Manager PID 80011478

21 SAAD UL HAQ Assistant Manager PID 80009222 22 S. MOHIB UR REHMAN Assistant Manager PID 80011783 23 MEHBOOB SUBHANI Assistant Manager PID 80011850 24 CH. HUZAIFA WAHEED Assistant Manager PID 80013022 25 MUHAMMAD BILAL Assistant Manager PID 80012225

26 FARAZ AHMED KHAN Assistant Manager PID 80013013

27 MAAZ SIDDIQUI Trainee Engineer PID 60000931

28 MARYAM ASIF Trainee Engineer PID 60000932

29 ZULFIQAR A MEMON Trainee Engineer PID 60000933 30 HUNAIN Trainee Engineer PID 60000937

31 TANVEER AHMED Senior Assistant Engineer PID 6105

32 HASAN AHMAD KHAN Assistant Engineer PID 80010306

33 QAISER RAZA JAFFERY Associate Engineer PID 14880

34 M. ZAFAR IQBAL Management Support Exc. PID 466 35 WAHEED MAQSOOD DCO PID 80010163 36 S.M.ABBAS DCO PID 80010177 37 ALI AHMED RIZVI DCO PID 80011163 38 MUHAMMD HAMID KARKUN PID 10604 39 MEHMOOD KARKUN PID 10809 40 IFTIKHAR ALAM GM LDC 7473 41 IQBAL AHMAD DGM TXNW 80009506 42 MUHAMMAD ABDUL FAHIM DGM CHSEQ 80008996 43 M.IMRAN MANAGER CHSEQ 80008798 44 SELMAN HEMANI DM CHSEQ 80011776 45 M.QASIM AM HSEQ 80011734

PICTURES OF PARTICIPANTS

Training Report

Training Topic: Environmental Incidents & Impacts

Trainers: Mr. Chander Perkash & Ms. Beena Riaz

Training Dates: March 24 - 27 and April 15, 2014

A comprehensive training module on “Environmental Incidents & Impacts” was prepared by Corporate Compliance & Environment Section and run across the generation plants.

In this regard five (05) training sessions were organized at BQPS-I, KPC, KTGTPS, SGTPS and BQPD-II on March 24, 25, 26, 27 and April 15, 2014 respectively.

The learning objectives were as follows;

 Develop understanding of an environmental incident / violation

 Identify and report an environmental incident / violation at the workplace

 Plan response to environmental incident / violations and emergencies

 Investigate for Root Causes

Mr. Chander Perkash, GM (CC&E) & Ms. Beena Riaz, Manager (CC&E) conducted the trainings. They covered the various aspects and provided information related to environmental incidents for the knowledge of audience. The participants were encouraged to interact and ask questions from the beginning. Through this process of interaction, vital knowledge and skills for identifying environmental incidents and understanding environmental legal obligations were transferred to the audience. Power Generation Plants are already being monitored for the effluents and emissions, and regular environmental monitoring reports are being submitted to the Sindh Environmental Protection Agency in accordance with Self Monitoring & Reporting Initiatives. The results are in compliance with the National Environmental Quality Standard and the staff thus has some basic knowledge of the subject. At the end of the session, a short quiz was conducted, duly participated by all. The overall results reflect that the participants were able to understand the topic well. A copy of the presentation was given to the HSEQ Coordinator at each plant. The feedback forms were also gathered for further improvement in presentation content and delivery style. New topics for future trainings were also gathered. The first phase of training was carried out in December 2013. In the second phase, 97 employees (AM-GM) from Generation Plants were trained. More such sessions will be arranged for the managerial staff of other units to ensure same level of environmental awareness throughout KE. DISTRIBUTION OF PARTICIPANTS

Designation General Dy. General Manager Dy. Assist. Assist. Others Manager Manager Manager Manager Engineer

No. of 7 10 20 8 25 8 19 Participants

PICTURES OF PARTICIPANTS

Training Report

Special Training: Environmental Awareness & Waste Management

Trainer: Ms. Beena Riaz

Training Date: May 14, 2014

Venue: SITE Gas Turbine Power Station

A special training module on “Environmental Awareness & Waste Management” was prepared by Corporate Compliance & Environment Section on the request of SGTPS.

In this regard a training session was organized at SGTPS on May 14, 2014.

The topics covered were as follows:

. Introduction to Environment . Global Environmental Issues . Global Warming . Ozone Depletion . Acid Rain . Deforestation . Human Health Impacts . Local Perspective . Waste Management . Environmental Aspect/Impact Identification

Ms. Beena Riaz, Manager (CC&E) conducted the training. The session was based on interactive participation by all. The participants were encouraged to share their knowledge and experience with each other and ask questions without any reservations.

At the end of the session, a short quiz was conducted. The overall result is indicative of the fact that the topics were well received by the participants. A copy of the presentation was given to the HSEQ Coordinator.

The feedback forms were also gathered for further improvement in presentation content and delivery style. New topics for future trainings were also gathered.

The training was attended by 23 employees (Trainee - DGM).

DISTRIBUTION OF PARTICIPANTS

DGM Manager DM AM AE Trainee Others

PICTURES OF PARTICIPANTS

ATTENDANCE SHEET

TOPIC: ENVIRONMENTAL AWARENESS TRAINING DATE: 14-05-2014 LOCATION: SGTPS TIME: 10am – 12:30pm SNO NAME DESIGNATION DEPARTMENT EMP NO 1 Irfan Ali Shabbir Assistant Manager E & I/C 2 Khurram Afzal Qureshi Assistant Manager E & I/C 3 Osama Shafique Assistant Manager E & I/C 4 Haji Mohammad. Associate Engr. E & I/C 5 Mohammad Bilal Trainee Engineer M/M 6 Mohammad Adil Assistant Manager M/M 7 Syed Ahmed Ali Sr. AE M/M 8 Istafa Arif Sr. AE M/M 9 Saqib Shaheen Manager Perf. 10 Ansab Ali Assistant Manager Perf. 11 Syed Wasim Hasan DM Admin Admin 12 Syed Ahmer Sibtain Sr. AE Admin 13 Irfan Tahir AM E & I/C 14 Saeed Akhtar DGM Operation 15 M.Iqbal Manager S&K 80013088 16 Javed Manager Operation 80011806 17 Zuhair Zahid Trainee Performance 80001184 18 Nadeem A.Khan Sr.AE Operation 7961 19 Syed Aman Sr.AE BA 80011015 20 Syed Sajjad Hussain - B.O 3515 21 Kazi Mohammad Khalid - - 6943 22 Asghar Ali - - 10621 23 Moinuddin Manan Manager HSE 10621

Training Report

Training Topic: Monsoon Safety & Summer Preparedness

Trainers: Mr. Chander Perkash

Training Dates: June 09 – 11, 2014

A comprehensive training module on “Monsoon Safety & Summer Preparedness” was prepared by Corporate Compliance & Environment (CC&E) Section and run across the generation plants.

In this regard three (03) training sessions were organized at AZM Learning Institute on 9th, 10th and 11th June, 2014 respectively.

The learning objectives were as follows:

 Develop an understanding of overall Health & Safety Risks in Generation Plants  Focus specifically on the Health & Safety Risks during Monsoon & Summer season  Manage Risks and Plan Response to Emergencies

Based on his two decades experience in Generation Plants and being an HSE Expert, Mr. Chander Perkash, GM (CC&E) prepared an extensive training module and conducted the trainings. He covered almost each and every HSE aspect related to generation plants in general and HSE issues triggered during monsoon and summer in particular.

Effective videos and real pictures were shared at regular intervals, to which the participants associated with easily. This kept them engaged till the end of the session. Besides, the participants were also encouraged to interact and ask questions from the very beginning.

Through this process of interaction, vital knowledge and skills for identifying and managing HSE risks during monsoon and summer season were transferred to the audience.

Power Generation Plants are already taking preventive actions through pre-monsoon inspections and no major accident during monsoon has been recorded for the past two years now. These training sessions are expected to further enhance their understanding and effectiveness of skills. Overall 56 employees from Generation Plants were trained A copy of the presentation is given to each participant for their record.

DISTRIBUTION OF PARTICIPANTS

DGM Manager DM AM AE Others

PICTURES OF PARTICIPANTS

ATTENDANCE SHEETS

TOPIC MONSOON SAFETY AND SUMMER PREPAREDNESS LOCATION AZM LEARNING INSTITUTE 9th June 2014 SNO NAME DESIGNATION DEPARTMENT EMP NO SIGNATURE Electrical/ 1 Irfan Shabbir AM 80012461 Present SGTPS Muhammad Farukh 2 AM MM 80009673 Present Shahzad 3 Rasool Bux AE MM 80011920 Present 4 Abdul Haleem Admin Present 5 Pervez Khan Associate Engineer I&C 80012409 Present 6 Abdul Rasheed SR AE Operation 5574 Present 7 Multasim Electrical officer Electrical 80009166 Present 8 Shakeeb Jaweed Trainee Engineer I&C 60001021 Present 9 Hasan Haider I & C Technician I&C 13857 Present 10 Kh Ghayazuddin Foreman I&C 6313 Present 11 Shakeel Ahmed. Associate Engineer Boiler 6440 Present 12 M. Farrukh Nawaz Senior officer OHSE/Admin 80012929 Present 13 Shahid Hafeez. Manager Chemical 80000063 Present 14 Faraz yousufi DM Performance New joining Present 15 Muhammad hadi AM Mechanical 80011766 Present

16 Nasir Jamal DGM Mechanical 80011951 Present 17 Arif Sr.AE 6005 Present 18 Shahid Razak Manager HSEQ 80013043 Present 10th June 2014 19 Mirza Saad Ali Baig Manager Operation 80012916 Present 20 Abid Hassan Charge man Operation 5554 Present 21 Hussian Ahmed Siddiqui AE Operation 3566 Present 22 Sami Uddin Sr AE Operation 5941 Present 23 Muhammad Shahid Associate Engineer I&C 80011835 Present 24 Ghuffran HVAC officer Electrical 80009406 Present 25 M. Rafiq Malik Associate Engineer Electrical 80009744 Present 26 Muneer Skilled Fitter Electrical 4077 Present 27 Muhammad Nawaz AE MM 80011018 Present 28 Mr. Ali Akber Mazari Manager Electrical 80008842 Present 29 Munawar Almani Junior Officer Planning 80012893 Present 30 Shahab Akhtar Manager Store 80009790 Present 31 Waqar Ahmed Asstt. Manager Operation 80011594 Present 32 Umair Abid DM Operation 80012509 Present 33 Waqar Ahmed AM Electrical 80012022 Present 34 Salah Uddin AE HSEQ Kccpp 3584 Present 35 Manazar Jafri Sr.AE Performance 5862 Present 11th June 2014 36 M. Waqas Ejaz Ali Asstt. Manager Elect. & Inst. 80012980 Present 37 Muhammad Zubair Sr. A.E Operation 1534 Present 38 Kamran Shams DCO Admin / SGTPS 80010068 Present Operation / 39 Kamran Manzoor Sr. AE 80012045 Present SGTPS Operation / 40 Tariq Mohammad AE 80010068 Present SGTPS 41 Naeem Tahir AE MM 80009391 Present 42 Zia Ur Rehman Officer Admin 7882 Present 43 AHSAN AFTAB Associate Engineer I&C 80012551 Present 44 Azeem Semi Skilled Fitter Electrical 5725 Present 45 Raghib Mehmood Sr AE Operation 7935 Present 46 Sabir KHan AE Operation 5582 Present 47 M. Amir Admin Present 48 NAJAM ALI Associate Engineer I&C 80012232 Present 49 Syed Nasir Ali Manager Operation 7696 Present 50 Syed Kamran Iqbal AssociateEngineer. BOP 80011009 Present 51 M. Sulman DAE APPRENTICE Turbine 60001230 Present 52 Syed Raza Hussain Manager Electrical 80008958 Present 53 Abdul Waheed Tech. officer Workshop 7912 Present 54 Murtaza Adeeb AM Mechanical 80012110 Present 55 Mateen AE Mechanical 80013039 Present 56 Rashid Adil Bhatti DM Admin 80012422 Present

Training Report

Awareness Session on EHS Audit Compliance for Distribution

As a part of Corporate Compliance & Environment’s business, yearly updates are acquired from all the departments on action points of EHS Audit of T&D assessts carried out by M/s 0EcoConServ in the year 2009. In April, 2013 updates were requested from all the departments including GSM, Transmission, Transformer Workshop, Inventory Management and Substation (HT). During the process it was observed that numerous representatives of Substation (HT) department, who earlier were reporting the compliance, have moved on or their portfolios have been changed. After a little effort and correspondence, information was communicated to relevant personnel. As expected most these representatives lacked the background information and compliance knowledge, therefore a need to plan awareness session on EHS Audit Compliance was sensed.

A two hour awareness session was planned on 1st October, 2013 at 12th Floor Technology Park for higher and middle management that is manager to general manager and HSEQ coordinators of HT- Substation departments of all the regions. For refresher HSEQ coordinators of GSM, Transmission and Transformer Workshop were also invited to attend the session.

Highly interactive sessions were conducted by GM Corporate Compliance and Environment, Chander Perkash with active participation and two-way experience sharing; covering from background of EHS and EHS Aduit in KESC, IFC Action Plan and extending to detailed discussion on all the 21 action point of audit for Substation (HT) department.

Out of 24 nominees for the session, 18 were able to attend and actively participate in the sessions. List of participants follows with report. At the end of session, participants affirmed the commitment to take necessary actions on audit points. The presentation module used during the session has been send to participants for ready reference.

LIST OF PARTICIPANTS

SNO NAME DESIGNATION DEPARTMENT EMPLOYEE NO 1 Mola bux GM LT R-III 7455 2 Mohammad Ali Qureshi DGM HT R-III (South) 7437 3 Idal Abbasi DGM HT R-III (East) 80009683 4 Wajid Ali Memon Manager SSM R-3 SOUTH 80000233 5 Masood Khaliq Manager SSM R-3 EAST 7671 6 Suhail Ahmed Shaikh Deputy Manager DCDO OFFICE 80009440 7 Murtaza Qamari E.E H.T P.M 7529 8 Munaim Akhter Assistant Manager HSE Coordinator 80012595 Deputy Executive 9 Ramesh Kumar OPN 80008831 Engineer 10 Muhammad Bilal Shaikh HSE Coordinator DCDO Office 80012265 11 Tariq Ali Manager SSM HT R2 ( Soc ) 80008824 12 Azam Shaikh Manager SSM HT R2 ( Def) 80000512 13 Hira Rehman DM DCDO OFFICE 80009162 14 Shahid Nadeem Manager SSM 9878 15 Muhammad Raza Manager UGM 9875

16 Imran Sheikh Manager DCDO OFFICE 80009224 Safety Coordinator 17 Muhammad Iqbal Ahmed DGM 80009506 (TNX) Safety Coordinator 18 Zaheer Ahmed Shaikh DGM 7334 (GS)

Training Report Awareness Session on Environmental Incidents and Impacts

A very detailed though basic Environmental Incidents and Impact training module was prepared which intended to take departments Grid, Transmission, Transformer Workshop and IM a step ahead towards achievement of ISO 14001 Environmental Management System Certification.

In this regard a training session was organized at 1st Floor Civic Center on 5th of December for Grid (GSM East, West, North, South, and Protection), Transmission (OH and UG), Transformer Workshop and Inventory Management.

Mr. Chander Perkash, trainer for the session initiated the session by highlighting the learning objectives as;

 Develop understanding of an environmental incident / violation  Identify and report an environmental incident / violation at your workplace  Plan response to environmental incident / violation and emergencies  Investigate Root Causes

Through his vast experience in KESC, background in Environmental Sciences and relevant exposure in field he kept audience indulged and passed on the knowledge required to understand environmental issues. From the very beginning, audience was encouraged to interact and raise queries. Through this process of interaction, vital tools for environmental management were transferred to the audience.

Several practices of environmental management already in place at KESC and industrial best practices as well were shared with audience to have practical knowledge of the management.

In phase one of the training, 27 managers from target departments were trained. More such sessions would be arranged for managers of BU Distribution, Generation and Supply Chain as well to ensure same level of environmental awareness throughout the company.

LIST OF EMPLOYEES TRAINED

SNO NAME DESIGNATION DEPARTMENT EMP NO 1 Mubbasher Hussain GSM East T.E 60000961 2 Muhammad usama GSM East T.E 60001182 3 Jamil Ahmed GSM west D.G.M 7647 4 Shuja M.Anwer GSM west Manager 7656 5 Farhan Ahmed GSM West T.E 60001026 6 Syed Adeel Shaukat GSM West T.E 60001028 7 Muhammad Salman Younus GSM North T.E 60001005 8 Muhammed Khalid Ahmed GSM North A.M 80011860 9 Asif Tameez GSM south T.E 60000962 10 Sajid Ali GSP Manager 80000384 Syed Muhammad Saad 11 GSP A.M 80011949 Aminuddin 12 Manzoor Ali Khan Qaim Khan GSP A.M 80011573 Mohammad Hossein 13 GSP A.M 80012538 Rahimnezhad 14 Zahir ahmed Shaikh GSM HSE D.G.M 7334 15 Kashif Memon GSM HSE A.M 80011632 16 Faraz Ahmed Khan TMOH DM 80009393 17 Maaz Ahmed TMOH AM 80011873 18 Masood Elahi TMOH AM 80011604 19 Alam Sher TMUG DGM 7545 20 Ashfaque Ahmed TMUG DM 8000059 21 Kamran Muzaffar TMUG AM 80012244 22 Abdul Haq IM DGM 7566 23 Shamuel Shees IM AM 80011919 24 Amir Haider Zaidi IM AM 3695 25 Adnan IM AM 80012096 26 Anwar Ashraf Ali TWS DM 80012102 27 M. Irfan Ibrahim TSW DM 80012699

Safety Inspection Report

Annexure - B

Energy Conservation Department Milesstones July '2013 ~ May '2014

Energy Conservation Activity Activity Addressed Date July 2013 NED University (IEEE - Power & Energy Society (PES)) Interactive Session 500 IN-HOUSE - Climate Change Policy adhering CEO EC Guidelines (11 IBCs) Interactive Session 600 04~31-July-13

August 2013 IN-HOUSE - Climate Change Policy adhering CEO EC Guidelines (06 IBCs) Interactive Session 280 05~28-Aug-13 Port Grand (Bohra Community) BTL 20,000 16~18-Aug-13 Shelter Public School Interactive Session 80 21-Aug-13 Harvard Grammar School Interactive Session 300 29-Aug-13 The Vision School Interactive Session 200 30-Aug-13

September 2013 IN-HOUSE - Climate Change Policy adhering CEO EC Guidelines (04 IBCs) Interactive Session 215 04~23 Sep-13 The Vision School Interactive Session 100 2-Sep-13 ECD Seminar at Rangoon Wala in Collaboration with USAID Seminar 100 6-Sep-13 NCFL Orientation (In-House at A.L.I) Orientation 70 09~10-Sep-13 Workshop at PHMA (Pakistan Hoisery Manufacturing Association) Workshop 40 11-Sep-13 Little Folks School Interactive Session 200 16-Sep-13 Okhai Memon Jamat School Interactive Session 700 18-Sep-13 Railway Govt. School Interactive Session 100 23-Sep-13 Govt. Technical Grammar School Interactive Session 300 25-Sep-13 Azam Learning Institute (Solar Transformation) (5KVA) Transformation 25-Sep-13 True Guide Grammar School Interactive Session 120 26-Sep-13 Boston Grammar School Interactive Session 130 26-Sep-13 Region 4 HT-Control Room & DD Room Transform on LED Transformation 28-Sep-13 NED University (New Comers Students) BTL 7,000 30-Sep-13 Workshop on "Save energy Rather Generate" at A.L.I with Trainees Workshop 50 30-Sep-13

October 2013 EC Awareness at Seminar on LED Light by Gneral Electric (G.E) Seminar 100 2-Oct-13 13th Information Technology Communication Network (ITCN) ASIA 2013 BTL 10,000 08~10-Oct-13 North Hill Academy Interactive Session 200 22-Oct-13 The Sesame School Interactive Session 180 23-Oct-13 West Minister School Interactive Session 100 24-Oct-13 EC Awareness at Seminar on Quality Standard by PSQCA Seminar 300 24-Oct-13 Shah Public School Interactive Session 180 25-Oct-13 Dr. Shah Secondary School Interactive Session 100 28-Oct-13 Industrial Electrical & Electronics Exhibition of Pakistan (IEEEP) Fair 2013 BTL 10,000 29~31-Oct-13 Fatmiyah Girls School Interactive Session 1,000 29-Oct-13 Brilliant Acdemy Interactive Session 100 30-Oct-13 Juful Hurst Girls Secondary School Interactive Session 300 31-Oct-13 Workshop on EC Awareness A.L.I with Dawood University of Engineering & Tech. Workshop 60 31-Oct-13

November 2013 Kiran Kids Academy (Gulistan-e-Johar) Interactive Session 60 1-Nov-13 Central Grammar School (Nazimabad) Interactive Session 200 1-Nov-13 The Vision School (N.Nazimabad) Interactive Session 100 4-Nov-13 ECD BTL Jinnah Women University ( Empowering women to Save Power) BTL 1,767 6-Nov-13 ECD Tree Plantation Jinnah Women University Tree Plantation 100 6-Nov-13 MCA Public School (City Station Railway Colony) Interactive Session 100 7-Nov-13 Moses Grammar School (N.Nazimabad) Interactive Session 150 18-Nov-13 Agha Khan School () Interactive Session 200 19-Nov-13 Agha Khan School (Karimabad) Interactive Session 400 20-Nov-13 Fairview School (Gulshan) Interactive Session 80 21-Nov-13 Agha Khan School (Karimabad) Interactive Session 300 25-Nov-13 Defence Public Grammar School (Akhter Colony) Interactive Session 80 26-Nov-13 Bright Future School (Gulshan) Interactive Session 200 27-Nov-13 Sindh Tech. & Vocational Education Interactive Session 100 28-Nov-13 Escense Public School (PECHS) Interactive Session 150 28-Nov-13 Ghazali Public Grammar School () Interactive Session 513 29-Nov-13

Page 1of 4 Annexure - B Energy Conservation Department Milesstones July '2013 ~ May '2014

Energy Conservation Activity Activity Addressed Date December 2013 FAST University BTL 1000 2-Dec-13 PAF Degree Collage (Tree Plantation) BTL 800 4-Dec-13 Al-Maaz Public School Interactive Session 200 5-Dec-13 ST. Lawrence Girls School Interactive Session 400 6-Dec-13 ST. Lawrence Boys School Interactive Session 800 6-Dec-13 Karachi International Book Fair Exhibition - EXPO BTL 5,000 7~9-Dec-13 Bagh-e-Hillar School Interactive Session 600 9-Dec-13 APWA Govt. Girls Collage Interactive Session 150 10-Dec-13 Gulshan-e-Fatima School Interactive Session 150 12-Dec-13 NASRA School Interactive Session 400 16-Dec-13 Sunrise Public School Interactive Session 600 19-Dec-13 ENTECH PAKISTAN AN IEP EXHIBITION - EXPO BTL 2,000 26~28-Dec-13

January 2014 1st Batch issuance of CFLs to all regions NCFL 5-Jan-14 NCFL Program Launched NCFL 7-Jan-14 EC Promotional activity at IBC - KIMZ Interactive Session 60 11-Jan-14 ABC Model School - PECHS Interactive Session 200 17-Jan-14 Rank High School - Interactive Session 100 20-Jan-14 Brookes Pharma education and health centre on hybrid Solar system along with LED Lighting Energy Audit Review 21-Jan-14 Solutions (Review) TW9Y Family Festival - Clifton BTL 1,500 25-Jan-14 Skill Tech International Institute - G.Johar Interactive Session 80 27-Jan-14 DMS Girls School - PECHS Interactive Session 200 27-Jan-14 Shaheen Secondary School - Malir 15 Interactive Session 250 29-Jan-14 Govt. Corcks Secondary School - Muslimabad Interactive Session 250 30-Jan-14

February 2014 Nature Carnival - PAF Measum BTL 2,300 2-Feb-14 Lady Marium Adamjee Girls School Interactive Session 250 6-Feb-14 Karachi Literature Festival 2014 - Beach Luxury BTL 1,400 07~09-Feb-14 New Safdar Secondary School Interactive Session 200 10-Feb-14 Secred Heart School Interactive Session 400 13-Feb-14 ARY Family Festival 2014 - EXPO BTL 8,000 15~16-Feb-14 Islamic Institute of Education - PECHS Interactive Session 200 17-Feb-14 Garden English Grammar School - Interactive Session 250 19-Feb-14 Karachi Folks High School Interactive Session 300 20-Feb-14 Govt. Boys / Girls Secondary School - Younusabad Sandspit Interactive Session 300 20-Feb-14 Govt. Boys Secondary School - Murripur Village Interactive Session 200 26-Feb-14 George Mason Grammar School - PIB Colony Interactive Session 200 27-Feb-14 NED Spring Festival 2014 BTL 5,000 27-Feb-14

March 2014 Women's EXPO at Sunset Club - DHA BTL 2,000 02~03-Mar-14 Basant Spring Fetival - Gym Khana BTL 1,000 9-Mar-14 Sirsyed University Seminar / BTL 900 10-Mar-14 Govt. Boys Secondary School - PIB Colony Interactive Session 250 11-Mar-14 NAPA International Theatre Festival (9 Days Activity) BTL 5,000 05~07-Mar-14 Chaman Faiz Alam Govt. Boys Sch. School - Memon Goth Interactive Session 150 17-Mar-14 International Conference on Engineering and Emerging Technology - Lahore Seminar 300 18~20-Mar-14 Kingsley American School - PECHS Interactive Session 200 28-Mar-14 Alternative Energy & Education Park (Pre-Inauguration Tree Plantation) Tree Plantation 300 29-Mar-14 Earth Hour Activity at Sindh Assembly Earth Hour 300 29-Mar-14 Earth Hour Activity at Port Grand Earth Hour 800 29-Mar-14 11th ITIF (Int'l Trade & Inds. Fair Asia Exhibition and Conference - EXPO BTL 1,000 29~31-Mar-13

Page 2of 4 Annexure - B Energy Conservation Department Milesstones July '2013 ~ May '2014

Energy Conservation Activity Activity Addressed Date April 2014 Govt. Vocational & training Center - saddar Interactive Session 300 9-Apr-14 Bano Govt. Girls School - Nazimabad Interactive Session 100 10-Apr-14 Inauguration Ceremony of Alternate Education Model Park - Hyderi Participation 11-Apr-14 Govt. Girls Secondary School - Malir City Interactive Session 150 14-Apr-14 Interactive Session / Tree Green House Grammar school - Malir Hault 200 21-Apr-14 Plantation Zaheer Public School - North Nazimabad Interactive Session 100 21-Apr-14 Earth Day - Power House complex (ALL) Tree Plantation 500 22-Apr-14 Earth Day - BQPS I & II - (IA & TP) Tree Plantation 500 22-Apr-14 Earth Day - FG Boys Secondary School - Manora Tree Plantation 300 22-Apr-14 Earth Day - Govt. Boys Secondary School - Nazimabad Tree Plantation 300 22-Apr-14 Earth Day - Alternate Energy Model Park BTL 500 22-Apr-14 Interactive Session / Tree The Haracks School - Chappel City G. Jouhar 250 23-Apr-14 Plantation

KE b/w NED real time mapping of EHT network for enhancing system reliability & efficiency MOU 24-Apr-14

The Al-hamd Academy (North Karachi) Interactive Session 120 24-Apr-14 Interactive Session / Tree Akbar Public School (APS) - North Nazimabad 540 22-Apr-14 Plantation All Karachi Private School Talent Exhibition & Fun Gala 2 - EXPO BTL 10,000 26~27-Apr-14

May 2014 Korangi Kay Rang Umangon kay sung + Umeed Ki Kiran (Grand Finale) - Art Council Interactive Session 700 28~30-Apr-14 Paraas Model School - DHA Interactive Session 350 29-Apr-14

Ayesha Academy Secondary School Interactive Session 200 5-May-14

Seminar on Energy Conseration at Karachi University Seminar 100 5-May-14 Katchi Memon School - Saddar Interactive Session 200 6-May-14 Interactive Session / Tree Ehtashamia Govt. Boys Secondary School - Lines Area 90 7-May-14 Plantation Merry Homes School - Jamshed Road Interactive Session 150 7-May-14 Meezan School System - Mehmoodabad Interactive Session 150 9-May-14 The Vision Secondary School (N. Naz) Interactive Session 80 12-May-14 Generation Grammar School (PECHS) Interactive Session 200 12-May-14 MAKWAY Grammar School (N.Naz) Interactive Session 350 13-May-14 Hira Sec. School (PECHS) Interactive Session 50 13-May-14 The Paris Girls School (DHA) Interactive Session 300 13-May-14 Bukingham Grammar School (PECHS) Interactive Session 80 14-May-14 JMA Boys & Girls School (Saddar) Interactive Session 350 14-May-14 Interactive Session / Tree National Public School (N. Naz) 100 15-May-14 Plantation The Pinnacle School (N. Naz) Interactive Session 100 16-May-14 Muslim Hands Grammar School (DHA) Interactive Session 60 16-May-14 Karachi Grammar School (KGS) BTL 400 20-May-14 Bilal City Grammar School (Garden) Interactive Session 150 20-May-14 Interactive Session / Tree Stanmore Public School -Boys Campus 300 21-May-14 Plantation Interactive Session / Tree Stanmore Public School -Girls Campus 400 21-May-14 Plantation Scientific Grammar School (N.Naz) Interactive Session 120 21-May-14 7th PowerGen & Energy Conference and Energy Leader Award 2014 Seminar 300 22-May-14 ECD- KE join hands with M/S Haier MOU 23-May-14 Interactive Session / Tree Educational Tree 100 23-May-14 Plantation Tarbyat e Islam Public School (DHA) Interactive Session 120 23-May-14

Page 3of 4 Annexure - B Energy Conservation Department Milesstones July '2013 ~ May '2014

Energy Conservation Activity Activity Addressed Date June 2014 ECD- KE join hands with TESLA ( Solar company) MOU 12-May-14 Oxford Academy Sec. School (Mehmoodabad) Interactive Session 120 28-May-14 Usman Public School (N.Naz) Interactive Session 250 30-May-14 IQRA Islamic Education Academy (N.Naz) Interactive Session 100 2-Jun-14 Ocean Mall (Clifton) BTL 500 15-Jun-14 Muhammad Ali Jinnah University (MAJU) BTL 300 17-Jun-14 Zamzama Park (Clifton) BTL 200 19-Jun-14 Bright Star (Summer Camp) Interactive Session 30 19-Jun-14 Sarsabz-O-Pursakoon Karachi at Commissioner House Workshop - 20-Jun-14 My Karachi EXPO at EXPO Center) BTL 10,000 20-22 Jun-14 Millennium Mall (Gulistan-e-Johar) BTL 400 24-Jun-14 Forum (Clifton) BTL 600 25-Jun-14 H.A. Institute Interactive Session 60 26-Jun-14 Makro (Saddar) BTL 300 26-Jun-14 Azam Learning Institute (A.L.I) (Tree Plantation) (103 Plants) Tree Plantation - 27-Jun-14 Dolmen Mall (Clifton) BTL 2,500 27-28 Jun-14 Dolmen Mall (Hyderi) BTL 1,500 27-28 Jun-14

Total ECI Message Conveyed to Consumers 140,365 All EC events were regularly covered by media and circulated through newspaper all over Karachi

ECD Miles Stone Achievement Summary ECD Activities Cons. Participation 178 140,365 Interactive Sessions BTLs Others 101 31 14 MOU Transformations Tree Plantation 3 2 15 Orientations Seminars Workshop 1 7 4

Page 4of 4 Complaints Received (Jul'13 - Jun'14)

Total Count Avg. Resolution Time

450000 96:00:00 400000 84:00:00 350000 72:00:00 300000 60:00:00 250000 200000 48:00:00 150000 36:00:00 100000 24:00:00 50000 12:00:00 0 0:00:00 Phase Voltage Current Sparking PoleDash PMT Fault Shutdown PMT Flash SupplyOff Main Wire… HTJumper Two Phase Fluctuation FeederTrip Breaker Off Three Phase LowVoltage Meter Burnt LowTension… Service Wire… High Voltage Jumper Wire… Neutral Wire… Service Cable… Load Sheding Underground… Wire Intangle HTCable Fault PMT LinkDrop Lead Burnt Out Neutral Missing Neutral + Phase HTWire Broken Main CableFault Jumper Burnt Out

Alternate Channels (Jul'13 - Jun'14)

E-Mail SMS

7000 6000 5000 4000 3000 2000 1000 0 Ticket Type Total Count Avg. Resolution Time Breaker Off 16301 76:07:08 Ticket Type E-Mail SMS Grand Total Current 24135 70:16:06 Breaker Off 109 315 424 Feeder Trip 4591 64:21:36 Current 26 92 118 Fluctuation 109148 67:41:30 Feeder Trip 2 57 59 High Voltage 15286 69:10:51 Fluctuation 435 1545 1980 HT Cable Fault 890 72:06:29 High Voltage 35 176 211 HT Jumper 1868 82:47:23 HT Cable Fault 2 1 3 HT Wire Broken 1990 74:26:09 HT Jumper 5 16 21 HT Wire Broken 7 12 19 Jumper Burnt Out 95480 68:50:29 Jumper Burnt Out 411 1221 1632 Jumper Wire Broken 140925 75:14:08 Jumper Wire Broken 257 2018 2275 Lead Burnt Out 4805 69:55:18 Lead Burnt Out 42 522 564 Load Sheding 4157 72:56:08 Load Sheding 3 15 18 Low Tension Cable Fault 1317 68:22:25 Low Tension Cable Fault 2 7 9 Low Voltage 125864 72:44:41 Low Voltage 499 2141 2640 Main Cable Fault 1652 72:40:28 Main Cable Fault 7 9 16 Main Wire Broken 44285 75:10:25 Main Wire Broken 132 337 469 Meter Burnt 4358 83:25:01 Meter Burnt 31 15 46 Neutral + Phase 6838 74:34:01 Neutral + Phase 12 44 56 Neutral Missing 5864 80:26:59 Neutral Missing 12 76 88 Neutral Wire Broken 18795 77:27:05 Neutral Wire Broken 52 235 287 Phase 391204 60:59:17 Phase 812 5185 5997 PMT Fault 10645 86:15:58 PMT Fault 58 55 113 PMT Flash 35571 55:55:15 PMT Flash 31 381 412 PMT Link Drop 5183 71:52:55 PMT Link Drop 19 74 93 Pole Dash 2920 67:25:45 Pole Dash 8 5 13 Service Cable Fault 3491 63:44:12 Service Cable Fault 16 39 55 Service Wire Broken 47835 82:47:00 Service Wire Broken 142 596 738 Shutdown 16122 47:11:15 Shutdown 24 425 449 Sparking 19736 51:50:54 Sparking 43 126 169 Supply Off 393458 49:32:21 Supply Off 664 5784 6448 Three Phase 219825 54:42:44 Three Phase 677 5133 5810 Two Phase 253 1780 2033 Two Phase 97481 67:42:08 Underground Fault 2 9 11 Underground Fault 5540 58:43:29 Voltage 208 957 1165 Voltage 28951 67:29:05 Wire Intangle 16 17 33 Wire Intangle 5925 72:50:11 Query / Reminder 14298 170543 184841 Total 1912436 62:28:44 Grand Total 19352 199963 219315

SUMMARY OF INDUSTRIAL ACCIDENTS

WORKING HOURS LOST FOR THE PERIOD FROM 01.07.2013 TO 30.06.2014

Emp. Date of Lost SNO Name Category Cause of Accident Lost Day No. Accident Time 1 Shakeel Aslam 12736 24-07-2013 Minor Electric Shock. 66 528

2 Pervaiz 2856 13-09-2013 Major Flash – Burn injuries. 19 152

3 Khalid Shah 12339 13-09-2013 Major Flash – Burn injuries. 19 152

4 Masood Ahmed 2216 28-09-2013 Major Electric Flash. 143 1144

5 Nisar Ahmed 6472 27-10-2013 Major Shifting of dismantled Pole 150 1200

6 Malik Javed Anwar 13373 04-02-2014 Fatal Flash on 11 KV - -

7 Shahid Ali 13168 04-02-2014 Fatal Flash on 11 KV - -

8 Muhammad Babar 11066 04-02-2014 Minor Flash on 11 KV 21 168

9 Zaheer Ahmed 10688 04-02-2014 Minor Flash on 11 KV 21 168

10 Asghar Ali 5800 09-02-2014 Major Fell from Ladder 141 1128

11 Saleem Tanoli 6000 17-02-2014 Minor Accident of MTL 7 56

12 Abid Hussain 14650 17-02-2014 Major Accident of MTL 58 464

13 M. Dawood 11985 03-03-2014 Major Fell from pole 119 952

14 Muhammad Aslam 13133 23-05-2014 Major Fell down from Ladder 38 304