Environmental Monitoring Report PAK: Jamshoro Power Generation Project

Environmental Monitoring Report

2020 1st Semestral Report November 2020

PAK: Jamshoro Power Generation Project

Prepared by the Jamshoro Power Company Limited (JPCL), with the assistance of Mott MacDonald Limited (United Kingdom) in joint venture with MM Pakistan (Pvt) Ltd (Pakistan), for the Islamic Republic of Pakistan and the Asian Development Bank.

This environmental monitoring report is a document of the borrower. The views expressed herein do not necessarily represent those of ADB’s Board of Directors, Management, or staff, and may be preliminary in nature.

In preparing any country program or strategy, financing any project, or by making any designation or reference to a particular territory or geographic area in this document, the Asian Development Bank does not intend to make any judgements as to the legal or other status of any territory or area. Semi-annual Environment Monitoring Report January to June 2020 October 2020

Project Number: 47094-001 Reporting period: Month Year: January to June 2020

Islamic Republic of Pakistan: Jamshoro Power Generation Project Financed by the Asian Development Bank

Mott MacDonald Prepared by: L Stone Victory House Trafalgar Place Mott MacDonald Brighton BN1 4FY United Kingdom

T +44 (0)1273 365000 mottmac.com For Jamshoro Power Company Limited

Endorsed by (JPCL)

Semi-annual Environment Monitoring Report January to June 2020 October 2020

Mott MacDonald Limited. Registered in England and Wales no. 1243967. Registered office: Mott MacDonald House, 8-10 Sydenham Road, Croydon CR0 2EE, United Kingdom

Mott MacDonald | Semi-annual Environment Monitoring Report January to June 2020

Issue and Revision Record

Revision Date Originator Checker Approver Description 01 16.10.202 Laura Stone Jim JMV for Dario Reported information in the 0 Venetucci Cacciatore absence of most Contractor supplied reporting

Document reference: 334014 | JPCL-R-02916 | A33014-MML-JPCL-R-02916

Information class: Standard

This Report has been prepared solely for use by the party which commissioned it (the 'Client') in connection with the captioned project. It should not be used for any other purpose. No person other than the Client or any party who has expressly agreed terms of reliance with us (the 'Recipient(s)') may rely on the content, information or any views expressed in the Report. This Report is confidential and contains proprietary intellectual property and we accept no duty of care, responsibility or liability to any other recipient of this Report. No representation, warranty or undertaking, express or implied, is made and no responsibility or liability is accepted by us to any party other than the Client or any Recipient(s), as to the accuracy or completeness of the information contained in this Report. For the avoidance of doubt this Report does not in any way purport to include any legal, insurance or financial advice or opinion.

We disclaim all and any liability whether arising in tort, contract or otherwise which we might otherwise have to any party other than the Client or the Recipient(s), in respect of this Report, or any information contained in it. We accept no responsibility for any error or omission in the Report which is due to an error or omission in data, information or statements supplied to us by other parties including the Client (the 'Data'). We have not independently verified the Data or otherwise examined it to determine the accuracy, completeness, sufficiency for any purpose or feasibility for any particular outcome including financial.

Forecasts presented in this document were prepared using the Data and the Report is dependent or based on the Data. Inevitably, some of the assumptions used to develop the forecasts will not be realised and unanticipated events and circumstances may occur. Consequently, we do not guarantee or warrant the conclusions contained in the Report as there are likely to be differences between the forecasts and the actual results and those differences may be material. While we consider that the information and opinions given in this Report are sound all parties must rely on their own skill and judgement when making use of it.

Information and opinions are current only as of the date of the Report and we accept no responsibility for updating such information or opinion. It should, therefore, not be assumed that any such information or opinion continues to be accurate subsequent to the date of the Report. Under no circumstances may this Report or any extract or summary thereof be used in connection with any public or private securities offering including any related memorandum or prospectus for any securities offering or stock exchange listing or announcement.

By acceptance of this Report you agree to be bound by this disclaimer. This disclaimer and any issues, disputes or claims arising out of or in connection with it (whether contractual or non-contractual in nature such as claims in tort, from breach of statute or regulation or otherwise) shall be governed by, and construed in accordance with, the laws of England and Wales to the exclusion of all conflict of laws principles and rules. All disputes or claims arising out of or relating to this disclaimer shall be subject to the exclusive jurisdiction of the English and Welsh courts to which the parties irrevocably submit.

Contents

Abbreviations 1

1 Introduction 2 1.1 Preamble 2 1.2 Headline information 2

2 Project description and current activities 3 2.1 Project description 3 2.2 Project contracts and management 4 2.3 Project activities during current reporting period 5 2.4 Description of any changes to project design 7 2.5 Description of any changes to agreed construction methods 8

3 Environmental safeguard activities 11 3.1 General description of environmental safeguard activities 11 3.2 Site inspections/audits – remediation lots 3 and 5 11 3.3 Site inspections/audits – 660MW power plant 12 3.4 Issues tracking (based on non-conformance notices) 17 3.5 Trends 18 3.6 Unanticipated environmental impacts or risks 19

4 Results of environmental monitoring 20 4.1 Overview of monitoring conducted during current period 20 4.2 Lot 5 – Colony sewage treatment plant 20 4.2.1 Overview 20 4.2.2 Trends 22 4.2.3 Summary of monitoring outcomes 22 4.2.4 Material resources utilisation 22 4.2.5 Waste management 22 4.2.6 Health and safety 23 4.2.7 Training 23 4.2.8 Conclusion 23 4.3 660MW power plant – main contract 23 4.3.1 Trends 26 4.3.2 Summary of monitoring outcomes 26 4.3.3 Material resources utilisation 26 4.3.4 Waste management 26 4.3.5 Health and safety 27 4.3.6 Training 28

5 Functioning of the CEMMP 30 5.1 CEMMP review 30 5.1.1 Lot 5 30 5.1.2 660MW power plant – main contract 30

6 Good practice and opportunity for improvement 32 6.1 Good practice 32 6.2 Opportunities for improvement 32 6.2.1 Lot 5 – Colony sewage treatment plant 32 6.2.2 660MW power plant – main contract 33

7 Summary and recommendations 36 7.1 Summary 36 7.2 Recommendations 37

Annexes 38

A. EHS photographs 39 A.1 Remediation Lot 3 39 A.2 Lot 5 40 A.3 2x660 MW EPC 42

B. 660MW Site location/layout plan 44

C. Lot 5 contractor monitoring report 46

D. 660MW main build contractor monitoring reports, January – June 2020 47

Tables Table 1: Main organisations 4 Table 2: Main project construction activities 6 Table 3: Worker numbers (maximum) during reporting period 7 Table 4: Environmental safeguard audits 11 Table 5: EHS meetings January to June 2020 12 Table 6: Lot 5 resource use January – June 2020 22 Table 7: Main build environmental and H&S monitoring/reporting 24 Table 8: Health and safety statistics 27

Figures

Figure 1: Actual progress against schedule 7 Figure 2: Rehabilitation/remediation Lots 1 to 6 9 Figure 3: Extract of Siemens-HEI ‘Summary of EHS Issues Highlighted by JPCL and PIC’ 18 Figure 4: Extract of Siemens-HEI ‘Summary of EHS Issues Highlighted by JPCL and PIC’ 19 Figure 5: EHS training trends presented in April-June 2020 EHS Report 29 Figure 6: 660MW power plant layout 45

Photos Photo 1: Rains and ponding of water resulting in lateral scope erosion and growth of vegetation 39 Photo 2: Open duct on the top slab of the newly constructed septic tank to be covered 40 Photo 3: Unsuitable location for electricity meter at the JPCL quarter at Septic tank III 40 Photo 4: Drinking coolers should be labelled as suitable for drinking water, clean and chilled and kept in a shaded area with seating provided 41 Photo 5: Inappropriate kitchen facilities for workers 41 Photo 6: Non-conformance raised regarding working at height and scaffolding 42 Photo 7: Sub-standard scaffolding at the circulating water pipeline area 43 Photo 8: Unsafe working at height at the stack area 43

Abbreviations

ADB Asian Development Bank

CEMMP Construction environmental management and monitoring plan

EMR Environmental monitoring review

GHCL Genco Holdings Company Limited

HEI Harbin Electric International

JPCL Jamshoro Power Company Limited

JPGP Jamshoro Power Generation Project

MW Megawatt

PIU Project implementation unit

PIC Project implementation consultant

PMU Project management unit

SAEMR Semi-annual environmental monitoring report

1 Introduction

1.1 Preamble 1. This report represents the Semi-annual Environmental Monitoring Report (SAEMR) for Jamshoro Power Generation Project.

2. This report is the 12th SAEMR for the project.

3. Due to the current travel restrictions as a result of Covid-19, the PIC was unable to travel to site. As such this SAEMR is based on reports received for the period and site walkover inspections completed prior to 12 March 2020, following which site restrictions were imposed.

1.2 Headline information 4. Of the six remediation lots, Lot 1 and Lot 2 are complete, and Lot 4 is now largely complete with minor punch list items remaining. The status of the remaining three lots is are as follows:

● Lot 3 - Municipal waste disposal site (worker’s colony): No significant progress has been made in this reporting period.

● Lot 5 - Worker’s colony sewage treatment plant construction started on 01 June 2019 and is ongoing.

● Lot 6 - Remediation of contaminated land has been combined with the main project construction and plans are under development. No physical progress to date.

5. Siemens-HEI Consortium commenced construction of the 660MW power plant (the main project) on 28 January 2019 with partial handover of the site to the consortium by JPCL. Reported progress is on non-critical path and critical path items.

2 Project description and current activities

2.1 Project description 6. The Government of Pakistan aims to increase the share of coal-based generation from almost zero in 2016 to 15% over the next few years. In support of this initiative Jamshoro Power Company Limited (JPCL) and Genco Holding Company (GENCO), supported by the Asian Development Bank (ADB), is planning a brownfield extension of the Jamshoro Power Station to improve the total plant efficiency and increase the power output. The project is known as the Jamshoro Power Generation Project (JPGP).

7. The project site is approximately 15km northwest of Hyderabad, and about 150km northeast of Karachi in the Sindh Province of Pakistan. The Indus River is about 3.5km east of the power plant site. Currently there are four fossil fuel-fired electricity generating units installed and operating at the site (Unit 1 is oil fired and Units 2 – 4 have dual-fuel capability (oil/gas).

8. JPGP is proposed to initially comprise of 1x660MW (net) supercritical coal fired power plant with facilities to expand to 2x660MW plants. The project aims to decrease the existing power shortfall in Pakistan and address environmental concerns from the existing oil-fired power units. The new boiler(s) will be designed to utilise imported sub- bituminous coal blended at 80/20 with local lignite as its fuel. This report relates to development of phase 1 (1x660MW) only.

9. As part of the feasibility study for the project and as required by the ADB, an environmental audit was undertaken of the existing plant. The audit was included as part of the environmental and social impact assessment (ESIA) for the 2x660MW supercritical power plant (Environmental Impact Assessment; Jamshoro Power Generation Project; Hagler Bailly Pakistan, October 29, 2013 (the ESIA report)). Section 6 of the ESIA report (Issues Related to Existing Plant and

Corrective Actions) identified several items related to the existing plant that require remediation or rehabilitation.

10. The items that were identified are subject to a loan condition applied by ADB that requires the identified remediation works to have a signed contract in place prior to commencement of works on the new facility (660MW supercritical power plant).

11. The rehabilitation and remediation items were split into six lots. These lots are:

● Lot 1 – Rehabilitation of evaporation ponds ● Lot 2 – Rehabilitation of blowdown effluent channel ● Lot 3 - Municipal waste disposal site (worker’s colony) ● Lot 4 - Hazardous waste disposal and hazardous waste facility ● Lot 5 - Worker’s colony sewage treatment plant ● Lot 6 - Remediation of contaminated land Lots1 and Lot 2 are complete and have been handed over to JPCL and Lot 4 is completed with punch list items remaining; these lots are not considered further in this report.

2.2 Project contracts and management

12. Table 1 provides details of the main organisations involved in the project and relating to Environmental Safeguards.

Table 1: Main organisations Role Organisation Environmental Contact details lead Lender Asian Safia Shafiq [email protected] Development Bank Borrower Jamshoro Power A A Memon [email protected] / Station [email protected] Company PIU Jamshoro Power A A Memon [email protected] / Station [email protected] Company PIC Mott MacDonald Laura Stone [email protected] Ltd Muhammed Ali [email protected] Shishmahal Main contractors Rehabilitation Lot 3 MAJ & ICC Joint Safar Korai [email protected] / (municipal waste Venture [email protected]

Role Organisation Environmental Contact details lead disposal site for worker’s colony) Rehabilitation Lot 4 ATL – GPL Wajahat Nadeem [email protected] / (Hazardous waste Consortium [email protected] disposal and construction of hazardous waste disposal site) Rehabilitation Lot 5 Hebei Liu Gang [email protected] / (Worker’s colony Installation [email protected] sewage treatment Engineering plant) Rehabilitation Lot 6 Contract to be under the main build. Contractor to be appointed by Siemens- HEI (Remediation of consortium. contaminated land) 1x600MW coalfired Siemens-HEI Jin Gangzhu [email protected] / plant construction consortium [email protected] and operation

13. Supervision is being carried out by the Project Implementation Unit (PIU) which is comprised of Jamshoro Power Company Limited (JPCL) staff who are assisted by the Project Implementation Consultant (PIC) (Mott MacDonald) for technical and commercial matters.

14. Project Management Unit (PMU) and PIU will ensure that mitigation and management measures proposed in the EIA report are implemented. Top management of JPCL and Genco Holdings Company Limited (GHCL) will ultimately head the PIU and PMU. For this purpose, JPCL and GHCL will develop internal institutional capacity for environmental management.

2.3 Project activities during current reporting period

15. During the reporting period, January to June 2020, the status of the remediation work packages was as follows:

● Lot 5 Domestic sewage treatment for worker’s colony. Activities in the reporting period included: – Construction of reinforced concreate sewage treatment station septic tanks #1 and #2 was completed – Equipment infrastructure construction was completed – Main construction of equipment room completed and tiling of duty room and toilet also completed

– Cable trench drainage ditch for septic tank #2 completed. ● Lot 6 Remediation of contaminated land. Work has not commenced. 16. For information, the approximate locations of the remediation activities (Lots 1 to 6) reported above are shown in Figure 2. Site location and lay out of the 660MW power plant is shown in Annex B.

17. The Siemens-HEI consortium commenced construction of the 660MW power plant (main project) on 28 January 2019, with partial handover of the site to the consortium by JPCL. Remediation Lot VI (contaminated land remediation) land has also been partially handed over. Construction activity during the reporting period is reported in Table 2. Actual progress against the construction schedule is shown in Figure 1.

Table 2: Main project construction activities No. Project component Description 1. Levelling in new power plant Levelling and grading of unit # 1 area is complete area Levelling and grading work of unit # 2 is in progress 2. Concrete work in Concrete work of cooling tower. main power building, canteen, administration, new power plant warehouse, workshop, chimney, flue gas desulphurisation building, unit#1 absorber, absorber circulating pump house, emergency storage tank, central area control building, turbine generator building, electrostatic precipitator, underground hoper, water treatment building, waste water treatment building, clarifier and combined water drainage pumphouse, firefighting pump house, coal mill and feeder water pump house is complete. Foundation work is in progress for the chemical treatment plant, clarifier, complex water pump house, underground hopper#1, water recycling tank and flue gas duct., transfer tower T1, circulating water pump house, FD fan foundation, PA fan foundation. Reinforced cement concrete (RCC) work is in progress for the steam turbine generator foundation, cooling water pipe, cooling tower, cooling water pump house foundation, administration canteen building superstructure, chimney super structure, central control building superstructure and chemical treatment plant superstructure. Unreinforced concrete work is in progress for the crush house, coal unloading ditch and transfer tower 3, 4 and 5. Construction work of second layer of boundary around the living camp is complete. 3. Blasting at hilltop Blasting work for the cooling tower #2, coal handling system and railway line and new power area was completed in March 2020. plant area 4. Levelling, grading and Fencing between the existing and new power plant is complete. fencing Levelling and grading work of the equipment storage yard has been completed. 5. Batching plant Batching plant unit 1 and unit 2 are working and supplying concrete for concrete work. Installation of batching plant unit 3 has been completed. Calibration and auxiliary work completed

No. Project component Description 6. Excavation work Excavation work of the Compressor house, demineralization water area, water retention basin, dam, induced draft fan area, chemical water treatment building and raw water treatment area for Unit #1 is completed. 7. Cooling water pipeline Installation of cooling water pipeline is in progress with approximately 50% complete. 8. Piling work The piling work associated with the water intake pump has been completed. Source: Siemens-HEI consortium monthly reports

Figure 1: Actual progress against schedule

18. Maximum numbers of workers on site for the main build during the reporting period are shown in Table 3.

Table 3: Worker numbers (maximum) during reporting period Number of Male Number of Female Total S.No Company Workers Workers Chinese Local Chinese Local 1 HEI – EPC contractor (and its 16 71 2 0 57 subcontractors) 2 TEPC – Civil sub-contractor 150 1336 2 1488 3 NEPC – Electrical/mechanical 27 53 3 0 83 sub-contractor 4 HR: - Civil piling work 0 54 0 0 54 HIE 24 24 Total 1738 Source: Siemens-HEI Monthly EHS report February 2020 when where was a peak number of workers at site. * HIE does not report information on gender or ethnicity of workers 2.4 Description of any changes to project design

19. Whilst there have been changes to the design which are captured in the PIC monthly report reports, none of these changes are anticipated to have a significant environmental and social impacts.

20. There has been a change to the flue gas desulphurisation technology proposed which incorporates a wet stack with high efficiency demisters, which will improve sulphur dioxide removal to that originally proposed.

2.5 Description of any changes to agreed construction methods

21. The key change to construction approach in the reporting period was as a result of the restrictions imposed due to the Covid-19 pandemic resulting in changes to working practices on site.

22. Initially in March, the number of construction workers was reduced. However, all construction activities were suspended by JPCL for a period.

23. Throughout the reporting period the PIC reported to JPCL that the Contractor’s site safety protocol has not been properly modified to provide Safe Working Conditions under the COVID-19 Pandemic. The present HSE plan fails to conform to the Sindh Order SO(Jud-I) HD/8- 1(04)/2020-Corona/SOPs (April 14,2020), the Sindh Order SO(Jud-I) HD/8-1(04)/2020-Corona/SOPs-Constr. (May 10,2020), "other protocols” for works projects applicable under Sindh governance, and, current, applicable International laws and regulations.”

24. We are yet to see an update of the Contractors site HSE plan setting out how it will comply with Sindh and international good practice with respect to Covid-19. The PIC reports and feedback have continued to stress the importance of Covid-19 awareness raising amongst the workforce.

25. The reporting does indicate that some measures have been imposed including pictorial evidence of covid-19 awareness training, use of masks and PPE and more frequent hand washing. It is considered that further continued efforts are required.

26. To date, no cases of Covid-19 amongst the workforce have been formally raised.

Figure 2: Rehabilitation/remediation Lots 1 to 6

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3 Environmental safeguard activities

3.1 General description of environmental safeguard activities

27. The contractor for each rehabilitation/remediation lot and the main 660MW coal plant site has responsibility for ensuring compliance with the requirements of the construction environmental management plan for their work area.

28. The PIC has undertaken inspections/audits on active lots, which have been limited during the reporting period due to the restrictions caused by Covid-19. As such, there were no inspections/audits undertaken between 13 March and end July 2020. The degree of scrutiny expended on each lot is reflective of the magnitude and duration of the works and the perceived risks. The main build of the 660MW power plant will be inspected more frequently than the remediation lots.

3.2 Site inspections/audits – remediation lots 3 and 5

29. Environmental safeguard audits were undertaken by the PIC during the reporting period. Details are provided in Table 4. Conditions at Lot V were noted to have deteriorated during the safety walk undertaken in February 2020. Contractors were issued with details of the issues to be addressed and actions required to be taken discussed.

30. Most issues are a result of poor housekeeping and poor safety practices.

Table 4: Environmental safeguard audits Work package Audit Auditor/ (lot number) date auditing body Lot III - Municipal Letter M A Findings waste disposal site issued 13 Shishmahal/ (workers colony) February PIC 2020 It was observed that rain and the resulting ponding of water inside the facility had resulted in lateral slope erosion and growth of unwanted vegetation. The project EIA Chapter 10, EMP Section 10.13, Construction Management Plan, Table 10-7 states that mitigation and management measures should be taken against the items noted in this issue. It was advised that the area should be dewatered, and site restoration activities completed in accordance with the approved design. Lot V – Colony 04 M A Findings sewage treatment February Shishmahal/ plant 2020 PIC

Mott MacDonald Reference 334014-MML-JPCL-R-0291 12

Work package Audit Auditor/ (lot number) date auditing body During a weekly site safety walk, a number of HSE issues were identified requiring immediate attention: A new set of safety signs including sit safety policy, parking signs, caution signs, HSE statistics display board, mandatory signage, and assembly points should be established at both septic tank locations. Old safety signs should be cleared or repaired. At septic tank #2, the existing open drain pit should be covered with plastic/tarpaulin sheets, barricaded/marked and signs installed to minimise impacts (odour, mosquito breeding, falling risk into the pit). A watchman/guards should be appointed in shifts, particularly at night to prevent unauthorised entry, given that both septic tank locations are situated near residential areas. Guards should be provided with uniforms for easy identification and acceptance of their authority. A traffic management plan should be in place for the loading/unloading of heavy equipment, goods and machinery and a banksman/flagman should be deployed. Effective communication and instructions should be made before performing transportation activities when and where necessary for the routes taken by heavy transport. A safe distance should be maintained with colonial overhead power lines. The open duct on the top slab of the newly construction septic tank(s) should be covered to ensure water does not enter the tanks to prevent vector borne diseases. The electricity meter monitoring on the exterior call of the JPCL colonial quarter at Septic tank II is unacceptable. It should be remounted at a suitable and safe location by contacting WAPDA authorised persons or a qualified and certified electrician. It should be clearly labelled, marked and identified. Moreover, good electric safety practices such as the use of industrial receptacles, cord protector, circuit breakers etc should be adapted at site. Hot refreshments are being made using wood for fuel. Such activities are strictly prohibited and if required, a kitchen facility should be provided for refreshment purposes. Damaged/broken leg of a chair should be repaired or discarded immediately. Cabin containers should be procured at site for establishing an onsite office with all the necessary safety requirements. Drinking coolers should be labelled as ‘whole-some drinking water’. It should be cleaned and chilled ensuring availability of cups. Its location should have seating and shade. Leftover cement/cement bags left on the ground should be cleaned, labelled and placed in a suitable area. Ladders (frame or step) must be robust, appropriate for the task and rest on firm and event ground. Housekeeping efforts are required to ensure the site is organised and free from slip/trip hazards. Guards should be appointed to prevent unauthorised entry to site. The working platform should be guarded by means of a top-rail, mid-rail and toe-boards. The erection of scaffold components in place should have all the necessary requirements with respect to scaffold tags and ladders should only be used for access. All site workers and employees including visitors should strictly comply with site safety rules and must be equipped with suitable and mandatory PPE. Source: Mott MacDonald

3.3 Site inspections/audits – 660MW power plant

31. Main build construction activities continue. Site walkover and contractor meetings were undertaken by PIC national environmental expert and the PIC project manager and/or project director on 13 dates in the reporting period.

32. The audits are labelled ‘safety walks’ and they cover environmental, and health and safety issues. Details of the schedule of the meetings and site walkovers held during the reporting period are shown in Table 5.

Table 5: EHS meetings January to June 2020 Date Activity 14.01.2020 Regular safety walk Comments During welding operations, guards/portable welding curtains/screens should be used to confine slag, spark and heat if the object to be welded or cut cannot be moved.

Mott MacDonald Reference 334014-MML-JPCL-R-0291 13

Mandatory PPEs sign boards should be installed at the entrance of each project specific location and all workers should be equipped with necessity PPE. The trimming/cutting of tree branches should be avoided. Moreover, existing trees should be watered and look after frequently and regularly inside the newly constructed power plant. Caution signs should be installed and unauthorised personnel should not be allowed inside/ within working radius of the rebar cutting and bending working platforms. Only those designated for the task should be allowed within the working area. Bent rebars should not be stored too high. Floors where rebars shall be stacked should be firmed and even. It was observed that dustbins were not always available. Colour coded dustbins should be available and later emptied at the waste collection point It was observed that first aid boxes were not always available. These should be installed where required and regularly stocked. All employees should be trained on use, handling and storage of gas cylinders. Oxygen cylinders should be stored approximately 20 feet away from fuel gas cylinders and combustible materials in a well ventilation, must be labelled, secured and dry place. Handling of cylinders shall be j in a proper cylinder cart and always stored upright. Safety caps/guards should be securely installed. Emptied cylinder should be stored separately from filled ones. Warning signs should also be placed in the areas where cylinders are stored. Spill kits should be available where flammable materials are stored. Emergency drainage system should be established to safe dispose the flammable material into waste stream. All stored material should be labelled and SDS (safety data sheets) should be made readily available. Storage area should be free from combustible materials and equipped with adequate portable fire extinguishers. Emergency contact numbers and emergency response plan shall be developed for in the event of an emergency. Fire-proof lighting and doors should be provided where necessary. Lighting switches should be outside the storage room in case mechanical exhaust is used. Aisles, egress and emergency exits should be provided. Regular checks of leaking containers should be done and leaked container should be removed immediately. Materials should be handled safely in addition with mandatory PPEs. "No Smoking" signs shall be pasted and smoking should be prohibited in the area. Every hazardous chemicals/ flammable storage room should be provided with a ventilation system and emergency spill kit. This should be applicable to all storage areas where flammable materials are being stored. It was observed that contaminated heavy fuel oil contaminated scrap from the existing weighbridge roads has been openly dumped. Until an investigation is completed, the top layer of stored area should be covered with plastic sheets to avoid rainwater penetrating into ground and moved to an impermeable area. 21.01.2020 Regular safety walk Comments Only permitted/appointed person holding the appropriate licences should operate vehicles. This negligence are unacceptable and appropriate action for such violations is recommended. Materials should be secured when being transported and an appropriate vehicle/ cart should be selected for loading and unloading formwork, rebars, equipment, machineries etc. This should applicable to all equipment loading/unloading equipment. A tractor was observed as being overloaded with quilt material. Vehicles used should be intended for its purpose, secure by ropes and transported by safe means. Electrical connections should be undertaken by a qualified person/ WAPDA authorised personnel; hazards should be recognised, exposed live parts should be accessible to qualified persons only, signs should be provided and communication and training should be provided to workers. Unavailability of whole some drinking water with upward jet cup. Despite EPC claiming to provide mineral water to construction labourers during working hours, drinking water coolers are being filled from JPCL colonial water facility, JPCL colonial gate electrical cooler, RCC building and JPCL existing units etc. A third-party drinking water testing is required which has been in discussion since March/April 2019. Pictorial evidences are being shared with EPC EHS staff on regular basis An initial task risk assessment has been carried out by PIU, PIC and EPC EHS team for further communication with the gas company. Before the dissenting activity, TSA should be followed step by step and this should not be limited to following: Isolation (Lock Out/Tag Out) procedures, Identification of buried utilities/cables/ piping and ensuring all are dead, hot/cold work permit, measuring lower explosion level, toxic gas testing, inspection of all equipment and machinery, traffic management plan, lifting/hoisting in line with lifting plan, emergency response plan, antivenom vaccine (for snake bites), provision of first aider and first aid kit. The removal, handling and storage of asbestos sheets (used for roofing inside gas station) should be undertaken as per EIA guidelines. If tree cutting is planned at the gas station, trees should be replanted using a 6:1 ratio. Working areas of tower crane erected at main power building should be controlled by warning line or control zone (if possible) or the hazard area should be clearly established and signed as Danger- Swinging Zone or Attention- Crushing Hazard. Each employee should be communicated about the hazard through Task TBT. Ignorance, awareness and effective communication by TBT and training should be transferred to all the workers, working inside the steel rebar cage of newly built power plant. If workplace requires permits for activities such as confined spaces, then its training should be provided. Working atmosphere should be tested and forced ventilation should be provided where necessary etc. An emergency response plan should also be made. A mobile phone use policy is required and the use of mobile phones should be restricted in the areas of EPC jurisdiction. Unsafe practices including using mobile phone while driving, operating earthmoving machineries, while riding a bike, attending phone calls while walking and performing job task are common. This issue was raised by PIC on 10-12-19 during safety walk.

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There should be a restriction on motorbikes/ 150 CC loader in working areas inside JPGP/EPC jurisdiction. This issue was initially raised by PIC on 26-11-19. Motorbikes shouldn't be allowed inside JPGP and the preferred option would be to park at the parking stand established at existing oil tanker gate. This should be applicable to all staff. A traffic management plan is required. Separate routes need to be clearly identified for pedestrians where heavy traffic movements are in place. Installation of additional traffic signs, directional signs, designated parking areas with signs, walkways, flagman(s),speed limits, requirements for the safe and smooth movement of heavy transport carrying goods, equipment's inside JPGP, maintaining safe distance from overhead power lines where required, proper communication etc. 22.01.2020 Regular safety walk Comments A worker was found to be driving and operating a crawler crane whilst not having the required licence in place. Only authorised, licensed holders and trained operators should be allowed to operate cranes.

28.01.2020 Regular safety walk Comments Precautions mentioned in HEI-050FPKJS1-0202FW-SITE-0102 dated 27 Jan 2020 should be strictly followed, including use of PPEs (respirators, hand gloves if necessary) by workers, staff and visitors. An awareness campaign should be held. A traffic management plan (TMP) should be strictly implemented at site. Temporary road inside JPGP should also be regularly maintained. Activities include but not limited to grading, pothole repairs, patching, road widening, installation of traffic signs, speed breaker sign, speed control signs, clearly identifying potential signs such as narrow, winding and steep roads, flagman, road pavement and street light should be considered where necessary and applicable. As per Contract Agreement Volume II, Section 6, Part Geotechnical Specification signed between Siemens-HEI and JPCL and Social Augmentation Plan (SAP) section 10.17 of EMP of EIA, Siemens-HEI is bound to fulfil all the contractual and legal requirements as mentioned above. Matter was raised previously in EHS meetings and a draft letter from PIU reference no CE/PIU/CFPP/PIU/1106 has also been shared with Siemens-HEI as a reminder. As per Contract Agreement Volume II, Section 6, Part Geotechnical Specification signed between Siemens-HEI and JPCL and Social Augmentation Plan (SAP) section 10.17 of EMP of EIA, Siemens-HEI is bound to fulfil all the contractual and legal requirements as mentioned above. Matter was raised previously in EHS meetings and a draft letter from PIU reference no CE/PIU/CFPP/PIU/1106 has also been shared with Siemens-HEI as a reminder. Domestic waste which is also shifted from its initial location (local sub-contractor’s cabin containers) to the current location (behind JPCL existing oil storage tanks) should be handed over to a SEPA approved waste handler or transferred to landfill sites. Similarly components such as brace plate, concrete sleepers, bridge plates, screws, bolts, dip trays etc. (if present). It should be hand over to owner (JPCL) and stored separately. During the visit, steel pipes seen stored in the similar area where contaminated material has been stored. Until steel pipes which are the property of JPCL are handed to owner, the area should be barricaded and signs should be displayed such as ”JPCL/ Owner’s Property” or ”Material belongs to JPCL”. Later it should be shifted to designated area separately. HEI-Siemens should also incorporate comments provided by PIC on the method statement for removal of contaminated soil from oil tanker road and method statement for removal of contaminated soil from railway track. 04.02.2020 Regular safety walk Comments A waste management plan should be developed clearly mentioning the area calculation methodology, how much time the qualified waste handler is going to clean out the waste storage cells, construction of cell in an environmental friendly manner, segregation and storage of solid waste, construction waste, wooden waste, scrap steel and domestic waste with signs indicating waste streams. A mobile phone policy should be enforced. Mobile phone may only be used (if allowed) in designated areas and in line with practical applicable regulations for mobile phone by use by PIU, PIC, visitors and EPC management. A policy for the use of motorbikes policy must be enforced and restricted at construction sites. Parking zones should be established where necessary. Vehicles and pedestrians shall be separated by providing clear pathways for workers to walk within highly visible barricading, barriers/handrails, safety gates at intersections where applicable. Communication training regarding access routes should be established by each site team. A joint meeting with top EPC management, PIC EHS team and JPGP EHS team should take place in which EHS tracking sheet should be reviewed for effectiveness. The installation of fixed and mobile ambient air quality monitoring stations was initially planned for Dec 2019 and rescheduled for Feb 2020. In this regard, EPC should fulfil the commitment. 11.02.2020 Regular safety walk Comments Toilets were not fully functional and do not meet OSHA standards in terms of no. of workers. Toilets should be placed within convenient distance from the workplace.

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Workers were found sitting and taking lunch under the shades of NDTC Unit I ring foundation Rest. Shaded facilities should be provided depending on the occupancy and the scope of work at different components in newly build components of power plants. Colour coded waste bins should be in place at all specified locations as part of the waste collection and disposal processes. Exclusion zones should be established prior to initiating any lifting jobs. There should be constant clear lines of communication maintained between the crane operator and signaller. Site layout plan covering social points of interest such as rest and food eating areas, toilet facility(s), drinking water point(s), smoking zone(s), mobile phone usage area(s), parking area(s), walkway(s), dispensary(s), muster point(s) shall be installed at appropriate site locations such as entry points and shall be displayed with high visibility. Hand-out of the same shall be available for all first-time workers or visitors. Working activities at night such as concrete pouring, steel fixing, formwork activity, lifting activity should be done whilst meeting lighting and visibility requirements. There should be a policy in place for visitors to site, including the installation of signage, Guards should be deployed with proper communication with the Contractor's security department, cross barriers shall be installed and only those persons/vehicles shall be allowed that have valid identification cards/visitors pass provided by JPCL/PIC. PPEs shall be available at entrance if needed with a visitor pass clearly mentioning site rules. These must include items such as requirement of induction training, emergency evacuation procedure, muster points, use of PPEs, site rules regarding no smoking, photographs, mobile phones etc. and risk associated with site hazards where necessary such as blasting activity, overhead cranes, movement of heavy vehicles etc. A focal person should be designated to record complaints and maintain records. The contractor and its sub-contractor are responsible for logging written complaints. Complaints received verbally should be recorded. 18.02.2020 Regular safety walk Comments Policies including ethics, environment, health, safety & security, quality (signed off by relevant personnel) should be prominently displayed inside EPC office. Policies should be current, relevant and must be reviewed and updated periodically. Fall protection pertaining to construction work activities such as leading edges, working on steep roof and walk or working platform above or more than two metres above ground level should be protected by either Personal Fall Arrest System of Guard railing System or Safety Net System (as and where applicable). Above all should be safe and regularly and frequently inspected prior to use. Components such as safety belt(s), horizontal lifeline(s), vertical lifeline(s), lanyard(s), snap hook(s), ropes and straps, anchorage(s) should be inspected prior to use. Defective equipment ones should be immediately discarded. Tagging (in case of safety belts) and record should be maintained. Work at height and fall protection training programs should be provided to workers involved in work at height by EPC. Trainer should be competent, assuring that each worker involved in work at height has been trained and records of training should be kept and available when required. Medical assessments should be held for those workers working at height to ensure that employees are medically fit. The assessment should include but not limited to general health (weight, height, blood pressure, Pulse, urinalysis for Proteins and Sugars, Finger Prick test for Glucose and Cholesterol), Audiometry (Hearing) test, Respiratory Function test, Vision test, Musculoskeletal etc. Test records should be available when and as required. Safe work practices should be adopted while work at height. Appropriate training, supervision and instruction should be provided to the working crew. Factors such as level of competency of person involved in work at height, weather condition, safe mean of access and egress, safe working platform, edge protection against people and material falling (use of guardrails systems where possible), ensuring tack specific PPEs and its regular and frequent inspection, suitable and inspected equipment and machineries, emergency reuse plan should be considered and in practice at EPC site. Insurance should be in place covering all EPC staff, first tier, second tier and all petty contractors. The unsafe handling of weapons was observed on site. Security guards should be in uniform (high-visibility for clear visibility and safety), well equipped with equipment's they must-have. Training programmes should be arranged for security guards covering the handling and use of weapons. 25.02.2020 Regular safety walk Comments In accordance with the requirements of the Factories Act 1948, as an industry with over 250 employees, a canteen facility should be provided and maintained by the occupier on behalf of the workers. A prayer facility should be developed immediately that can accommodate the Muslim staff working at JPGP, ensuring that the facility is in line with religious requirements and provision of sufficient ventilation. 03.03.2020 Regular safety walk Comments The oil tanker road is used for entry and exits by both vehicles and employees (entering and leaving site). A separate entrance route(s) should be provided for pedestrians to avoid any collision/accidents. A grievance was raised by an employee of Al-Mustafa Company regarding two months of wages being overdue. It was noted that measures should have been taken to address the grievance particularly given there had been a previous grievance raised regarding late salary payments.

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An emergency response team and emergency procedures should be in place at the stack area in case of a power breakdown, short-circuiting, equipment failure, health issues, medical emergencies or any unforeseen circumstances. Moreover, emergency contact numbers should be displayed, fire-fighting equipment's should be easily accessible, an ambulance should be available on site with medical staff. Tower crane operators should be competent and should have knowledge, ability, training and experience. Operator should be medically fit for the job and should have valid operator’s certificate. Tower crane operator(s) are at a risk of fall as they have been seen accessing the tower by using fixed ladder without fall protection system. To prevent personnel falling and safely accessing towers, fall arrest system or ladders assist safety device should be used. These are acceptable methods of accessing tower workstations regardless of height. Training and usage of fall protection system should be provided to those who climb/access the tower cranes. An emergency plan to rescue tower crane cab operator should also be made and drills should be conducted. It was observed that two tower cranes have been installed in parallel adjacent to railway area where installation of third tower crane is in progress. Given that there are now multiple cranes are in place and the number is expected to increase, a risk of collision between the tower cranes (jibs) exists. To make it safe, anti-collision systems with ground monitoring system and built-in Safe Load Indicator (SLI) and wind velocity control which should be regularly inspected, and records maintained. A tower crane specific risk assessment should be carried out to identify who might be harmed, the chances of being harmed and the consequences of being harmed. The assessment should be recorded and reviewed as and when necessary. The EPC should take lead in communicating environmental accurate guidance on COVID-19. A standard operating procedure (SOP) on Coronavirus should be developed and circulated among the sub-contractors as well as local subcontractors. Special attention should be paid to contractor and subcontractor canteen and mess areas where mask and respirators are being taken off. Good practices such as use of hand gloves (surgical gloves/disposable gloves) should be adopted to prevent contact. Appropriate stock of mask should be readily available for outsiders/visitors at the entrance(s). Outsiders/ visitors shouldn’t be allowed without screening inside JPGP. Workers should be communicated regarding” Coronavirus-Precautionary and Preventative measures” in daily toolbox talks. As the EPC being keen to protect its employees from local and outsiders and taking preventive measures, EPC plans to request the client in writing to reschedule the upcoming visit till the situation is declared conducive. In place of site meetings if necessary than video call meetings should be considered.

04.03.2020 Regular safety walk Comments It was observed that a view of oncoming traffic was obstructed by the stacked mast section of a tower crane. To reduce the risk of blind corners, convex mirror and warning signs should be installed. 05.03.2019 Regular safety walk Comments Due to the condition of the site, the frequency of dust suppression activities should be increased during periods of high winds, particularly focussed on the stockpiles, access roads and areas of bare soil. Appropriate safety goggles and dust respirators should be used as a last resort and EPC should be vigilant in implementing this at site those who will be exposed to dust. 10.03.2020 Regular safety walk Comments At the JPGP site, safety rebar caps/wooden troughs should be used for protruding ends of steel rebar, which could represent a major hazard. It is recommended that access to the area be limited for unauthorized personnel where protruding rebars, formwork, rebar cages and sharp edge material are present. Rebar hazards should also be discussed in daily toolbox talks with workers. Scrap rebar should be routinely pick up and discarded from site. In line with site requirements, the rest area should be equipped with adequate seat arrangements, drinking water facilities, cigarette bins, standing fans etc in accordance with site requirements. Adequate PPE should be provided whilst spraying using hazardous paints to cover all exposed parts of the body. During spray paint operations, a full-face respirator or loose-fitting hood respirator should be used. Drip trays should be provided for the storage of oil, paint and chemical containers. These should be placed away from ignition sources and safety data sheets should be readily available. Hand gloves should be provided where appropriate. A number of items were found to be missing from the first aid box at the first aid station including band aids, surgical gloves, hand wash/sanitiser, face masks, CPR mouthpiece and emergency blankets which should be in place as per site requirements. A procedure is required for the laying of long cables connected to distribution boxes. Cable ramps, covers and the laying of cables underground or overhead in conduits (as and where necessary) should be adopted. It is acknowledged that the construction crew are vulnerable during the warm and hot summer season and as such a heat wave/heat stroke management plan should be developed particularly during the month of Ramzan. This should include the gathering of weather forecast information from the Meteorological Department (MD), based on the information supplied by MD, alerting system to raise

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awareness among the employees should be in place, a heat wave awareness campaign through leaflets, banners, handouts (must be in Urdu/Sindhi for locals) should be started at earliest, an onsite heat stroke emergency camp should be fully stocked with all necessities and paramedic staff, an emergency response coordinator(s) should be appointed who should ensure that all appropriate actions are in place and reviewed. Industrial firefighting vehicles should be made available at the JPGP site at all times. An onsite fire-fighting team should be established. 12.03.2020 Regular safety walk Comments The remaining portion of the excavated railway track should be hard barricaded to minimise risk of workers falling. Source: PIC/Siemens-HEI EHS – non-conformance tracker and meeting minutes

3.4 Issues tracking (based on non-conformance notices)

33. The PIC has developed an EHS issues and non-conformance tracker (JPGP-PIC Non-Conformance Tracker) to log all EHS issues and non- conformances observed during site walkovers. The tracker clearly identifies the issue, corrective action(s), level (minor-major) and associated priority risk and the responsibility for the action. The status and date that the issue was closed out. This provides a useful tool to determine the close out periods for action and also as means for determining trends.

34. Of the observations made, the PIC issued three non-conformance notices during this reporting period (one in January, two in February). These relate to working at height and scaffolding issues. These non- conformance notices have since been closed out and accepted.

35. As detailed in the last reporting period, the Siemens-HEI report details the numbers of EHS issues, raised, closed and outstanding, identified by PIC during the site walkovers/audits. In the March 2020 EHS report, pending issues were detailed in the report and a summary of progress against the EHS issues raised given as shown in Figure 3. Efforts should be made to improve the close out times of the EHS issues identified as there has been a number of reoccurring issues identified.

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Figure 3: Extract of Siemens-HEI ‘Summary of EHS Issues Highlighted by JPCL and PIC’

Source: Siemens-HEI Consortium Monthly EHS report March 2020

36. This level of information is not provided in the report for the second quarter of the reporting period. Whilst it is accepted that there was a reduction in the work undertaken during April-June 2020 as a result of Covid-19, future EHS monthly reports should include more detail on the closing out of issues raised by including the non-conformance tracker being maintained.

3.5 Trends

37. There was an increase in the number of non-conformances reported in January 2020 compared to the number of monthly non-conformances reported in the previous reporting period. However, as shown in Figure 4, the number of EHS issues raised reduced in February and March 2020. The monthly reports still do not report trends in the non-conformances being raised, which as previously reported should be included. However, internal inspections completed by the HEI EHS team within the reporting period identify trends in terms of the types of issues being highlighted; this is discussed further in section 4.3. These correspond to some of the EHS issues being raised by the PIC.

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Figure 4: Extract of Siemens-HEI ‘Summary of EHS Issues Highlighted by JPCL and PIC’

Source: Siemens-HEI Consortium Monthly EHS report, March 2020

3.6 Unanticipated environmental impacts or risks

38. The previous SAEMR reports that contaminated material that is part of Lot 6, remediation of contaminated soils, has been excavated and is either stored on site or transported off the site. A waste management procedure method statement was prepared during the reporting period pertaining to the removal of contaminated soil from the railway track and road has been conditionally approved by the PIC.

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4 Results of environmental monitoring

4.1 Overview of monitoring conducted during current period 39. During the reporting period (January to July 2020) the following work packages were in progress:

● Lot 3 - Municipal waste disposal site (worker’s colony) ● Lot 5 – Colony sewage treatment plant ● 660MW power plant – main build 40. Work at Lot 4 was largely completed at the start of the reporting period and no monitoring reports were received.

41. Lot 5 is contracted to Hebei Installation Engineering (HIE) and work is progressing on site. The monitoring report for Lot 5 prepared by HIE is attached as Annex C.

42. The 660MW power plant is contracted to a consortium of Siemens and Harbin Electric International Company (HEI), together referred to as Siemens-HEI.

4.2 Lot 5 – Colony sewage treatment plant 43. Information reported here is extracted from the contractor’s ‘Construction of sewage treatment plant for site remediation package Lot V, Jamshoro Power Company Limited. EHS Report; First half of 2020’. The monitoring report is attached as Annex C.

4.2.1 Overview 44. The report presents details of the project (installation of sewage treatment plants), the parties involved and construction activities during the period. The level of detail provided is limited and many of the issues raised in the previous SAEMR report remain outstanding.

45. The report refers to the site-specific construction environmental management plan and environmental and social risk register and monitoring plan in line with the EIA are in place.

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46. The report refers to monthly site audits undertaken to identify and correct site environmental issues and that there were no significant findings were identified. There is, what appears to be an internal instruction to include the audit as an annex to the report but has not been inserted.

47. Whist the report states that no major issues were identified by HIE in its audit, insertion of the audit findings would assist in understanding the adequacy of the audit scope and the nature of those issues identified and adequacy of the corrective actions identified.

48. Issue tracking has been provided by reproducing a letter from the PIU detailing an issue regarding a lack of HSE signage with photos provided to demonstrate that this issue has been addressed. A table is provided, reporting that two issues were raised and indicates that both issues are closed but no detail of how the context of the second issue or how it was resolved are provided.

49. The report provides a high-level description of mitigation measures for environmental aspects. The report includes a table populated with unanticipated environmental impacts or risks. It is considered that these should not be considered as ‘unanticipated’ impacts or risks but should be part of the CEMMP.

50. Testing of wastewater is reported in a poor-quality copy of a test report, indicating some exceedances of the NEQS, 2000 permissible limits. However, no context is given.

51. A screen shot of an air quality analyser. No context is provided in terms of the monitoring methodology, monitoring locations or of results shown.

52. The report states that mineral water is available for officer staff and water from a community filter plant is available for construction workers. No detail of drinking water testing is provided to confirm that the water meets drinking water quality standards.

53. The report refers to noise monitoring being undertaken by the subcontractor, but no further detail or monitoring results are presented.

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4.2.2 Trends 54. The report states that all are stable without any significant or new changes. However, given lack of data and limited context provided, no trends are identifiable.

4.2.3 Summary of monitoring outcomes 55. As reported in section 4.2.1, whilst there is some monitoring being completed no context is provided to determine appropriateness of the monitoring approach, exceedances or subsequent actions taken.

56. Contractors will be requested to undertake monitoring appropriate to the scale and duration of the project and to provide an analysis of the results presented.

4.2.4 Material resources utilisation 57. Water, electricity and fuel use are reported as shown in Table 6.

Table 6: Lot 5 resource use January – June 2020 Month Water consumption Electricity Fuel gasoline (L) (ton) consumption 1 70 294 212

2 64 189 201

3 62 415 220

4 20 303 199

5 16 402 198

6 23 1512 160

4.2.5 Waste management 58. The report states that waste arising from the construction stage comprises of construction waste, domestic waste and sewage which is removed via a connection to the existing municipal wastewater line. However, no quantities are reported and limited detail with respect to the disposal routes is given.

59. A general statement is given that were possible waste should be recycled to reduce the quantities being disposed of at the waste treatment station, and some pictorial evidence is provided to indicate some waste

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segregation but no detail is given on what wastes are being recycled or recycling rates.

4.2.6 Health and safety

4.2.6.1 Community health and safety 60. Whilst it is not clear from the reporting, it is understood that no community health and safety issues occurred during the monitoring period.

4.2.6.2 Worker safety and health 61. It is reported that no worker health and safety issues occurred during the reporting period. However, no records are presented to indicate the reporting of any H&S incidents including near misses or detail on unsafe acts or unsafe conditions identified.

4.2.7 Training 62. Some pictorial evidence and a list of attendees indicates that training has been provided for health and safety. This included training on Covid-10 prevention measures.

4.2.8 Conclusion 63. The semi-annual environmental monitoring report for Lot V, prepared by HIE presents still requires significant improvement. In previous reporting periods the contractor has been advised of the deficiencies and advised how to improve its reporting. Further advice will be provided by the PIC.

4.3 660MW power plant – main contract 64. Information reported here is extracted from the 2x660MW Jamshoro coal fired power plant monthly EHS reports for prepared by Siemens HEI. No summary semi-annual report has been provided.

65. In future, the contractors will be asked to summarise the monthly data in a semi-annual report, which is a contractual requirement.

66. The reports contain details of the project, the consortium, construction activities and actual work during the reporting period. Inspection checklists, monitoring records and training summaries are presented in the appendices.

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67. During the reporting period the monitoring/reporting activities and approaches presented in Table 7 have been undertaken.

Table 7: Main build environmental and H&S monitoring/reporting Sr. Monitoring and management January to June 2020 No. parameters 1. Vehicle and machinery inspection checks Check lists completed 2. Housekeeping inspections Health and safety related 3. Daily safety inspections and audits Breakdown of key issues presented 4. Noise monitoring Undertaken weekly at work sites 5. Toolbox talks Health and safety related 6. Vibration monitoring In connection with blasting (now complete) 7. Compliance with the construction Checklist completed management plan 8. Excavation inspections Inspection records provided 9. Scaffolding inspections Inspection records provided 10. Dust suppression Log maintained

68. Vehicle safety checks are appropriate and are mainly a maintenance and safety function. As noted in the previous SAEMR, there is no requirement for the vehicle checks to be reported in detail in the contractor’s reports.

69. Basic health and safety housekeeping checklist completed on a monthly basis. No details of locations inspected are provided.

70. Daily safety inspection and audits are completed by the contractor and sub-contractor(s), EHS manager and EHS engineer. Issues are shared with the supervisors for closure. The HEI provides a breakdown of the EHS issues by type, which is to be commended. The key EHS issue identified in the reporting period related to working at height/scaffolding, chemical and explosive handling and handling of tools, equipment & machinery, which is aligned to the EHS issues and non-conformances identified by the PIC. The report identifies that training sections are planned to cover these topics accordingly.

71. Ambient air quality monitoring was due to be undertaken in the reporting period by a Sindh Environment Protection Agency certified laboratory in the reporting period; however, this did not take place as a result of the Covid-19 site restrictions. This forms a condition of the Sindh

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Environment Protection Agency and should be undertaken as soon as possible.

72. Permanent automatic monitoring equipment was scheduled to be installed before the end of April 2020 and include two stationary and one mobile monitoring device. However, due to the site restrictions, this is now due to be installed by the end of 2020.

73. Noise monitoring is undertaken on a weekly basis and the data is presented in a graph. The last SAEMR requested that environmental noise be monitored at the site boundary/workers colony and the methodology be provided to confirm the duration of the monitoring undertaken; these recommendations have not been taken forward. We will discuss these requirements with Siemens-HEI.

74. The monthly EHS reports refer to compliance against the prescribed international OSHA standards for Permissible Exposure Limit (PEL) of noise levels of 90dB (for 8 hours), and on this basis there were no exceedances. However, for international financed projects, the IFC employee exposure noise guideline of 85dB(A) for a period of more than eight hours per day without hearing is typically used. On this basis, some exceedances occurred in the reporting period, but it is not clear if the noise levels measured would likely be sustained over an eight-hour period and whether hearing protection is provided in areas of high noise exposure.

75. Continuous noise monitoring was due to be undertaken in the reporting period by a Sindh Environment Protection Agency certified laboratory however, this did not take place as a result of the Covid-19 site restrictions.

76. Vibration monitoring was undertaken whilst blasting activity at the main build areas of the project and the railway were ongoing. There is no analysis or interpretation of the data. Blasting activities are now complete.

77. According to the Contractor, worker accommodation audits are now being completed. However, no information is provided in the EHS

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monthly reports and based on site walkovers, neither the workers accommodation or canteen areas are in accordance with Sindh or IFC/EBRD accommodation guidelines. The quality of the worker welfare facilities needs to be improved and expanded to meet the demands of the increasing construction workforce.

4.3.1 Trends 78. Siemens-HEI reporting now includes trend graphs in some areas of its reporting including EHS training and EHS issues and Figure 3 illustrates the EHS issues trend provided in the March report. We consider that this improvement in reporting can be further built on through the identification of specific trends relating to work activities, the cause of EHS issues and subsequent corrective actions to assist in developing appropriate mitigation mechanisms.

4.3.2 Summary of monitoring outcomes 79. Monitoring, and reporting has improved. However, the quality of reporting has been significantly affected during the Covid-19 restrictions and the PIC expects to see this improve over the second half of 2020. PIC will continue to work with Siemens-HEI to continue improvements.

80. In line with a previous recommendation, Siemens HEI now provides more detailed on visual monitoring data as evidenced by checklists which should be used daily and results summarised monthly and bi-annually.

4.3.3 Material resources utilisation 81. No data provided.

82. Contractors will be requested to provide data on fuel, electricity and water use.

4.3.4 Waste management 83. Some waste management data is reported. As data increases this it will be reported and analysed in more detail. More detail is required on disposal of construction related waste, although it is understood that the waste handling contractor used is unlicensed which is a Sindh requirement. Licensed waste contractors should be sought, and end disposal sites confirmed.

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84. A waste management procedure method statement was prepared during the reporting period pertaining to the removal of contaminated soil from the railway track and road has been conditionally approved by the PIC.

4.3.5 Health and safety

4.3.5.1 Community health and safety 85. No community health and safety issues were reported during the monitoring period. 86. An emergency preparedness and response plan has been prepared for the project and also covers the local community.

4.3.5.2 Worker safety and health 87. Occupational health and safety data is reported. Cumulative data from the January to June 2020 EHS monitoring reports is reproduced in Table 8.

Table 8: Health and safety statistics EHS indicator Jan Feb Mar Apr May Jun Cumulative Total man-hours 203,085 390,064 212,068 136,460 127,040 150,819 2,472,594 Safe Man-Hours 203,085 390,064 212,068 136,460 127,040 150,819 1,473,358 Number of toolbox talk 457 406 342 223 186 190 4662 conducted Man-hours of OHS 751 593.5 11 0 226.5 428.25 4217.85 training Number of spills 0 0 0 0 0 0 1 reported Number of incidents 0 6 reported* Near miss (high 0 0 1 3 2 0 11 potential incidents) First Aid Cases (OSHA 5 6 0 2 1 2 21 300 Log provided in contractors report) Medical treatment cases 0 0 0 0 0 0 0 Lost Time Injury (LTI) 0 0 0 0 0 0 3 Lost Time Injury ------1.21 Frequency Rate (LTIFR) Source: Cumulative statistics based on data provided in EHS monthly report for April, May, June 2020 * Incidents not reported in the monthly EHS reports for February-June 2020. 88. Scanned copies of the OSHA 300 logs are provided in each of the monthly EHS reports. Limited information is included indicating where the incident occurred, and a description of the illness/body part affected. No

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information is provided in terms of how the incident occurred and any subsequent corrective actions taken.

89. Other than the limited details of first aid incidents, no details of the incidents in Table 8 are provided. As previously reported, the contractor will be required to provide details of incidents in future reporting.

90. It is understood that on 05 February 2020, a worker fell from height (18 feet) whilst working at the NDCT at the stack, sustaining a severe head injury, which would constitute an LTI. The Contractor’s EHS team initially denied that this incident had occurred but later accepted that it took place. However, this incident is not included in the EHS figures in the reporting and an accident report was not generated, which should be completed for each incident. All incidents should be reported in the future.

91. Grievances are reported in a table showing the numbers of grievances raised and mitigated. Cumulatively over the period, 11 worker grievances were logged and resolved. Four of these grievances were raised in March 2020 but no detail is provided on the nature of the grievances raised. No community grievances are reported.

4.3.6 Training 92. Training has been undertaken and pictorial evidence is provided in the report. Training, in the form of toolbox talks, are conducted daily and is primarily health and safety related, including on measures on the control of Covid-19. Training subjects provided are generally in line with the relevant risks on site.

93. As a result of Covid-19, training was limited in March 2020 and training sessions were not held in April due to staff availability and in order to practice physical distancing. Training manhours provided are now represented in a graph as shown in Figure 5.

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Figure 5: EHS training trends presented in April-June 2020 EHS Report

Source: Siemens-HEI Consortium Monthly EHS report, April-June 2020

94. Safety workshops are reported with signed attendance sheets appended. Training topics have included safety induction, occupational health training, working at height and scaffold safety training and crane rigging.

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5 Functioning of the CEMMP

5.1 CEMMP review

5.1.1 Lot 5 95. Lot 5 is considered to have relatively low environmental risks during the construction phase with excavations and installation of the sewage treatment facilities having relatively small footprints. Impact can easily be controlled with appropriate management techniques and adopting the mitigation measures within the EIA and CEMMP.

96. Given Lot 5 is within the residential colony, community health and safety is a significant concern and steps must be taken to ensure occupants of the residential colony are not exposed to avoidable risks. Appropriate monitoring and reporting are needed to demonstrate that necessary measures are in place. There is no evidence that this is currently being undertaken.

97. As previously reported, the function of the CEMMP for Lot 5 could be significantly improved by improving the standard and consistency of reporting in the monthly and semi-annual EHS reports.

5.1.2 660MW power plant – main contract 98. The 660MW power plant main contract is now in the main build phase.

99. Compliance against the CEMMP is reviewed monthly and the checklist results are appended to the EHS monthly reports. Key and repeat non-compliances identified over the reporting period are largely related to traffic management including the development of a traffic management plan, the designation of routes including for the transportation of hazardous materials, the installation of high efficiency mufflers on construction equipment to reduce noise generated and the use of machinery with appropriate exhaust systems and emission control devices. Some corrective actions are identified but not for all non-compliances.

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100. The HEI EHS team conducted an internal audit of its environment and social OHS management system (ES-OHS-MS) and the results are awaited.

101. As anticipated in the last semi-annual report, environment and health and safety monitoring and reporting is improving, and we expect the contractor to continue to improve the reporting by including further analysis of trends in future reporting. The PIC will continue to work with Siemens-HEI to further improve the reporting.

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6 Good practice and opportunity for improvement

6.1 Good practice

102. The current work lots are following standard good practice for concreting in terms of the operation of the batching plant, production and delivery to site.

6.2 Opportunities for improvement

6.2.1 Lot 5 – Colony sewage treatment plant 103. Lot 5 is not considered to present significant environmental risks provided best practice environmental management procedures are followed. It is important that monitoring is appropriate to the risks and is accurately and consistently reported in the monthly and semi- annual reports and sufficient detail is provided.

104. The following specific items to be addressed were noted from the received reports, a number of which were raised in previous reporting periods:

● Update the environmental monitoring plan so that it details the monitoring that will be undertaken (currently mitigation measures are reported rather than monitoring details). This should include providing monitoring methodologies.

● In addition to the information already presented in the reporting, measure/monitor, record and report the following:

i. Waste generated and disposal route of the waste (with evidence such as consignment notes)

ii. Monitor and report any community health and safety issues arising from Lot 5 activities (this is in addition to worker health and safety reporting) and should include details of any stakeholder engagement activities

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iii. Maintain detailed worker health and safety records and provide detailed statistics in monthly /semi-annual reports. This should include the reporting of lost time incidents, medical treatment, first aid, near misses, unsafe acts/unsafe conditions

iv. Provide audit finding reports as part of the monthly/biannual reporting

v. Keep accurate records of training undertaken (date, time, location and subject of the training and a list of attendees signed by each attendee)

vi. Provide evidence of site induction HSE training which includes environmental duties of all site personnel.

vii. Report specific details of HSE incidents reported in the reporting

6.2.2 660MW power plant – main contract 105. Construction of the 660MW plant involves a variety of construction techniques and activities. Construction needs to be appropriately managed to avoid adverse environmental impacts. It is important that monitoring is appropriate to the risks and is accurately and consistently reported in the project reporting.

106. Further oversight of the contractors is required.

107. The following specific items, as discussed in section 4.3, were noted from the received reports:

● More detailed information is required to support the HSE statistics provided. The EHS report should incident reporting and include an analysis of OHS trends identified and detailing the nature of incidents that arise including the identification of the root cause, action to be taken, responsibility for the action, evidence of action being undertaken, date action completed.

● Noise monitoring and reporting should be improved as follows:

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i. Provide details of calibration procedures and certification of the sound level meter

● Noise monitoring should be undertaken to demonstrate compliance with environmental as well as health and safety requirements. Receptors such as the JPCL residential colony should be considered and noise measurements should be taken at the site boundary and compared to appropriate Sindh and World Bank/IFC guidelines.

● At the time of this report, some restrictions had been lifted on external parties attending site, air quality monitoring and noise monitoring should be undertaken using the subconsultant. This is a precondition of SEPA and is contained within the monitoring plan. Air quality monitoring should be repeated at least monthly until the permanent monitoring is installed and fully operational.

● Efforts should be made to install continuous ambient air quality analyser by the end of 2020.

● Where new plans have been developed, these should be appended to the report.

● Undertake regular audits of the workers accommodation and worker welfare facilities, ensuring that there are sufficient facilities in place for the increasing number of workers on site. Additional facilities should be provided as and when required.

● Measure/monitor, record and report the following:

ii. Resource utilisation (fuel, electricity, water used per month)

iii. Include details of disposal routes of all waste (with evidence such as consignment note) and contractors used iv. Inspect and report on the quality of worker accommodation provided

v. Monitor and report community health and safety issues arising from site activities (in addition to worker H&S reporting)

vi. Report any security incidents that occur.

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vii. Report the details of grievances (worker and community) raised, and the actions taken to resolve these. The report should identify any trends in the grievances raised. Regular worker awareness campaigns should be held so workers are aware of the grievance mechanism process.

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7 Summary and recommendations

7.1 Summary

108. This is the 12th monitoring report for the Jamshoro Power Generation Project.

109. Construction activities during the reporting period, January to June 2020 included:

● Lot 3 Municipal waste disposal site (worker’s colony)

● Lot 5 Domestic sewage treatment for worker’s colony. Work was ongoing during the reporting period.

● 660MW power plant (main project) construction is now in the main build. The contractor (Siemens-HEI consortium) commenced construction on 28 January 2019 with partial handover of the site to the consortium by JPCL.

110. There has been a general improvement in the reporting produced for the main project, although further detail is required with respect to EHS incident reporting, particularly in terms of the nature of health and safety incidents.

111. There are concerns that some incidents are not being appropriately reported, included in the HSE statistics and investigated. All incidents should be reported.

112. Additional efforts are required with respect to the measures that need to be in place to minimise the risk of Covid-19. The Contractor should focus on updating the Site Safety Protocol in accordance with Sindh requirements.

113. As a result of the various restrictions in place during the reporting period as a result of the Covid-19 pandemic and also through the ramping up of work, there are a number of environmental risks that have been identified. These mainly relate to risks associated with working at height and worker welfare facilities including

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accommodation. It is considered that further efforts should be made to improve worker facilities provided.

114. Improvements in monitoring and reporting of environmental aspects have been made by Siemens-HEI although further work is required. PIC will continue to work with Siemens HEI to further improve monitoring and reporting.

7.2 Recommendations

115. There are currently no recommendations for consideration by the ADB for changes to the Environmental Safeguarding process for the project.

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Annexes

A. EHS photographs 39 B. 660MW Site location/layout plan 44 C. Lot 5 contractor monitoring report 46 D. 660MW main build contractor monitoring reports, January – June 2020 47 A. 48

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A. EHS photographs

A.1 Remediation Lot 3

Photo 1: Rains and ponding of water resulting in lateral scope erosion and growth of vegetation