Monthly Monitoring Report (MMR) : Third Party Environmental Monitoring CCCC KKH-Phase II (Havelian-Thakot) Project

Third Party Environmental Monitoring
CCCC KKH-Phase II (Havelian-Thakot) Project
Monthly Monitoring Report (MMR)
December, 2016
JUNE 2014
MMR-Third Party Environmental Monitoring-KKH Phase-II (Havelian-Thakot) December- 2016
EXECUTIVE SUMMARY
KKH-Phase-II is a part of China–Pakistan Economic Corridor (CPEC). Its

length is 118 Km and spans from Havelian to Thakot. The work is awarded to China
Communications Construction Company Limited (CCCCL). Jers Engineering
Consultants (JEC) has been hired for third party environmental monitoring. JEC
has to submit monthly monitoring report of its activities. The entire road length is
divided into four section viz.
1. A (Havelian-Sajikot)
2. B (Sajikot-Badai)
3. C (Badadi-Quza Banda)
4. D (Quza Banda-Thakot).
In order to carry out the job of environmental monitoring, JEC has deployed
one Environmental Monitor (EM) at each section. In addition, head office support
is given to this field team. This monthly monitoring report pertains to December
2016.
Currently the activities of road construction are in initial stages. The summary
of major findings is as under:
1. There is a need to develop traffic management plan and share it with the
district governments and people
2. Road signage is good but there is a need to put more sign boards
3. Personal Protective Equipment (PPEs) are provided but these are
inadequate. Most of the labour do not use it
4. The health and safety (H&S) staff of CCCCL may impart induction H&S
training to labourers. In addition, training of labour, which is site and job
specific, should be made a regular feature
5. Although dust problem is currently mitigated by water sprinkling yet there
are sites where sprinkling is not adequate and frequency needs to be
enhanced.
6. There is no solid waste management plan.
7. The position of labour camp is not satisfactory with respect to hygiene
conditions. Toilets are in a very bad shape. There are toilets which have
no door. Water ponds in the toilet area.
8. Emergency preparedness plan needs to be put in place
9. Wastewater treatment at labour camp is not being practiced
Jers Engineering Consultants (JEC) 1

10. Environmental tests (air, water, noise, surface water) needs to be

conducted on regular basis at a frequency, at least once per month.
11. Drinking water is not available to the worker at few sites
12. There are no toilets for labourers at few sites
13. GRC exists, however, there is a need to widely disseminate the existence
of GRC and to whom people may contact in case of any complaint
14. As per contract agreement, EIA and relevant portion of contract
agreement between CCCCL and NHA having health and safety clauses
has not yet been provided to third party environmental monitoring
consultants
15. CCCCL H&S policy and details may be shared with EMs/head office of
JEC.
During December-2016, a field visit was also paid by head office staff to
discuss various issues with section managers of CCCCL and to oversee the work
of EMs deployed by JEC.

LIST OF ABBREVIATIONS
CCCCL China Communication and Construction Company Limited
EHS Environment health and safety
EIA Environmental impact assessment
EMP Environmental management plan
GRC Grievance redress committee
H&S Health and safety
IEE Initial environmental examination
JEC Jers Engineering Consultants
MMR Monthly monitoring report
PPE Personal protective equipment

Table of Contents
EXECUTIVE SUMMARY 1
LIST OF ABBREVIATIONS 3
BACKGROUND 7
PROJECT AREA 7
METHODOLOGY ADOPTED FOR ENVIRONMENTAL MONITORING 8
3.1 Deployment of Environmental Monitors (EMs) ....................................................... 8
3.2 Study of relevant legal and regulatory framework .................................................. 9
3.3 Study of project related documents ........................................................................ 9
3.4 Development of monitoring check lists ................................................................... 9
3.5 Site visits ................................................................................................................. 9
3.6 Meetings and discussion ........................................................................................ 9
3.7 Taking pictorial evidence of non-compliance........................................................ 10
3.8 Compilation of reports by each EM ...................................................................... 10
STRUCTURE OF THE REPORT 10

Environmental Monitoring Findings 11
Section-A (Havelian-Sajikot) 11
SECTION A (HAVELIAN-SAJIKOT) 12
5.1 Contractor health and Safety Staff ....................................................................... 12
5.2 NEQS Compliance ................................................................................................ 12
5.3 Implementation of Mitigation Measure.................................................................. 12
5.4 Compensation of losses ....................................................................................... 12
5.5 Sanitation during construction and operation phase ............................................ 13
5.6 Landscaping ......................................................................................................... 13
5.7 Solid waste management Plan ............................................................................. 13
5.8 Information Sharing .............................................................................................. 13
5.9 Wastewater Management Plan ............................................................................ 13
5.10 Labour camp ......................................................................................................... 14
5.11 Traffic Management Plan...................................................................................... 14
5.12 Noise Pollution ...................................................................................................... 14
5.13 Cordon off work areas .......................................................................................... 14
5.14 Dust Control .......................................................................................................... 14
5.15 Health Safety and Environment ............................................................................ 14
5.16 Shifting of Utility Services ..................................................................................... 15
5.17 Grievance Redressal Committee .......................................................................... 15
5.18 Site Inspection Detail ............................................................................................ 15
5.19 Dumping sites ....................................................................................................... 17

5.20 Compliance Status with NEQS ............................................................................. 18
CONCLUSIONS/RECOMMENDATIONS (SECTION-A) 18
Section-A- pictorial views of environmental monitoring .................................................... 20
Section-B (Sajikot-Badadi) 29
SECTION-B (SAJIKOT-BADADI) 30
7.1 Contractor’s health and Safety Staff ..................................................................... 30
7.2 NEQS Compliance ................................................................................................ 30
7.6 3.6 Landscaping ................................................................................................... 31
7.7 3.7 Solid waste management Plan ....................................................................... 31
7.10 Labour camp ......................................................................................................... 32
7.12 Noise Pollution ...................................................................................................... 33
7.13 Cordoning of Areas ............................................................................................... 33
7.14 Dust Control .......................................................................................................... 33
7.18 Waste Dumping Sites ........................................................................................... 34
7.19 Magazine: ............................................................................................................. 35
CONCLUSION AND RECOMMENDATIONS (SECTION-B) 36

Section-B pictorial views of environmental monitoring ..................................................... 37
Section-C (Badadi-Kuza Banda) 47
SECTION-C (BADADI-KUZA BANDA) 48

9.1 Contractor Health and Safety Staff ....................................................................... 48
9.2 NEQS Compliance ................................................................................................ 48
9.4 Compensation for Losses ..................................................................................... 48
9.5 Sanitation during Construction and Operation Phase .......................................... 49
9.6 Landscaping ......................................................................................................... 49

9.10 Preparation of Wastewater Management Plan ..................................................... 49

9.11 Labour Camp ........................................................................................................ 50
9.13 Noise Pollution ...................................................................................................... 50
9.14 Cordoning off Areas .............................................................................................. 50
9.15 Dust Control .......................................................................................................... 50
9.16 Health, Safety and Environment ........................................................................... 50
9.17 Accident Reported ................................................................................................ 51
9.18 Grievance Redressal Committee (GRC) .............................................................. 51
9.19 Waste Dumping Site ............................................................................................. 51
9.20 Monitoring observation ......................................................................................... 51
CONCLUSIONS/RECOMMENDATIONS (SECTION C) 52
Section-C pictorial views of environmental monitoring ..................................................... 53
Section-D (Kuza Banda-Thakot) 59
SECTION-C (BADADI-KUZA BANDA) 60

11.1 Contractor health and Safety Staff ....................................................................... 60
11.2 NEQS Compliance ................................................................................................ 60
11.6 Landscaping ......................................................................................................... 61
11.10 Labour camp ......................................................................................................... 62
11.12 Noise Pollution ...................................................................................................... 62
11.13 Coordoning of Areas ............................................................................................. 62
11.14 Dust Control .......................................................................................................... 62
11.18 Site Inspection Detail ............................................................................................ 63
CONCLUSIONS/RECOMMENDATIONS (SECTION-D) 67
Section-C pictorial views of environmental monitoring ..................................................... 68
Annex-1 78
Environmental Checklist developed for KKH-Phase-2 78

BACKGROUND
As part of the China–Pakistan Economic Corridor (CPEC), reconstruction and

upgrade works are underway on the National Highway 35 (N-35), which forms the
Pakistani portion of the Karakoram Highway (KKH). A portion of this project, i.e.
KKH-Phase-II is awarded to China Communications Construction Company
Limited (CCCCL). KKH-Phase-II has length of 118 Km. It starts from Havelian and
ends at Thakot.
Environmental monitoring, during project execution, is an important activity.
The purpose is to oversee that all the mitigation measures, as envisaged in
Environmental Management Plan (EMP) has been observed. And that
environmental impacts are kept to a minimum acceptable levels. Jers Engineering
Consultants (JEC) has been assigned the duty of performing third party
environmental monitoring.
PROJECT AREA
The route plan of KKH-Phase-II is shown in Figure 1.1. It may be seen that
there are four base camps on the route as enumerated below
1. Havelian base camp
2. Sajeekot base camp
3. Badadi base camp
4. Kuza Banda base camp
The entire route is divided into four section. Each section spans from one base
camp to the next. The details of sections and their lengths is given in Table 2.1
Table 2.1: Details of section on KKH-Phase-II

Section From to Length (Km)
Section-A Havelian Sajikot 20
Section-B Sajikot Badadi 20
Section-C Badadi Quza Banda 45
Section-D Quza Banda Thakot 33

Figure 2.1: Route plan of KKH-Phase-II and base camps
METHODOLOGY ADOPTED FOR ENVIRONMENTAL MONITORING
3.1 Deployment of Environmental Monitors (EMs)
Due to the long geographical spread of the area, four Environmental Monitors
(EMs) were deployed at the site; one for each section. These EMs are
environmental engineers/scientists with relevant qualifications and expertise to

conduct the job. The details regarding their deployment is given in Table 3.1.
Table 3.1: EMs deployment details

Section EM
Section-A Muhammad Zeeshan
Section-B Zafar Ullah Khan
Section-C Tashfeen Abbas
Section-D Muhammad Shaukat
3.2 Study of relevant legal and regulatory framework
The legal framework related with the project includes: (1) Pakistan
Environmental Protection Act, 1997 and (2) IEE/EIA Regulations 2000. Other
related regulations were also looked into.
3.3 Study of project related documents
All the project related documents, provided by CCCCL were studied by the
EMs.
3.4 Development of monitoring check lists
Keeping in view the ToR given in the contract agreement between JEC and
CCCCL, legal and regulatory framework, and documents provided by CCCCL,
check list for environmental monitoring were developed (Annex-1). It was used for
arranging information related to environmental monitoring.
3.5 Site visits
All the EMs are station at or in near vicinity to the base camp. The purpose is
to get easy access to the site of work. Frequent visits are paid to acquire data on
environmental compliance and observance of EMP during execution process
3.6 Meetings and discussion
Meeting and discussions with the Health Safety and Environment (HSE) staff
of CCCCL and other stakeholders were conducted for gathering as much as was
possible.

3.7 Taking pictorial evidence of non-compliance
Pictorial evidence of any violation of environmental norms, health and safety

matters, discharge of untreated effluents into environment, improper management
of solid waste, etc. were taken and made a part of this report.
3.8 Compilation of reports by each EM
Each EMs compiled environmental monitoring report of his section. The

individual reports were combined, improved and quality assurance at head office.
STRUCTURE OF THE REPORT
The report is structured as per scope of activities given in the ToR of contract
agreement between CCCCL and JEC. Thus findings are structured as per the
following headings. Each section (A, B, C and D) is discussed separately under
these headings.
1. Contractor’s health and safety staff

2. NEQS compliance
3. Implementation of mitigation measures
4. Compensation of losses
5. Sanitation during construction and operation phase
6. Landscaping
7. Solid waste management plan
8. Information sharing
9. Wastewater management plan
10. Labour camp
11. Traffic management plan
12. Noise pollution
13. Cordoning off area
14. Dust control
15. Health safety and environment
16. Shifting of utility services
17. Grievance redressal committee
18. Waste dumping site
19. Magazine
20. Observations during site visit
21. Conclusion and recommendations
Pictorial evidences are added after above headings, for each section of the
KKH-Phase-II route.
Findings of Environmental Monitoring-Section A (Havelian-Sajikot) December- 2016
Environmental Monitoring Findings
Section-A (Havelian-Sajikot)

SECTION A (HAVELIAN-SAJIKOT)
5.1 Contractor health and Safety Staff
CCCCL has their own health and safety policy, however, JEC would
appreciate if it is shared with the EMs at site. CCCCL also has Health & Safety
(H&S) staff but the detail of this staff is yet to be shared with JEC EMs. Some lack
of communication was observed between H&S and technical staff of CCCCL.
5.2 NEQS Compliance
As per agreement and Conditional Approval the proponent (CCCCL) has to

conduct the testing of following parameters, to avoid any contamination to
environmental. Since the project is in preliminary stages therefore no test are being
conducted by contractor on site. Following parameters need to be tested on site;
1. Air Quality
2. Surface Water Quality
3. Drinking Water Quality
4. Noise Level
It is recommended to conduct these testing on monthly basis. After testing
these parameters, then results may be compared with National Environmental
Quality Standards (NEQS).
5.3 Implementation of Mitigation Measure
The implementation of mitigation measures is very important factor for any

project. Due to some reasons, best known known to CCCCL, Environmental
Impact Assessment (EIA) report is not yet provided to JEC. In the absence of EIA,
it is not possible to monitor that the mitigation measures proposed in Environmental
Management Plan (EMP), which is a part of EIA, are being observed or not.
Nevertheless, JEC EMs are currently monitoring common mitigation measure
related to road project, such as: Sprinkling of water (Dust problem), provision of
PPEs, water Testing, air testing, noise testing, proper solid waste management
etc.
5.4 Compensation of losses
Compensation is the biggest hurdle for the road projects. National Highway
Authority (NHA) is responsible for compensation for any type of loss in property,
shops or any assets. On visited site, as per public and CCCCL staff communication
proper compensation is given to the effected. The CCCCL staff told that they are
giving compensation per tree for cutting tree but they have no permit on the site. It
was recommended to provide the copy of permit.
5.5 Sanitation during construction and operation phase
Sanitation practices was near to satisfactory at some sites, however

improvement is require at almost all the sites. In labour camp, sanitation conditions
were not good. In Kherawala Labour camp, there is no water facility in wash rooms.
In Havelian labour camp, water facility is available but sanitation was in very poor
condition. Poor sanitation may lead to unhygienic conditions and spread of
diseases.
5.6 Landscaping
In the current preliminary stage of the project, landscaping is not possible. It

will be done at the final stage of project. According to CCCCL, proper plantation
and landscaping will be implement when project will be near completion (1% of the
total project fee as per agreement).
5.7 Solid waste management Plan
The generation of solid waste from camp is being stored in plastic bags and
then dispose to solid waste site at the end of day. However, the disposal of solid
waste from construction site was not proper. No solid waste management plan was
shared with JEC EMs.
5.8 Information Sharing
It was observed that heavy vehicle movement from one camp to other camp
in day time, caused congestion and traffic problem to the local population. It was
learnt that vehicle movement was not shared with the local administration, enabling
them to devise methods to reduce the congestion problems. Information sharing
regarding the project activities, with local administration is important and may be
practices by CCCCL H&S staff.
5.9 Wastewater Management Plan
At this stage of work, wastewater is not a problem because almost no

wastewater in being generate from the site however the wastewater is being

generated from camps. It is disposed to nearby deap areas, however no

wastewater treatment plant was observed. The current main activities are cutting
& filling, installation of machinery & crush plants, drilling of tunnels etc.
5.10 Labour camp
Labour camp are located away from the residential area except one camp at
K600+900 (Lundi). Complaint received from the public about the toilet system of
that camp because the camp boundary is very close to the inhabitants. It is
recommended to construct a wall around the camp to resolve this issue.
5.11 Traffic Management Plan
No proper traffic management plan at site was observed. Signage for diversion
of roads, speed limits, road marking, caution signs etc., nothing was observed
during site visits.
5.12 Noise Pollution
Noise generation is a common problem in road projects. No noise test was

being conducted at site. JEC recommends noise level measurement. Secondly,
no ear plug/muff were provided to worker at site. Heavy machinery is working on
site which causing vibration and noise. Monitoring of noise is recommended for
compliance with NEQS.
5.13 Cordon off work areas
It was observed the signage was good but not sufficient number of signs were
installed at the site of work. Yellow tape during construction, to cordon off work
areas was observed at most of the sites.
5.14 Dust Control
Water sprinkling was occasional to control dust. At most of the sites, no water
sprinkling was observed. Especially at approach road, the dust problem was high.
5.15 Health Safety and Environment
Proper signage and banners were being used for safety at work site but no
training was given to worker about their importance. At some site contractor has
provided the PPEs to worker but they were not using. Safety helmets, ear plug and

safety shoes were missing at most of the sites. The biggest issue observed at site
was non-availability of drinking water for the workers.
5.16 Shifting of Utility Services
All public utilities including existing gas lines, electricity poles,

telecommunication lines etc. must be shifted to a safe location before
commencement of any construction activities to avoid any damage to these
utilities.
5.17 Grievance Redressal Committee
As per the conditions set forth by KP EPA, a Grievance Redressal

Committee (GRC) should be constituted at district level. The prime purpose
of this committee is to resolve the issues of land acquisition, crop
assessment, and compensation amount paid for the losses. Currently public
relation department of the contractor is involved in resolving such issues.
No such a committee was witnessed during the monitoring period
5.18 Site Inspection Detail
During inspection of different sites of KKH-II, Section-A (Havelian Camp)

following Issues werer observed;
Table 5.1: Observation of site inspection-Section A (Havelian-Sajikot)

Visited Sites Observation Remarks
RD K60+900 Welder Not using Gloves while Recommended Sprinkling of
(Lundi) welding (Figure-1 at Annex-1) Water twice a day
Dust Problem in Approach Welder had gloves but he was
Road (Figure-2 at Annex-1 ) not using. Instruct welder to use
gloves.
RD K61+395 Dust Problem in site due to Recommended Sprinkling of
cutting and filling water because there were
esixting house nearby.
Magazine at No fencing in front of gate of Recommended fencing for area
Salhad magazine where deep dry to avoid from any incident
stream (Figure-3 at Annex-1)
Shimla Hill Proper Sprinkling of water Satisfactory
were observed.


K60+900 (Crushing No Safety belt were being Instruct safety incharge to
Plant) used while working at hight provide safety belt ASAP.
(Figure-4 at Annex-1) Provision of Wash rooms and a
No wash room facility for wall is required at crushing plant,
worker at crush plant, Open which will be used as curtain for
defecation is common which is nearby inhabitants.
unethical because plant is
nearby the population.
K61+100 No Safety Helmets (Figure-5 Mostly worker had 1st day on
at Annex-1) site. It is recommended to
provided safety helmet and will
be checked on next inspection.
K61+395 No gloves were provided while Provide the gloves ASAP
hammering (Figure-6 at
Annex-1)
K62+815 No proper arrangement of Provide the clean drinking water
drinking water for worker to worker on site.
Some workers have not safety Mostly worker had 1st day on
helmets, however most of site. It is recommended to
worker were using the provided safety helmet and will
helmets. be checked on next inspection
Havelian Main Need of one check post for Construct check post for security
Camp (Labour security guard. guard.
Camp) Wash room were in poor Take hygienic action in labour
condition. No proper camp and driver’s wash room
cleanliness on regulary. Provide the doors in wash
(Figure-7 at Annex-1). rooms.
There is a system of drainage
of water but slope of drain not
maintained good (Figure-8 at
Annex-1)
No door arrangement in wash
room (Figure-9 at Annex-1)
K78+660(Tunnel # Safety signage were Provide drinking water for worker
2) satisfactory (Figure-10 at Provide ear Plug or ear muffs to
Annex-1) worker during working of noisy
No Drinking Water Facility for machine
worker Complete the testing ASAP


No PPE of Noise during using
noisy machinery for drilling in
tunnel
No air, water, noise etc testing
K75+234 No safety helmets Provide safety helmets to worker
Banda Khairwli Poor condition of wash room Provided water in wash rooms
labour camp (Figure-11 at Annex-1) and arrange proper door and
No supply of water in wash electricity in wash rooms.
rooms (Figure-12 at Annex-1)
Tunel-1 Exit Point Shortage of PPEs (Shoes, Provide Proper and all PPEs to
(K75+000) gloves, dust mask) worker
Non availability of drinking Provide a clean water tank at
water to worker site which should be filled daily
No security cards for worker for drinking purpose
(they are facing security issue Issues the security card to all
on daily basis) worker because they are facing
No proper sprinkling at problems at check post of army
working site (Figure-13 at and police
Annex-1 Increas the frequency and
Polluting the natural stream container for sorinklinh
water (Figure-14 at Annex-1) Avoid to pollute the natural
No proper toilets facility for surface water. Construct a
worker (Figure-15 at Annex-1) temporary small bridge for
No proper disposal of soild crossing the vehicles
waste (Cement bags) (Figure- Provide toilet facility for worker
16 at Annex-1) Proper storage of soild waste
Poor storage of Oil Tank and dispose at propoer site at
(Figure-17 at Annex-1) the end of day
Good Fencing/barriers for Store oil tank safety
deep working site (Figure-18
at Annex-1)
5.19 Dumping sites
In the section-A of KKH-II, 12 sites have been selected for dumping of soil
which is surplus from project activities. It was observed that some sites were in
natural drains (drain for rainy water). It is recommended to avoid the dumping of
soil in sloppy area because in rainy season it will create lot of issues. Although, the
contractor communicated with owner of land for dumping of soil and they are

agreed but they have no approval letter or permission from concerned department
for using the site for dumping.
5.20 Compliance Status with NEQS
No tests are being conducted by contractor on site. Following parameters need

to be tested on site;
1. Air Quality
4. Noise Level
After testing of these parameters, then results may be compare with National
Environmental Quality Standards.
CONCLUSIONS/RECOMMENDATIONS (SECTION-A: HAVELIAN-SAJIKOT)
Following conclusion and recommendation are given based on the period of

one month under review:
1. Safety helmets were observed at most of the sites but other PPEs (safety
shoes, ear plug/muff, Gloves etc) were missing. It is recommended to
provide the proper PPEs to worker as soon as possible.
2. For dust control sprinkling of water was being done on site but approach
road needs more sprinkling. It is recommended to increase the water tank
for sprinkling and also increase the frequency of water sprinkling (at least
twice a day).
3. No testing (Air, drinking water, surface water, soil and noise) were
conducted on site. It is recommended to complete the testing of
environmental paramters so that effect of project activities on the state of
the environmental and the effectiveness of mitigation measures could be
judged.
4. It was observed that safety signs/ caution signs were good but these were
very less in number. It is recommended to increase the number of sign
board.
5. Improper disposal of solid waste was observed at some places (at exit
point of tunnel-1 Abbottabad) where they were throwing the cement bag in
open natural drains.
6. There is need of some type of training to worker about awareness of their
safety.

7. In short, the HSE parameters are expected to improve with the passage of
time because project is in at initial stages.
8. Proper Uniform/PPEs must also be provided to camp staff for visual
identification.
9. Develop an Environmental Management committee, to increase the
environmental performance of the company
10. Implement training programs about environmental awareness, importance
of occupational health and safety for the employees and labour
Although the project is at preliminary stages but there are some
positive points about the safety of people. At most of the places safety sign
boards are observed, good housekeeping in main camp of Havelian.

Section-A- pictorial views of environmental monitoring
Figure-1: K60+900 Not using proper PPEs
Figure-2: K61+395 No Sprinkling of Water

Figure-3: K70+00 No proper fencing
Figure-4: K60+900 Not using safety belt

Figure-5: K61+100 Not all people using safety helmets
Figure-6: K61+395 Not using Safety Gloves

Figure-7: Labour and Driver’s wash room condition
Figure-8: Poor Sanitation condition at labour camp

Figure-9: No proper door arrangement at labour camp’s Wash rooms
Figure-10: Proper Safety Signage at K78+660

Figure-11: Poor Condition of Wash Rooms
Figure-12: Poor Condition of Wash Rooms

Figure-13: No proper water sprinkling system at site
Figure-14: Pollution of natural water stream due to release of untreated wastewater

Figure-15: Workers using natural steam as a toilets
Figure-16: Poor management of solid waste

Figure-17: Poor storage of Oil tank
Figure-18: Good Fencing for working in deep area

Findings of Environmental Monitoring-Section B (Sajikot-Badadi) December- 2016
Section-B (Sajikot-Badadi)

SECTION-B (SAJIKOT-BADADI)
7.1 Contractor’s health and Safety Staff
The contractor does have a health and safety policy which is already been
displayed on various places in the vicinity and shared with the environmental
monitoring consultants. Also the contractor has hired some staff in the top
management to develop occupational health and safety strategies, but
unfortunately there is no adequate staff found in the field to implement these
practices. There is no proper means of communication between the contractor and
workers to share health and safety related issues such as risk assessments, site
specific hazards, mitigation measures to be taken, compulsion of personal
protective equipment etc.
7.2 NEQS Compliance
As per Section D, Clause (i) of the Conditional approval given by Pakistan

Environmental Protection Agency, the contractor is liable to take sufficient control
measures to avoid any contamination to air, water and land. But as the project is
at its preliminary stages no environmental quality tests are carried out yet about
the following parameters.
1. Air Quality
4. Noise Level
Pakistan National Environmental Quality Standards 2000 will be used for
compliance after testing of the above mentioned parameters. Recommendations
will be made in this report to the contractor for carrying out environmental quality
tests on frequent basis.
The mitigation measures about some specific issues are put in place; regular
sprinkling of water is carried out to control the dust, PPEs are provided to the
workers. The details of other mitigation measures to be implemented are
mentioned in the environmental management plan section of Environmental Impact
assessment report. Due to the reasons best known to the company, EIA report has
not been shared with the environmental monitoring consultants.

National Highway Authority Pakistan has the responsibility of land acquisition

for the project. According to the CCCCL officials; the company has paid the amount
of land to NHA. The payment to the affected for the acquired land and other
damages is made by NHA. Public relation department of CCCCL is in routine
consultation with the local people and paying the amount for trees removed. No
case has been reported to or observed by the field environmental monitor about
any issue of compensations.
Provision of proper sanitation is very important during the construction

activities. Poor sanitation may lead to unhygienic conditions and spread of
diseases, which will ultimately result in poor work progress by the workers. The
contractor has built toilet facilities for its workers but no water facility is provided
yet and some of them have no doors although they are in use. No temporary or
permanent sanitary workers found at the construction sites.
7.6 3.6 Landscaping
Landscapes and natural features are important because they contribute

significantly to our well-being and quality of life. There is a temporary impact on
overall landscape of the area because of removal of trees, cut and fill activities and
deployment of machinery and other human intervention. Environmental protection
and landscape designs are mentioned in detail designs of the project by the
contractor. They will be implemented at the end of the project and 1% of the total
cost of this project will be spent on the landscaping.
7.7 3.7 Solid waste management Plan
Solid waste is generated daily, mainly at the camps site. Currently the solid
waste being generated consists of food & beverage polythene packaging, foam,
paper and cartons, metal scrap, bottles etc. Dustbins are provided in the camps
only but not at the construction sites. In the labour camps food waste is released
to the open sewers, which may increase BOD levels downstream. There is no
solid waste disposal plan prepared and implemented yet by the contractor.

The policies, procedures made and decisions taken on certain issues are of
no importance if they are not communicated to relevant departments and
personnel. During monitoring it was observed that there is an immense need to
develop a channel through which the information can be shared with the workers
and relevant local government bodies. The issues which must be communicated
are details of hazards present at site, traffic routes, waste & wastewater
management plan, company’s occupational health & safety policy, environmental
policy and other details.
Management of wastewater must be put on priority during the construction

phase because it is not only capable of polluting the natural environment but also
results in unhygienic conditions which may result in outbreak of a serious disease.
In this regard the wastewater discharged must comply with the National
Environmental Quality Standards. During this period of monitoring, no wastewater
has been observed at construction sites. However, in the workshop of Sajikot
Camp the wastewater is being released to environment without any treatment.
7.10 Labour camp
There are three labour camps constructed by the company, two of which are
in use and one is still in finishing phase. During the inspection of both the camps;
issues of improper toilet facility, unhygienic place for dinning and improper disposal
of solid waste were observed as well as complaints were made by the workers
about these issues. Good hygiene of the labour must be the top priority of the
company as timely accomplishment of work activities rely on their work progress.
The currently active construction sites are away from population and the
contractor has made its own alternative routes for access. Besides this, some
signage is installed about the presence of heavy vehicles and to avoid entry of
public vehicles in the area.

The noise in the construction activities is mostly caused by the heavy

machinery and vehicles. Because of initial work stages and the good conditions of
machinery brought by CCCCL, no high noise area is experienced and no public
complaint has been registered in this regard. However, monitoring of noise through
specialized equipment is recommended for compliance with NEQs.
7.13 Cordoning of Areas
General public must be kept out of the work sites, for this purpose some
signage is already installed by the contractor. The areas are barricaded using “flag
lines” and barbed wire. The practice is good but needs some improvement. It is
better to use Yellow Tape instead of flag lines as the flag lines are used to
‘welcome’ people.
7.14 Dust Control
At this stage mostly cutting, filling, excavation and transport of earth material
is being carried out. This activity is producing huge quantity of dust in the area.
Frequent water sprinkling is done by the contractor to control the dust using water
bowsers. This practice can only control the production of dust to some extent, but
there is no remedial measure to settle down the dust particles suspended in the
atmosphere.
The company has a good occupational health and safety policy. Overall the
health and safety practices observed are satisfactory. CCCCL has provided safety
helmets, steel toed safety shoes and gloves to the workers. But there are a lot of
other issues observed related to occupational health and safety. These issues
include absence of filtered drinking water facility, unhygienic toilets, absence of
safety training programs, absence of hazard communication, incident reporting
methods and absence of documented safe working procedures.

telecommunication lines etc must be shifted to a safe location before
commencement of any construction activities to avoid any dangerous occurrences,
fines and compensations. WAPDA has been requested by the contractor to shift
the electricity poles from the proposed construction sites to safe locations and the
shifting is presently in process. A gas pipeline was damaged during the earthworks
on a site by CCCCL after which SNGPL took immediate notice and sent a
compensation invoice of 1.8 Million Pakistani rupees.
As per the conditions set forth by KP EPA, a Grievance Redressal Committee

(GRC) should be constituted at district level. The prime purpose of this committee
is to resolve the issues of land acquisition, crop assessment, and compensation
amount paid for the losses. Currently public relation department of the contractor
is involved in resolving such issues. No such a committee was witnessed during
the monitoring period.
7.18 Waste Dumping Sites
Following recommendations are made while selecting a dumping site by

CCCCL
1. Seek written permission from the land owner and the local government
2. Conduct a survey to ask the local residents of the area about dumping of earth
material
3. Avoid dumping of soil in the slopes, these slope act as a water channel during
the rainfall
4. Please avoid dumping of soil directly in stream, never along the bank, this may
cause flooding
5. Please make sure the soil does not contain any hazardous chemical or any
other inorganic compounds, may cause contamination of ground water
6. Where applicable build a protection wall around the waste bank and stabilize
the material
7. During the transport of the soil material from site to waste banks, reduce the
dust levels to minimum
8. Please consider the conditions set by EPA-KP in the conditional approval, in
case of failure to comply with them the conditional approval may be suspended.
EPA KP condition approval also sets following guidelines for dumping
Section-C (CONDITIONS SET BY EPA KP) Clause ii(b): Before start of
construction work on any section of the corridor, the consultant must carry out
detailed survey and prepare mitigation and monitoring plan for addressing the
following issues: "Estimated quantities of excavated material to be produced in

each section of corridor and its disposal/management plan".
Section D: GENERAL CONDITIONS, Clause xiv : The proponent shall

ensure to avoid dumping of debris and construction material into down slope and
green belts. Stabilization of area along the retention walls etc to be done by planting
grasses/shrubs in order to avoid soil erosion. AND Clause xx: The proponent shall
ensure that rain fed streams / perennial nullahs found in the project area must be
protected from erosion and blockage.
7.19 Magazine:
Magazine is place where explosive materials are stored, which are to be used
for blasting works in construction sector. Two magazines have been built and they
will soon be functional. A huge quantity of explosive material will be stored.
Magazines are well designed and equipped with firefighting equipment. High
security will be ensured to avoid any unauthorized entry, theft of explosive
materials and any other incident.
Besides recommendation of carrying out a detailed risk assessment of the
magazine, here are some other suggestions made for the safe storage of explosive
materials:
1. Access control procedures shall be established for entry to all explosives areas
2. Permit must be obtained from the safety and security department in order to
carry out any maintenance work
3. Operating personnel should not carry metal articles (e.g., keys, jewelry, knives,
coins, etc.) in explosives area; they act as hazard if dropped
4. There shall be no smoking in explosives storage, except in designated
locations
5. No matches, lighters, or other fire, flame, or spark-producing devices shall be
taken into an explosives control area except with written authorization
6. There must be good ventilation inside the magazine
7. All security personnel must be trained about firefighting to overcome any
emergency situation
8. In case of any unauthorized entry into magazine, theft of explosive material,
immediately report to local police, and antiterrorism department
9. A regular inspection must be carried out by the safety department of CCCCL
to ensure the safety practices are in place

CONCLUSION AND RECOMMENDATIONS (SECTION-B; SAJIKOT-BADADI)
The KKH-Phase II (Sakikot-Badadi) section is at initial stages, although the

contractor had to face various challenges about land acquisition, deployment of
construction teams, hiring of labours, making compensations and construction of
site camps, the environmental performance is fair. During this specified monitoring
period, no major environmental, occupational health and safety concerns are
identified. Only a few problems arose, out of them various are temporary. The
contractor has prepared a detailed environmental as well as occupational health
and safety policy and started to implement the practices. Section Manager Mr. Li
Yusheng, is found well versed and highly committed to put environmental quality
at top priority and implement good practices of occupational health and safety for
the workers.
Some recommendations are mentioned below to improve the environmental
health and safety performance.
1. Develop an Environmental Management committee, to increase the
environmental performance of the company
2. Implement training programs about environmental awareness, importance of
occupational health and safety for the employees and labour
3. Conduct tests for environmental quality parameters (air, water, soil and noise)
necessary for the compliance with National Environmental Quality Standards
of Pakistan
4. Implement Safety policies by force and train the workers about site specific
hazards and their mitigation measures
5. Safety Signage is installed on some locations; increase the number of signage
about speed limits, mandatory personal protective equipment, avoid public
entry and presence of washroom, drinking water and first aid facilities
6. Develop an Emergency Response Plan and implement for the camp premises
as well as for the construction site

Section-B pictorial views of environmental monitoring
Sanitary Wastewater discharge into environment
Oil Spillage outside Sajikot Camp

Unsafe Work Practices
Unsafe work practices/Misuse of Equipment

Oil patches/Grease Spillage at Shahkot Camp
Large oil Spillage at Shahkot Camp

Solid Waste Disposal at Shahkot Camp
Improper Storage of Materials at Shahkot Camp

Improper Insulated Live wire +Water = Electrocution Hazard
General Public at the work site

Formation of a pond due to blockage in stream
Shared Toilet Facility without any partition (Shahkot Camp)

Toilets without any doors (Shahkot Camp)
Unhygienic Dinning Place for Workers (Shahkot Camp)

Release of Food Waste to Sewer line
Poor Erection of Scaffolding / No baseplate

Wastewater discharged to environment at Sajikot Workshop
Oil Spillage Near generator at Sajikot Workshop

Improper Solid Waste Storage at Sajikot Camp
Stagnant Water/Mud near Sajikot Asphalt Plant

Findings of Environmental Monitoring-Section-C (Badadi-Kuza Banda) December- 2016
Section-C (Badadi-Kuza Banda)

SECTION-C (BADADI-KUZA BANDA)
9.1 Contractor Health and Safety Staff
CCCCL has deployed EHS engineer, however more EHS staff in the form of
EHS supervisors are needed at site for better enforcement of EHS rules,
regulations and personal protective equipment. Violation of H&S practices were
observed, like some workers had gloves but not using these gloves due to no
enforcement actions.
9.2 NEQS Compliance
According to Section D, Clause (i) of the Conditional approval given by

Pakistan Environmental Protection Agency, the contractor is liable to take sufficient
control measures to avoid any contamination to air, water and land. But as the
project is at its preliminary stages no environmental quality tests are carried out yet
about the following parameters.
1. Air Quality
4. Noise Level
The mitigation measures about some specific issues are put in place; regular
sprinkling of water is carried out to control the dust, PPEs are provided to the
workers. The details of other mitigation measures to be implemented are
mentioned in the environmental management plan section of Environmental Impact
assessment report. Due to the reasons best known to the company, EIA report has
not been shared with the environmental monitoring consultants.
9.4 Compensation for Losses
National Highway Authority is responsible for land acquisition for road and they
have started their work. CCCCL work starts after land acquisition . But land
acquisition for labour camp and dumping site is responsibility of CCCCL and they
made agreement with owner and according to owner agreement is made but no
money is given to them yet.

9.5 Sanitation during Construction and Operation Phase
Provision of proper sanitation is very important during the construction

activities. As the work has just started so no issue have found for sanitation.
9.6 Landscaping
Landscape designs are mentioned in detail designs of the project by the

contractor. They will be implemented at the end of the project and 1% of the total
cost of this project will be spent on the landscaping.
As project is in initial phase so not large quantities are waste generated at site.
According to CCCCL they have plan for future on solid waste management.
The policies, procedures made and decisions taken on certain issues are of
no importance if they are not communicated to relevant departments and
personnel. During monitoring it was observed that there is an immense need to
develop a channel through which the information can be shared with the workers
and relevant local government bodies. The issues which must be communicated
are details of hazards present at site, traffic routes, waste & wastewater
management plan, company’s occupational health & safety policy, environmental
policy and other details.
Still No utility service has found on site which required shifting except on main
Camp (Bedadi) where towers of electricity are shifted outside the camp.
9.10 Preparation of Wastewater Management Plan
Project is in initial stage. No wastewater management plan is in place which

can cause trouble once project is started. CCCCL may prepare proper wastewater
management before work stars.

9.11 Labour Camp
Labour camp is located at suitable distance away from the local people. It is
still under construction, and will be inspected as soon as it is completed.
Signage for vehicle is in place, however, speed limit is not set and it is
observed that drivers over speed. So proper speed limit should be set for driver
and drives may be carefully when passing near residential areas.
Currently, all heavy machinery is working away from the residential area.
There is no noise issue for the nearby inhabitants. However, no ear plugs or muffs
are provided to the workers at site. At least one of these may be provided for the
safety of workers. In addition, no noise testing practice was observed at the site.
9.14 Cordoning off Areas
Signage at site are proper and common people cannot enter into site due to
barriers and also security of Chinese.
9.15 Dust Control
Sprinkling of water is done 2 times on Battel site. At other two site( Maswal
and Sheikhabad) the sprinkling is not done regularly and dust levels are high there.
No dust masks are provided at any site to workers which can cause damage to
worker’s health. No testing for dust level is done on sight.
9.16 Health, Safety and Environment
Health, safety and environment of every site is very poor. Workers are
unaware of construction hazards. No training is yet provided to workers. Only
gloves and helmet are provided at site (in Sheikhabad Safety harness is also
provided) but others like dust mask, steel toed safety shoes are not provided to
workers. First Aid kit is not available at any site.

9.17 Accident Reported
One accident also occurred due to poor safety at K144+760 at 9:40 AM on 05

Dec 2016 in which one worker died and three are seriously injured. The accident
occurred when workers were working near wall and site incharge asked the
excavator to put soil near wall which cause fall of wall on workers. This was a
serious lapse. Compensation has been given to the effected workers and work
remained suspended for almost two days. This accident could have been
prevented by following EHS rules and regulations
9.18 Grievance Redressal Committee (GRC)
According to CCCCL staff GRC meetings are held at main office Manshera ,
however, but local people are not aware about GRC. Hence, it is recommended
that CCCCL may convey proper message to locals about GRC and that they could
lodge their complaints, if any, in GRC.
9.19 Waste Dumping Site
Section-C (CONDITIONS SET BY EPA KP) Clause ii(b) and Section D:

GENERAL CONDITIONS, Clause xiv may be followed for dumping.
9.20 Monitoring observation
Following observation are found during monitoring of K100+922, K103+450

and K144+874.
Table 9.1:Site observation and recommendation-Section C (Badai-Kuza Banda)

Issues Recommended Mitigation Measures
Dust emission due to drilling and Carry out water spraying along the site atleast twice daily
other activities during dry weather period.
Dust mask should be provided to workers
Personal protective equipments Provide PPEs to all construction workers and hire
(PPEs) are not given to all worker competent field supervisor to enfore a strict policy of
and supervisors are not present wearing PPE at work site.
to enforce given PPEs
No Testing is done for any Hire registered testing lab
perameter yet i.e water, Noise,
Air
No storage for Flameable Build separate storage for flameable material
material

Issues Recommended Mitigation Measures

No first aid kit Provide first aid kit
Dust mask, safety shoes and ear Provide these items to workers
muffs or ear plugs are not
provided
CONCLUSIONS/RECOMMENDATIONS (SECTION C; BADADI-KUZA BANDA)
Based on site visits, following conclusion may be drawn and recommendation

made thereof:
1. Safety helmets and gloves were observed at most of the sites but other PPEs
(steel toed safety shoes, ear plug/muff, dust masks) were missing. It is
recommended to provide the proper PPEs to worker as soon as possible.
2. Give first aid kit at every sight
3. For dust control sprinkling of water was being done on site but approach road
need improvement of sprinkling. It is recommended to increase the water tank
for sprinkling and also increase the frequency of water sprinkling (at least twice
a day).
4. No testing (Air, drinking water, surface water, soil and noise) were conducted
on site. It is recommended to complete the testing of environmental parameters
5. Road signage needs improvement. Currently fewer signage is used. It needs
to be increased in number.
6. There is need of some type of training to worker about awareness of their
safety.

Section-C pictorial views of environmental monitoring
Figure 10.1: open area fuel storage
Figure 10.2: No Enforcement of PPES due to unavailability of supervisors

Figure 10.3 :Condition of hand without Gloves
Figure 10.4: condition of gloves

Figure 10.5: Dust due to vehicle movement
Figure 10.6: Dust due to drilling on tunnel and dust masks are not provided

Figure 10.7: steel toed safety shoes are not provided
Figure 10.8: Dust due to movement of vehicle

Figure 10.9: No training to wear safety harness

Figure 10.10:open area cooking
Figure 10.11:No guard rail and poorly erected plateform

Findings of Environmental Monitoring-Section-D (Kuza Banda-Thakot) December- 2016
Section-D (Kuza Banda-Thakot)

SECTION-D (KUZA BANDA-THAKOT)
11.1 Contractor health and Safety Staff
The contractor have not provided us the health and safety policy uptill now.
Contractor have some safety staff but detail of staff is not share with us. There are
no safety persons present at work sites and no toolbox talks and safety trainings
carried out till yet. No proper communication between contractor health & safety
staff and technical staff.
11.2 NEQS Compliance
No test are being conducted by contractor on site. Following parameters need

to be tested on site;
5. Air Quality
8. Noise Level
After testing these parameters, then results will be compared with National
Environmental Quality Standards 2000. Recommendations will be made in this
report to the contractor for carrying out environmental quality tests on frequent
basis.
Environmental Impact Assessment (EIA) report is not provided by CCCCL to

Jers Engineering Consultant. We don’t know about specific mitigation measure that
are mention in EIA report. However, common mitigation measures about road
project are sprinkling of water (dust problem), water testing, air testing, noise
testing, proper solid waste management, provision of ppes etc. implementation of
these is satisfactory.
Compensation is the biggest hurdle for the road projects. During site visits, as
per public no proper compensation are provided to effected people. In meeting with
CCCCL staff, they said that compensation is given by NHA. Also CCCCL do not
have a permit for cutting of trees because they said that cutting of trees is done by
NHA not by CCCCL. It was recommended to CCCCL to get a copy of permit.

Sanitation was satisfactory at some sites, however improvement is requires at

most of the sites.
In main Kuza Banda camp the condition of toilets is very unhygienic and
wastewater is scattered all around. Water stagnation is also seen at some places
which can cause some disease problems like dengue etc. Solid waste was also
accumulated at some places in camp.
11.6 Landscaping
According to CCCCL, landscaping will be carried out in the final stage of

project.
Solid waste is generated daily, mainly at the camp sites. The solid waste being
generated at camp consists of food & beverage polythene packaging, foam, paper
and cartons, metal scrap, bottles etc. Dustbins are provided in the camps only but
not at the construction sites. In the labour camps food waste is released to the
open sewers, which may increase BOD levels downstream. There is no solid waste
disposal plan prepared and implemented yet by the contractor.
During monitoring it was observed that there is an immense need to develop

a channel through which the information can be shared with the workers and
relevant local government bodies. The issues which must be communicated are
details of hazards present at site, traffic routes, waste & wastewater management
plan, company’s occupational health & safety policy, environmental policy and
other details.
At this stage of work wastewater is not a problem because almost no

wastewater in being generate from the site. The current main activities are cutting
& filling, installation of machinery & crush plants, drilling of tunnels etc. Septic tank
was installed in camp for sewage treatment. Although there is no proper
arrangement for disposal of sanitary wastewater from camp and it was disposed-

off in nahla of Kuzabanda in front of camp which joins the river. Proper wastewater
management plan may be adopted in this regard.
11.10 Labour camp
There is no labour camp on this site till yet. It is recommended to construct

toilets at work sites.
The currently active construction sites are away from population and the
contractor has made its own alternative routes for access. Signage for diversion of
roads, speed limits, road marking, caution signs etc.; nothing was observed during
site visits. Besides of that no information sharing is being done for heavy vehicles
movement to nearby communities.
No noise test was being conducted at site and it is recommended that noise
testing should be done on frequent basis. Secondly, generators and other
construction machinery operating at work sites produce high noise and no ear
plug/muff were provided to workers working there for ear protection.
11.13 Coordoning of Areas
General public must be kept away from work sites. It was observed that
signage was good but need some improvement because number of singage was
not adequate. Yellow tape during construction to cordoning areas was observed at
most of the sites. Besides of this the areas are barricaded using “flag lines” and
barbed wire.
11.14 Dust Control
At this stage mostly cutting, filling, excavation and transport of earth material
is being carried out. This activity is producing huge quantity of dust in the area.
However, there is water sprinkling at site but at most of the sites no water sprinkling
was observed. It is recommended to increase the frequency and magnitude of
water sprinkling at sites and approach roads.

However, proper signage and banners were being used for safety at work site
but no training was given to the workers about their importance. At some site
contractor has provided the PPEs to workers but they were not using. Ear Plug and
safety shoes were missing at most of the sites. No use of ladder to come out from
depths. Workers working at height have no safety belts and working even without
scaffolding. But there are a lot of other issues observed related to occupational
health and safety. These issues include absence of filtered drinking water facility,
unhygienic toilets, absence of safety training programs, absence of hazard
communication, incident reporting methods and absence of documented safe
working procedures.

telecommunication lines etc. must be shifted to a safe location before
commencement of any construction activities to avoid any unpleasant incidence,
fines and compensations. Shifting of utilities is under process and no case of
damage or other problem repoted yet.
As per the conditions set forth by KP EPA, a Grievance Redressal Committee

(GRC) should be constituted at district level. The prime purpose of this committee
is to resolve the issues of land acquisition, crop assessment, and compensation
amount paid for the losses. Currently public relation department of the contractor
is involved in resolving such issues. No such a committee was witnessed during
the monitoring period.
11.18 Site Inspection Detail
During inspection of different sites of KKH-II, Section-D (Kuzabanda Camp)

following Issues were observed;
Table 11.1: Observation of site inspection-Section D (Kuza Banda-Thankot)

Visited Sites Date/Time Observation Remarks
RD 05-Dec-2016 No Barricading of Site (Pic- Recommended Sprinkling
K147+780(Battal 1) of Water twice a day
Tunnel Exit)


Dust Problem in Approach It is told to give the proper
Road (Pic-2) PPEs to workers for their
Workers do not have PPEs safety.
i-e, Helmets, Gloves etc Asked to for Barrication of
(Pic-3) Site
RD K147+780 to 05-Dec-2016 • Dust Problem in site due • Sprinkling of water

K149+000 to cutting and filling and was done for dust
vehicle movement control at site (Pic-4)
K155+100 (Kharari 05-Dec-2016 • Workers were working • Recommended to

Crushing Plant) under the crane without wear the helmets and
wearing helmets other required PPEs
RD K176+150 30-Nov-2016 • Workers working without • PPEs were not
(Thakot Tunnel) safety helmets, gloves given to the
etc. (Pic-5) workers
• Welders working without
wearing helmets. (Pic-6)
K176+150 07-Dec-2016` • Dust problem at • It is recommended to
approach road. (Pic-7) sprinkle the water at
• Barrication is done from least twice a day.
road side of the site. (Pic-
8)
K152+600, 15-Dec-2016 • Workers were working in • It was asked to site
K157+655, piles up to 10 to 15 ft of supervisor to provide
K162+275 (Bridge depth without safety the masks, gloves,
Foundations) gloves, shoes, masks, ladder and other
etc. PPEs to the workers
• Ladders were not there to as early as possible.
go in and come out from
piles.
K160+500 (Main 09-Dec-2016 • Wastewater was • It was asked to stop
Kuzabanda Camp) discharged into an open discharging water and
drain via pipe from recommended to
camps septic tank. It make a wastewater
caused smell problem in management plan
the nearby area (Pic-9) with the help of
concerned


department or to get a
permit for wastewater
discharge.
K147+780 15-Dec-2016 • Proper safety signage • Provide the clean
were seen a site. (Pic-10) drinking water to
• No proper arrangement worker on site.
of drinking water for • It was told to the staff
worker for good
• Poor housekeeping at housekeeping of site.
site. It may cause trips • To work at height
during movement at site scaffolding should be
(Pic-11) installed with proper
• Separate compartments guard rail and fall
were there for storage of protection
material. (Pic-12)
• Work at height without
proper scaffolding and
fall protection (Pic-13)
K153+700 26-Nov-2016 • A dumper caught fire • Dumper was burnt
(Near Banniyan) when it touched the fully but no one injured
overhanging electrical but it can cause
transmission line. electrocution
(Pic-14) • No safety trainings
• No fire extinguisher given to the drivers
present at site • It is recommended to
• No emergency have a emergency
preparedness or response team and
firefighting team firefighting equipment
should be present of
work sites and in
camps.
K176+150 (Thakot 17-Dec-2016 • Safety signage were • Provide drinking water
Tunnel) satisfactory (Pic-15) for worker
• No Drinking Water • Provide ear Plug or
Facility for worker ear muffs to worker
• No PPE of Noise during during working of
using noisy machinery noisy machine
works


• Littering of water on site • Complete the testing
• Work at height without as early as possible
proper scaffolding and • To work at height
fall protection (Pic-16) scaffolding should be
installed with proper
guard rail and fall
protection
Main Kuzabanda 20-Dec-2016 • Condition of toilets was • Door of washroom
Camp not good and number of should be installed
toilets is not enough (Pic- • Fire extinguisher
17) should be hanged
• Washroom is open over the walls and
without any door (Pic-18) SOPs for these should
• Fire extinguishers were be there
placed in front of doors • Number of Toilets
but no SOP was there should be increased in
(pic-19) camp for journal use
• Observed good
cleanliness and tidiness
in main camp
(Pic-20)

CONCLUSIONS/RECOMMENDATIONS (SECTION-D; KUZA BANDA-THANKOT)
Some conclusion and recommendation, based on site visits in section-D are

given as below;
1. Safety helmets, gloves, safety shoes, safety belts were observed at most of the
sites but other PPEs (ear plug/muff, masks etc) were missing. It is
recommended to provide the proper PPEs to worker as soon as possible.
2. For dust control sprinkling of water was being done on some sites but most of
the sites need sprinkling of water on regular basis. It is recommended to
increase the water tank for sprinkling and also increase the frequency of water
sprinkling (at least twice a day).
3. There is need of Environmental Management Committee for betterment of
company’s environmental performance.
4. No testing (Air, drinking water, surface water, soil and noise) were conducted
on site.
5. There is need of training/toolbox talks to worker about awareness of their
safety.
6. Housekeeping is not good at some sites and needs to be improved.
7. No medical unit at camp and at work sites for first add is present. It is
recommended to hire a medical person and provide the medical unit at camp
and first add box on work sites.
8. Compensation for property is not yet accorded to locals, it may be paid on
urgent basis.
9. Almost 10,148 trees of different kinds were cut down during land clearance. It
is said that tree plantation will be done after completion of project.
10. Develop an Emergency Response Plan/team

Section-D pictorial views of environmental monitoring
Pic- 1: No Barricade on the site
Pic- 2: Dust problem due to no water sprinkling

Pic- 3: Workers Working without PPEs
Pic- 4: Water Sprinkling is done on approach road to site

Pic- 5: Workers working without PPEs i-e, Helmets, Gloves, Safety shoes etc
Pic- 6: Welders working without safety Helmets

Pic- 7: Dust problem due to no water sprinkling at approach road
Pic- 8: Barricade of site is done from road side

Pic- 9: Wastewater discharge from main camp
Pic- 10: Safety signage provided at site

Pic- 11: Poor Housekeeping at site
Pic- 12: Separate compartments for material storage at work site

Pic- 13: Working without scaffolding/fall protection at height
Pic- 14: Dumper burnt due to electrocution

Pic- 15: Safety signage installed at work site
Pic- 16: Working without scaffolding/fall protection at site

Pic- 17: Unhygenic condition of camp toilets/ponding of water
Pic- 18: Washroom not having a door at camp

Pic- 19: Fire extinguishers placed in camp at door sides
Pic- 20: General cleanliness/tidiness of main camp

Annex-1: Environmental Checklist December- 2016
Annex-1
Environmental Checklist developed for KKH-Phase-2

Third Party Environmental Monitoring- KKH Phase II (Havelian-Thakot) Project
Site Location:
Camp Location:
Construction Stage:
Inspected By: Environmental Monitor (JEC)
Inspection Date:
INSPECTION ITEMS YES NO REMARKS

CONTRACTORS HEALTH & SAFETY
Company have suitable Occupational Health & safety
policy
Company has sufficient health & safety staff?
OHS management plan developed and communicated
to all the departments?
Any training plans for OHS for staff and labour
NEQs COMPLIANCE
Is drinking water being supplied for labour and
contractor’s personnel meets National Standards for
Drinking Water Quality?
Air sampling and test conducted
Noise levels are being monitored
Wastewater disposed meets NEQS
Wastewater collection and disposal system is in place
IMPLEMENTATION OF MITIGATION MEASURES
Proper arrangement exists to keep dust levels under
control?
Proper arrangement exists to dispose of oil and
lubricants?
Proper arrangement exist for collection and disposal of
solid waste produced at site and at the labour and
contractor’s camp?
Is wastewater produced at site of work and in labour
and contractor’s camp given sufficient treatment before
disposal into the environment?
In case of cutting of trees, is new plantation being done
(10 trees for one tree cut)?
If blasting is being done at site, then proper SOPs
being followed?

COMPENSATION OF LOSSES
Are the compensations been paid for loss of
crops/agriculture land?
Are the compensations made for removal of trees?
SANITATION DURING CONSTRUCTION &
OPERATION
Are toilets provided in the labour camp?
Are the toilets being kept clean?
Does proper arrangement of wastewater collection and
disposal exist in labour and contractor’s camp?
LANDSCAPING
Is there any record of total number of trees removed?
Is there any tree plantation plan for the trees cut?
Is there any landscaping plan?
WASTE MANGEMENT PLAN
Does any waste management plan prepared by the
contractors at the site of work and at labour and
contractor’s camp?
Are dust bins placed at the labour and contractor’s
camp
Does proper arrangement exist for the collection and
disposal of waste at reasonable frequency?
Are proper PPEs provided to waste management
crew?
Equipment and machinery used in solid waste
management meets the standards for such gadgets?
Is solid waste collected being disposed properly?
INFORMATION SHARING
Is the alternative routes designed been communicated
to local government?
Other precautionary measures taken shared with local
government?
Is information on health and safety properly shared
with labour and staff in the form of posters, banners,
sign boards and handouts?
SHIFITNG OF UTILITY SERVICES
Are the concerned departments communicated for
shifting of exciting utilities e.g Gas lines, electricity
poles, drinking water supply lines?

Is there any event of inconvenience to local people

been observed?
WASTE WATER MANAGEMNT PLAN
Does a wastewater management plan in the form of
provision of drains/sewers at the contractor’s and
labour camp exists?
Does any plan for wastewater treatment and proper
disposal exists?
LABOUR CAMP
The labor camps are constructed away from the local
population?
Proper water supply system exist in Labour camp?
Proper wastewater collection system exist in labour
camp?
Waste bins are provided in the labour camp?
There are proper arrangements of solid waste
collection from the labour camp?
Proper toilet facilities exist in labour camp?
Proper dining room exist in labour camp where labour
is served food?
Fire extinguishers are installed in labour camp?
Small scale, at site, medical facilities are available at
the labour camp?
Rooms for the residence of labour are properly
ventilated and sufficiently spaced to accommodate the
labour?
Wastewater generated and collected in the labour
camp is given any treatment before release into the
environment?
Are any recreational facilities provided for the labour in
the labour camp?
TRAFFIC MANAGEMENT PLAN
Is the traffic management plan been developed by the
contractor?
Is the traffic management plan displayed with the help
of large size posters and banners with the general
public
Is the traffic management plan been shared with local
government?

Is there any event of inconvenience to the local people

related to traffic e.g traffic jam, traffic accident
Is enough signage for diversion, speed limit, and
caution installed?
Are people deployed by the contractor for traffic
management and control?
NOISE POLLUTION CONTAINMENT
Noise barriers installed near high noise areas?
Ear muffs/Ear plugs provided to the workers working in
high noise area?
Proper signage exits having instructions to use ear
protection PPE before entering a high noise area?
COORDONING OF AREAS
Caution & Prohibition Signage installed to avoid
entrance of public in work areas?
Excavations/trenches are barricaded with yellow
warning tape?
Is work area properly cordon off to avoid entrance of
public or vehicles?
DUST CONTROL
Water sprinkling is done frequently to control dust?
Any other mitigation measure taken against dust?
Are dust levels monitored at regular interval?
HEALTH SAFETY & ENVIRONMENT
Does any health and safety management plan exist?
If H&S plan exist, do proper steps are taken by the
contractor to implement it (sufficient PPEs, sufficient
H&S staff deployed by the contractor)?
Is there any emergency response plan been developed
and implemented?
Do emergency evacuation drills conducted at site?
Does any fire emergency plan exit and evacuation
routes and exits are properly marked with clear
visibility?
Personal Protective Equipment (steel toed shoes/ear
muffs/helmets) provided to the workers?
Personal protective clothing & gloves provided to
handle hazardous Waste?

Is induction training (initial training given to labour

when they are newly hired) given to the labour
regarding major health and safety hazards at their
respective site of work?
Is there any program for the periodic H&S training for
the workers and staff to be repeated at regular interval
and act as refresher to the H&S matter?
Are tool box talks a regular feature at the site of work?
GRIEVANCE REDRESSAL COMMITTEE (GRC)
Is the GRC been developed in chairmanship of Deputy
Commissioner?
Is the GRC comprised of local representatives and KP
EPA, NHA, Revenue Department, Forest Department
representatives?
Is the GRC working on following issues:
Land Acquisition /compensation
Price Determination of Damages
Assessment of Crops Compensation
Forest Removal & Compensation
Loss of Wild life
Other damages to properties
Are the compensation of any of above issues made
before starting work?
Do regular meeting of GRC convened to take up the
issues and resolve within a reasonable time frame?
Is the formation of GRC properly advertised through
newspaper, notice boards placed at different location
among the community for their awareness that GRC
exist and they may place their grievances before i?.

Monthly Monitoring Report (MMR) : Third Party Environmental Monitoring CCCC KKH-Phase II (Havelian-Thakot) Project

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Monthly Monitoring Report (MMR) : Third Party Environmental Monitoring CCCC KKH-Phase II (Havelian-Thakot) Project

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Third Party Environmental Monitoring

CCCC KKH-Phase II (Havelian-Thakot) Project

Monthly Monitoring Report (MMR)

KKH-Phase-II is a part of China–Pakistan Economic Corridor (CPEC). Its

Jers Engineering Consultants (JEC) 1

10. Environmental tests (air, water, noise, surface water) needs to be

Jers Engineering Consultants (JEC) 2

CCCCL China Communication and Construction Company Limited

EHS Environment health and safety

EIA Environmental impact assessment

EMP Environmental management plan

GRC Grievance redress committee

H&S Health and safety

IEE Initial environmental examination

JEC Jers Engineering Consultants

MMR Monthly monitoring report

PPE Personal protective equipment

Jers Engineering Consultants (JEC) 3

STRUCTURE OF THE REPORT 10

Jers Engineering Consultants (JEC) 4

5.20 Compliance Status with NEQS ............................................................................. 18

CONCLUSION AND RECOMMENDATIONS (SECTION-B) 36

SECTION-C (BADADI-KUZA BANDA) 48

Jers Engineering Consultants (JEC) 5

9.10 Preparation of Wastewater Management Plan ..................................................... 49

SECTION-C (BADADI-KUZA BANDA) 60

Jers Engineering Consultants (JEC) 6

As part of the China–Pakistan Economic Corridor (CPEC), reconstruction and

Table 2.1: Details of section on KKH-Phase-II

Jers Engineering Consultants (JEC) 7

Figure 2.1: Route plan of KKH-Phase-II and base camps

METHODOLOGY ADOPTED FOR ENVIRONMENTAL MONITORING

3.1 Deployment of Environmental Monitors (EMs)

environmental engineers/scientists with relevant qualifications and expertise to

Table 3.1: EMs deployment details

3.2 Study of relevant legal and regulatory framework

3.3 Study of project related documents

3.4 Development of monitoring check lists

3.5 Site visits

3.6 Meetings and discussion

Jers Engineering Consultants (JEC) 9

3.7 Taking pictorial evidence of non-compliance

Pictorial evidence of any violation of environmental norms, health and safety

3.8 Compilation of reports by each EM

Each EMs compiled environmental monitoring report of his section. The

STRUCTURE OF THE REPORT

1. Contractor’s health and safety staff

Environmental Monitoring Findings

Jers Engineering Consultants (JEC) 11

5.1 Contractor health and Safety Staff

5.2 NEQS Compliance

As per agreement and Conditional Approval the proponent (CCCCL) has to

5.3 Implementation of Mitigation Measure

The implementation of mitigation measures is very important factor for any

5.4 Compensation of losses

5.5 Sanitation during construction and operation phase

Sanitation practices was near to satisfactory at some sites, however

In the current preliminary stage of the project, landscaping is not possible. It