AMGG-S - 1 - Environmental Safeguard Monitoring - 25.03.2021
AMGG-S - 1 - Environmental Safeguard Monitoring - 25.03.2021
AMGG-S - 1 - Environmental Safeguard Monitoring - 25.03.2021
Submitted To
For
Environmental Safeguard Monitoring Report (January’2021-March’2021)
Table of Contents
EXECUTIVE SUMMARY ........................................................................................................................................... 5
CHAPTER 1: INTRODUCTION ........................................................................................................................ 7
1.1 PROJECT DESCRIPTION ..........................................................................................................................................7
1.2 PROJECT PROGRESS STATUS AND IMPLEMENTATION SCHEDULE .....................................................................................8
1.3 BACKGROUND .....................................................................................................................................................8
1.4 OBJECTIVES OF THE STUDY......................................................................................................................................8
1.5 PROJECT LOCATIONS .............................................................................................................................................9
1.6 CONTRACTORS’ ACQUAINTANCE............................................................................................................................10
1.7 SURROUNDING INFRASTRUCTURES .........................................................................................................................10
1.8 TRANSMISSION LINE TOWER EQUIPMENT................................................................................................................15
1.7 SCOPE OF STUDIES ..............................................................................................................................................16
1.8 MONITORING POLICY STANDARD ..........................................................................................................................17
1.9 ADB LOAN COVENANTS WITH PGCB .....................................................................................................................20
1.9.1 Implementation Arrangement: ............................................................................................................20
1.9.2 Environment:........................................................................................................................................20
1.10 SAFEGUARDS RELATED PROVISIONS IN BIDDING DOCUMENTS OF WORKS AND WORK CONTRACTS ...................................20
1.11 SAFEGUARD MONITORING AND REPORTING .........................................................................................................21
1.12 LABOR STANDARDS: .......................................................................................................................................21
1.13 PROJECT REVIEWS: ........................................................................................................................................21
CHAPTER 2: APPROACH AND METHODOLOGY ...................................................................................... 22
2.1 INTRODUCTION ..................................................................................................................................................22
2.2 ENVIRONMENTAL MONITORING TEAM ...................................................................................................................22
2.3 METHODOLOGY .................................................................................................................................................22
2.4 PHYSICAL ENVIRONMENT .....................................................................................................................................23
2.4.1 Ambient Air Quality .............................................................................................................................23
2.4.2 Ambient Noise level .............................................................................................................................23
2.5 SOIL MANAGEMENT ...........................................................................................................................................23
2.6 WATER QUALITY ................................................................................................................................................23
2.7 WASTE MANAGEMENT .......................................................................................................................................23
2.8 ECOSYSTEM AND BIODIVERSITY CONSERVATION .......................................................................................................24
2.9 TERRESTRIAL VEGETATION....................................................................................................................................24
2.10 FLORA AND FAUNA ........................................................................................................................................24
CHAPTER 3: MONITORING RESULTS ........................................................................................................ 25
3.1 PHYSICAL ENVIRONMENT .....................................................................................................................................25
3.1.1 Ambient Air Quality Monitoring ..........................................................................................................25
3.1.2 Ambient Noise Level Monitoring ..........................................................................................................26
3.1.3 Water Quality Monitoring ...................................................................................................................28
3.2 SOIL QUALITY MONITORING .................................................................................................................................31
3.3 WASTE MANAGEMENT .......................................................................................................................................32
3.4 BIOLOGICAL ENVIRONMENT .................................................................................................................................32
3.3.1 Ecosystem and Biodiversity ..................................................................................................................32
3.5 ENVIRONMENT, HEALTH AND SAFETY .....................................................................................................................33
3.6 PERSONAL PROTECTIVE EQUIPMENT ......................................................................................................................33
3.7 STAKEHOLDER ENGAGEMENT ................................................................................................................................34
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LIST OF TABLES
Table 1: Project Status Summery .................................................................................................... 8
Table 2: Location of the Tower ...................................................................................................... 9
Table 3: Equipment used at Transmission Tower......................................................................... 15
Table 4: Selected IESCs and Parameters ...................................................................................... 19
Table 5: The Composition of the Team ........................................................................................ 22
Table 6: Ambient Air Quality monitoring .................................................................................... 25
Table 7: Standards for Sound ........................................................................................................ 27
Table 8: Ambient noise quality monitoring result ........................................................................ 27
Table 9: Ground Water monitoring result ..................................................................................... 28
Table 10: Surface Water monitoring result ................................................................................... 29
Table 11: Waste Water monitoring result ..................................................................................... 30
Table 12: Soil quality monitoring result ....................................................................................... 31
Table 13: Training Summery ........................................................................................................ 36
Table 14: Accident Inventory ....................................................................................................... 37
LIST OF FIGURES
Figure 1: Project Location .............................................................................................................. 7
Figure 2: Map of Proposed 400kV Transmission Line in PGCB area ......................................... 10
Figure 3: Location of Tower 61/4 ................................................................................................. 11
Figure 4: Location of Tower 63/4 ................................................................................................. 11
Figure 5: Location of Tower 64 .................................................................................................... 12
Figure 6: Location of Tower 65/3 ................................................................................................. 12
Figure 7: Location of Tower 66 .................................................................................................... 13
Figure 8: Location of Tower 66/1 ................................................................................................. 13
Figure 9: Location of Tower 66/2 ................................................................................................. 14
Figure 10: Location of Tower 67 .................................................................................................. 14
Figure 11: Project site Air Quality Monitoring............................................................................. 26
Figure 12: Project site Noise Level Monitoring ........................................................................... 28
Figure 13: Water Sampling ........................................................................................................... 31
Figure 14: Soil Sampling .............................................................................................................. 32
Figure 15: Organogram of the Project Directorate ....................................................................... 35
Figure 16: Occupational Health & Safety training ....................................................................... 37
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Executive Summary
Environmental Safeguard Monitoring has been executed at the 8nos of construction tower of new
400 kV double circuit transmission line and construction of distribution network of AGTL
project under PGCB, financed by ADB. Monitoring has been executed based on ADB’s
Environmental safeguard policy, the laws and the National Policies of Bangladesh and loan
covenants between ADB and Government of Bangladesh. At this stage, environmental
monitoring has been completed on eight transmission tower locations. The construction work is
ongoing for establishment the eight towers of 400 kV double circuit transmission line.
Based on the prepared checklist, the monitoring team observed the physical (Air quality, Noise
quality, Water and Soil quality), ecosystem and biodiversity status of the construction sites
following both qualitative and quantitative approaches.
Air quality analysis shows that all the parameters has found within the standard limits of eight
specific project site given by DoE. Vehicular movement, nearby construction activities were
ongoing during the time of field visit. These activities triggered the amount of fine particulate in
the air. No trace of SOx, NOx and O3 have been found in any project sites. However, most of the
parameters have found in compliance with the DoE standard.
The noise levels in day time were found higher than national standard limit in some of the
project area regardless of construction or operational unit. Traffic and road site activity
predominantly increases the noise activity in almost all of the project sites as all sites are located
adjacent to the nearby road. So, noise generation from the construction and operation phase will
not affect the nearby households.
Major construction works at the eight project sites are ongoing. Construction wastes and leftover
construction materials had been found dumped scattered in Tower 61/4 and Tower 67 areas. In
terms of waste disposal, the waste management of all the project area was not so satisfactory
level. The disposal of waste needs to be managed properly according to the Environment
Management Plan (EMP). Based on the findings of EMR, advice provided to the EPC contractor
to dispose the construction waste to the designated municipal dumping area and number of waste
bins at the respective site where the waste management not in satisfactory condition.
In terms of ecosystem and biodiversity, the monitoring team observed the existing vegetation,
flora and fauna. Besides, the impact of project implementation has been identified and observed
the compliance status regarding the selected parameters.
There were very few herbs and shrubs at the project sites as all sites are situated in cornfields
areas. Some common trees and common minor wild life habitats also found around the project
sites. As per the findings, there are no more problems due to the project implementation.
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During the pandemic Covid-19, health risks have been considering in the project site. An EHS
officers’ conduct daily basis awareness training starting at the work to reduce health risk. During
the working in the construction site, the following tips can help reduce the risk of exposure to the
coronavirus:
✓ Encourage workers to stay home if they are sick.
✓ Allow workers to wear masks over their nose and mouth to prevent them from spreading
the virus.
✓ Continue to use other normal control measures, including personal protective equipment
(PPE), necessary to protect workers from other job hazards associated with construction
activities.
✓ Advise workers to avoid physical contact with others and direct
employees/contractors/visitors to increase personal space to at least three feet, where
possible. Where work trailers are used, all workers should maintain social distancing
while inside the trailers.
✓ Train workers how to properly put on, use/wear, and take off protective clothing and
equipment.
✓ Encourage respiratory etiquette, including covering coughs and sneezes.
✓ Promote personal hygiene. If workers do not have immediate access to soap and water for
hand washing, provide alcohol-based hand rubs containing at least 60 percent alcohol.
✓ Use WHO approved cleaning chemicals from the List or that have label claims against
the coronavirus.
✓ To the extent tools or equipment must be shared, provide and instruct workers to use
alcohol-based wipes to clean tools before and after use. When cleaning tools and
equipment, workers should consult manufacturer recommendations for proper cleaning
techniques and restrictions.
✓ Keep in-person meetings (including toolbox talks and safety meetings) as short as
possible, limit the number of workers in attendance, and use social distancing practices.
✓ Clean and disinfect portable jobsite toilets regularly. Hand sanitizer dispensers should be
filled regularly. Frequently-touched items (i.e., door pulls and toilet seats) should be
disinfected.
✓ Encourage workers to report any safety and health concerns.
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CHAPTER 1: INTRODUCTION
1.1 Project Description
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The proponent set their millstone to complete Piling of 12Nos of Transmission towers among
213 during this reporting period. A summery is concluded for the progress status in the following
table:
Table 1: Project Status Summery
1.3 Background
The proponent (PGCB) has already obtained Site Clearance Certificate (SCC) and received
approval based on Environmental Impact Assessment (EIA) and EMP reports. PGCB has
engaged Consortium of SEPCO1-MIL JV as EPC contractor for the construction and as a
complementary part of the project, GREENBUD has been entrusted with environmental
compliance monitoring regarding EMP and ADB’s environmental safeguard policy and the loan
covenants between ADB and Bangladesh.
The principal objectives of this study were to monitor the construction and operation work of
these projects in line with standard Engineering practices/safe guard, Environmental, Health &
Safety (EHS) and social issues in line with DoE and Asian Development Bank (ADB)’s Guide
line.
The specific objectives of this report were to:
❖ Analyze water, soil, air and noise quality in construction phases as well as operation stage
of the projects
❖ Explore adjacent land characteristics of the project sites
❖ Analyze the waste management system of concerned authority or EPC Contractor
❖ Identify and assess all potential environmental and social impacts of the projects;
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❖ Monitor working condition and occupational health safety of workers throughout project
life
❖ Verify compliance with the environmental regulations and relevant standards;
❖ Identify non-conformity and recommend measures to improve the environmental and
social management system;
The location of the project is shown in Figure 2. The proposed 400kV transmission lines will be
constructed in different location under PGCB area in Munshiganj District. The locations of eight
monitoring area of transmission line transfer tower are given in the table 2 below:
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The name of the contractors engaged with these eight Transmission Line tower construction and
erection is given in below table:
Lot
1. T-61/4
2. T-63/4
Design, Supply, Erection, 3. T-64
Installation, Testing &
PGCB/ADB/3522/400KV/TL/ 4. T-65/3
SEPCO1-MIL JV AGTL
1 Commissioning of 8 Nos.
400 KVA Electricity 5. T-66
Transmission tower 6. T-66/1
7. T-66/2
8. T-67
Tower 61/4: In the east side of this tower is located Dhaka-Mawa Highway and some houses of
local habitant are located in west side of the project. This road and habitant are very adjacent to
the Tower 61/4. But, due to nature of the project activities, the possibility of this facility getting
affected is negligible.
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Tower 64: This Transmission Tower is surrounded by some local habitant and agriculture field.
A village road and habitant are very adjacent to the Tower 64. But, due to nature of the project
activities, the possibility of this facility getting affected is negligible.
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Tower 66: This Transmission Tower is surrounded by agriculture field. But, due to nature of the
project activities, the possibility of this facility getting affected is negligible.
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To commence operation the proposed Transmission Line will require various equipment
including current and voltage transformer, automation system, telecommunication equipment etc.
The details of this equipment are listed below:
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The EIA report provides information on the baseline environmental condition (physical, soil and
agricultural, biological and social environment) of the project area. Following DoE guidelines,
the report identified potential impacts of the proposed project activity on the environmental
components of the project area. It includes the Terms of Reference (ToR) for the EIA and the
Environmental Management Plan (EMP) against adverse impacts. The EMP also includes an
Environmental Monitoring Plan, cost and institutional arrangements for future monitoring.
In line with the aforementioned objectives the scope of the services should cover the following:
i. Monitoring ambient air quality of the project site and its adjoining area before
construction stage;
ii. Monitoring Ambient Noise Quality of the project site and its adjoining area before
construction stage
iii. Monitoring Water Quality (surface water, ground water, waste water) of the project site
and its adjoining area before construction stage
iv. Monitoring Soil Quality of the project site and its adjoining area before construction
stage
v. Review of environmental management and environmental monitoring plan suggested in
the EIA report
vi. Upgrade (if required) the environmental monitoring framework and work plan specifying
the indicators, method, location, time, frequency of monitoring provided in the EIA that
shall be followed by the EPC contractor;
vii. Monthly monitoring of construction activities to see their compliance with national
environmental and social regulations, and ADB’s performance standards on social and
environmental sustainability;
viii. Physical observation to assess that all mitigation measures are carried out or in place in
conformity with the EMP and action plan;
ix. Monthly monitoring of implementation of environmental monitoring activities as
specified in the environmental monitoring plan;
x. Monthly monitoring of different activities of EPC contractor regarding analysis of air
quality, water quality, soil texture and quality, soil and land erosion, noise measurement,
waste management, etc. in connection with the environmental monitoring plan
xi. Monthly monitoring of socio-economic issues like community safeguard due to pollution,
hazards and employment opportunity;
xii. Suggestion of pollution prevention and mitigation measures to ensure environmental
safeguard, to ensure compliance with national environmental and social regulations;
xiii. Keep close liaison with the project implementation office and EPC contractor;
xiv. Provide a monitoring report in line with the reporting requirement of ADB satisfying
equator principles.
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According to the Safeguard Policy Statement 2009 (SPS 2009) of ADB, the project is classified
as category B requiring an Initial Environmental Examination (IEE). The environmental
safeguard of the Government of Bangladesh (GoB) as provided for by the Environment
Conservation Act, 1995 and the Environment Conservation Rules, 1997 requires that power
projects like this also prepare an IEE and an environmental impact assessment (EIA) in obtaining
the Site Clearance and Environmental Clearance Certificate (ECC) from the Department of
Environment (DoE). The site clearances based on IEE have been obtained from DoE. As per the
Bangladesh Govt. policy standard, environmental compliance monitoring is one of the important
parts that would be initiated following the Environmental compliance monitoring guidelines by
the DoE and the agreement between ADB and Bangladesh Govt. based on the ADB loan
covenants.
PGCB has taken initiative to expand its infrastructure of the distribution system through
construction of new lines, installation of new substations and rehabilitation of existing
substation. Now, the purpose of the environmental monitoring is to monitor whether the
construction and operational activities are performing based on the EMP or is creating any
environmental impacts or any adjustment is required in safeguard measures.
The Bangladesh Environment Conservation Act of 1995 (ECA, 1995) is the key legislation in
relation to environment protection in Bangladesh. According to ECR 1997, Schedule-I, Category
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(D), section 64 the project for Power supply/Transmission Line/Tower construction is under the
Red category. This Act is promulgated for environment conservation, standards, development,
pollution control, and abatement. It has repealed the Environment Pollution Control Ordinance of
1977.
The main objectives of the Act are:
• Declaration of ecologically critical areas and restriction on the operations and processes,
which can or cannot be carried/initiated in the ecologically critical areas;
• Regulations in respect of vehicles emitting smoke harmful for the environment;
• Environmental clearance;
• Regulation of the industries and other development activities’ discharge permits;
• Promulgation of standards for quality of air, water, noise and soil for different areas for
different purposes;
• Promulgation of a standard limit for discharging and emitting waste; and
• Formulation and declaration of environmental guidelines.
The ECA, 1995 specified that no industrial unit or project shall be established or undertaken
without obtaining Environmental Clearance from Director General in a manner prescribed by the
Rules. The project promoter must obtain Environmental Clearance from the Director General of
Department of Environment (DoE). Failure to comply with any part of this Act may result in
punishment of imprisonment or fine or both.
The Environment Conservation Rules, 1997 is the first set of rules, promulgated under the ECA
95. The ECR, 1997 has provided categorization of industries and projects and identified types of
environmental assessments needed against respective categories of industries or projects.
Among other things, these rules set (i) the National Environmental Quality Standards for ambient
air, various types of water, industrial effluent, emission, noise, vehicular exhaust etc., (ii) the
requirement for and procedures to obtain environmental clearance, and (iii) the requirement for
IEE and EIA’s according to categories of industrial and other development interventions. The
proposed project, according to the DoE, is considered under the “Red” category of the
Environmental Conservation Rules, 1997.
Compliance with DOE’s Guidelines
As mentioned above, the project activities fall under Red category according to the Environment
Conservation Rules, 1997. For projects under this category, it is mandatory to carry out IEE and
subsequently EIA including Environmental Management Plan (EMP) and where necessary
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develop a Resettlement Plan for getting environmental clearance from the DoE. The DoE has
issued EIA Guidelines for Industries and addresses the IEE and EIA for several industrial sectors
and activities. The Proponent shall conduct an IEE or EIA and is expected to consult and follow
the DoE guidelines. The provisions of the environment legislations and the EIA guidelines of the
DoE have been reviewed under this study. The DoE has issued application procedure for
obtaining site/environmental clearance.
Environmental quality standards for air quality, soil, noise, odor, sewage discharge, industrial
effluents, and industrial project emissions for Bangladesh.
The Environment Conservation Act, 1995 and the Environment Conservation Rules, 1997 are the
main legislative base in Bangladesh for protection and conservation of natural environment. The
Environment Conservation Rules (1997) place activities of power plant into the Red category.
However, the Safeguard Policy Statement (SPS) of Asian Development Bank has also been
reviewed since ADB is financing the project in partnership with the GoB. As per the ADB
categorization, the sub-station and transmission line tower construction activities are under the
category B considering the significance of the project’s potential environmental impacts.
Therefore, the EMP is prepared based on the combination of both the national and the ADB.
The environmental standards are determined in the Environmental Conservation Rules. The
standards for air, water, sound, odor and other components of the environment are started to
monitor in accordance with the standards specified in Schedules - 2, 3, 4, 5, 6, 7 and 8. The
Bangladesh standards, in general, are less stringent compared to the developed countries. This is
in view to promote and encourage industrialization in the country. The Bangladesh standards are
not for any specific period of time. There is no provision for partial compliance too. For this
reason, monitoring is based on the national standards unless there is absence of clear standards;
only then ADB’s standard is being considered. Following IESCs and parameters are selected for
monitoring in PGCB’s eight Transmission Line tower areas which have presented in Table 3.
Table 4: Selected IESCs and Parameters
IESCs Parameters
Air SPM, PM2.5, PM10, Sulphur dioxide, Carbon Monoxide, Oxides Nitrogen
Waste Waste generation and proper waste disposal
Noise dB at both day and night time
Surface Water (if DO, pH, BOD, Arsenic whether water is usable for irrigation or by
any) fisheries
Ground/Drinking
pH, Mn, Fe, As, TC, Fc
water
Waste water pH, BOD, COD, TDS, TSS, EC, DO, Oil and grease
Biodiversity Habitat conversion and fragmentation
Risk of electrocution, safety measures within the construction site,
Health & Safety
emergency plan.
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According to the loan covenants PGCB should carry out the project with the due diligence and
efficiency and conformity with sound administrative, financial, engineering, environmental and
power sector practices for the execution of project following criteria should be followed.
1.9.1 Implementation Arrangement:
PGCB should ensure the project implementation in accordance with the detailed arrangements
set forth in the PAM. Besides, it is responsibility of PGCB to ensure their project management
staff who have the qualification to undertake necessary tasks of procurement, construction,
supervision, inspection and testing of equipment, payments to the contractors, monitoring
environmental and social safe guards’ due diligence and reporting progress relevant to the
components under their responsibility.
1.9.2 Environment:
PGCB should ensure that the preparation, design, construction and operation of the project and
all project facilities comply with
▪ All applicable laws and regulation of the relating to environment, Health and safety.
▪ The environmental safeguard
▪ All measures and requirements set forth in the respective IEE and EMP and any
corrective or preventive action set forth in a safeguard monitoring report.
1.10 Safeguards related provisions in bidding documents of works and work
contracts
PGCB should ensure the following compliance in relation to contract or bidding during the
project implementation.
a) Comply with the measures and requirements relevant to the contractors set forth in the
IEE, EMP and RP (if required) any small ethnic community peoples plan and any
corrective or preventive actions set out in a safeguard monitoring report.
b) Make available budget for all such environmental and social measures.
c) Provide the borrower with a written notice of any unanticipated environmental
resettlement or small ethnic community people’s plan.
d) Adequately record the condition of roads, agricultural land and other infrastructure prior
to starting to transport materials and construction.
e) Completely reinstate pathways, other infrastructure and agricultural land to at least their
pre-project condition upon the completion of construction.
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Submit safeguards monitoring reports to ADB and disclose relevant information from such
reports to the affected person.
a) Any anticipated environmental and social as well as impacts arise during the
construction, implementation or operation of the project that were not considered in the
IEE, the EMP or the RP promptly inform ADB of the occurrence of such risks and
impacts with detailed description of the events and proposed corrective action plans
b) Reporting would be completed based on the any potential beach of compliance with the
measures and requirements set forth in the EMP.
1.12 Labor Standards:
Labor standards should be followed as per ADB loan covenants are as follows:
a) Comply with all applicable law and related international treaty obligations of the borrower
and do not employ child labor as defined under the Bangladesh Law.
b) Provide safe working condition for male and female workers.
c) Carryout HIV/Aids and human trafficking prevention and awareness campaigns in the
campsites and corridor of influence.
d) Engage women workers as wage laborers depending on their skill.
e) Provide equal wage for equal works between men and women.
1.13 Project Reviews:
a) The project progress would be reviewed by the ADB with necessary mid-course
corrections.
b) The assistance should be provided by the executing agency (i.e., PGCB).
The environmental monitoring will assess the compliance that has been suggested under the
Bangladesh Govt. laws, policies and national standards (i.e., air, noise and water quality) and
ADB loan covenants. As there is no involuntary resettlement and ethnic minority issues,
therefore, this monitoring assesses the environmental and social safeguard issues in accordance
with the Govt. laws and ADB loan covenants like the above-mentioned ways.
The results of the monitoring will be compared with the established benchmarks/baseline and
compliance status and help to identify the areas where adverse environmental and social adverse
impacts are still occurring. It will help to formulate the corrective actions accordingly and in a
timely manner.
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This chapter includes methodology following which the monitoring of various physical,
biological, and socio-economic components was carried out. This study considers six
components which are likely to be affected due to construction and operation of the substations
such as air, water, noise, Soil, biological environment and social issues. In the following
sections, these components along with indicators, tools and techniques are discussed.
2.2 Environmental Monitoring Team
GREENBUD has prepared the report with its multidisciplinary team of environmental and social
assessment expert of having experience of conducting Impact Assessment of medium and large-
scale industrial projects. The name of the professionals’ involved in the study is listed below:
Table 5: The Composition of the Team
2.3 Methodology
The compliance monitoring of the project has been carried out following important
environmental and social component during field investigation. Methodology for the
investigation of each component is given below:
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To assess the baseline condition of the ambient air in the project areas, the air has been
sampled and analyzed at spots, using hand held direct reading instruments and experts. Ambient
air quality has been monitored for CO, CO2 SO2, NO2, CH2O, VOC, Particulate Matter (PM2.5
and PM10) and Suspended Particulate Matter (SPM) following the standard method.
2.4.2 Ambient Noise level
Noise monitoring is important for any construction activity as excessive noise may create
disturbance to the wild life, indigenous species, fragile ecosystems, communal stability in
case of sudden intrusion and workers due to construction activities and subsequent increased
traffic movement.
The ambient noise level has been monitored monthly at nearby sensitive receptors around the
project sites. Each time, noise level has been recorded using portable noise level meter for a two
minutes time span at 5 minutes interval depending on the site condition. Noise level has been
recorded at day and night time as the construction works held at both day and night. A probable
increase in noise level in the same area may provide the tools for assessment of impact on
environment.
2.5 Soil Management
Most of the site located at the cornfield and surrounded the villages. Soil sample has collected by
the GREENBUD team for the monitoring Chromium, Cadmium and lead content of soil
following the standard method. Changing the soil quality for the construction works can have an
impact on crop yields.
2.6 Water Quality
To determine the quality of water (ground, surface, waste) sample was collected from the tube
well, nearest pond and piling point respectively of the existing project site and analyzed in the
lab for different parameters following the standard method. Changing of any parameters of water
due to construction, can be affected on the crops, flora and fauna.
2.7 Waste Management
Infrastructure work for any development, usually generate variable quantities and types of waste
materials which have the potential to cause adverse environmental impacts during generation,
storage, transport and disposal. For this reason, the project aims to implement waste management
procedures immediately after the commencement of the civil works in order to maintain minimal
potential impacts to the environment. The project sites were observed visually during sites visit
to investigate concerns related to waste disposal.
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Proposed substation sites are situated in urban area, so urban ecosystem as well as vegetation and
wildlife are major components for this environmental monitoring.
2.9 Terrestrial Vegetation
Project site specific data (i.e., Cocos, Psidium, Cynodon, Scorpia, Croton, Leucas, Cyperus,
Chan grass) were collected through visual observation and use of GPS, Camera etc instruments
for proper ecological monitoring. In addition, local people were interviewed for getting data.
Monitoring of intercultural operation was done quarterly through consultation with stakeholders
and local people.
Flora and Fauna of all sites observed through regular field visit. The impact of project
implementation (i.e., land development; vegetation clearing, Labor and vehicle movement) on
small mammals, amphibians, reptiles and local urban birds have been identified through in
depth observation and consultation relevant stakeholders according to the prepared checklist.
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At present, constructions work is ongoing for eight project sites. The main concern is particulate
matter (PM) during the construction period as well as air born particulate from road side
vehicular activity. The dust particles will affect the nearby households. Besides, use of heavy
construction machineries (concrete mixer), transport vehicles may cause SO2, NOx and CO
emission.
GREENBUD technical team conducts air quality monitoring at all eight project sites. The report
with test result is enclosed with this report. Transmission Tower 61/4, 66, 66/1 and Tower 66/2
site was just beside the road. For that Air quality data indicates in the Road side project area is
relatively higher than village area projects. Heavy vehicle like truck, bus, car, bike etc are
moving through these roads all day long. Construction works on some nearby house buildings
were taking place during the time of field visit. These activities triggered the amount of fine
particulate in the air. These could be the reason of increasing particulate matter in project area.
However, particulate matter in all other project location was within the national standard. No
trace of SOx and NOx have been found in any project sites. Traces of PM have been found in all
the sites. The reason could be the vehicle movement. However, most of the parameters have
found in compliance with the DoE standard.
Table 6: Ambient Air Quality monitoring
(0.14 ppm)
100µg/m3
365µg/m3
(µg/m3)
(µg/m3)
(µg/m3)
(0.053
9 ppm
(ppm)
ppm)
NYS
150
200
65
1E.C.R (1997), “Environmental Conservation Rules, 1997” (amendment 2005), Schedul-02, Department of Environment, Govt.
of Bangladesh
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(standard 9 ppm)
(100µg/m3)
(365µg/m3)
(Standard 200
(Standard 200
(Standard 65
PM2.5
PM10
Tower
SPM
NO2
SO2
µg/m)
µg/m)
µg/m)
(ppm)
CO
O3
S/N Co-ordinates
ID
23°34'06.1"N
01 T-61/4 117 45 68 4 0 0 0
90°17'58.8"E
23°36'35.8"N
02 T-63/4 58 21 33 0 0 0 0
90°15'56.6"E
23°36'047.8"N
03 T-64 49 15 32 1 0 0 0
90°15'53.6"E
23°37'58.4"N
04 T-65/3 45 15 26 1 0 0 0
90°15'24.6"E
23°38'08.5"N
05 T-66 105 39 60 3 0 0 0
90°15'23.0"E
23°38'21.8"N
06 T-66/1 88 32 53 2 0 0 0
90°15'29.1"E
23°38'30.8"N
07 T-66/2 73 26 42 1 0 0 0
90°15'33.3"E
23°37'03.2"N
08 T-67 64 24 37 0 0 0 0
90°15'49.7"E
Source: GREENBUD field monitoring
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However, due to situating near the road, noise level is already above the limit for day time due to
vehicular traffic and people’s noise. Noise level in night time has also measured and found
relatively lower than day time and it’s met the DoE standard limit. So, noise generation from the
site operation will not affect the nearby households. The average noise levels of the project sites
are shown in the below table 7 and Standards of noise levels for different zones of Bangladeshis
shown in the below table 6.
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23°34'06.1"N
01 T-61/4 6.3 <2.0 1.2 0.14 Nil
90°17'58.8"E
23°36'35.8"N
02 T-63/4 6.8 <2.0 0 0.16 Nil
90°15'56.6"E
23°36'047.8"N
03 T-64 6.2 <2.0 0 0.22 Nil
90°15'53.6"E
23°37'58.4"N
04 T-65/3 7.3 <2.0 0 0.27 Nil
90°15'24.6"E
23°38'08.5"N
05 T-66 7.9 <2.0 0 0.19 Nil
90°15'23.0"E
23°38'21.8"N
06 T-66/1 6.5 <2.0 0 0.18 Nil
90°15'29.1"E
23°38'30.8"N
07 T-66/2 6.2 <2.0 1.1 0.14 Nil
90°15'33.3"E
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23°37'03.2"N
08 T-67 7.4 <2.0 1.3 0.12 Nil
90°15'49.7"E
Source: GREENBUD Water Lab, (BOD= Biochemical Oxygen Demand, COD= Chemical Oxygen Demand, NH3=Ammonia)
ECR
Co-ordinates ECR ECR ECR ECR
Standard
ECR
ECR Standard
ID Standard Standard Standard Standard Standard
(1200 (10mg/L)
(6-9) (50mg/L) (200mg/L) (2100mg/L)
μS/cm)
(4.5-8 mg/L)
23°34'06.1"N
01 T-61/4 6.8 12.4 18.6 248.1 344 4.52 < 2.0
90°17'58.8"E
23°36'35.8"N
02 T-63/4 7.4 9.9 27.7 266.1 231 4.62 < 2.0
90°15'56.6"E
23°36'047.8"
03 T-64 N 7.6 8.1 21.5 318.6 274 3.43 < 2.0
90°15'53.6"E
23°37'58.4"N
04 T-65/3 6.7 10.6 12.9 227.4 256 3.44 < 2.0
90°15'24.6"E
23°38'08.5"N
05 T-66 6.2 14.9 12.7 341.5 331 4.51 < 2.0
90°15'23.0"E
23°38'21.8"N
06 T-66/1 7.6 16.2 12.1 263.3 316 3.96 < 2.0
90°15'29.1"E
23°38'30.8"N
07 T-66/2 7.1 11.7 11.6 366.7 291 4 < 2.0
90°15'33.3"E
23°37'03.2"N
08 T-67 7.5 13.5 10.4 244.1 283 3.8 < 2.0
90°15'49.7"E
Source: GREENBUD Water Lab, (BOD=Biochemical Oxygen Demand, COD=Chemical Oxygen Demand, TDS=Total Dissolved Solid, EC=
Electro-Conductivity, DO=Dissolved Oxygen)
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GREENBUD technical team conducts soil quality monitoring at all eight project sites visually
and collect sample to test the parameters of its Chromium, Cadmium and Lead concentration.
The report with test result is enclosed with this report
Table 12: Soil quality monitoring result
Chromium Cadmium
Lead (pb)
S/N Tower ID Co-ordinates (Cr) (Cd)
ppm ppm ppm
23°34'06.1"N
01 T-61/4 0.42 1.14 1.24
90°17'58.8"E
23°36'35.8"N
02 T-63/4 0.36 2.29 1.37
90°15'56.6"E
23°36'047.8"N
03 T-64 0.37 2.37 1.31
90°15'53.6"E
23°37'58.4"N
04 T-65/3 0.49 2.16 1.18
90°15'24.6"E
23°38'08.5"N
05 T-66 0.41 2.09 1.21
90°15'23.0"E
23°38'21.8"N
06 T-66/1 0.68 2.37 1.27
90°15'29.1"E
23°38'30.8"N
07 T-66/2 0.42 1.36 1.48
90°15'33.3"E
23°37'03.2"N
08 T-67 0.58 2.31 1.29
90°15'49.7"E
Source: BCSIR
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The construction work is going for the Transmission Tower. Workers are now present at site.
They manage their food locally. So now there is no kitchen waste at site and construction waste
is also minimum. At 66/2 site, construction wastes were observed dumped scattered. Stock piling
of leftover construction material was seen at 66/1 site. This leftover material like stone, sand etc.
will act as source of air pollutant. Water logging was observed around the project area. However,
the project proponent has ensured that these were temporary dumping due to the ongoing
erection and maintenance operation work and after completing the work, these waste materials
will be transferred to municipal dumping area immediately.
During the time of field visit, the waste management issues were found satisfactory in all the
eight-project site. There were no construction wastes only some household wastes were present.
Monitoring team has advised the proponent to improve the waste management and labor
accommodation. Sanitation facility was found poor in some project area. Monitoring team
accordingly has advised the proponent to increase the frequency of cleaning and washing of the
latrines. Increase the number of dustbins in these areas and immediate installation of sufficient
number of dustbins in those areas where scattered dumping was observed has been advised.
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addition to this a number of fruits yielding trees were fell down at all eight sites during
construction.
Low density of herbs like Vasant (ClerodendrumViscosum) and shrubs like Henna
(LawsoniaInermis), Garden Croton (CodiaeumVariegatum) etc were also present there
and most individuals of which were cut/damaged due to land filling and land development
activities. At this time, habitats of some urban birds, (i.e., House Sparrow, Common Myna,
Bulbuls, House crow etc) small mammals (i.e., Mongoose and Mouse), amphibians (Common
Toad) and reptiles (Lizards) inside the project site were disturbed and this wildlife were
gradually relocated from the proposed site. Here should be mentioned that, the populations of
this wildlife were very low and observed occasionally. Occurrence of wildlife is not significant
as per informed by the concern staffs. As a result, impacts on local wild life and their habitat
were found negligible.
PGCB has appointed an Assistant Engineer to function as the EHS manager for taking care of
EHS issues. PGCB has developed an EHS Policy which has also been translated in Bengali.
EHS Policy in both English and Bangla has already been displayed in the operational site and
will be displayed in other under construction site.
The EHS Plan of the Contractor has been developed focusing on site specific construction
activities, which outlines the key procedures and permits to be implemented to safeguard onsite
employees and workers of PGCB and subcontractors at the same time ensuring safe working
conditions and efficient operations contractor also implemented No-Smoking Policy, different
types of safety notice throughout the substations for ensuring safety of all the labors, senior
officials who are working in the Transmission Line tower project. They have also implemented
the program of no use of cell phone/cameras in various places of the project. All the documents
have been translated into English, and for some cases, in Bengali also.
A Personal Protective Equipment (PPE) Matrix has been developed for ensuring workers’ safety
for different types of jobs, e.g., cutting, grinding, excavation, work at height, pipe laying or
manual lifting, confined spaces, electrical work, welding, spray painting, concreting etc. All the
personnel/workers are bound to use mandatory PPEs i.e., safety helmet and safety shoes as well
as wear or use job/site specific other PPEs i.e., safety shield, safety gloves, safety goggles, safety
mask, gum boots, safety harness/belt etc. Field Supervisors ensure the use of PPEs, while EHS
Team of Contractor surveys/monitors it regularly.
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PGCB has prepared a Stakeholder Engagement Plan (SEP). SEP has been translated into local
language. PGCB has developed a commitment register as a part of stakeholder engagement
process in order to document the outcomes of public consultations and respond to local
community expectations, and ensure that these are communicated back to stakeholders and
updates provided. Community Development Manager maintains a stakeholder engagement file
that includes a sheet named as commitment register. This includes brief mentioning of the issues
shared by community and action taken upon those issues by the company.
PGCB didn’t have to go through involuntary resettlement phase as some lands were previously
owned, purchased or leased by the PGCB. Rest of the lands has been purchased with high value
from the owner. Therefore, no issue of involuntary resettlement was generated as it didn’t affect
any personal land holder directly.
Based on the primary observation during site visit, no habitat of any indigenous community has
been reported at the project area. So, the project has been categorized as Category-C for
Indigenous Peoples (IP) safeguards concluding that there is no issue about adversely affecting IP
neither in construction phase nor in operation phase. However, PGCB has conveyed that they are
gender and caste neutral. So, any qualified person coming from the indigenous community will
be equally treated during the recruitment process, and will be given the same benefits as like as
other personnel.
A developed fire extinguishing system can prevent any unexpected incident. It is one of the key
issues that an organization should take care of. Oil filled transformers pose the greatest fire risk
in any substation or tower. Various flammable chemical, grease can also be potential reason for
fire incident.
While inspecting the project sites, it was noticed that transformers would be properly insulated.
Layer of rocks were seen in the project site so that no oil can leak and penetrate through the
ground and contaminate it. Fire extinguisher (CO2, ABC dry powder, water) equipment, fire
detection alarm was available in the site.
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Chief Engineer/Project
Director
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Promote good safety, culture and Behavior through positive communication and cooperation we
work towards incident free-zero accident, zero loss no harm to people, excellent result in HSE
performance, HSE would not compromise cultivating HSE excellence as a core value, manage
HSE like we do quality, cost and schedule, no operation will have greater importance over HSE
and no damage to the environment.
With reference to the ESMP of the project, a number of training was committed to be provided.
List of trainings provided is given below:
Table 13: Training Summery
Number and Position Location/s and
Trainings/Drills/ Inspections Remarks
of Participant/s Date/s
Verbal exam was taken by the
Lifting Works Safety 45 Laborers 5th January’2021 trainer about lifting works
safety
COVID-19 Health & Safety Preventative
60 Laborers 12th January’2020 -
Measures for workplace
Tower Erection Works Safety & Work at Verbal exam was taken by the
80 Laborers 2nd February’ 2021
Height Safety trainer about work at height
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It is also mentionable that, no mentionable Accident was occurred during the Monitoring period.
Table 14: Accident Inventory
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a) Only licensed disposal collects or shall engaged to carry out the disposal.
b) The hazarders material, liquids or chemicals shall be disposed in designated bin in
collection point, separated from other form of waste such as rubbish or scraps.
c) All garbage, refuse, waste, debris etc. shall be disposed in designated Bins or containers.
5.4 In-House Rules and Regulations
a) The factory act and regulation (Bangladesh Government) Permission held and strictly
following the CP (Code Purchase)
b) Work place must be indicated the emergency assembly points, evacuation and rescue
plant contacts by immediate in charge of project.
c) Emergency First AID Box and Quality first Aides appointed.
d) First Aider should be qualifying on CPR & AED.
e) safety Awareness and safety articles are available at the work place.
f) All inflammable material are stored separates in an open shed with proper barricading,
caution Boards like “No” smoking etc. are displayed.
g) Firefighting facilities was provided like sand bucket, fire extinguisher.
h) Safety talk/Tool Box meeting was conducted daily before start of work to create safety
awareness about the hazards in the particular job to avoid accidents.
i) Nobody is allowed to work without wearing certified safety Helmet, Goggles, fluorescent
jacket & safety shocks and other DPE, as required.
j) Usage of protection when works without wearing certified safety Helmet.
k) Usage of eye protection when works man one engaged for grinding, chipping welding
and gas cutting.
l) Emergency contact numbers like ambulance, Fire station, local police station Nos. was
displayed at site office or sites.
m) Emergency vehicle stand by deployed at site.
n) All excavated pits barricaded and barricaded maintained fill the back filling is done.
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o) Adequate lighting facilities such as flood-lights, hand lights and area lighting was
provided at the working sites.
p) Pilling zones, erection zones and dismantling zone has been barricaded.
q) Scaffoldings/work platforms are used sound proof materials.
r) Flagman was deployed during movement of heavy vehicles.
s) Fall arrestor was used while working at heights.
t) Daily manpower report, accidents/near miss report submitted.
u) Safety meeting hold at regular intervals.
v) To be submitted organization chart with contact nos.
w) Medical certificate should be kept before engaging workman.
x) Safety audit compliance prepared by contractor on daily basis.
y) Name and blood group was reflected on helmet and new employees was updating on
daily basis.
The basic objective of the Grievance Redress Mechanism (GRM) shall be to provide an
accessible mechanism to the affected people, community and any stakeholder(s) having stake in
the project to raise their issues and grievances as well as concerns. The Grievance Redress Cell
(GRC) shall be officially recognized “non-judicial” body that will seek to resolve non-judicial
disputes arising out of various matters related to the implementation of the ESMP, as well as
other aspects of the project, as may deemed fit to be raised before the GRC.
The fundamental objective of GRM is to resolve any resettlement and environmental related
grievances locally in consultation with the aggrieved party to facilitate smooth implementation of
the EMP. Another important objective is to democratize the development process at the local
level and to establish accountability towards the stakeholders.
The compliance monitoring team has been empowered with the responsibility of complying with
social safeguards. A grievance readdress procedure has been developed for taking into account
the grievances due to the project’s intervention (if occurs). While auditing the project sites by
respective field monitoring team, a Grievance Log Book has been found at main entrance, which
seems to be easily accessible to the adjacent people and the project’s stakeholders for lodging
their comments, suggestions or complaints. PGCB is committed to resolve of any grievance
within 15 days of receiving the grievance. However, based on the discussion with local people, it
has been assumed that there is no issue of grievances. Because the workers coming from the
local community are given priority to work in the project.
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GREENBUD official made frequent visits on the eight project sites of Transmission Line tower
during construction phase from January- 2021 to March-2021. It was found that the proponent
has formed committee to maintain and reserve all the acts pertinent to environment and social
impacts. They have done their best to assure these are no negative and adverse impact on
environment and society as a result of construction and maintenance of substation on those areas.
PGCB officials and contractor employees were quite co-operative during this site visit. They
provided all the necessary information which were asked and were frank to comply with all the
acts and safeguards of different institutions.
During the reporting period, the environmental and social team along with the technical team has
consultation meeting with the officials of PGCB at different stages of visit. The consultation
meetings were to sensitize the officials about ADB’s framework and monitor compliances
required in the project, such as implementation of resettlement plan, documentation needed on
mutual negotiation, approach to social impact assessment identification of affected persons,
progress of work etc.
Keeping in mind the significant of engaging the local stakeholders in the whole process,
GREENBUD team kept in touch with several local people to know about their view about those
towers of transmission line. It was also important to justify their opinions with those of PGCB
officials. This consultation helped to find out if there was any issue regarding transmission line
among those local stakeholders. But it was found that they were jubilant as this construction and
operation didn’t require owning land or their properties. Additionally, they will be beneficial as
electricity will be always available in those areas.
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Annexure-A
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Annexure-B
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