Environmental Monitoring Report UZB: Talimarjan Power Project · Bi-annual Environmental Monitoring Report – (July-December 2016) Talimarjan Power Project 5 PART I - INTRODUCTION

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Environmental Monitoring Report

Semestral Report for July - December 2016

UZB: Talimarjan Power Project

Prepared by State Joint Stock Company UzbekEnergo for the Republic of Uzbekistan

and the Asian Development Bank.

This environmental monitoring report is a document of the borrower. The views expressed herein do not necessarily represent those of ADB's Board of Directors, Management, or staff, and may be preliminary in nature. In preparing any country program or strategy, financing any project, or by making any designation of or reference to a particular territory or geographic area in this document, the Asian Development Bank does not intend to make any judgments as to the legal or other status of any territory or area.

Bi-annual Environmental Monitoring Report – (July-December 2016)

Talimarjan Power Project

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Table of Contents

PART I - INTRODUCTION ........................................................................................................................... 5

1.1 CONSTRUCTION ACTIVITIES AND PROJECT PROGRESS DURING THE PREVIOUS 6 MONTHS ................. 5

1.2 CHANGE IN PROJECT ORGANIZATION AND ENVIRONMENTAL MANAGEMENT TEAM ............................... 8

1.3 RELATIONSHIP WITH CONTRACTOR, OWNER, AND LENDER................................................................... 9

PART II - ENVIRONMENTAL MONITORING ............................................................................................ 11

2.1 NOISE.......................................................................................................................................................... 11

2.2 WATER QUALITY ......................................................................................................................................... 12

2.3 AIR QUALITY ................................................................................................................................................ 13

2.4 FLORA AND FAUNA MONITORING ................................................................................................................ 13

2.5 OTHERS ...................................................................................................................................................... 14

PART III - ENVIRONMENTAL MANAGEMENT ........................................................................................ 16

3.1 ENVIRONMENTAL MANAGEMENT SYSTEM (EMS), SITE SPECIFIC ENVIRONMENTAL MANAGEMENT PLAN, AND WORK PLAN ................................................................................................................................................ 16

3.2 SITE INSPECTIONS AND AUDITS .................................................................................................................. 18

3.3 NON-COMPLIANCE NOTICES ....................................................................................................................... 18

3.4 CORRECTIVE ACTION PLANS ...................................................................................................................... 20

3.5 ACTIONS TAKEN TO REFLECT THE FINDINGS OF ADB MISSION DURING THE REPORTING PERIOD ............ 24

3.6 CONSULTATION AND COMPLAINTS ............................................................................................................. 25

PART IV – ACTION PLAN FOR THE NEXT PERIOD .............................................................................. 26

ANNEXES ..................................................................................................................................................... 29

ANNEX 1. MONİTORİNG DATA ........................................................................................................................... 29

NOISE MONITORING DATA EXTRACTED FROM THE HDEC MONTHLY ENVİRONMENTAL REPORT OF

DECEMBER 2016 .............................................................................................................................................. 29



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.......................................................................................................................................................................... 29

ANNEX 5: SITE PHOTOGRAPHS ........................................................................................................................ 34



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ABBREVIATIONS

ADB Asian Development Bank

CS-MM Corporate Solutions and Mott MacDonald Team

CCGT Combined Cycle Gas Turbine

CSCL Corporate Solutions Consulting Ltd

DMF Design and Monitoring Framework

DRM Design Review Meeting

EA Executing Agency

EIA Environmental Impact Assessment

EMP Environmental Management Plan

EPC Engineering Procurement Construction

GoU Government of Uzbekistan

GTG Gas Turbine Generator

HDEC Consortium of Hyundai and Daewoo

H&S Health & Safety

HSE Health, Safety, and Environment

HRSG Heat Recovery Steam Generator

HVAC Heating Ventilation and Air Conditioning

IA Implementing Agency

IC Implementation Consultant

IAS International Accounting Standards

IFI International Financial Institution

ISO International Organisation for Standardisation

JICA Japan International Cooperation Agency

MFERIT Ministry for Economic Relations and International Trade

MoM Minutes of Meeting

MPR Monthly Progress Report

PAM Project Administration Manual

PFS Project Financial Statements

PMU Project Implementation Unit

PPE Personal Protective Equipment

PPMS Project Performance Monitoring System

STG Steam Turbine Generator

TPP Talimarjan Power Project

UE SJSC UzbekeEnergo

UFRD Fund for Reconstruction and Development of the Republic of Uzbekistan

UZS Uzbekistan Som (currency unit)

VAT Value Added Tax

WA Withdrawal Application

ZEP Zone Environmentally Protected -Environmental Effects/Impact Statement

ДВ Maximum permitted emissions to air

Д Maximum permitted waste disposal

ДС Maximum permitted water discharges



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PART I - INTRODUCTION

1. The Government of Uzbekistan has received a loan from the ADB to part finance the construction of the Talimarjan Clean Power Project (the project) - a combined cycle gas generation plant. The project is located in Kashkadarya Province of Uzbekistan, 440 km south west of Tashkent. The site is an existing power plant, which currently generates 800 megawatts (MW). The project will install two combined cycle gas turbine (CCGT) units of about 450 MW each at the site.

2. Construction of CCGT units is planned for the expansion of TPP to improve the overall ОППiciОncy and ОnvironmОntal pОrПormancО oП UzbОkОnОrgo’s gОnОrating activitiОs across thО country. The most advanced and efficient CCGT units available in the 370-450 MW range were considered for this project.

3. Based on ADB's safeguards policy statement (SPS), the Project is classified as follows: (i) environment (category A) – environmental impact assessment (EIA), (ii) involuntary resettlement (category C) – no actions, and (iii) indigenous peoples (category C) – no actions. Therefore, an environmental clearance from ADB was obtained in December 2009.

4. According to the Decree of the CabinОt oП Ministry oП RОpublic oП UzbОkistan № 491 “On government ecological expertise”, the Project was classified as a class 1 Project under the Uzbekistan Environmental Legislation. The environmental clearance was obtained from the Nature Protection Committee (NPC) on 5 October 2009. Moreover, in order to comply with environmental legislations of the Republic of Uzbekistan, a new Conclusion of Ecological ExpОrtisО № 18/768 was rОcОivОd on 13 August 2013 Пrom thО StatО NaturО ProtОction Committee for the project.

5. The State Committee for Nature Protection, Kashkadaria regional committee for nature protection, was given the responsibility to oversee compliance to the local environmental legislations on the protection of nature during the project implementation.

6. The Environmental Impact Assessment (EIA) has been prepared to meet the requirements of the Uzbekistan Environmental Legislation as well as the ADB’s environment policy requirements. The EIA was published on 15 December 2009. Two rounds of public consultations were held prior to project appraisal. The environmental sensitivity of the Project site and its surrounding areas is low. Town of Nuristan is the only community close to the plant where the employees of Talimarjan TPP live. The nearest settlements are over 5 km away. The Project's key environmental issues are air quality and emissions, noise impacts on the Nuristan settlement and waste management.

7. The objective of this report is to report progress of implementing Site Specific Environmental Management Plan and Environmental Monitoring Plan (EMP), as stated in the Environmental Impact Assessment report. This bi-annual environmental monitoring report covers the period January to June 2016. The report is prepared jointly by the Project Implementation Unit (PMU) and the project implementation consultant, Corporate Solutions and Mott MacDonald (CS-MM).

1.1 CONSTRUCTION ACTIVITIES AND PROJECT PROGRESS DURING THE PREVIOUS 6 MONTHS

8. In this review period, the Project is at an advance stage of construction. Below is a summary of construction activities and project progress during the reporting period:

CCGT1 (Unit 2) has been commissioned and performance tests are done. The Unit is under reliability test since the last week of December. Air quality measurements have not been completed as per the Contract. Contract calls for NOx and CO



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measurements to be performed at 50%, 65%, 80% and 100% base load. However, only 50% and 100% tests were completed.

GT2 of CCGT2 (Unit 3) has been commissioned in December and generating electrical power via GTG2 and steam via HRSG2. The steam is being used for cleaning the steam pipes. It is estimated the cleaning with high temperature steam will continue till the second week of January 2017. After then steam turbine reinstatement and commissioning activities will take place. It is supposed to admit first steam in the 2nd week of February 2017.

Most of the construction works in CCGT1 (Unit 2) are completed with several punches. Punch clearing activities are ongoing.

Similarly major construction activities in CCGT2 (Unit 3) are completed. There are control and instrumentation works ongoing. Pre-commissioning works are also ongoing.

In the cooling tower, the pre-commissioning activities continue.

In Intake facility, cabling works continued. Chemical dosing building for GT Evaporative system and HRSG of unit -2 is completed with some punches on finishing works.. The bulding has been commissioned in November and operational.

Chemical Dosing Building for GT Evaporative Cooler System and HRSG of Unit-3 is under pre-commissioning.

CPP Regeneration unit. Setting-up the acid and alkali dosing pumps for the regeneration and neutralization is in progress.

Referring to the Overall and the Construction S-Curves, below, the overall delay is around 0.31% (planned is 100%, achieved is 99.69%) and the delay in construction is around 0.53% (Planned is 100% whereas the achieved is 99.47%). Just 1.13% progress is achieved in last month.

Fig. 1: Overall Project S-Curve as of 31 December 2016



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Fig. 2: Construction S-Curve as of 31 December 2016

Table 1: Construction Progress



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The overall pre-commissioning S-curvО, ОxtractОd Пrom thО HDEC’s Monthly Progress Report for December 2016, is shown in Figure 3 below.

Fig.3: Pre-Commissioning S-Curve as of 31 December 2016

Within this period, Pre-Commissioning Works increased to 92.48%. In the previous period it was 59.62%. Average progress is 11% in the last three months. This progress figure cannot be achieved unless some major commissioning activities are omitted.

The commissioning progress is around 70% in Unit-3.

1.2 CHANGE IN PROJECT ORGANIZATION AND ENVIRONMENTAL MANAGEMENT TEAM

9. The PMU and the CS-MM’s Organizational Structure has remained the same during this reporting period except Mr. Asim Acikel who left the project in August 2016. EPC contractor’s organization is also samО in thО sОcond half of the year. Moreover, former contractor’s IntОrnational HSE ManagОr Mr.JОong-Hyeon Kim left the site in May 2016 and former environemental expert of sub-contractor Tupalang, Mr. Oybek Shaybalov started working as local environmental expert for sub-contractor KTI in January 2016, and accordingly sub-contractor Tupalang hired a new local environmental expert Mr. Erkin Kayliyev in January 2016. Environmental Management team for the project is shown in Table 2.

Table 2: Environmental Management Team for the Project

Name Company Position Contact (email and/or tel.)

Ms.Magfirat Muminova

Uzbekenergo Head, Environmental Department

[email protected]

+998 90 929 1302

Ms.Diana Rakhimova

PMU Environmental/Social Expert

[email protected]

mailto:[email protected]



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+998 93 555 0595

Nizom Rakhimov TPP Talimarjan Environmental expert

+998 93 900 1936

Rajab Khojamuratov

CS-MM Deputy Team Leader [email protected]

Ki Ho Kang Hyundai Senior International HSE Manager

[email protected]

+998906176908

Husan Khidirov Hyundai Local HSE Engineer [email protected]

+998 93 423 3114

Oybek Amanov Hyundai Local Environmental Officer

[email protected]

+998 90 639 5418

Erkin Kayliyev PGU Tupalang Local Environmental Officer

+998 93 930 09 89

Oybek Shaybalov KTI Local Environmental Officer

+998 93 697 1112

Arsalan Chowhan RCG International HSE Inspector

[email protected]

+998 91 949 6187

Nurjan Niltullaev KTI Local HSE Manager [email protected]

+998 90 593 0035

1.3 RELATIONSHIP WITH CONTRACTOR, OWNER, AND LENDER

10. The project is implemented by the Executing Agency (EA), Uzbekenergo. It is under the control of a Project Management Unit (PMU), headed by a Project Director appointed by the EA. The PMU works closely with the corresponding departments within the existing TPP organization to achieve the necessary coordination and integration with the ongoing operation of TPP Unit 1.

11.The contractor (HDEC) was appointed in March 2013 as the EPC Contactor responsible for the design, supply, delivery, erection, testing, and commissioning of the two CCGT units. The contractor conducts environmental monitoring at site and prepares and submits monthly environmental monitoring report to the PMU. There are a number of sub-contractors for the implementation of the project, and the list of main companies working during this reporting period is shown in Table 3.

Table 3: Main Companies Working during reporting period

Company Position

HDEC EPC Contractor

PGU Tupalang Sub-Contractor for civil works

KTI Sub-Contractor for piping work and welding

RCG Sub-Contractor of PGU Tupalang for HRSG, ST, GT erection

12. ThО Consultant’s contract was signОd on 26 NovОmbОr 2011. ThО rolО oП thО Consultant is to help PMU assure that the plant is constructed to the standard specified in the EPC Contract, complОtОd on schОdulО, and costs arО monitorОd and controllОd. ThО Consultant’s








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role covers dОsign audit, monitoring oП thО Contractor’s works, issuancО oП nОcОssary progress reports and payment certificates, and the provision of general project management. Audit of compliance with the site-based Environmental Management Plan and site monitoring are carried out on a monthly basis by the Consultant and monthly Environmental Reports are prepared and submitted to the PMU. Consultant also reviews the contractor’s monthly environmental report to identify any non-compliance issues and to evaluate environmental monitoring progress and prepare written comments to allow the PMU to control compliance with the site based Environmental Management Plan, and to be aware of any issues affecting the project.

13. Initially Monthly Progress Review Meetings were foreseen between the PMU, the contractor, and CS-MM. The PMU decided to cancel the Monthly meetings but instead meet on every Friday since June 2015. The TPP management is responsible for the agenda of progress meetings, but CS-MM was neither requested to submit items for the agenda, to reflect environmental issues, nor requested to participate in the progress meetings. During this reporting period, the environmental issues were not on the agenda of the progress meeting at all.

14. Environmental and Social expert of CS-MM and the environmental experts of TPP and the contractor and sub-contractors meet regularly to discuss and coordinate environmental concerns and agree remedial actions. CS-MM provides on the job training on environmental matters to the PMU environmental expert, contractor’s ОnvironmОntal ОxpОrt and sub-contractor’s ОnvironmОntal ОxpОrts.

15. The PMU reviews and analyses monthly environmental reports both from the contractor and the CS-MM. To ensure proper and timely implementation of the EMP and adherence to the agreed environmental covenants, the ADB requires Uzbekenergo to submit bi-annual reports on the implementation of the EMP, and this requirement is reflected in the loan agreement. The PMU submits the bi-annual environmental monitoring reports to the ADB. The PMU also sends the bi-annual Environmental monitoring reports to the Kashkadarya Regional Committee of the Nature Protection for reference as well.



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PART II - ENVIRONMENTAL MONITORING

16. Main progress during the previous reporting period was that the contractor completed obtaining conclusions of ecological expertise/environmental permits for all temporary facilities except welding workshop as well as borrow pit as of 30 June 2016. The main non-compliance with local environmental regulation was that the measures required/mentioned in the environmental permits have not been executed by the Contractor as of end of 30 June 2016. Moreover, the normative documents provided/listed in the environmental permits of the temporary facilities were not filled in/executed by the contractor as of end of 30 June 2016 in order to meet requirements of the environmental permits. Due to this non-compliance with the environmental permits, the Contractor was requested to pay compensation including penalty for non-compliances with local environmental regulations. In this reporting period, the Contractor started to execute the environmental permits and fill the forms regularly as per the permits. However, there is no progress in obtaining the permits for the borrow pit. By end of October, 2016 KTI closed the welding shop and there is no welding activity there anymore.

17. In accordance with the EIA and the accompanying Environmental Monitoring Plan (EMP), the Contractor is required to undertake parametric measurements and observations on air quality, water quality, noise, dust and vibration. Accordingly, the monitoring guidelines were set as shown below in the table 4 below:

Table 4: Parameters of monitoring measurements and frequency

Parameters Frequency of Measurements

Remarks

Dust Weekly TSP

Air emissions Weekly SO2, NOx, CO, CO2. Since the CEMS is in operation, it is measured daily at the sources (Stacks).

Noise Weekly

Water usage record Daily and monthly total

Wastewater quality and quantity

Quarterly Suspended Solids, BOD5, Dissolve Oxygen, Oil Products, Coli Index. Done by TPP Laboratory.

Potable water quality Daily and Monthly Volumetric Control

2.1 NOISE

18. The EIA requires monitoring of noise during the construction stage. During construction of the CCGT units, there are short-term and reversible impacts on local residents caused by construction noise. Sources of noise include increased traffic and construction equipment.



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19. Construction works involving particularly noisy equipment or activities are, however, contained to daylight hours. Equipment are properly maintained and operated to minimize noise and its impact on the residents of Nuriston. A survey of the site and surrounding areas were undertaken during construction at weekly intervals, with additional checks during unusual high noise activities to check for excessive noise levels. The noise measurements were carried out by thО contractor’s EnvironmОntal ОxpОrt with calibratОd noisО mОtОrs oП thО contractor.

20.The noise monitoring results at the Nuriston community indicate that the existing noise emissions at and near the site are lower than limits set by Uzbekistan legislation (regulatory noise limits for Uzbekistan is 75 dBA for day and 75 dBA for night) but are higher than limits set by the IFC/World Bank. According to the IFC, noise impacts should not exceed the levels presented in Table 5 or result in a maximum increase in background levels of 3 dB at the nearest receptor location off site.

Table 5: IFC Noise Level Guidelines

One hour Laeq (dBA)

Receptor Daytime 07:00 – 22:00

Nighttime 22:00 – 07:00

Residential; institutional; educational 55 45

Industrial; commercial 70 70

21. According to a noise test, which is carried out from 23rd December 2016 for unit-1 and unit-2 noise pollution level is equal to 110.3 db and 100.4 db respectively, which exceed norms by almost 1.3 times.

22. Taking into account farness of housing settlement Nuristan (700 m), noise impact does not spread apart the TPP boundary.

23.The following mitigation measures are provided to reduce noise:

CCGT’s noisО is ОxpОctОd to rОducО with thО installation oП casing.

Installation of air silencer at the outlet of HRSG.

24.Turbine exhaust gas does not have an air silencer considering that exhaust gas enters to the atmosphere through the tall chimney, with that noise is reduced by means of intensity and direction. The noise from the intake of the gas turbine, exerting pressure in the high frequency band can also be easily weakened by the means of sound proofing.

25 If abovementioned methods will be used to reduce noise of the units 1 and 2, in this case specifications will not exceed the allowable values (80 dB) according to UZB ZVOS (EIA). The noise monitoring data extracted from thО contractor’s December 2016 monthly environmental report is given in Annex 1.

2.2 WATER QUALITY

26.The area surrounding the TPP has no natural surface water features and the manmade structures, such as the irrigation canal, have low environmental values. The potential risks to surface water features from the construction of the new turbines are therefore low, which is why the EIA does not require monitoring of surface water quality during the construction phase.



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27. As groundwater exists over than 16 m deeper, therefore, the EIA does not require monitoring of ground water quality during construction phase as well.

28. Monitoring of water and wastewater quality is conducted by TPP laboratory, but TPP laboratory has licence only for measurement of wastewater quality and does not have licence for water quality measurements. Therefore, it has been decided to use Karshi laboratory to verify water quality measurement data of TPP laboratory and in case of positive results further use TPP laboratory. But due to the financial problems of TPP, Karshi laboratory has not been hired during this reporting period. Karshi Laboratory has conducted water quality measurements only in January 2017. The results of measurement data will be reflected in next monthly environmental monitoring report.

2.3 AIR QUALITY

29. The EIA does not require monitoring of air emissions during the construction phase, but the EIA requires monitoring of dust levels in the surrounding areas to adjust or increase the frequency or intensity of control measures accordingly during construction phase. Although, dust level monitoring measurement was required by the EIA, the Contractor was not carrying out such monitoring measurement since the beginning of the project. The Contractor was requested to take necessary measures and actions to monitor dust levels in the surrounding areas during rest of construction phase.

30. The contractor brought a dust measuring instrument in early November 2016 and dust measurements have been done by the Environmental Expert of the Contractor and included in thО EPC Contractor’s Monthly EnvironmОntal RОport.

31.Obtaining environmental permits and normative documents: ДВ (maximum pОrmittОd emissions to air), were completed for all temporary facilities except welding workshops from the local environmental authorities during this reporting period. The environmental permits for temporary facilities requires monitoring of air emissions by the contractor. However, the contractor did not monitor air emissions as requested in the environmental permits of these facilities during the reporting period until November 2016.

32. During commissioning of gas turbines the Continuous Air Monitoring System installed onto the main stack and NOx, CO has been monitored since October 2016. However, the log data has not been shared with PMU/CSMM. During the performance test of CCGT1, the official raw data submitted by the Contractor. NOx and CO should be measured at 65% and 80% of base load according to the EPC Contract. However, only 50% and 100% base load data are available.

33.The Continuous Emission Measurement System data has been included in the recent two monthly reports of HDEC. The contractual guaranteed level for NOx has been exceeded in several instances. The max level is 25 ppmvd (15% O2 Dry) whereas the measured maximum is 40 ppmvd (14.37% O2 dry).

34.The Air Emission and Dust Control data sheet of HRSG#2 and HRSG#3 Main Stack and Bypass Stack is given in Annex 3.

2.4 FLORA AND FAUNA MONITORING

35. Despite the region generally being a source of habitat to a significant number of native and introduced species, including some of conservation significance, the CCGT and TPP sites are highly modified, having been cleared of vegetation, and having a habitat unlikely to support any flora or fauna species of environmental significance. No impacts that would adversely affect these areas are likely to result from the construction of the new CCGT units, therefore, the EIA does not requires flora and fauna monitoring during construction phase.



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2.5 OTHERS

36. Record of water consumption: Both the EIA and local environmental regulations require the monitoring of water consumption. But, the Contractor was not monitoring actual water usage since the beginning of the project. The monthly water data for non-potable and potable water is 240,591 and 59,336 m3 cumulative total respectively extracted from the contractor’s monthly environmental report for June 2016, provided at Annex 2 of this report indicates total monthly allocated water quantity by the TPP, but it is not the actual usage data consumed at the construction site. With advice and guidance of PMU/CS-MM, the Contractor did obtain normative documents for water usage monitoring ( OД-11) and started to install additional water meters at the site. TPP requested that the contractor completes the proper installation of water meters and obtains certification for the installed water meters from the TPP during the previous reporting period. As of September 2016, the Contractor installed 12 water meters except the one missing in the Cooling Tower Area. However, in October, 3 of them were damaged. Contractor has not replaced them with the calibrated ones in the reporting period yet. The Contractor also started to fill in the executive normative documents and keep the records for monitoring water usage in September 2016.

37. Waste: Waste management still needs to be improved at the construction site by the contractor. Progress was observed related to the preparation of waste logs, which are kept at contractor’s oППicО for different waste types and classes. Data of waste log book are reflected in CC’s monthly rОport as oП NovОmbОr and December 2016 and attached to the report as an Annex. Contract was signОd with local licОnsОd company “Nuriston Tozalash” Пor hand-over and disposal of hazardous and construction waste. Luminescent lamps are disposed separately at special containers and removed from site periodically by licensed company. But waste management at TPP landfill area as well as at construction site still needs improvement. The EPC contractor together with TPP team started separation of different kind of construction waste at TPP landfill in December 2016. Waste monitoring data extracted from the HDEC Monthly Environmental Report of December 2016 are given in Annex 4.

38. Drinking Water: Drinking water is supplied from the Potable Water Treatment Plant of existing power plant (TPP) with a steel pipe to the site. TPP Environmental Expert declared that organic and inorganic settlement, chlorination, etc are all done in the existing plant. TPP is also monitoring the potable water quality regularly. The water pipe was cleaned before putting into the service, and has been in service more than 3 years. There is no need to have a sediment filter at the outlet of the pipe. PMU/CSMM advised the contractor to take regular samples and analyse them in TPP laboratory. Although the TPP laboratory is accredited, the accreditation expired. It should be renewed in every 6 month. TPP is also supplying drinking water to Nuristan and to the existing plant. Kashkadarya State Environmental Institute accepts their measurements and permits for the supply.

39.The valve stopping the water flow was damaged and removed from the pipe. Therefore, the water is wasted. This is an outstanding issue. The Contractor should install a new valve.

40. Wastewater: Both the EIA and local environmental regulations require monitoring of wastewater discharges. The Contractor obtained environmental permits and normative documОnts Пor wastОwatОr dischargО monitoring ( OД-13) and normative documents started to be filled in and the records have been kept during this period. The contractor monitors both domestic wastewater and industrial waste water quantity and quality. Domestic and industrial waste water quantities are calculated. The Industrial water is also supplied by TPP and supplied amounts are measured. Water and wastewater analysis data has been provided in the contractor’s monthly environmental reports since July 2016. The wastewater



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is transПОrrОd to TPP’s WastО WatОr TrОatmОnt Plant by pipОlinО. TPP ExpОrts chОck thО incoming waste water quality in the Power Block Area and just before Treatment Plant.

41. Soil and Borrow pit: Despite the requests of PMU/CSMM (letter of PMU dated by 12.08 2016; #1468), obtaining licences and permit for borrow pit by the contractor is still pending as of 31 December 2016. The contractor started disclosing of the records of soil borrowed. The soil pit has been decided to be used as garbage dumping area by the Nuristan Municipality. A new company has been awarded to operate the garbage dumping area. Hence, the some part of construction waste dumped before seems to remain there. The Contractor promised to implement corrective actions and remove all waste from borrow pit in January 2017.

42. Accident and incidents: The EIA requires monitoring and keeping reports of accident and incidents. One incident has been fixed in December 2016 regarding the damage of TPP worker during the construction activities. The Contractor (Hyundai) has provided first aid assistance to the worker and taken to hospital.



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PART III - ENVIRONMENTAL MANAGEMENT

3.1 ENVIRONMENTAL MANAGEMENT SYSTEM (EMS), SITE SPECIFIC ENVIRONMENTAL

MANAGEMENT PLAN, AND WORK PLAN

43. The contractor established an operational system for managing environmental impacts and carries out the monitoring and mitigation measures set out in the Site based Environmental Management Plan. The contractor submits to the PMU monthly environmental reports on the implementation of such measures.

44. The contractor prepared site specific environmental management plan (EMP) at the beginning of the project. The site specific EMP was prepared by the Contractor, reviewed and commented by the CSMM and approved by the PMU on 6 August 2014. The status of other environmental plans is given in Table 6.

Table 6. Status of Environmental Management Plans

Management Plan Status

Site Based Environmental Management Plan Submitted, approved on 06.08.2014. The revised one is submitted on 07.12.2016 for approval.

Environmental monitoring program Submitted as an annex to the site specific environmental management plan, approved on 06.08.2014

HS Plan Submitted.

Dust control plan It is included in Site Based EMP as a section 5.4.

Wastewater control plan It is included in section 5.6 of Site Based EMP

Waste management plan Submitted as a part of SB EMP Sec 5.8

Pollutants spillage control plan Submitted as a part of SB EMP Sec 5.

MSDS contents of hazardous materials MSDS are kept in HDEC HSE dept. It is open to PMU and CSMM since August 2016.

Traffic plan Not submitted

Rainwater control plan Not Applicable

Emergency preparedness and response plan Emergency Preparedness is in SB EMP Sec.4.10. HDEC Emergency Preparedness and Response Procedure for Overseas Projects , HMS-AH-114 Rev 0/01 March 2004 and Emergency Response Procedure HMS-AJ-107, 01 April 2015 are applicable to the Project.

Site plan It is submitted as Rev.2 and also included in the Monthly Environmental Reports.

45. The two environmental officers from the contractor and the main subcontractor need to continue to work together on implementing the site-based EMP and improving the environmental conditions. The revised site-based EMP from 30 November 2016 has been used for this review. The contractor changed the attitude and more adhering to the EMP.



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46. Substantial progress has been made by the contractor in addressing environmental issues raised during the previous reporting period, starting from September 2016. Key issues on site addressed partially or in full are: drainage, water metering, waste management, wastewater discharges, handling of hazardous materials such as bitumen, storage and disposal of hazardous wastes, vehicle washing area, and environmental monitoring and monthly reporting from the contractor, as well as compliance with the local environmental regulations.

48. Monitoring of the compliance with site-based EMP for July, August, September, October and December 2016 were carried out on the site by PMU/CS-MM and CSMM submitted the monthly environmental reports to the PMU. The contractor submitted monthly environmental reports for the same months and CSMM reviewed and commented them and then PMU submitted these commands to the EPC Contractor. The comments are also included as appendices to the CSMM Monthly Environmental PMU/CSMM works closely with the Environmental Expert of the EPC Contractor to follow up the concerns and remedial solutions as much as possible. The main concern on the monthly environmental reports from the Contractor was that there are some statements in reports that may be misleading. Some of the statements did not reflect the actual situation at the site, and some statements were not related or relevant to the mitigation measures. The reports had lack information on key environmental issues such as mitigation measures, compliance with local regulations, payments, qualitative and qualitative environmental measurement/monitoring data, etc. Starting from September, HDEC incorporated most of the comments by clearing or correcting the misleading statements in their monthly reports

49. PMU/CSMM issued a letter to submit all of the environmental audit reports of the indepОndОnt intОrnal ОnvironmОntal audit tОam appointОd by EPC Contractor’s hОad oППicО. However, the EPC contractor has not answered positively yet

50.One of the concerns of the previous reports was the lack of Project Execution Plan (POS - plan organizatsiya stroitelstvo). HDEC declared that the HSE Plan (B-000-T-64-001 Rev A 06.09.13) is the one referred as POS, in which HS&E measures are described. Within the vendor supplied work statements and in the pre-commissioning/commissioning procedures, proper HSE measures are usually described. The procedures show the amounts of water, demin water, oil, commissioning gases, chemicals to be consumed and how the wastes produced to be treated, as well as the pre-cautionary statements. 51.Since the construction phase almost finished, the inclusion of HSE measures to construction method statements are not necessary anymore. 52. Moreover, the contractors were not providing any reports and statistics for the produced waste, waste water and emissions arising from the construction activities and operation/running of temporary facilities to the local Environmental Committee. There are two sets of data to be submitted to Local Authority. The first one is Temporary Camp Facilities Data set and the second is the Construction Site Data Set. HDEC submits the first set directly to Local Authority. For the Construction Site, HDEC provides the data to PMU and PMU sends quarterly to the Local Environmental Authority, in Kashkadarya. Contractor Started to provide these data sets by mid July 2016. 53. Local environmental regulations require submission of quarterly reports to the Nishon branch of Kaskadaryanski Regional Environment Committee according to terms and conditions and conclusions of the Ecological expertise review. The PMU is submitting quarterly report to the Nishon branch of the Committee.



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3.2 SITE INSPECTIONS AND AUDITS

54. During the reporting period, the site monitoring was conducted on a monthly basis by TPP’s environmental expert, and audit of compliance with the Environmental Management Plan and site monitoring were carried out on a monthly basis by CS-MM and Environmental Reports were prepared and submitted to the PMU.

55. In the ADB Mission held in November, 2016, ADB Environmental Experts audited the PMU/CSMM and thО EPC Contractor’s pОrПormancО in supОrvision and implОmОntation oП the Site Specific Environmental Management Plan.

56. During reporting period, PMU Environmental Specialist, TPP environmental specialist

and CS-MM Environmental Specialist conducted the following site visits, the list of all review

missions conducted by PMU and SC are described in the table 7 below:

Table 7: List of review missions conducted by PMU and SC (CS-MM)

Date of Review Mission

Conducted by

July 2016 PMU Environmental Specialist, CS-MM Environmental Specialist

August 2016 TPP Environmental Specialist, CS-MM Environmental Specialist

September 2016 PMU manager, CSMM

October 2016 TPP Environmental Specialist, CSMM

November 2016 PMU Environmental Specialist, CSMM

December 2016 PMU manager, TPP Environmental Specialist, CSMM

3.3 NON-COMPLIANCE NOTICES

57. During this reporting period, two non-compliance reports were issued by CS-MM, in particular: 1. NCR-HSE-046 - regarding the unfenced chemical storage area and missing spill response kits; and 2. NCR-HSE-052 - is on the Acid/Passivation Liquids temporary pond utilized during acid cleaning of steam pipes. The summary and details of new and previous NCRs are as follows:

Resource records keeping: No accurate monitoring of water usage at the project site. Keeping a resource records for water usage is required by the local environmental regulations, which is a high ranking risk. Status: The contractor started to disclose resource records as of August 2016. They are being kept.

No waste log is kept for all type of wastes produced at the project site. Keeping a waste log is required by both the local environmental regulations and site based EMP, which is a high ranking risk. Status: Progress was observed related to the preparation of wastО logs, which arО kОpt at contractor’s oППicО for different waste types and classes. Data of waste log book are rОПlОctОd in CC’s monthly rОport as oП November and December 2016 and attached to the report as an Annex. NCR has been closed.



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No waste separation to the domestic, metal scrap, used oil, paper, hazardous, etc., as well as no separate waste disposal area designated at the project site. Both local environmental regulations and site based EMP require waste separation and designation of separate waste disposal area in the project site, which was a high ranking risk. Status: These are started to be segregated. In fact, almost all of the waste are commercially valuable scraps and always segregated before removing from the site. These are all delivered to the TPP. The EPC contractor together with TPP team started separation of different kind of construction waste at TPP landfill in December 2016.

No spill response kits were present at the project site, which is a medium ranking risk. Status: The EPC Contractor placed some spill response kits to the site. Since the construction is almost finished, the spillage risk is really low.

The practice of burning of waste, wood, etc., on site, which was a low ranking risk. Status: This is very rare at the site since September 2016.

Bitumen was not handled in accordance with provisions of site based EMP as well as the local environmental requirements, which is a medium ranking risk. Status: Since the construction and bitumen use almost finished, it turned out to be a lower risk.

Wastewater and residue from cleaning of concrete-mixing equipment are discharged on the ground, which is a low ranking risk. Status: Almost all concrete use is completed and hence, it is now a low risk.

Hazardous waste were not stored separately in accordance with the provisions of site based EMP and local environmental regulations, which is a medium ranking risk. Status: HDEC started to segregate the hazardous materials and dispose all the cans, drums to TPP (PMU) storage facilities.

The watering to control dust was not sufficient due to the summer conditions, which is a low ranking risk. Status: Starting from September 2016, the EPC contractor started to water the dusty roads. By end of November 2016, all the roads in the Power Block Area have been completed and the risk of dust is very low.

The surplus excavated soils were not removed in a timely fashion from the construction site causing dust pollution due to summer conditions, which was a low ranking risk in the previous reporting period. Status: Almost all of the surplus excavated soils were removed from the site. There are some piled near the Cooling Tower area to be utilized for grading and reinstatement.

During the operation of Unit 2 and Unit 3 gas turbines, Contractor claimed that the Methane concentration is too high whereas Ethane concentration is too low compared to the contractual gas supply data. This may lead to excess NOx emissions since the turbines were not trimmed for this gas concentration. This may also lead to affect the net power output and net heat rate. Status: This will be resolved by the PMU.

During steam blowing of HRSG2 and HRSG3 and the steam lines, the pH of the used demin water was much lower than the acceptable levels in couple of days, in October 2016. Status: PMU polished the demin water supplied to the EPC contractor and the concern resolved.

During the performance test of Unit 2, although the contract strictly calls for it, NOx and CO measurements only done at 50% and 100% base load running. Status: The associated measurements at 65% and 80% are still outstanding.

The contractual guaranteed level for NOx has been exceeded in the recent two months during the operation. The max level is 25 ppmvd (15% O2 Dry) whereas the measured maximum is 40 ppmvd (14.37% O2 dry). Please refer to Annex 1-



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Monitoring Data. These could be because of inefficient burning or simply of calibration of the instruments. Status: HDEC has been requested to explain the reason and take the remedial actions to lower the values to the guaranteed one.

3.4 CORRECTIVE ACTION PLANS

58. The contractor has started to take actions to rectify the NCRs and substantial progress has been made to address environmental concerns raised previously, during this reporting period.

59.The status of corrective actions taken are given in Table 8.



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Table 8. Status of corrective actions taken to reflect the action plan of the previous report

Date of submission

Description on non-compliance Corrective Action Required (CAR) including deadline

Performance Date/Resolution Status of CAR

ADB Mission in June 2015

Local environmental permits for all temporary facilities- obtaining local environmental permits for all temporary facilities by the Contractor are still pending.

Statutory monitoring measurements requested by the permits are not conducted by the contractor yet.

Local environmental permits for all temporary facilities should be obtained from local authorities by end of March 2016.

Statutory monitoring measurements requested by the permits should be conducted regularly by the contractor starting from April 2016.

Mostly completed. The Contractor obtained permits for all temporary facilities except welding workshops.

Mostly completed within this period.

ADB Mission in June 2015

Licences and permits for borrow pit- obtaining licences and permits for borrow pit by the Contractor are still pending since beginning of construction Works.

Poor environmental management at borrow site- Borrow site near the Project site is becoming a dumpsite. No record of all soil taken from the borrow pit and returned to the pit

Licences and permits for borrow pit should be obtained from local authorities by end of March 2016.

The Contractor should improve environmental management at borrow pit. After completion of the operations in its certain section, the idle material should be backfilled, compacted, terraced and harmonized with the landscape by end of March 2016.

The contractor should keep record of all soil taken from the borrow pit and returned to the pit and the data should be included in monthly environmental reports of the contractor.

Not completed.

Not completed. The borrow pit is not yet re-instated and is filling with garbage from the local community. According to TPP management, the borrow pit area has now been purchased from the borrow pit operator and an application has been made to turn the borrow pit into a licensed landfill. However, before the borrow pit can be established as a landfill the pit must be reinstated or at least properly graded.

Completed.

ADB Mission in November 2015

Drinking water- drinking water for workers is not filtered in construction site to provide clean potable water supply to workers.

Filter should be installed to provide clean potable water supply to workers at construction site by end of March 2016.

It is understood that the incoming water is already treated in TPP Water Treatment Plant. The supply pipe has been flashed and no sediment comes. Hence No need



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for any additional filtering. CLOSED.


environmental non-compliance notices- environmental non-compliance notices issued by CSMM are still pending for closure,

The Contractor should respond to environmental non-compliance notices issued by CSMM by end of March 2016

Most of them addressed but not officially closed yet.


Batching plant site-Poor environmental management at the batching plant site

Cement sludge is seen everywhere an settling basins are not being used,

The Contractor should improve environmental management at the batching plant site and batching plant should be cleaned up and surface gravelled by end of March 2016.

No washing of cement mixers outside the washing areas by end of March 2016.

Gravelled and concrete pavement done partially. However it is not sufficient. Water from the concrete batching yard is not directed to the sludge pits, instead the water is being channeled off-site to an area adjacent to the batching yard. A pool of sludge is now building up in this area.

In the reporting period, substantial improvement was there. However, in December, it turned out to be as before. Concrete mixers appear to be being washed out on open ground next to the concrete batching plant. Mixers should be washed out in the dedicated vehicle washing areas. Not completed.

ADB Mission in November 2016/PMU and CSMM

Vehicle/mixer washing area- there is no oil separator at vehicle/mixer washing area and poor environmental management at vehicle/mixer washing area

Oil separator should be installed at vehicle/mixer washing area and proper drainage system should be installed and wastewater should not be disposed onto ground. It is recommended that the contractor should conclude a contract with TPP to accept wastewater from the vehicle/mixer washing area.

Not completed

November 2015 Monitoring measurement data for wastewater- normative documents for wastewater discharge monitoring ( OД-13) are not kept by the Contractor as requested by local environmental permits for temporary facilities

normative documents for wastewater discharge monitoring ( OД-13) should be kept regularly starting April 2016

Completed. CLOSED.

November 2015 Water usage records- normative documents for watОr usagО monitoring ( OД-11) are not kept by the Contractor as requested by local environmental permits for temporary facilities

normative documents for water usage monitoring ( OД-11) should be kept regulalry as requested by local environmental permits starting April 2016

Completed. CLOSED.

June 2015 The EIA requires that prior to the start of The Contractor should develop an inventory of Not done properly. During pre-



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construction, the contractor develops an inventory of waste fractions expected to be generated during construction for the approval of disposal routes and sites by the local authorities, but the issue is still pending

waste fractions expected to be generated during construction for the approval of disposal routes and sites by the local authorities by end of March 2016,

commissioning and commissioning phases, individual method statements included the amount of waste expected at the end. Although the expected waste fraction inventory has not been prepared, the methods for disposal are all defined. CLOSED.

June 2016 The contractor has no contract with the licensed organization on the hand-over and disposal of municipal waste and construction waste

The contractor should execute a contract with the licensed organization on the hand-over and disposal of municipal waste and construction waste by end of March 2016

Completed. The subcontractors construction waste have been working since August 2016 where as the municipal waste is also dumped to the Municipality waste dumping area. CLOSED.

June 2015 The contractor has not executed the contract with the licensed organization on the hand-over and disposal of hazardous waste

The contractor should execute the contract with the licensed organization on the hand-over and disposal of hazardous waste by end of March 2016

Partially completed.

November 2015 Waste passports- normative documents (i.e.waste passports) are not kept for different waste types and classes as requested by local environmental permits for temporary facilities

normative documents (i.e. waste passports) should be kept for different waste types and classes starting April 2016

Partially completed and on-going.

June 2015 Absence of licenses/certificate for both the noise meter and for the user.

The Contractor should obtain certificate/calibration for both the noise meter and for the user or conclude a contract with a licensed laboratory to conduct noise measurements by end of March 2016.

Noise meter is calibrated and the usage is very simple not to have a special licence.

CLOSED.

November 2015 Submissions of environmental plans (i.e. Dust control plan, Noise control plan, Wastewater control plan, Pollutants spillage control plan, MSDS contents of hazardous materials, Traffic plan, Rainwater control plan, Emergency preparedness and response plan and site plan) are stil pending

The contractor should submit environmental plans (i.e. Dust control plan, Noise control plan, Wastewater control plan, Pollutants spillage control plan, MSDS contents of hazardous materials, Traffic plan, Rainwater control plan, Emergency preparedness and response plan and site plan) by end of March 2016

Submitted. CLOSED.



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3.5 ACTIONS TAKEN TO REFLECT THE FINDINGS OF ADB MISSION DURING THE REPORTING PERIOD

60. For the identified shortcomings by ADB review mission in Nov 2016, the status of corrective actions taken to reflect the findings of ADB missions are given in Table 9. As seen from Table 9 the contractor has shown substantial progress to rectify the recommendations/action plan of ADB Mission in Nov 2016.

Table 9. Status of corrective actions taken to reflect the findings of ADB missions

Date of submission

Description on non-compliance Corrective Action Required (CAR) including deadline

Performance Date/Resolutiion Status of CAR

ADB Mission in Nov 2016

The Contractor should obtain permits for KTI Welding Shop.

HDEC to obtain the permit by end of November 2016.

HDEC obtained the permits. KTI Demobilized and closed the Welding Shop by End of November 2016. CLOSED.


The Contractor should obtain permits for Soil Borrow Pit.

HDC to obtain permit for borrow pit by end of November 2016. HDC to manage the borrow pit as required (remove waste from the borrow pit), keep record of all soil taken from the pit and returned to the pit.

Borrowing soil from the soil pit is completed. There are sufficient soil piled up in Cooling Tower Area for grading and reinstatement. However the pit area should be graded by HDEC.

Not completed.

ADB Mission in Nov 2016.

Site-Specific Environmental Management Plan (SSEMP)

Should be updated. It is revised and submitted on 7th December, 2016. Pending for approval. CLOSED.

ADB Mission in Nov 2016.

NCRs Should be closed formally. Not Completed yet.



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3.6 CONSULTATION AND COMPLAINTS

61. Grievance redress mechanism is in place at the project site. The logbook is available for logging of complaints at the TPP’s entrance gate. A contact phone number and a contact email address were publicly made available at public consultation events and at the TPP entrance. Complaints will be reviewed by the TPP Environmental Management Team as part of each audit. There are no complaints received and logged on the logbook during the construction phase of the project by the stakeholders and local residents as of 31st December 2016.



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PART IV – ACTION PLAN FOR THE NEXT PERIOD

62. The contractor should conduct monitoring of environmental quality under the project during next 6 months. The specific plan for measurement is provided in Table 10.

Table 10. Monitoring Environmental Quality

Parameters Frequency of Measurements

Dust Weekly

Air emissions Daily.

Noise Weekly

Water usage record Daily and monthly total

Wastewater quality and quantity Quarterly

Potable water quality Quarterly

63. Action Plan for corrective measures for the next period is provided in Table 11.



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Table 11. Corrective Measures for the Next Period

Date of submission Description on non-compliance Corrective Action Required (CAR) including deadline

Excess NOx Emissions

The Continuous Emission Measurement System data has been included in the recent two monthly reports of HDEC. The contractual guaranteed level for NOx has been exceeded in several instances . The max level is 25 ppmvd (15% O2 Dry) where as the measured maximum is 40 ppmvd (14.37% O2 dry).

The contractor should find the reason why the guaranteed values have been exceeded in several instances and take the remedial actions to correct.


Licences and permits for borrow pit- obtaining licences and permits for borrow pit by the Contractor are stil pending since beginning of construction Works.

Poor environmental management at borrow site- Borrow site near the Project site is becoming a dumpsite.

Record of all soil taken from the borrow pit and returned to the pit

Licences and permits for borrow pit should be obtained from local authorities by end of February 2017.

The Contractor should improve environmental management at borrow pit. After completion of the operations in its certain section, the idle material should be backfilled, compacted, terraced and harmonized with the landscape by end of February 2016.

The contractor should keep record of all soil taken from the borrow pit and returned to the pit and the data should be included in monthly environmental reports of the contractor


Environmental non-compliance notices- issued by CSMM are stil pending for closure

The Contractor should respond and close officially all environmental non-compliance notices issued by CSMM by end of February 2016


Batching plant site-Poor environmental management at the batching plant site.

Cement sludge is seen everywhere an settling basins are not being used,

The Contractor should improve environmental management at the batching plant site and batching plant should be cleaned up and surface graveled by end of February 2016.

No washing of cement mixers outside the washing areas by end of July 2016

ADB Mission in Vehicle/mixer washing area- there is no oil Oil separator should be installed at vehicle/mixer washing



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Date of submission Description on non-compliance Corrective Action Required (CAR) including deadline November 2016/PMU and CSMM

separator at vehicle/mixer washing area and poor environmental management at vehicle/mixer washing area.

area and proper drainage system should be installed and wastewater should not be disposed onto ground by end of February 2016. It is recommended that the contractor should conclude a contract with TPP to accept wastewater from the vehicle/mixer washing area by end of February 2016.

November 2015 Monitoring measurement data for wastewater- normative documents for wastewater discharge monitoring ( OД-13) are not kept by the Contractor as requested by local environmental permits for temporary facilities.

They are being kept. Ongoing process and should be followed up.

November 2015 Water usage records- normative documents for watОr usagО monitoring ( OД-11) are not kept by the Contractor as requested by local environmental permits for temporary facilities

They are being kept. Ongoing process and should be followed up.

June 2015 The EIA requires that prior to the start of construction, the contractor develops an inventory of waste fractions expected to be generated during construction for the approval of disposal routes and sites by the local authorities, but the issue is still pending

The construction waste have been segregated in TPP area and the amounts are recorder. Ongoing process and should be followed up.



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ANNEXES

ANNEX 1. MONİTORİNG DATA

NOISE MONITORING DATA EXTRACTED FROM THE HDEC MONTHLY ENVİRONMENTAL REPORT OF DECEMBER 2016



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Annex 2: Monitoring data extracted from the HDEC Monthly Environmental Report of December 2016



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Annex 3: The Air Emission and Dust Control data sheet of HRSG#2 and HRSG#3 Main Stack and Bypass Stack from HDEC Monthly Environmental Report of December 20



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Annex 4: Waste monitoring data extracted from the HDEC Monthly Environmental Report of December 2016.



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ANNEX 5: SITE PHOTOGRAPHs

Pic-1. Storing of chemicals reagents at the customs

storage area

Pic-2. Storing of oil at construction site.

Pic-3. KTI workers camp

Pic-4. Vessels storing KTI.

Pic-5 storage area



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Pic-6. Bitumen preparing at the level 11.90 m of

Main Building.

Pic-7. Discharging pit after the acidic flushing

Pic-8. Storing of packing materials and boxes at

storage area

Pic-9. Car wash at the batch plant area

Pic-10. Littered formworks, metal scraps and

materials at the Cooling Tower area

Pic-11. No sewer system at Tupalang workers camp.



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Pic-12. Bitumen preparing at the PP area

Pic-13. Cleaning of FGCS fuel gas filter

Pic-14. Waste storing at PP area.

Pic-15 Pipe Rack of Unit-2 installation is completed

Pic-16. The backfilling process of the wastewater

pouring pond.

pic-17. Waste at the Condensate Polishing Plant area

P



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Pic 18 /19 Luminescent lamps are disposed separately at special containers

Pic.20 Wastes at the CCPP #3 Step-up Transformer area Pic.21 waste at the HDEC area

Documents

Environmental Monitoring Report UZB: Talimarjan Power Project · Bi-annual Environmental Monitoring Report – (July-December 2016) Talimarjan Power Project 5 PART I - INTRODUCTION