Ghorasal Polash Urea Fertilizer Project
This Environmental and Social Review Summary (ESRS) is prepared by MIGA staff and disclosed in advance of the MIGA Board consideration of the proposed issuance of a Contract of Guarantee. Its purpose is to enhance the transparency of MIGA’s activities. This document should not be construed as presuming the outcome of the decision by the MIGA Board of Directors. Board dates are estimates only.
Any documentation which is attached to this ESRS has been prepared by the project sponsor, and authorization has been given for public release. MIGA has reviewed the attached documentation as provided by the applicant and considers it of adequate quality to be released to the public but does not endorse the content.
The Hongkong and Shanghai Banking Corporation Limited (HSBC), has requested MIGA to provide a Non-Honoring of Sovereign Financial Obligation guarantee for up to US$ 450 million to support part of the debt financing for the Ghorasal Polash Urea Fertilizer Project (GPUFP) (hereafter referred to as ‘the Project’) in Bangladesh. The construction of the Project is being managed by Bangladesh Chemical Industries Corporation (BCIC) (“The Project Enterprise”), a state-owned corporation founded in 1976 and is based in Dhaka, Bangladesh.
As part of the Government of Bangladesh plan to increase the production of chemical fertilizer within the country, the Project will involve the construction and operation of a new natural gas-based urea fertilizer plant with capacity of 2,800 tons per day (tpd). The major components of the proposed Project are: (i) an ammonia plant, (ii) a urea melt plant, (iii) a urea granulation plant, iv) a water treatment plant; v) a wastewater treatment plant (WWTP) (vi) a carbon dioxide (CO2) recovery plant, and (vii) a jetty. In addition, there will be maintenance workshops and a power plant consisting of two steam turbine generator (STG) with the capacity of 32 MW each and a gas engine generator unit with the capacity of 9 MW as well as their auxiliaries and ancillaries.
The Project will be located within the existing premise of BCIC’s Polash Urea Fertilizer Factory Ltd (PUFFL) in Polash Upazila under Narsingdi district, adjacent to the Shitalakshya river and approximately 50 kilometers (km) northeast of the capital city Dhaka. The project will utilize natural gas and will have the capacity to produce 1,600 tpd of ammonia and 2,800 tpd of urea. The Project area is about 110 acres of land comprised of modified vegetation (herbs, shrubs and trees planted as landscaping) and vacant buildings. The buildings are old civil structures, which occupy 59,204 square meters (m2), including in use administrative buildings, houses, health center, warehouse, club, and canteen. An old, disused rail line and road, and an operational 132KV transmission line also run across the Project site. Natural gas, the main fuel for the Project, will be supplied by Titas Gas, a subsidiary of Petrobangla, and there are already existing pipelines servicing the existing projects Urea Fertilizer Factory Ltd. (UFFL) and Polash Urea Fertilizer Factory Ltd. (PUFFL) within the premise. At time of MIGA due diligence, BCIC did not finalize the potential timeline to demolish the two old plants (PUFFL and UFFL), but BCIC plans to be demolished once they have concrete plan and conducted a risk assessment to demolish them.
An Engineering, Procurement and Construction (EPC) contractor (a consortium of Mitsubishi Heavy Industries Ltd. (MHI) of Japan and China National Chemical Engineering No.7 Construction Company Ltd. (CC7)) has been selected to undertake the demolition of existing civil structures (excluding the PUFFL and UFFL plants), construction of the new plants and its pre-commissioning and commissioning phases. After the pre-commissioning, commissioning and PGTR (Performance Guarantee Test Run), the project will be handed over to BCIC for operation with a 12 months warranty period with MHI. In addition, MHI will provide technical training to BCIC operators, engineers and teams during pre-commissioning and commissioning. MHI is the consortium leader and will provide overall project management, technical expertise and engineering while CC7 will oversee procurement and transportation of heavy machinery, equipment and construction materials, demolition of civil structures and site preparations, construction of the plants, hiring of workers and establishing workers accommodations facilities. The Project construction period is expected to be 39 months including commissioning provisionally starting on September 2019.
BCIC has a plan to construct about 13 km long railway line to connect the Project to the main railway line at a junction point (Ghorasal /Jinardi). BCIC will request the Bangladesh Railway Authority to build the new railway line within the project time and BCIC will fund its construction (the new project and the railway line will be constructed simultaneously). This will be treated as an associated facility, as the railway is not funded as part of the Project finance from the lenders covered by MIGA, but it would not have been constructed without the Project. The construction and completion of the railway is critical to the project as a corridor to transport the urea fertilizer to other parts of the country. The Bangladesh Railway Authority will be operating the railway line. BCIC does have leverage but doesn’t have control over the railway operation.
HSBC is lead arrangers for financing of the MIGA guaranteed facility for the Project. HSBC is an Equator Principles Financial Institution (adopting IFC Performance Standards), and as part of this commitment, it has commissioned independent technical and environmental consultants (IESC), Mott MacDonald Private Ltd., to undertake Project environmental and social (E&S) due diligence. The E&S due diligence review was done against national laws, IFC/MIGA Performance Standards, and the World Bank Group (WBG) Environmental, Health and Safety (EHS) Guidelines.
If Project design and plan changes from ones shared with MIGA at due diligence and presented in this review summary, BCIC will provide additional information, MIGA may update the Environmental and Social Review Summary (ESRS) and if needed, ESAP action items may be added. Such information disclosure will be governed by MIGA Access to Information Policy.
The Project is classified as Category A project according to MIGA’s Policy on Environmental and Social Sustainability (2013). E&S risks and impacts associated with the Project are mostly related to potential legacy and cumulative impacts associated with the location of the Project within an existing fertilizer plant in an industrial area. The Project poses potential significant adverse environmental or social risks and/or impacts that are diverse, irreversible, or unprecedented. It is expected that most of the Project-specific risks and impacts can be addressed through the implementation of applicable Performance Standards (PSs), E&S Management plans and procedures, Environmental Health and Safety (EHS) guidelines and / or design criteria.
The key E&S risks and impacts include: 1) the BCIC’s E&S management, capacity and monitoring systems covering demolition of civil structures and old buildings, construction and operation of the plant; 2) occupational health and safety issues; 3) risks associated with labor and working conditions including labor influx; 4) emergency preparedness and response; 5) life fire, and safety; 6) noise and air emissions (including greenhouse gases); 7) airshed pollution; 8) water usage and effluent discharge; 9) handling, storage and use of hazardous material (Asbestos); 10) contractors and subcontractor management; and 11) traffic management. Additional risks are also associated with the project including land acquisition and resettlements risks that could be related to the rail, stakeholder engagement and effective grievances mechanism, use of armed security forces as well as general community health and safety.
While all Performance Standards (PSs) are applicable to this Project, current information indicates that the proposed Project will have impacts which must be managed in a manner consistent with the following PSs:
- PS1: Assessment and Management of Environmental and Social Risks and Impacts
- PS2: Labor and Working Conditions
- PS3: Resource Efficiency and Pollution Prevention
- PS4: Community Health, Safety and Security
- PS5: Land Acquisition and Involuntary Resettlement
PS6: The Project area is heavily modified and the Shitalakshya River, adjacent to the Project, is critically polluted from effluent discharges from the chemical plants upstream of the Project per the Environmental Impact Assessment (EIA) baseline studies. The Project is not expected to have an impact on natural or critical habitats, ecosystem services or species of conservation significance, and therefore, PS6 does not apply.
PS7 and PS8 are not triggered since there are no potential impacts on indigenous peoples and cultural heritage.
In addition, the WBG EHS General Guidelines and Guidelines for Nitrogenous Fertilizer Production and Thermal Power Plants will apply to this Project.
MIGA E&S due diligence of this project consisted of reviewing and discussing the following documents:
- Inception Report on Environmental Impact Assessment (EIA) of Ghorasal Polash Urea Fertilizer by CEGIS dated November 2018.
- Feasibility Study of new industry and of all running Fertilizer Factories of BCIC by CEGIS dated March 2019.
- Environmental Impact Assessment (EIA) of Ghorasal Polash Urea Fertilizer by CEGIS dated March 2019.
- Environment, Health and Social Summary and Environmental and Social Action Plan report for BCIC Ghorasal Polash Urea Fertilizer by Mott MacDonald’s dated May 15, 2019.
In addition to the documents listed above, MIGA E&S due diligence of the Project focused on the BCIC’s and EPC’s capacity to manage environmental, social, health and safety (ESHS) risks and compliance with the Bangladeshi regulatory requirements and MIGA’s PSs, as well as review of other available E&S information about the area near the Project. MIGA also conducted a site visit on April 23-25, 2019, which comprised visiting existing plants (UFFL and PUFFL), the new plant site, and meetings with Government of Bangladesh (GoB), Ministry of Industries, BCIC, Ministry of Environment and Forests, communities (Khanepur) living close to the project, HSBC, the IESC, and the EPC contractor. Moreover, MIGA team held additional meetings with Ministry of Industries and BCIC to discuss Project E&S risks and impacts and conducted a site visit to the Project on July 18-19, 2019.The findings of the site visit are incorporated into this ESRS.
Key E&S issues associated with the Project business activities are summarized in the paragraphs that follow.
PS1: Assessment and Management of Environmental and Social Risks and Impacts
Identification of Risks and Impacts
In order to address project-specific impact assessment requirements, the EIA for the project, dated March 2019, was prepared by a local consulting company, the Center for Environmental and Geographic Information Services (CEGIS) in accordance with the Bangladesh Department of Environment (DoE’s) guidelines and the WBG EHS Guidelines. The EIA covered the construction and operation phases of the project and identified and assessed the potential E&S risks and impacts associated with the Project. The EIA also provided management, mitigation and enhancement measures. Key risks, issues and proposed management measures are discussed in the sections below under the appropriate PSs. The Department of Environment (DoE) has approved the EIA on July 8, 2019 and some of the permits conditions include:1) Project shall not pollutant. 2). air and water quality monitoring system should be made functional throughout the life of the plant.3) Project will implement mitigations measures during Project construction and operation 4) Cultural heritage sight and ecological critical areas will be protected and avoided during project construction phase 5) Construction works shall be restricted to day time hours 6) Proper and adequate sanitation facilities shall be provided within the project and labor camps 7) Proper and adequate on-site precautionary measures and safety measures will be implemented etc. DoE permit conditions will be part of MIGA E&S conditions.
As mentioned earlier, an independent E&S Due Diligence review was undertaken by Mott MacDonald and included a gap analysis of the EIA against, Government of Bangladesh (GoB) regulations, IFC/MIGA PSs, the WBG EHS General Guidelines, and Guidelines for Nitrogenous Fertilizer Production and Thermal Power Plants, and the Equator Principles. The review also included other documents for review as the feasibility study provided by BCIC and the EPC contractor, as well as a site visit in April 2019. The gap analysis identifies Project risks and impacts and evaluates the potential effectiveness of the proposed management measures. MIGA prepared an Environmental and Social Action Plan (ESAP) to address the identified gaps (see attached and actions identified in the relevant sections below). It is expected that the outstanding issues will be addressed by BCIC and the EPC Contractors to ensure consistency with MIGA’s PSs. Key gaps include: i) lack of risk assessments for the hazardous materials (asbestos) handling and disposal; ii) gaps on working conditions per MIGA PS2 requirements; iii) risks associated with armed security guards; and iv) pollution legacy issues including, airshed, watershed and soil pollution and, sources of pollution.
Any additional E&S risks and/or impacts because of the considered railway line construction will be reflected in an updated ESAP in line with the requirements of the MIGA Access to Information Policy.
In addition, there is lack of clarity as to when BCIC plans to demolish and dismantle the two old fertilizer plants (PUFFL and UFFL) that are decommissioned and closed within the project site as of February 18, 2019 and July 02, 2019 P respectively. BCIC has already formed a technical committee to study the options, process and budget for dismantling of the two old plants. BCIC will incorporate MIGA’s PSs in the plans for dismantling these plants and share with MIGA for review. Once BCIC confirms the demolition process plans and timelines, BCIC will hire an experienced, qualified and competent company to demolish the old plants, manage all the E&S risks including the occupational health and safety risks, disposal of solid and hazardous waste (e.g. asbestos) in line with MIGA requirements per the ESAP. The Lenders’ Technical independent engineer will be tasked to oversee and supervise the demolition to ensure it meets MIGA’s and lenders’ requirements. MIGA also recommended that BCIC demolish the plant after the new plant is constructed and operational to minimize further risks to workers and communities. Moreover, BCIC confirmed that the two old plants will be secured to ensure that no visitors, workers’ families or unauthorized personnel can access the site without prior BCIC authorization and approval.
Risks related to changes in climate could potentially impact project operations leading to higher maintenance and operational costs. Based on available documentation and climate change projections, vulnerabilities related to a changing climate in the Project area include changes in frequency and intensity of fires, cyclones, and increased flooding events. Specifically, for the Project, identified climate risks could have significant impacts on the performance of project infrastructure and utilities. Climate impacts could also result in damage to the structural integrity of buildings and riverbank erosion due to increased flooding. A high-level climate risk and vulnerability screening was carried out for the Project area by the independent technical consultant. Per the ESAP, BCIC will carry out a comprehensive climate risk vulnerability assessment for the project and consider opportunities to enhance resilience of the Project components.
The EIA details the cumulative impact of industries around the proposed Project. Nineteen (19) industries having potentially significant impacts were identified in the EIA in the immediate vicinity of the Project. These industries include power plants, sugar mills, textile, chemical and fertilizer plants among others. The existing airshed and watershed in the vicinity of the Project is highly degraded. Further details of pollution is under respective section of PS3.
Since the new Project will be developed in an area with degraded air and watershed, as per the ESAP, BCIC will need to hire consultants to conduct a cumulative impact assessment study that details the extent of impacts from the two existing fertilizer plants, the proposed new Project, and other plants’ impacts in the surrounding area and BCIC will implement the CIA study outcomes and proposed action plan to address the potential impacts around Project area influence.
Environmental and Social Assessment and Management System
BCIC does not currently have a formal Environmental and Social Management System (ESMS). However, the BCIC is planning to develop and maintain an ESMS; including an E&S policy and procedures supported by detailed monitoring and recording systems and training. As per the ESAP, BCIC will require EPC Contractors to develop and implement a Project -specific ESMS for construction that conforms with Bangladesh Laws, and MIGA/IFC PSs as well as applicable WBG EHS guidelines. In addition, prior to the plant commissioning, BCIC will develop and implement an ESMS for the operations phase in accordance with the requirements of PS1 per the ESAP. BCIC will submit to MIGA the Project ESMS manual and the E&S Management plans for construction and operations once developed and completed for review and approval.
The EPC contract is a key tool for ensuring compliance with the ESHS requirements of the BCIC. BCIC will require that the EPC contract/addendum includes specific requirements to comply with MIGA’s PSs and provide of resources for E&S management, monitoring and compliance of its subcontractors per the ESAP. Subcontractor and supplier contracts will also reference MIGA’s PS were applicable.
Organizational Capacity and Competency
The EPC Contractors, experienced in the construction of large-scale ammonia/urea fertilizer plants, will be responsible for managing all the Project’s E&S risks and impacts during construction, including implementation of the monitoring program and the preparation of monthly construction reports. BCIC will require the EPC Contractors to appoint a qualified Quality, Health, Safety, and Environmental (QHSE) Manager and additional environmental officers, health and safety (EHS) staff and engineers during Project construction and commissioning phase and BCIC will appoint a QHSE manager and additional environmental officers, health and safety (EHS) staff and engineers as required to manage Project E&S risks and impacts during construction in line with the requirements MIGA PS1. In addition, as per ESAP BCIC will appoint a qualified QHSE manager to and additional environmental officers, health and safety (EHS) staff and engineers as required to manage the Project E&S risks and impacts during operations phase. During construction, the EPC Contractors’ QHSE manager will ensure all contractors and subcontractors adhere to EHS protocols and the ESMS. The QHSE manager will be supported by EHS staff, as required, to manage the E&S risks identified. The EPC Contractors are responsible to ensure that all their personnel and subcontractor ’s personnel are well-trained and experienced to perform their jobs and responsibilities prior to construction.
The EPC Contractors’ QHSE Manager and its team will also collaborate with the construction and technical teams to ensure all the E&S risks are managed adequately. BCIC will require the EPC Contractors QHSE Manager to conduct hazard analysis identifying critical control points and preventive measures; establishing critical limits, monitoring procedures, corrective actions, and verification procedures prior to construction per the ESAP. In addition, the EPC Contractors’ QHSE Manager will ensure that all the contractors and subcontractors meet the agreed E&S standards and adequately implement the Environmental, Social, Health and Safety Management Plans (ESHS MP) per the contractual agreements.
BCIC Project Director and HSE team will need to have strong oversight of the EPC Contractors and its subcontractors during the construction phase to ensure that they meet their contractual E&S obligations. As indicated above, BCIC will appoint a QHSE manager and/or EHS officer to oversee the new plant construction activities and during the operation of the plant BCIC will appoint an QHSE manager and required EHS team that will be responsible in effective implementation of the Project ESMS and manage EHS risks. The ESMS will include an E&S training plan for the staff.
BCIC will commercially operate the plant after MHI’s successful pre-commissioning, commissioning and Performance Guarantee Test Run (PGTR). As mentioned earlier, during pre-commissioning and commissioning process, MHI will provide technical training and build the capacity of BCIC operators, engineers and teams. These technical trainings are essential to enable them to manage and operate the plant effectively. BCIC QHSE Manager and the team will manage project EHS risks during operations in collaborations with plant’s Project director, managers, technical engineers, supervisors and workers to ensure that EHS risks are managed effectively and non-compliances corrected in a timely manner within their respective units. Moreover, the BCIC plant manager will ensure that workers understand the E&S requirements, measures, and protocols stipulated within the procedure and plans through trainings and on job trainings.
As part of MIGA’s support for the Project, BCIC will ensure that ESHS risks and impacts identified in the EIA are appropriately addressed in the Project’s ESMS. As per ESAP, the ESMS to be developed will includes management plans and procedures to address construction and operation existing ESHS impacts and risks from the Project and assigns clear responsibilities to the EPC Contractors and BCIC EHS team. As part of this, the ESHS MP will be further developed into a clear plan of actions for the identified risks/impacts with assigned responsibilities and deadlines. The ESHS MP will include specific plans related to: construction management plan, traffic management plan, facilities demolition plan, waste management plan (non-hazardous and hazardous materials), Response; Emergency Preparedness and Response plan, water management plan, wastewater management plan, noise management plan, air quality management plan, labor influx and workers accommodation plan. During construction, the ESHS MP will be implemented by the EPC Contractors and their subcontractors with strong oversight from BCIC. The EPC Contractors shall also conduct a systematic detailed risk assessment and risk management for construction stage and develop mitigation measures. The management plans will also include details on monitoring actions, and the frequency of monitoring, along with the performance indicators. BCIC will submit to MIGA the Project E&S Management plans for construction and operations once developed and completed for review and approval.
BCIC and the EPC Contractors will ensure that workers understand the requirements, measures, and protocols stipulated within the management plans through induction training and a workers’ manual that is translated into Bengali, Chinese and English. It will also ensure that all E&S personnel are competent to carry out their duties through the hiring and selection process, or, where necessary, arrange for suitable training to be undertaken to achieve this level of competency.
Emergency Preparedness and Response
As part of the ESMS, BCIC will require the EPC Contractors to develop and operationalize an Emergency Preparedness and Response Plan (EPRP) during the construction and the building/civil structures demolition and BCIC will develop a comprehensive Emergency Preparedness and Response Plan (EPRP) to address the facility wide risks including fire and other external emergencies during operation as per the ESAP. The EPRP shall articulate the steps needed to collaborate with nearby communities, local government agencies and other, relevant third parties to facilitate response to emergency situations and to prevent and mitigate harm to people and/or the environment. In addition, the EPRP will detail emergency response procedures in the event of fire/explosion, severe traffic accidents, natural disasters, earthquakes, hazardous material spills, floods, and violence and/or social unrest. The plan will include: broad response principles; a description of roles and responsibilities; and the chain of command; site-specific management and response procedures under different emergency situations and awareness training. A clinic and first aid station will be provided on site during construction and operations.
Potential fire and/or explosion are major emergency risks for the Project’s construction and operations, and therefore, as per the ESAP, BCIC will require the EPC Contractors to develop comprehensive Life, Fire and Safety (LFS) manual/procedure in line with national requirements, MIGA PSs and WBG EHS guideline. BCIC will also develop LFS manual/procedure and implement it during the plant operation phase. BCIC and EPC Contractors shall ensure that all the Project facilities are equipped with fire and smoke detection systems, fire cabinets, foam systems, automatic shut-down systems for the plants, as well as fire hoses and extinguishers that are functional, well maintained and controlled as per the requirements of the WBG General EHS guidelines.
Monitoring and Review
During construction and commissioning, the EPC Contractors will undertake regular on-site EHS monitoring of the implementation of key ESHS plans and programs. The EPC Contractors shall systematically report all the findings to BCIC in a timely manner and will ensure that all identified correctives actions are implemented effectively and well documented. MIGA will also require periodic monitoring reports that will evaluate the performance of the Project against MIGA’s E&S requirements and will include sections on E&S risks and impacts, updates of the Project and development indicators throughout the guarantee period. The Lenders will continue to be supported by the IESC who will carry out independent site visits and supervision periodically during the Project construction and operations to monitor the implementation of the Project-specific ESMS, ESHS MPs and the ESAP.
During the operation phase, BCIC EHS teams will monitor key environmental aspects that includes solid wastes, hazardous waste materials management, occupational health and safety, life and fire safety equipment maintenance, energy use, water usage and report to BCIC Management and relevant regulatory authorities as required. As mentioned above, BCIC will be required to prepare and submit to MIGA periodic E&S monitoring report.
PS 2: Labor and Working Conditions
Currently BCIC have approximately 885 employees in the existing two old fertilizer plants (PUFFL and UFFL). PUFFL has been closed and decommissioned already while UFFL is currently non-operational. PUFFL plant retained 74 employees that are responsible to manage BCIC’s administrative, finance and security issues at the site. UFFL plant currently have approximately 811 employees. Since UFFL shut down, BCIC confirmed that all the employees will be transferred to other BCIC plants and no one will be retrenched although the reassignment of staff to other BCIC locations may take some time to complete. BCIC starts discussions with UFFL employees on the plant closure and transfer the workers to other BCIC plants as soon as there is a clear workforce transition plan. In addition, BCIC has already discussed with the workers labor union representatives on July 23, 2019 on the plant closure plans and the employees transfers process.
The EPC Contractors are expected to have around 400 workers including unskilled, skilled, supervisors, engineers, management staff of local and expatriates during the demolition stage; around 600 during site preparation; and around 4,000 during construction. The 126 existing employees of BCIC will also be deployed during the construction and commissioning phases. BCIC will hire 842 employees during the operation of the Project.
Human Resources Policies and Procedures
BCIC will require the EPC Contractors to develop Human Resources (HR) policy and procedures that are Project specific during construction and commissioning in line with the requirements of Bangladesh Labor Law (2006, amended 2013) and MIGA PS2 per ESAP. The EPC Contractor will ensure that all direct and indirect employees are aware of its content. BCIC will also ensure that EPC apply these to their sub-contractors. Moreover, BCIC will develop and update its HR policy and procedure for operations to ensure they are in line with MIGA’s PS2 and with Bangladesh Labor Law (2006, amended 2013) per the ESAP. Training workers on the HR policy and procedures is to be included in the EPC Contractors’ procedures. In addition, as per the ESAP, BCIC will require the EPC Contractors to develop Project Code of Conduct for all employees and applied to the subcontractors during construction phase and BCIC will develop Project Code of Conduct for all employees during the operations phase. EPC Contractor’s HR policies will be applied to their workers and subcontractors; as the subcontractors will likely be responsible for hiring workers, it is important that they implement their HR policy and procedures in line with the Code of Conduct.
Once construction and commissioning are complete, the operation of the plant will be managed by BCIC. BCIC will have a total of 968 employees who will be working for the new plant. BCIC currently has 126 employees and additional staff of 842 will be hired for the new plant. BCIC staff will be governed by the updated BCIC HR policies and procedures.
Working Conditions and Management of Worker Relationship
All employees will sign the term of employments with the EPC Contractors or their respective subcontractors. The HR policy and procedures will stipulate that the terms of employment, such as wages and benefits, hours of work, overtime arrangements and overtime compensation, annual and sick leave, maternity leave, vacation and holiday, health insurance and end of service benefits are established according to national labor regulations and PS2 requirements. These conditions will also be included in employee contracts. This policy will be handed out to all new hires together with an employment contract which outlines the terms and conditions of their employment as part of the hiring package and the policy made visible in the workers campsite. Working conditions including health, safety and security, employee termination, prohibition of forced or child labor, disciplinary actions, workers’ rights and obligations, employer’s rights and obligations will also be referenced.
The EPC Contractors plan to provide Project specific arrangements for workers’ accommodation. Therefore, as per the ESAP, BCIC will require the EPC Contractors to develop a worker’s accommodation plan for the construction stage prepared in line with the IFC and EBRD Guidance Note on Worker’s Accommodation: Processes and Standards. Accommodation services will be provided in a manner consistent with the principles of non-discrimination and equal opportunity and will not restrict workers’ freedom of movement or of association. For the operation stage, BCIC will update all its policy and accommodation requirements and will be included in the updated policies and procedures.
BCIC will require the EPC Contractors to develop and make available a worker grievance mechanism during the construction and BCIC will develop a worker grievances mechanism during operation phase in line with MIGA PS2 requirements per the ESAP. The EPC Contractors will inform all their workers of the grievance mechanism and provide training and information on how to use the workers grievances mechanism for the construction phase. Moreover, BCIC will inform all their employees of the grievance mechanism and provide training and information on how to use the workers grievances mechanism for the operation phase. The grievance mechanism will be accessible to other contractors and subcontractors performing work in core business processes of the Project. The grievance mechanism will also clearly define the response timeframes to grievances and incorporate a grievance log.
In line with PS2, BCIC and EPC Contractor’s HR policies will not impede workers from freedom of association and collective bargaining. Workers will be able to organize among themselves and will not be intimidated, punished or discriminated against for doing so. If workers are unionized, BCIC and EPC Contractors will communicate with workers’ organization’s and their representatives.
Non-discrimination and Equal Opportunity, Protecting the Work Force
BCIC is committed to avoid all forms of discrimination against its employees (including age, gender, sexual orientation, health, race, nationality, political opinions or religious beliefs). The requirements of non-discrimination and equal opportunities will be extended to all contractors and subcontractors as part of their contractual obligations to BCIC. BCIC’s HR policy will exclude the use of any form of forced or compulsory labor, in accordance with national law and MIGA PS2 requirements.
The EPC Contractors will ensure to train all workers including subcontractors on HR procedures and Occupational health and safety among others. Induction training on the HR policy and procedures and basic safety awareness training will be provided to all newly hired workers. Other types of technical skills training will be identified for staff on an as-needed basis. EPC Contractors will regularly conduct toolbox training sessions for its workers during the construction of the Project.
Child and Forced Labor
BCIC and EPC Contractors shall ensure they do not employ forced labor or children for the Project in line with the Bangladesh Labor Law and MIGA’s requirements. In addition, The EPC Contractors will conduct verification of workers ID/birth certificates to ensure all workers are of legal age. Through the contractor management plan, the EPC Contractors will have strong oversight over their subcontractors to ensure this is enforced strictly.
Workers Engaged by Third Parties
BCIC and the EPC Contractors will ensure that the third parties who engage workers are reputable and legitimate enterprises and have an appropriate environmental management system that will allow them to operate in a manner consistent with the requirements of MIGA’s PSs. BCIC will establish policies and procedures for managing and monitoring the performance of the EPC Contractors and third-party in relation to MIGA’s PSs as well as incorporate these requirements in contractual agreements with such third-party per the ESAP.
Occupational Health and Safety
The EIA identified key occupational health and safety (OHS) risks during construction that include slips and falls, working at heights, potential hazards from on-site moving machinery, trucks, handling hazardous materials, heavy load lifting, exposure to electric shocks and burns, and other related safety issues. As per the ESAP, BCIC will require the EPC Contractors to develop, as part of their ESMS, Project-specific OHS procedures for construction phase. These procedures and work systems permits will cover the following issues: hazard identification and assessment; the construction site safety; specific procedures for hazardous works; worker’s safety and training plan; personnel qualification; limitations and equipment need (e.g. personal protective equipment); site supervision and audit procedures; incident reporting system as well as intervention measures (first aid, etc.).The procedure will be designed to be specific to the terms of industry-specific hazards and the Project site. The OHS procedures will also be linked with the Project-specific EPRP which will include fire risk assessment and control systems, fire alarm systems and drills, emergency preparedness and planning, as part of OHS Procedures for both the construction and operation phases.
BCIC will also ensure that the EPC Contractors assess, track and record their OHS performance during construction. The EPC Contractors QEHS Manager will record and track any OHS incidents through an incident tracker and will include OHS performance in its monthly reports to BCIC during the construction phase. In addition, BCIC’s QEHS manager and teams will also be mandated to carry out monitoring of sites and workers’ accommodation and hold site meetings with safety officer to discuss health and safety improvements, compliance with Personal protection equipment (PPE) requirements and other OHS issues as they arise.
During Operations, BCIC’s QEHS Manager and EHS teams will manage the plant OHS and all related E&S risks. As per the ESAP, BCIC will develop as part of their ESMS Project-specific OHS procedures during operations and implement it effectively. Moreover, a permit to work system will be established to ensure during operations, potentially hazardous work is carried out safely. All workers will be provided with basic health and safety training during induction, including use of appropriate PPEs. Additional job-specific training will be given to workers on how to conduct tasks with specific health and safety risks such as operating machinery, handling hazardous chemicals, operating high risks plants (ammonia plant), managing and operating wastewater treatment plant (WWTP) etc... BCIC’s EHS team will maintain a record of occupational incidents (including near misses), accidents, and traffic incidents, diseases and that corrective measures are taken to prevent recurrence.
PS3: Resource Efficiency and Pollution Prevention
As mentioned earlier, legacy pollution, potential pollution and hazardous waste management are key E&S risks and impacts of the Project. Pollution include air, water quality, soil, noise and solid and hazardous waste includes asbestos. Several environmentally friendly components and technologies have been considered for the proposed GPUFP, such as, closed cycle cooling, water/effluent treatment system, energy, water and air efficient technology.
The new plant is located in a degraded airshed and the emissions from the recently closed two BCIC fertilizer plant (PUFFL and UFFL) are the main sources of the emission within the Project area of influence. Per the EIA baseline, the particulate matter (less than 10 microns PM10 and less than 2.5 microns PM2.5) and Nitrogen Dioxide (NO2) are in high concentration and exceeds national and international standards. The ambient air quality baseline data indicated that the ground level concentration (GCL) for PM2.5 and PM10 are 208 micrograms per cubic meters (μg/m³) and 300 μg/m³ 24-hour mean respectively which significantly exceeded the WHO guidelines limits (25 μg/m³ and 50 μg/m³ respectively) during the winter months (October to March.). However, the concentration of ambient air for PM2.5 and PM10 is 28 μg/m3 and 52.8 μg/m3 24-hour mean respectively which are within Bangladeshi national standards and are slightly above the WHO guidelines limits in the rainy season (March to October) because of rain water that flushes the concentrations in the air. In addition, the EIA baselines assessment also concluded that the two old plants discharge Ammonia (NH3) contaminated water into the lagoon adjacent to the two old fertilizer plants and has created significant impacts to ambient air quality, the aquatic life and communities living around the lagoon. The maximum background concentration of NH3 in the Project area is found to be 733 μg/m³ for 24-hr averaging period which will be increased utmost 753 μg/m³ and are above the WBG EHS Guidelines.
In order to predict the air pollution during operation of the proposed Project, an air dispersion modeling study has been conducted which includes 20kmx20km grid with one-hour interval annual atmospheric data, topographical effects, land use and land cover status without considering cumulative impacts of the PUFFL and/or UFFL and the area. Per the EIA, the United States Environmental Protection Agency (US EPA) regulatory model AERMOD was used to predict the effects of air pollutants (NO2, NH3 and PM10) on the ambient air quality in the airshed during operation of the new Plant only. During operation, the major sources of emissions are the stacks of boiler, catalyst-filled reformer tubes and granulation unit. Stack emissions would primarily be comprised of NO2, PM10, and NH3. During operation period, the maximum ground level NO2 for 1-hr and annual averaging are predicted to be 141.4 μg/m³ and 4.7 μg/m³ respectively. This will be within the WHO guidelines values (200 μg/m³ and 40 μg/m³ for 1-hr and annual average respectively). In addition, granulation stacks are the key sources of emission of PM10 into the ambient environment. During operation stage PM10 will contribute maximum 7.8 μg/m³ for 24-hour mean and 1.8 μg/m³ for annual mean at the ground level which is within the national and WHO limits. Since the natural gas of Bangladesh contains negligible percentage of Sulphur, formation of Sulphur Dioxide (SO2) is not anticipated. As mentioned above, the ESMS for the EPC Contractors will include an ambient air quality management plan to monitor and mitigate emissions of air pollutants.
Based on available information, MIGA concludes that legacy air pollution to the airshed exceeds the emission parameters in WBG EHS Guidelines. MIGA had meetings with BCIC on July 18, 2019 to discuss with BCIC on the Project E&S related risks and the UFFL plant operation status and BCIC confirmed that the UFFL plant will be permanently shut down, decommissioned and secured and will no longer produce fertilizers. To further assess E&S risks and impacts, MIGA will engage an air quality modelling consultant to conduct Project air quality assessment, establish baseline conditions and run air modelling scenarios to assess and document the E&S risks and impacts as well as identifying appropriate mitigating measures in accordance with MIGA’s requirements. As per the ESAP, BCIC will be required to fully implement the actions items, recommendations including mitigation measures from the air quality modelling study to meet MIGA requirements. As a result of the study outcome, the ESAP will be amended to include the specific recommended action items and mitigation measures to be implemented by BCIC as agreed.
During construction, the primary air emissions from the Project are likely to be dust (PM10) resulting from heavy machinery movement. However, this impact will be limited to the construction phase and the EPC Contractors will put in place mitigation measures to minimize dust generation
During Operations of the new plant, BCIC will also be required to develop an air ambient quality monitoring system to monitor NO2, PM10 and NH3 and address any potential pollution issues if any in line with the requirements of PS3.
Diesel generator (with capacity of maximum of 400KW each for 10 to 15 machines with, expected operation time of 10 hours/day) will be required during construction. The operation of this generators will impact air quality locally and require fuel management including fuel storage tanks that will be above ground with secondary containment in case of spills. EPC Contractors have a generator management plan that defines fuel use, regular maintenance and provision of adequate measures for air quality (such as the use of air filters), noise control and waste management. As per the ESAP under PS1, BCIC will require the EPC Contractors to develop environmental management plans and/or procedures for operations (as part of the Operational Element of the ESMS) relevant to the Project site to manage pollution related aspects of the Project in line with the WBG’s EHS Guidelines. Aspects should cover, among others dust, management of waste, hazardous materials, spills, occupational noise, etc.
Water and wastewater Management
For the operations phase, Water requirements for the Project have been estimated to be 0.5667 cubic meters per second (m3/s), for plant operation and cooling water systems, boiler and cooling blow down, which is less compared to water usage of old existing plants (UFFL and PUFFL) at 1.65162 m3/s, and 275 m3 potable water per day for construction phase. The plant cooling water will be drawn from the existing water intake on the Shitalakshya River. However, the water extraction permit is pending approvals from WARPO (Water Resources Planning Organization). The Project will construct a water treatment unit to treat the water extracted from the river before the water is used for Project. Raw Water Intake facilities will be located on the east bank of the Shitalakhya River. The raw water is pumped to settling basins located in the Jetty area and transferred to the Raw Water Storage Tank through the pipeline of about 1.1 km long. Raw water will be received in Intake Section from the Shitalakhya river at an amount of about 0.567 m3/s (2040 t/h) and stored in Raw Water storage Tank. Raw water from Storage Tank will be transferred to Raw Water Clarification and Filtration Unit at an amount of about 0.322 m3/s (1159 t/h). After clarified the net consumable water will be about 0.283 m3/s. Raw Water Clarification and Filtration Unit shall be capable of producing filtered water for Fire Water; Cooling Water Make-up, Potable Water, Service Water and Demineralized Water Unit Feed. Raw Water Clarification and Filtration Unit consists of the clarifier and sand filter Most of the water used will be recycled/in closed circuit, and only a small amount of contaminated water will be discharged into the new wastewater treatment plant to be constructed. The Waste Water Treatment System (WWTS)/Effluent Treatment Plant (ETP) with expected capacity of 257 m3/hr will be constructed and installed at the eastern side of the PUFF plant. Per the EIA, it is estimated that the environmental flow of the Shitalakhya River is about 92.2 m3/s and average dry season flow is about 83 m3/s. The water requirements for the Project have been estimated to be 0.5667 cubic meters per second (m3/s), the water extraction from the river for the Project will have no impacts to the communities within the project area of influence.
The EIA provides a baseline of hydrological conditions in the Shitalakshya River, the only surface water source that flows adjacent to the site. Average discharge in the river ranges from about 80 m3/s during the dry season and approximately 1,100 m3/s during the monsoon. The average maximum and minimum water level vary seasonally from 1.24 m Public Works Datum (PWD) to 5.86 m PWD respectively. The highest water level was recorded 7.84 m PWD in 1988, which was an extreme flood event in Bangladesh. The site is impacted by heavy precipitation events during summer monsoons, as is near the river, and the site elevation ranges from 7-12 PWD, the site is potentially vulnerable to riverine flooding. This can potentially be exacerbated by climate change impacts as there is good agreement across climate models that the region will see a significant increase in the frequency and intensity of extreme precipitation events in the near to mid-term future. The river inundates nearby agricultural lands during the monsoon and remains navigable year-round. The tendency of the river erosion is very low.
The average depth of the tube-wells around the Project site is 61 m (200 ft). As currently planned, groundwater resources will not be affected by the abstraction of water for the Project and the withdrawal of water from the Shitalakshya river in the dry season for the Project will not have significant impact on the flow and aquatic species of the river and should not generate tension with other river water users.
The EIA baselines assessment concluded that the wastewater from the fertilizer factories is disposed in the lagoon adjacent to the two old fertilizer plants and has created significant impacts to ambient air quality, the aquatic life and communities living around the lagoon. Communities also confirmed that as a result of pollution the fish quantities have declined sharply in the river. The two old plants injected and discharged ammonia (NH3) mixed water into the lagoon and after dilution and settling down, the contaminated water is discharged directly into the Shitalakhya River without further treatment. In addition, as a result of the water discharge to the lagoon that is not lined, there is a high possibility of water and soil contamination. Although BCIC have started infilling the lagoon with soil, there are no current studies to determine the level of contaminations for water and soil and baseline water quality in the lagoon and Shitalakshya River within the Project area of influence. As a result, MIGA will engage a consultant to conduct water quality (surface and groundwater) and soil contaminations assessments and provide detailed mitigation measures for remediation and treatment. As per the ESAP, BCIC will be required to implement fully the consultant’s recommendations including appropriate remediation/mitigation measures (this may include soil contamination cleaning) based on consultant’s findings and conclusions to meet MIGA requirements.
To minimize the impact of water abstraction and effluent discharge on the Shitalakshya River, as per the ESAP, BCIC will require the EPC Contractors to develop a detailed water management and monitoring plan during the construction phase and BCIC will develop one for the Project operation phase. The water management plan for the Project will also include information on water quality testing and water quantity estimates. In addition, water use will be a key performance indicator (KPI) and reported periodically to MIGA as part of the Project performance. EPC Contractors will be required to monitor water use and include information on water quality testing and water quantity estimates.
During the construction phase, there will likely be generation of about 2,400 m3 of sewage/ organic solid waste and generation of solid waste (kitchen waste) of about 1,500 kilograms per day (kg/day) for about 4,000 workers and Project team to be generated from the official dorms and labor camp. The EPC Contractors will have overall responsibility for the management, collection and disposal of sewage and other wastewater from the sites and will develop wastewater and effluent treatment facilities. During construction and operations, BCIC and EPC Contractors will ensure that the effective management of wastewater is done per local laws and MIGA requirements.
Per the EIA, the ambient noise levels were measured at 14 locations including 13 sensitive receptors inside and outside PUFFL, including schools, shops, residential areas and mosque that are close proximity to the Project. Noise levels varied between 48.1 decibels (dBA) to 78.1 dBA during the day time and between 42.7 dBA to 65.7 dBA during night time. The noise levels inside the PUFFL residential area currently exceed the standard levels for day time and night time in the WBG EHS General guidelines.
Noise and vibration are primarily related to the construction phase activities, such as demolition of existing civil structures/building and equipment, crushing of stones and bricks, installation of machines and equipment, using heavy machinery, and increased vehicles in the area. During operations, the Project’s ammonia plant, urea plant, granulation plant, Regulating Metering Station (RMS), gas pipes, and steam turbine are the major components of the Project that are expected to generate noise impacts. BCIC will require the EPC contractor to develop the noise management plan a noise monitoring system and implement measures to manage and minimize noise levels during construction phase and BCIC will develop the noise management plan and a noise monitoring system for operations phase per the ESAP. The noise management plan will include all the potential noise sources, noise impacts and appropriate noise reduction measures and consideration which will be incorporated into the final Project design.
Solid and Hazardous Waste Management
The construction phase will generate significant amounts of solid waste, soil, boulders, plastic, metal scraps and other construction material waste. BCIC will require the EPC Contractors to develop a waste management procedure during the construction phase and BCIC will develop waste management procedure and implement it during the Project operation phase per the ESAP. BCIC will ensure that the EPC contractors collect and separate the waste according to the designated risk levels and select authorized vendors for the final disposal of the materials; verify proper disposal and retain the chain of custody and disposal records.
Waste generated during demolition of the existing civil structures and construction comprises large quantity of debris and rubbles amounting to about 27,400 tons including 15 tons of asbestos containing material from the asbestos cement sheets. Disposal of asbestos will be challenging as there is no designated disposal site available for disposal of asbestos sheets. Asbestos being a hazardous material, BCIC will require the EPC Contractors to prepare an Asbestos Abatement and Management Plan, and ensure they include measures to address safe handling of asbestos in their Project -specific EHS Plan as per the ESAP. In addition, BCIC shall ensure that the Asbestos is handled and disposed as per the MIGA requirements, WBG’s Good Practice note on Asbestos (2009) and Bangladeshi national requirements to ensure health and safety of both workers and the public. Moreover, BCIC will ensure that the hazardous materials (Asbestos) are not sent to landfills and these materials are controlled and disposed of in the environmentally sound disposal site and the Asbestos washed water should be collected in a secure pit, the water treated before released into the environment per ESAP. Additionally, BCIC will ensure that all the contaminated soil (hazardous) is disposed to a secluded pit per Bangladeshi national and MIGA requirements per ESAP. In establishing this hazardous site, BCIC will coordinate with the Department of Environmental and ensure to accommodate and implement any requests. As a result of the old plant closure BCIC, will deactivate the catalyst and ammonia gas and ensure the site is secure.
The EIA concluded that, A large quantity of debris and rubbles amounting about 27,400 tons including 15 tons of asbestos cement sheet would be generated during dismantling and demolition of civil structures.
As part of the ESMS, BCIC and EPC Contractors shall have in place clear procedures for the storage, handling and final disposal of hazardous material during the construction and operations stage. BCIC will ensure that all workplaces minimize spillages of substances that are hazardous to the environment; the emission of dust and hazardous chemical into the atmosphere are monitored and controlled to prevent any environmental emergencies. Areas for depositing hazardous materials such as contaminated liquid and solid materials shall be approved by the appropriate local and/or national authorities before the commencement of work. As per the ESAP, BCIC will require the EPC Contractors to develop a comprehensive Hazardous Material (HAZMAT) procedure that clearly explains the process of managing all the hazardous materials and waste including but not limited to disposal and storage of Asbestos. The plan/procedure will also clearly detail how solid and hazardous waste will be managed, collected, segregated, labeled, stored and disposed effectively per the local laws and MIGA requirements. These waste streams will be segregated, and volumes recorded as per the procedures of the EPC Contractors which are to be included in the waste management plan. Hazardous materials will be stored in a dedicated area and handled with care; a register will be maintained, and Material Safety Data Sheets (MSDS) displayed/available in Bengali and English.
During construction, waste generated will be largely solid waste and will comprise of paper, wood, scrap metals, while hazardous waste will be likely to comprise of asbestos, fuel, used oils, used oil filters, lubricants and hydraulic fluids. The EPC Contractors will ensure that the disposal of hazardous waste will be managed through licensed third-party waste contractors in coordination with BCIC and Ministry of Environment, Forest and Climate Change. For operations phase, BCIC will manage all the waste per the waste management plan.
The new plant will be equipped with carbon dioxide capture technology designed to capture 240 tons of CO2 per day which will be used as input to the urea production process significantly enhancing the production capacity.
Greenhouse gases (GHG) emissions from the Project during the construction are expected to be predominantly associated with the use of fuels such as in generators, transport, on-site equipment, and machinery. The total amount of carbon dioxide emissions during construction is 84,902 tons of CO2 over the three-year construction period. This estimate includes the embodied CO2 (60,702tons of CO2) and emissions from transportation of materials and equipment to the Project site (24,199tons of CO2). Based on the information provided by the technical due diligence consultant (Mott), once operational, the new plant will result in average greenhouse gas (GHG) emissions savings estimated to be approximately 260,000 tons CO2 equivalent per year (tCO2e/yr) when compared against the GHG emissions from the existing UFFL and PUFFL fertilizer plants (approximately 1.2 million tCO2e/yr). According to the consultant’s analysis, the new plant will have an emission factor of 1.16 tons of CO2 per ton of ammonia produced (tCO2/tNH3), while the UFFL and PUFFL have an emission factor of 4.03 and 3.55, respectively.
The new plant will be significantly more energy efficient than the PUFFL and UFFL plants. According to information shared with MIGA, the natural gas required for production of urea in the new plant is also reduced by 24 gigajoule (GJ) per tons of Urea compared to older plant. The energy requirement of the proposed plant will be approximately 19 GJ/ tons of urea production. This are above the WBG EHS Guidelines industry benchmark (16.6 – 18.7 GJ/tons urea) since the new plant power generation system is steam turbine generators instead of gas turbine generators and + HRSG (Heat Recovery Steam Generation Unit). Per the ESAP, BCIC will be required to design, plan and implement technically/financially feasible, cost effective measures for improving efficiency of consumption of energy, as well as other resources and material inputs, with a focus on core business activity. Such measures shall integrate cleaner production technology into the design of the plant with the objective of conserving raw materials, energy to the WBG EHS guidelines.
PS4: Community Health, Safety and Security
Community health and safety risks
As mentioned earlier, the Project will be located within the existing premise of BCIC Polash Urea Fertilizer Factory Ltd in Ghorasal, and the premise is surrounded by shops and residential houses. The nearby community with a population of about 1,500 people living close to the proposed plant is Khanepur. In addition, there are workers and their families who live within the compound and will all have to be relocated to other BCIC plants before the construction of the new Project. At present there are about 885 employees and their families living in the residential area within the UFFL and PUFFL plant complex. After the closure of UFFL and PUFFL, a total of 200 workers and families are expected to be living within the BCIC Project compound. The residential area is separated from the plants with fences, controlled entrance and security guard and only authorized people get access to the plants. Children of the employees get preference for admission to the educational institutions (high school and college) within the complex. Students from the outside community also can get admitted.
The potential community health and safety risks include fire and explosion risks, vibrations, traffic accidents, air emissions, diseases from labor influx, and unauthorized access to the site. In addition, as per the ESAP, EPC Contractors will develop a labor influx plan to ensure they manage all the workers migrating and working for the Project. During operations potential risks include fire and safety issues, ammonia leakage, oil spillages, accidents and electrical faults. The EPC Contractors will conduct a risk assessment to ensure that during construction and commissioning community health and safety are top priority. Further, the EPC Contractors will also develop and implement a Worker Code of Conduct which will also apply to all subcontractor s to ensure they maintain high standards within the community and meet the requirements of PS4.
There is one firefighting station located five (5) km from the BCIC Polash Urea Fertilizer Factory. For the construction phase of the Project, temporary fire system requirements for the site (alarm system, emergency lighting etc.) will be planned by the EPC Contractors and subcontractor s to ensure any fire and explosions risks are managed. As previously mentioned and per the ESAP, BCIC and the EPC contractors will develop a comprehensive EPRP that will address any potential risks to this neighboring community. The Fire Safety Protocol of the company lists specifications which shall be met by the EPC Contractors on firefighting mechanisms, procedures on hot works, handling of gas cylinders, highly flammable liquids and combustible materials, and actions in the event of fire. The EPC Contractors will appoint a Fire Officer to undertake risk assessment and regular audits (daily inspections and weekly formal audits) and report directly to the Project director.
As noted in the EIA, during construction there will be increased number of vehicles and heavy machineries accessing the Projects site, which could present a potentially significant risk to the workers and personnel on site, and the local community along the main access roads unless it is well managed. Increased traffic on local roads will affect access to the trading center and, houses close to the road, deteriorate safety (especially the school children), increased risks of fuels and chemical spillage, and damage to infrastructures. In addition, transportation of construction materials may have different types safety issue including safety from increased traffic, accidents, flying of sand and dust from the carriers. Per the ESAP, the BCIC will require the EPC Contractors to develop and implement a Project-specific traffic management plan to ensure uninterrupted traffic movement during construction and BCIC will develop and implement the traffic management plan during operation. Moreover, BCIC will require that the EPC have hired qualified drivers with licenses and insurance and trained them on defensive driving, road safety and that all the Project vehicles are in good condition, have seatbelts have right documentation per the ESAP. In addition, BCIC will ensure that communities are aware of the transportation routes and the types of materials (hazardous and non-hazardous) and wide loads vehicles to minimize accidents and traffic congestions during the construction phase per the ESAP.
Currently, BCIC has two types of security personnel: one that is directly recruited by the BCIC and Ansar from Government of Bangladesh paramilitary auxiliary force responsible for the preservation of internal security and law enforcement. The Ansar security guards are armed at night and un-armed during the day. The security guards are trained by the government of Bangladesh. Security guards are stationed at the plant’s gates within the complex, at the jetty and at the complex entrance gates. They are responsible to provide maximum security including inspecting all the cars and workers entering the complex and keeping a log and records at the gate.
During construction, the EPC Contractors will be responsible for the security and they will hire a professional security company to protect the whole complex including all the gates, construction site, material and equipment. The EPC Contractors shall provide barricades, fences, warning signs, display lights, signals and signs at the construction site. BCIC will require the EPC Contractors to develop and implement a security risk assessment and a security management plan (SMP) prior to construction and BCIC will develop a security management plan during operation all to be in line with MIGA PS4 requirements as per the ESAP.
The Project plans to have perimeter fences and a single and controlled entry to ensure only authorized personnel get access to the Project site. As mentioned earlier, the EPC Contractors will establish a security contract with a private security company in Bangladesh which preferably hires unarmed security personnel from within the neighboring community. Security contracts will be managed by the assigned EPC Contractors Project manager, who will determine the detailed security plan during phases of execution and the reporting structure for security events or breaches. To ensure alignment with MIGA PS requirements for security arrangements, the EPC contractors will ensure that the private security provider’s team are not implicated in past abuses; will train them adequately in the use of force, and appropriate conduct toward workers and nearby communities; and require them to act within the applicable law. The EPC Contractors will not sanction any use of force except when used for preventive and defensive purposes in proportion to the nature and extent of the threat.
PS5: Land Acquisition and Involuntary Resettlement
A 13 km long railway line will be constructed to connect the Project to the main railway line at a junction point (Ghorasal/Jinardi). BCIC will request the Bangladesh Railway Authority to build the new railway line within the Project time of the new project construction and BCIC will fund its construction (the new Project and the railway line will be constructed simultaneously). The railway line is planned to be constructed along and adjacent to an existing road and the railway line will go through Khanepur, Palash, Paiksa, Ghorasal villages/communities. BCIC owns the land about 40 ft wide in both sides, as part of the Rights of Way (ROW), of existing road and might acquire additional land to construct the railway line. A total of 40 ft on the east side of the existing road will be required for the railway line. The railway line will be located within the Narsingdi district; therefore, land acquisition for the railway and negotiation with the affected people is managed by Narsingdi District government officials in collaboration with BCIC through initially “willing buyer-willing seller” arrangements. If the total land required is not acquired by the Narsingdi District government official, land will be expropriated on the grounds of national law and general/public benefit.
BCIC conducted a preliminary survey on the potential households and people to be impacted as a result of the land acquisition process and a total of 12 tin shed /residences, 50 small shops, one school (Madrasa) that is from Class –I to Class-X and one cattle farm will be physically displaced. Currently, MIGA does not have the total number of Project affected people. In addition, 4 culverts, a boundary wall and a few utilities that include 33KV and 11KV electrical Line and underground internet line will be demolished and relocated. The 50 shopkeepers may be physically and economically displaced. Moreover, BCIC’s preliminary survey concluded that there is no agriculture land and fishing activities within the proposed land for the railway line and no farmers or fishermen will be affected/ impacted. MIGA will engage a qualified consultant to review the land acquisition process vis-à-vis MIGA PS5 requirements and prepare a supplemental action plan to bridge any gaps identified and mitigate any livelihood impacts including compensation for loss of assets at replacement cost and any other applicable provisions. As per the ESAP, BCIC will implement all of the recommended action items from the consultant to meet MIGA requirements and this action will be included in the amended ESAP. The consultant will also assess the market price and facilitate and/or demonstrate the community engagement and information disclosure measures necessary for the process. Per the ESAP, BCIC will ensure that the land acquisition, resettlement, and compensation process for the affected and impacted households and people is done per the local laws and in line with MIGA PS5 requirements. Per the ESAP, BCIC will develop and implement a resettlement action plan (RAP). The RAP shall incorporate applicable requirements of PS5. Elements of the RAP shall be designed to mitigate the negative impacts of displacement; identify development opportunities; develop a resettlement budget and schedule; and, establish the entitlements of all categories of affected persons including host communities. Particular attention shall be paid to the needs of the poor and the vulnerable, and fully document all transactions to acquire land rights, as well as compensation measures and relocation activities. In addition, per ESAP, BCIC will develop and implement a livelihood restoration plan (LRP). The plan shall be designed to compensate affected persons and/or communities and offer other assistance to meet the objectives of PS5. The LRP shall establish the entitlements of affected persons and/or communities and shall ensure that these are provided in a transparent, consistent, and equitable manner. Mitigation of economic displacement shall be considered complete when affected persons or communities have received compensation and other assistance according to the requirements of the LRP and are deemed to have been provided with adequate opportunity to reestablish their livelihoods.
In accordance with the compliance of Environment Conservation Act, 1995 and Environment Conservation Rules (ECR), 1997 (all amendments), the proposed Fertilizer factory falls under “Red” category and BCIC will be required to submit both Initial Environmental Examination (IEE) and Environmental Impact Assessment (EIA to obtain the Site Clearance Certificate (SCC) and subsequently the Environmental Clearance Certificate (ECC) prior to Project construction. BCIC acquired the environmental clearance certificates in compliance with the Environmental Conservation Act, 1995 from the Department of Environment, tree cutting permission from divisional forest office and jetty construction from Bangladesh Inland Water Transport Authority (BIWTA). Other permits required that are pending include; the water intake permission from WARPO and the hazardous materials handling, disposal, storage and transportation per the Department of Environment laws and requirements.
Public consultation was undertaken as part of the ESIA with the affected population, local government bodies, public representatives, UFFL and PUFFL workers, NGOs and business communities to introduce the Project components and anticipated impacts. People around the Project interviewed are in favor of this Project as it would create employment opportunities for skilled, semi-skilled and unskilled people. Implementation of this Project would also alleviate the existing ammonia odor problem around the lagoon generated when ammonia mixed effluent is injected into it. Although within the EIA there is documented evidence of stakeholder engagement, a formal stakeholder engagement plan (SEP) has not been developed and there is no formal grievance redress mechanism. Therefore, BCIC will require the EPC Contractors to develop a SEP for the construction phase and BCIC will develop a SEP for the operation phase per the ESAP. The SEP will include the consultation and disclosure activities that will occur throughout Project preparation and implementation. The SEP will include including a formal grievance redress mechanism. The existing stakeholder consultation/disclosure process will be articulated within the SEP and will include stakeholders identified by BCIC as directly affected and vulnerable people.
BCIC will develop a Community Grievance Mechanism for the Project in alignment with PS1 and will be responsible for responding to any grievances which are raised in relation to the Project. BCIC will also require the EPC Contractors to develop a subsidiary Community Grievance Mechanism which will include details of how it will be responsible for responding to any grievances identified by BCIC as being caused by the activities of the Project, or the subcontractors hired by EPC Contractors as per ESAP. All responses to grievances will be processed by BCIC to ensure a consistent approach to stakeholder consultation for the Project. In addition, BCIC will need a systematic approach to engage with these communities and other stakeholders, disclose publicly relevant information and provide adequate channels for any grievance or queries they may have. BCIC will therefore develop a documented procedure for external communications which will include disclosing information to public about BCIC Project activities and EHS issues, as well as an external grievance mechanism to provide relevant contacts and processing of any concerns raised by the stakeholders per the ESAP.
Broad Community Support (BCS)
This Project will require BCS.
MIGA supports its clients (as defined in MIGA Policy on Environmental and Social Sustainability) in addressing environmental and social issues arising from their business activities by requiring them to set up and administer appropriate grievance mechanisms and/or procedures to address complaints from Affected Communities.
In addition, Affected Communities have unrestricted access to the Compliance Advisor/Ombudsman (CAO), the independent accountability mechanism for MIGA. The CAO is mandated to address complaints from people affected by MIGA-guaranteed business activities in a manner that is fair, objective, and constructive, with the goal of improving environmental and social Project outcomes and fostering greater public accountability of MIGA.
Independent of MIGA management and reporting directly to the World Bank Group
President, the CAO works to resolve complaints using a flexible, problem-solving approach through its dispute resolution arm and oversees Project-level audits of MIGA’s environmental and social performance through its compliance arm.
Complaints may relate to any aspect of MIGA-guaranteed business activities that is within the mandate of the CAO. They can be made by any individual, group, community, entity, or other party affected or likely to be affected by the environmental or social impacts of a MIGA-guaranteed business activity. Complaints can be submitted to the CAO in writing to the address below:
International Finance Corporation
2121 Pennsylvania Avenue NW
Washington, DC 20433 USA
Tel: 1 202 458 1973
Fax: 1 202 522 7400
- Environmental Impact Assessment (EIA) of Ghorasal Polash Urea Fertilizer by CEGIS dated March 2019.
- Inception Report on Environmental Impact Assessment (EIA) of Ghorasal Polash Urea Fertilizer by CEGIS dated November 2018.
MIGA prepared an Environmental and Social Action Plan (ESAP) to address the identified gaps.
The ESIA is available for viewing at the following location upon request:
Md. Rajiour Rahman Mollick
BCIC Project Director
E-mail : firstname.lastname@example.org