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Environmental Safeguards Report Quarterly Report November 2010

L2499-PAK: Sindh Cities Improvement Investment Program Prepared by RCC Consultants for the Government of Sindh and NSUSC and the Asian Development Bank.

ENVIRONMENTAL PROGRESS REPORT

(August – November 2010)

(Environmental Safeguards‐ Report – 2)

ENVIRONMENTAL SAFEGUARDS CELL

14-A Sindhi Muslim Cooperative Housing Society, Airport Road, Sukkur Phone: 071 9310866, 9310440

NORTH SINDH URBAN SERVICES CORPORATION 2ND Quarterly Report

ENVIRONMENTAL SAFEGUARDS CELL Page 2

ENVIRONMENTAL PROGRESS REPORT (AUGUST – NOVEMBER 2010)

Table of Contents 1. Sindh Cities Improvement Investment Program (SCIP) .......... Error! Bookmark not defined.

1.1 Safeguards Cell of NSUSC .................................................................................................... 3

1.2 Environmental Compliance Progress of Safeguards Cell .......................................... 3

1) Environmental Management Plan for Larkana priority sewerage works ................. Error! Bookmark not defined.

2) Environment policy ......................................................................................................... 3

3) HSE Policy ...................................................................................................................... 3

4) Initial Environmental Examination of Larkana sewerage priority Improvement Investment Project ................................................................................................................. 3

5) EMP Compliance of Improvement of Sewerage Project Khairpur City ........................... 4

1.3 ADB Mission Visit ........................................................................................................................ 5

1) Observations of ADB Mission member ........................................................................... 8

2) NSUSC’s Response regarding Observations ................................................................. 9



ADB MISSION VISIT COMMENTS

ENVIRONMENTAL COMPLIANCE REPORT (AUGUST – NOVEMBER 2010)

1.1 Safeguards Cell of NSUSC

Safeguard cell of North Sindh Urban Services Corporation (NSUSC) comprising two specialists, one environmental safeguard specialist (ESS) and other social, land and resettlement specialists. The responsibility of environment safeguard specialist is to review and finalize all the documents prepared by consultants relating to environment, assure its implementation, evaluate implementation progress and submit to Sindh EPA, ADB, SCIP and any other relevant agency as per reporting requirements.

1.2 Environmental Compliance Progress of Safeguards Cell

A brief description of progress of is as under:

1) Environment policy This policy has been approve by BOD, therefore now onward Environmental safeguards Cell will resume all capital works and regular operation in compliance with this policy

The main objectives of the policy are:

• Environmentally Sustainable Construction, Operations and Services • Prevention all environmental hazards and minimizing risk through life

cycle assessment • Continuous environmental improvement • Cooperation with stakeholders

NSUSC is committed to follow this policy for all its projects, operations and services.

2) HSE Policy This policy has been approve by BOD, therefore now onward Environmental safeguards Cell will resume all capital works and regular operation in compliance with this policy. The safeguards cell will conduct trainings for NSUISC staff, contractor and consultant to effectively comply the policy.



3) Initial Environmental Examination of Larkana sewerage priority Improvement Investment Project The IEE has been prepared by safeguard team, shared with ADB and submitted to Sindh EPA for environmental approval of the project. The document is prepared keeping in view the environmental guidelines of Pakistan EPA and Asian Development Bank. Main sections of the report are;

1) Project Description;

2) Environmental baseline

3) Environmental Impacts and Mitigations; and

4) Environmental Management and Monitoring Plan

4) EMP Compliance of Improvement of Sewerage Project Khairpur City The contractor M/S MOON has started his activities from 5th of March 2010. M/S JERS Lahore has been awarded for monitoring and supervision consultancy of the project. Total period of contract is 6 months. The overall scope of work of the contractor is

• Laying of sewer • New construction of Main disposal station • Major rehabilitation of Ostagahi disposal station • Rehabilitation of 13 disposal station and • Laying of Force Main • Compliance of EMP

Keeping in view the need of the project, NSUSC has awarded extension of the project for 5 months ending in February 2011.awarded The contractor is currently working on lying of sewer, forceman and construction of main disposal station (Plate: 1). The contractor is not capacious in the field of EMP implementation; this may be because he don’t have experience in EMP implementation and reporting. In first three months, his environmental compliance was around 20%, even his environmental engineer was not hired.



Plate: 1-Cotractors work in progress

Action to Mitigate Non-Compliance

After continuous pushing, holding various meetings, serving written letters, verbal communication and on job training he slowly performed to increase his performance. ESS of NSUSC held various EMP awareness sessions with environmental engineers of consultant and contractor. ESS has been conducting frequent site visits at all sites, finding weedy points delivering on site instruction and keeping in continuous contact to check the progress

After taking above all measures, contractor has improved his progress and currently he is performing in between 50% to 60 %. Also he submitted first environmental progress report in mid August.

NSUSC is committed, and it’s hoped that the compliance performance of the project will further increase in coming days.

1.3 ADB Mission Visit

ADB mission member Ms Zehra Abbas, Environmental Specialist visited NSUSC on 29.10.2010. Her visit was facilitated by Environmental Safeguards Specialist (ESS) and Manager Capital Works of NSUSC. The visit was scheduled as in plan hereunder;

ADB Mission Member, Environmental Specialist Visit Plan

Date Time Location Activity

29.10.2010 8.15 Sukkur NSUSC office



The mission member was briefed by NSUSC ESS at all the locations as mentioned in the visit plans. Plate-2 shows the visit snaps.

Numaish water treatment Plant, Sukkur

Numaish water treatment Plant, Sukkur

Do 8.30 Bundar Road Water Treatment Plant

Environmental Scoping w.r.t. new Design

Do 09.30 Rohri Visit of Existing Dump Site

Do 11.00 Khairpur • Visit of Improvement of Sewerage Project at locations: 1. Main Disposal 2. Sewer Route 3. Water table pits

• Project Briefing by Muhammad Ali Do 12.00 Khairpur • Khaki Shah Water Works

Project Briefing by Muhammad Ali • Existing Dump Site

Do 13.30 Khairpur/Sukkur • Namaz & Lunch Break

Do 14.45 Sukkur NSUSC Office

Meeting to Review: 1. IEE of Larlkana 2. Contracts/Agreements (Current & Under

preparation) 3. EMP of Khaki shah Water works



Solid waste Dump Site Rohri Main Disposal, Improvement of Sewerage Khaipur

Risingman from Main Disposal, Improvement of Sewerage Khaipur

Sewerage Laying site, Improvement of Sewerage Khaipur

Khakishah Water Treatment Plant, Khairpur

Khakishah Water Treatment Plant, Khairpur

Plate-2: Environmental Specialist of ADB visiting NSUSC Projects



The ADB specialist visited Numaish Water Traetment plant sukkur briefed by Director Operations, environmental specialist, then Rohri solid waste dump site, briefed by AMO. After Rohri, she was lead to Khairpur and visited Construction work Improvement of Sewerage Project, Khakishah water treatment plant and solid waste dump site.

1) Observations of ADB Mission member

ADB Environmental Specialist communicated some observations regarding NSUSC visit as under:

1. Environmental covenants are being followed at NSUSC, the Environmental Specialist is in place. However, PSU has not filled its Environment Specialist position to date.

2. Tender documents have been prepared for the Sanitation, Drainage, Sewerage Strategy and Prioritized Works Larkana and the Environmental management plan and Environmental conditions are included in the Bidding documents· In addition, NSUSC (under TA 7209) has also prepared their Environment Policy draft), Health Safety Policy and Occupational Health and safety Handbook.

3. Site Visits: a. Waste Disposal Sites: Waste disposal sites were visited in

Sukkur, Rohri, and Khairpur. These are open dump sites and waste disposed there is burnt by scavengers and other people to recover metallic items of potential value-such as steel webbing from tires. The Rohri site is a new site that is being managed by NSUSC, the site needs to be fenced or closed off by barbed wire, however, it was reported by NSUSC that the owner of the land has disallowed the construction of a boundary wall. Measures need to be taken to ensure that dumped waste is not burnt, dumped waste should be covered so as to protect from dust storms and rains. The natural drainage of the managed dump site should not be disturbed.

b. Water Treatment Plants: The plants are in a state of disrepair and are not working at full capacity. The filter beds are not functional.

c. Waste Water Disposal Station: The disposal station at Khairpur is under construction, the state of environmental compliance with the EMP was found to be poor, the works



are out of compliance as regards to Environmental Safeguards. The following was noted:

i. The EMP was not found onsite; ii. No training of the contractor’s staff has been

conducted implementing the EMP; iii. The contractor’s Resident Engineer (RE) was not

aware of the Asbestos management Framework (Appendix C of the IEE), pieces of Asbestos pipe recovered during excavation were seen lying along the original alignment of the pipe.

iv. No noise pollution measurements were being made, the contractor has not purchased noise meter. As reported by the Contractor’s Environment Specialist, water spraying is being conducted; however, there is no data or evidence of the same.

v. Monthly environmental monitoring reports are not being prepared.

4. IEE of Larkana: In order to bring the IEE in conformance with ADB’s SPS 2009 the IEE would need to be include a few aspects that had been omitted. These comments that included the inclusion of a Grievance Redressal Mechanism were communicated to the NSUSC team. Detailed comments will be emailed to them.

5. Asbestos Management Framework: The Asbestos management framework provided as Appendix C of the IEE of SCIIP is a very comprehensive and complete document, and sufficiently covers all eventualities, and can be applied to the projects at hand. NSUSC does not need to prepare another new Asbestos Management Plan. However, if the NSUSC team assess that the contractor has limited capacity to understand the AMF then the NSUSC team may then, based on the AMF adapt it to prepare a project specific Asbestos Management Plan that would include a checklist and project specific procedures to be followed. The existing AMF has many details that may not be relevant to each project.

2) Safeguards cell’s Response regarding Observations

NSUSC ESS prepared a descriptive report to address the comments raised by ADB Specialist. A view of title of report is as under;



The response to the ADB comments is prepared as below: In observations 1 &2 ADB Environmental Specialist has acknowledged the efficient performance of safeguard cell. Response to Observation-3: Site Visits:

a. Waste Disposal Sites: Manager Solid waste with the coordination of Safeguards cell will take following measures: • Fix sign boards at all sites in local language displaying

quotes as unlawful dumping is prohibited, firing strictly not allowed, any person found will be handed over to law enforcing agencies

• It will be tried and if agreed to owner , site will be fenced; • Continuous vigilance will be done to prohibit fire • Surrounding Natural Drainage will be kept clean;



b. Water Treatment Plants: EMPs are under preparation and

will be submitted after completion. c. Waste Water Disposal Station: this is regarding

Improvement of Sewerage, Khairpur Project. Following action are taken;

i. Copy of EMP is placed at Disposal station, Sewer laying site and Pipe Factory, In addition complain register daily and check list is also placed to be filled by contractor and verified by consultant on daily basis. All visitors will write their comments on register and consultant is to ensure the implementation.

ii. On job training of contractor/consultant is conducted, further a session will be held on or before 30th November 2010. This session is postponed

iii. A awareness session is conducted for consultant and contractor for knowing EMP and AMF, further to dispose-of Asbestos pipe pieces AMF has been followed with following steps:

• Workers handling were in proper dressing, wore safety equipment/cloths

• Collected Pieces of AC pipe • Folded/wrapped with plastic sheets • Placed in trench and covered with soil • Placing caution yellow tap and filled back with

soil • Similarly, wrapped Gloves and masks, put in

trench • Placed yellow tap after soil layer and finally

covered with soil.

A caution sign board will be fixed at this place. Keeping in view the health hazards all tools and body parts exposed including cloths were washed. A pictorial view is presented in Plate-3 hereunder;



AC pipe pieces at site Placing AC pipe pieces on plastic sheets

Wrapping AC pipe pieces on plastic sheets

Wrapping AC pipe pieces on plastic sheets

Placing AC pipe pieces in trench Placing yellow tap after soil cover



Finally covering with soil Wrapping gloves and masks

Placing along same trench Placing yellow tap after soil cover

Plate-3: Handling and burying AC Pipe Pieces

iv. Noise Measuring: Contractor has committed that he

will conduct noise monitoring before end of November.2010. For water sprinkling, daily based record will be maintained. Consultant and NSUSC will ensure it.

v. Monitoring Reports: Since August 2010 and onwards Contractor has been submitting compliance reports, which are annexed herewith.

4. IEE of Larkana: safeguard team is updating IEE as discussed with ADB specialist and document will be finalized after receiving all comments in this regard.

5. Asbestos Management Framework: The framework is now available on site. NSUSC has conducted a sitting with consultant and contractor for awareness regarding document. NSUSC and



consultant will continuously monitor and take action when and where required.

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