720mw karot hydropower project pakistankarotpower.com/uploads/karot hpp esia volume iv_esmp...

720MW Karot Hydropower Project Pakistan

Volume IV – Environmental and Social Management Plan

July 2015

Karot Power Company (Pvt) Limited

350133 PHR ENS 1 C

Karot HPP ESIA, ESMP

July 2015





July 2015


Mott MacDonald, Victory House, Trafalgar Place, Brighton BN1 4FY, United Kingdom

T +44 (0)1273 365 000 F +44(0) 1273 365 100 W www.mottmac.com

350133/PHR/ENS/1/C July 2015 Karot HPP ESIA, ESMP

720MW Karot Hydropower Project Pakistan Volume IV – Environmental and Social Management Plan

Revision Date Originator Checker Approver Description

A 02 July 2015 N Court V Warnock I Scott First draft

B 31 July 2015 V Warnock M Brownlee N Court

M Maxwell I Scott Final ESMP

C 19 August 2015 A Schoene M Maxwell M Maxwell Minor Client Comments

Issue and revision record

Information class: Standard

This document is issued for the party which commissioned it and for specific purposes connected with the above-captioned project only. It should not be relied upon by any other party or used for any other purpose.

We accept no responsibility for the consequences of this document being relied upon by any other party, or being used for any other purpose, or containing any error or omission which is due to an error or omission in data supplied to us by other parties.

This document contains confidential information and proprietary intellectual property. It should not be shown to other parties without consent from us and from the party which commissioned it.



Chapter Title Page

1 Introduction 1

1.1 Overview _________________________________________________________________________ 1 1.2 Project Parties _____________________________________________________________________ 1 1.3 Structure of ESMP __________________________________________________________________ 2

2 Implementation 3

2.1 Overview _________________________________________________________________________ 3 2.2 Summary of Project Impacts __________________________________________________________ 3 2.3 Summary of Commitments ____________________________________________________________ 3

3 Institutional Arrangements 18

3.1 Overview ________________________________________________________________________ 18 3.2 Construction ______________________________________________________________________ 21 3.2.1 KPCL EHS Management ____________________________________________________________ 21 3.2.2 EPC Contractor EHS Management ____________________________________________________ 24 3.3 Operational _______________________________________________________________________ 26

4 Policies, Plans and Procedures 27

4.1 Overview ________________________________________________________________________ 27 4.2 Construction and Operational Environmental and Social Management Plans ____________________ 29 4.3 Traffic Management Plan ____________________________________________________________ 29 4.4 Site Waste Management Plan ________________________________________________________ 31 4.5 Noise and Vibration Control Plan ______________________________________________________ 33 4.6 Air Quality Management Plan _________________________________________________________ 35 4.7 Water Quality Management Plan ______________________________________________________ 37 4.8 Spill Prevention and Response Plan ___________________________________________________ 39 4.9 Materials Handling and Storage Plan ___________________________________________________ 40 4.10 Blasting and Explosives Management Plan ______________________________________________ 41 4.11 Spoil Management Plan _____________________________________________________________ 42 4.12 Excavation and Slope Stability Plan ____________________________________________________ 43 4.13 Sediment and Erosion Control Plan ____________________________________________________ 45 4.14 Chance Finds Procedure ____________________________________________________________ 45 4.15 Biodiversity Management and Action Plan Framework _____________________________________ 46 4.16 Ecological Management Plan _________________________________________________________ 46 4.17 Habitat Removal and Restoration Plan __________________________________________________ 47 4.18 OHS Plan ________________________________________________________________________ 48 4.19 Site Security Management Plan _______________________________________________________ 49 4.20 Emergency Preparedness and Response Plan ___________________________________________ 49 4.21 Worker Accommodation Plan _________________________________________________________ 50 4.22 Resettlement Action Plan ____________________________________________________________ 50 4.23 Stakeholder Engagement Plan ________________________________________________________ 50 4.24 Labour Grievance Mechanism ________________________________________________________ 51

Contents



4.25 Community Grievance Mechanism _____________________________________________________ 51 4.26 Retrenchment Plan _________________________________________________________________ 51 4.27 Gender Strategy ___________________________________________________________________ 52 4.28 Recruitment Policy _________________________________________________________________ 52 4.29 Human Resources Policy and Procedures _______________________________________________ 53 4.30 Skills Training Programme ___________________________________________________________ 53 4.31 Community Investment Plan (CIP) _____________________________________________________ 54 4.32 Influx Management Strategy __________________________________________________________ 54 4.33 Local Content Strategy ______________________________________________________________ 55

5 Reporting Requirements 56

5.1 Introduction _______________________________________________________________________ 56 5.2 Adaptive Management ______________________________________________________________ 56 5.3 Monitoring and Reporting ____________________________________________________________ 56 5.3.1 The EPC Contractor Monthly Internal Reports ____________________________________________ 56 5.3.2 KPCL’s Monitoring of Construction Activities _____________________________________________ 57 5.3.3 KPCL’s Monitoring of Operational Activities ______________________________________________ 57 5.3.4 KPCL’s External Reporting for Regulatory Compliance _____________________________________ 57 5.3.5 Lenders Reporting Requirements ______________________________________________________ 58 5.4 Annual Independent Audits and Lenders Reviews _________________________________________ 58 5.4.1 Independent Monitoring _____________________________________________________________ 58

6 ESMP Budget 59

6.1 Indicative Budget __________________________________________________________________ 59 6.2 Reallocation of Funds / Update of Budgets ______________________________________________ 60

Appendices 61

Appendix A. Sediment and Erosion Control Plan ____________________________________________________ 62 Appendix B. Emergency Preparedness and Response Plan ___________________________________________ 63 Appendix C. Temporary and Permanent Project Components __________________________________________ 64 Appendix D. Biodiversity Management and Action Plan Framework _____________________________________ 66 D.1 Introduction _______________________________________________________________________ 66 D.2 Rationale and Scope of the BMAP _____________________________________________________ 66 D.2.1 Why is the BMAP Needed ___________________________________________________________ 66 D.2.2 Aims and Objectives of the BMAP _____________________________________________________ 66 D.2.3 Formulation of the BMAP ____________________________________________________________ 66 D.2.4 Stakeholder Consultation ____________________________________________________________ 67 D.2.5 Study Area _______________________________________________________________________ 67 D.3 Legal, Regulatory, Permitting and Third Party Requirements _________________________________ 67 D.4 Biodiversity Baseline _______________________________________________________________ 67 D.5 Current Biodiversity Threats and Project Impacts _________________________________________ 68 D.6 Priorities for Biodiversity Conservation __________________________________________________ 68 D.7 BMAP Actions ____________________________________________________________________ 68 D.7.1 Overview ________________________________________________________________________ 68 D.7.2 ESIA Biodiversity Mitigation __________________________________________________________ 69



D.7.3 Introduction and Spread of Non-Native and Invasive Species ________________________________ 69 D.7.4 Support for the Murree- Kotli Sattian-Kahuta National Park __________________________________ 70 D.7.5 Awareness Raising and Education _____________________________________________________ 70 D.7.6 Biodiversity Monitoring ______________________________________________________________ 70 D.8 BMAP Implementation ______________________________________________________________ 71 D.8.1 Responsibilities, Partnerships and Programme ___________________________________________ 71 D.8.2 Relationships with Other Plans ________________________________________________________ 71 D.9 Monitoring, Evaluation and Improvement ________________________________________________ 72 D.10 Reporting, Communication and Verification of BMAP Performance ____________________________ 73 Appendix E. Workers’ Code of Conduct ___________________________________________________________ 74 Appendix F. Labour Commitment ________________________________________________________________ 75



1

1.1 Overview

This report is the Environmental and Social Management Plan (ESMP) for the Karot Hydropower Plant

(HPP) (the ‘Project’). The primary objective of an ESMP is to safeguard the environment, site staff and the

local population from site activity which may cause harm or nuisance1. This ESMP for the Project is

intended to ensure transparent and effective monitoring, prevention, minimisation, mitigation, off-setting

and enhancement measures to address the environmental, health and safety (EHS) impacts associated

with the Project. The commitments and mitigation measures identified in the ESIA to avoid, mitigate, or

enhance project impacts are captured within this ESMP, which identifies specific management plans to be

developed by the Project Proponent and their EPC contractor to implement the measures described. The

measures described within this ESMP are applicable to the Project and its associated infrastructure during

both the construction and operational phase.

This document will form the basis of the EHS protection measures implemented by Karot Power Company

(Private) Limited (KPCL) (the Project Proponent) and their EPC contractor (and appointed sub-

contractors). The implementation of the ESMP ensures that EHS performance is in accordance with

international standards (including the relevant International Finance Corporation (IFC) Performance

Standards (PS), sector Environmental, Health and Safety (EHS) Guidelines, International Labour

Organisation (ILO) conventions and good international industry practice (GIIP).

This document constitutes Volume IV of the Environmental and Social Impact Assessment (ESIA) process

which has been undertaken by Mott MacDonald. The ESIA comprises seven volumes organised as

follows:

� Volume I: Non-technical Summary (NTS) of the International ESIA report

� Volume II International ESIA Main Report

� Volume III: Technical Appendices/Supporting Documents

� Volume IV: Environmental and Social Management Plan (ESMP) (this volume)

� Volume V: NTS of the Resettlement Action Plan (RAP)

� Volume VI: RAP

� Volume VII: Stakeholder Engagement Plan (SEP)

1.2 Project Parties

Karot Power Company (Private) Limited (KPCL) is the Project Proponent and is a wholly owned subsidiary

of China Three Gorges South Asia Investment Limited (CSAIL). CSAIL is an investment holding company

formed in September 2011 to acquire, develop, build, own and operate renewable power generation

projects in Pakistan. CSAIL is a wholly owned subsidiary of CWE Investment Corporation (CWEI) who is a

wholly owned subsidiary of the state owned China Three Gorges Corporation (CTGC) and serve as its

dedicated overseas investment platform.

1 Health and safety issues are addressed in this report at a community level and outlines basic worker health and safety measures;

however, the plans outlined here do not constitute detailed health and safety requirements, nor does it identify all the method statements and processes needed to protect site workers in their day to day activities.

1 Introduction



2

1.3 Structure of ESMP

Chapter 2 of this ESMP summarises the key impacts and required mitigation measures identified in the

ESIA and outlines how these are captured and implemented within project design measures,

commitments, and plans, policies and procedures.

Chapter 3 outlines the institutional arrangements through which the ESMP will be implemented and the

relationship and responsibilities between CSAIL, KPCL, and the EPC contractor. Where relevant, a

number of capacity building measures have been identified to ensure that the institutional arrangements

are appropriate and qualified for the allocated tasks.

Chapter 4 provides an outline on the various site specific EHS management and monitoring plans to be

implemented as part of the ESMP by KPCL and their EPC contractor. The sub-plans are intended to

ensure that the various mitigation measures / activities identified through the ESIA process are

incorporated by the Project in a structured way. Mitigation measures are presented for each sub-plan,

together with monitoring measures and key performance indicators (KPIs) where applicable. In addition,

relevant national and international standards and best practice guidelines have been identified.

Chapter 5 of the ESMP provides an overview of monitoring and reporting requirements associated with the

activities and commitments contained within the ESMP documentation. The monitoring and reporting

requirements include a “management of change” capacity to the ESMP reflecting that it is intended to be a

live document subject to regular review and update as the Project evolves.

Chapter 6 identifies the overall indicative budget for implementation of the ESMP through construction and

into operation. The budget as identified is subject to revision / change depending on evolution of various

detailed plans but is considered to be broadly indicative of the level of commitment by the Project to

mitigate EHS impacts identified through the ESIA process and to provide enhancement to EHS indices in

the Project region where relevant.



3

2.1 Overview

The Environment and Social Management Plan (ESMP) comprises all social and environmental mitigation

measures for the Karot HPP Project. The Plan summarises impacts, outlines institutional arrangements,

overarching environmental and social management system (ESMS), and provides a framework for the plans and

procedures required to implemented mitigation commitments.

2.2 Summary of Project Impacts

A brief summary of the key Karot HPP impacts is provided below, a full description of the impacts and the

project technical features is included in Volume II ESIA. The main project environmental and social impacts

include:

� Physical Resettlement of the village of Karot and part of the village of Hollar (75 households, including

permanent and seasonal residences due to construction of the dam site and ancillary structures)

� Loss of business and land due to inundation and project structures (private and public land)

� Alteration of hydrological river regime and sediment transport downstream of project

� Impacts on aquatic ecology and water quality

� Impacts on terrestrial ecology, including inundation, clearance for access roads and work sites, and

land loss due to spoil disposal

� Fragmentation of basin and potential barrier of fish migration to spawning grounds

� Long-term changes from a riverine environment to a lake environment along the Jhelum River over a

distance of 27km (extent of reservoir)

� Significant excavation works and requirement to manage and dispose of spoil material

� Initial loss of infrastructure (roads, bridges etc.) due to construction and inundation, but improved

infrastructure replacing loss providing long term benefit

� Temporary nuisance caused by increased dust, noise, congestion, and traffic on local communities

� Impact on landscape and visual amenity as result of reservoir creation and spoil disposal

� Opportunity for employment and income generation locally

� Improved market opportunities during construction (increased demand) benefiting local businesses

� Electricity generation supporting growth and meeting critical energy shortage in Pakistan.

2.3 Summary of Commitments

The ESIA has identified a number of mitigation measures to address impacts identified, in some instances

these measures are embedded in the design; in other instances they are based on providing a process

and plan through which to avoid and manage potential impacts, and in some cases additional interventions

such as compensation or offsets are required. Figure 2.1 below provides a conceptual illustration of the

development of commitments out of the ESIA process and how these commitments can be grouped into

different mitigation approaches. The commitments identified are comprised of a number of mitigation

measures, this section aims to capture those commitments and identify the most suitable implementation

mechanism.

2 Implementation



4

Figure 2.1: Development of ESIA Commitments

Source: Mott MacDonald

Table 2.1 and Table 2.2 provide a summary of all the commitments required to be adopted by Karot HPP

to avoid, minimise/enhance, restore and/or offset project impacts. Where ever possible commitments have

been identified within a plan

Table 2.1: Project commitments

Commitments Implementation Mechanism

Responsibility

Further Studies and Supporting Actions

Appoint independent technical advisors to review detailed design proposals, as they become available, including specifications and method statements to provide a technical challenge and reduce risk.

Independent technical advisor

KPCL

Appoint independent technical specialists to review how the assets are being operated and the adequacy of monitoring and surveillance provisions. It is recommended that special provisions are made following extreme events (eg extreme flood events or seismic event).

Independent technical specialist

KPCL



5


Responsibility

Contribute to the preparation and implementation of the Jhelum Catchment Management Plan (CMP) in coordination with other hydropower developers on Jhelum River, the Forest Departments and Environment Protection Agencies of Punjab and Pakistan-administered Kashmir, and the local communities. This plan will cover the areas along the new Karot reservoir, dam and downstream; up to the tail of Mangla Dam reservoir and include some of the cumulative impacts identified. Measures to control soil erosion will form a significant component of the plan.

Stakeholder Engagement, Financial Contribution

KPCL to instigate and participate in meetings with relevant agencies within the first 6 months of construction to develop action plan for CMP.

Throughout project development engage with relevant agencies and implement CMP actions.

Participate and support in the development and implementation of a Basin Level Biodiversity Management Strategy.

Engagement at basin level to develop and implement objectives of Karot HPP Biodiversity Management Action Plan.

Share data from further baseline and monitoring campaigns.

Discuss with relevant Forestry and Wildlife departments how KPCL can support objectives of the proposed Murree-Kotli Sattian-Kahuta National Park and ensure that the Karot HPP Biodiversity Management Action Plan complements those objectives.


KPCL – Throughout project development

Undertake further studies to better determine the likelihood of reservoir induced seismicity.


KPCL – Throughout project development

Undertake landslide risk assessment to be performed covering all project components to determine probability of hazard/impact.


KPCL – During both construction and operation phases

Undertake an E&S assessment prior to the development and exploitation of any new natural quarry/previously unexploited borrow pits. If existing borrow areas and quarries are to be used, KPCL or the EPC contractor will need to verify they are properly licensed and meet IFC PS requirements for supply chains prior to their usage.

ESMS and EPC Contract

KPCL and EPC contractor

Additional E&S assessment if additional road works are identified by the EPC contractor.



An E&S assessment in accordance with requirements at that time is to be undertaken prior to any decommissioning or refurbishment activities to appropriately assess likely E&S impacts based on an adapted baseline and to mitigate or enhance these impacts based on mitigation/enhancement measures available and feasible at the time.

ESMS KPCL

Prior to commencement of construction works, a detailed pre-construction building condition survey of identified at risk buildings, and structures ie the shrine within the Project site and mosques and public buildings up to a distance of 200m from the PAA.





6


Responsibility

Contribute to the preparation and implementation of a CMP together with other hydropower developers on Jhelum River, the Forest Departments and Environment Protection Agencies of Punjab and Pakistan-administered Kashmir, and the local communities. This plan will cover the areas along the new Karot reservoir, dam and downstream; up to the tail of Mangla Dam reservoir.

ESMS KPCL in collaboration with hydropower developers on Jhelum River, the Forest Departments and Environment Protection Agencies of Punjab and Pakistan-administered Kashmir, and the local communities

Design

Undertake risk based approach to assess seismic design in accordance with international standards for all project components.

Analyse alternative operating regimes to avoid sudden peaking flows, investigate the two scenarios identified in Chapter 10 - Biodiversity of the ESIA.

Use of natural and local materials informed by local vernacular building styles for the design of residential and administrative buildings.

Design mitigation planting to integrate the Project into the existing landscape, to screen it from sensitive receptors and to replace vegetation lost through construction, and allow natural regeneration.

Additional planting could be provided in locations identified by local residents in off-site areas to compensate for loss of woodland.

Design to include emergency environmental flow release mechanism. Definition of the design return period and hence selection of appropriate PGA values following ICOLD guidelines.

Provide warning systems for increases in HPP discharges, including sirens for river reach downstream of the dam at key locations on a risk based approach, in particular where gravel extraction activities historically take place.

Ensure that the spoil disposal sites are chosen to minimise impacts on more sensitive and locally valued landscapes.

Review design of landfill site and ensure that is sited at the shallow end of spoil disposal site #4. Drainage channels and culverts will be developed to divert the natural flow of the nullahs into the Jhelum River, which will mitigate against flooding and/or erosion of the spoil disposal sites.

Where dam safety standards are proposed that differ from commonly-accepted international standards, it is recommended that comparisons be made with such standards so that KPCL can gain an understanding and appreciation of the implications in terms of costs and risks

Dam safety aspects will be subject to review by the developer and independent scrutiny by international experts.

A grouting gallery is recommended to be incorporated into the design which will provide for additional grouting work to be done after reservoir impoundment, if deemed necessary. A gallery also allows seepage rates past the core wall to be monitored.

Detailed design KPCL to request EPC contractor to review design options



7


Responsibility

Independent verification of conditions, materials and standards applied during construction Design of permanent and temporary facilities on site and structures (eg powerhouse) to incorporate use of natural and local materials informed by local vernacular building styles for the design.

Culturally adequate portable toilets will be provided at all major work sites.

Pre-Construction and Construction

Plant new trees and vegetation in the areas subject to erosion.

EPC contractor required to plant trees in accordance with permit conditions2 .

Design of cut slopes for seismic actions (static and dynamic analyses).

Definition of the design return period and hence selection of appropriate PGA values following ICOLD guidelines.

Design of spoil area slopes for dynamic and static cases.

Stakeholder Engagement, Direct Financial Contribution, EPC contractor

KPCL and EPC

Local skills training programme to help local people gain skills to be employed on the Project.

EPC Contract EPC contractor to implement and KPCL to enforce and monitor compliance

Development and implementation of detailed plans, policies and procedures outlined in Chapter 4.


EPC contractor to implement and KPCL to enforce and monitor compliance

Medical screening of workers at no charge.

Onsite medical facilities/first aid room for treating workers onsite and not by public healthcare services as far as possible.


EPC contractor to implement and KPCL to enforce and monitor compliance

Operation

Monitoring increase in seismicity due to reservoir activities. Appropriate mitigation measures to change operations if problem is detected.

Liaison with operators of future upstream dams may allow the variation in reservoir level to be moderated.

Install mechanism to obtain real-time information on flows from upstream locations, enable adaptive management to inflows (may allow attenuation of flood peaks). Flow data to be made publicly available via project website.

Fish catch and release programme.

Commercial fish protection measures.

Fish hatchery breeding programme upstream of the reservoir.

Habitat enhancement: instream works to improve/increase areas of spawning habitats.

Purchase additional land in areas showing signs of slope instability.

Operating procedures, O&M plans and KPCL ESMS

KPCL

2 Consultation with the Forest Department of the EPA Punjab has indicated that compensatory planting will be required in the ratio of

1:10 for those removed.



8

Table 2.2 provides a summary of the policies, plans and procedures, identified in the ESIA, which will be

developed as part of the ESMP. These are elaborated on further in Section 4 of this report detailing the

GIIP measures required to manage and monitor Project risks and impacts during the construction and

operation phases.

9 350133/PHR/ENS/1/C July 2015 Karot HPP ESIA, ESMP


Table 2.2: Commitments of Plans, Policies and Procedures

Plan / Policy Objective / Content Impacts Implementation

Environmental

Construction Environmental and Social Management Plan (CESMP)

• To implement mitigation activities relevant to the construction phase of the Project and to avoid, mitigate and minimise EHS impacts during the construction phase.

• EPC contractor will be required to adopt a CESMP which will strictly follow and comply with the national legislation and general IFC EHS Guidelines during construction activities at all sites as well as incorporate specific mitigation as identified through the ESIA process. Each works contract will include a CESMP framework as a specific exhibit.

• Construction related impacts mitigated by the management plans detailed below

• Prior to any site preparation and construction works

Operational Environmental and Social Management Plan (OESMP)

• EPC contractor will be required to adopt a OESMP which will strictly follow and comply with the national legislation and general IFC EHS Guidelines during operation.

• Intended to guide the development of the programs by which KPCL Project Company will ensure operation activities are carried out in a way that meets the goals of the KPCL Environmental & Social principles/policies.

• The OESMP will include a series of management plans, or sub-plans, that are intended to control various aspects of operation that could lead to specific adverse impacts.

• Operation related impacts mitigated by the management plans detailed below

• Prior to operation commencing

Traffic Management Plan (TMP)

• To define the requirements that will be implemented to mitigate any potential negative risks to the environment, workers or the community resulting from construction traffic on both public and internal site roads.

• The Traffic Management Plan will advise and inform the EPC contractor and external suppliers of equipment and materials of access and entry points along with other key information such tipping areas and wash-out areas.

• The TMP will specify maximum speeds on both public and site roads.

• Intended to compliment and work alongside relevant CESMP. The TMP will be classed as “live” and therefore be subjected to updates as required.

• Increase in general traffic (cars and trucks) volumes and Abnormal loaded vehicles

• Nuisance (dust, noise and vibration) as a result of traffic

• Driver delay, pedestrian delay, severance, pedestrian amenity/ fear and intimidation

• Community road safety

• Improve transport infrastructure to handle the Project traffic movements and loads


• Develop operational TMP prior to operation




Site Waste Management Plan (SWMP)

• Identify measures for minimisation of waste and safe disposal of construction wastes.

• Identify opportunities locally for recycling wastes.

• Define minimum design and operating requirements for the proposed landfill site.

• Different SWMP will be required for the construction and operational phases to address different waste generated and management requirements of each phase.

• Non-hazardous waste generated as a result of general construction activities, including concrete offcuts, scrap ferrous and nonferrous metals, packaging materials (plastics, cardboard, pallets)

• Hazardous waste generated from general construction activities including fluorescent tubes, batteries, solvents and medical waste from camps

• Contaminated material generated from fuel spills and leaks

• Develop construction SWMP prior to any site preparation and construction works

• Develop operational SWMP prior to operation

Noise and Vibration Control Plan (NVCP)

• To guide the means by which KPCL and the EPC contractor will control noise and vibration caused by construction, traffic, operations, and other activities to ensure noise does not exceed applicable standards at the site boundary and beyond.

• Separate plans will be developed for construction phase and operational phase.

• Noise impacts as a result of site preparation excavation and foundations, construction and blasting / tunnelling. Significant effects during day time period were identified at the construction workers camp during construction of temporary facilities. During night time works, significant effects were identified in the village of Hollar, at the shrine near Karot and at the construction worker camp.

• Noise impacts (nuisance) as a result of site traffic movements to and from site, including abnormal loads. Significant effects are likely at the peak of the construction period.

• Construction phase NVCP prior to any site preparation and construction works

• Develop operational NVCP prior to operation

Air Quality Management Plan (AQMP)

• To define the minimum requirements that will be implemented to mitigate any potential negative risks to the environment, workers or the community resulting from air emissions that arise during the construction phase of the Project.

• Deterioration of air quality as a result of

– Site preparation; tunnelling; land clearing; quarrying; road construction; spoil deposition; general construction activities

– Traffic and vehicle movements on site roads

– Transportation of spoil to disposal sites

– Construction traffic and machinery





Water Quality Management Plan (WQMP)

• To guide the means by which KPCL and the EPC contractor will ensure that the Project and its activities do not cause unacceptable contamination or impacts to water resources and that process and potable water meet applicable standards.


• Pollution caused by the discharge of industrial process water (effluent) to a water resource

• Pollution caused by the discharge of sewage to a water resource

• In-river construction works contributing to a deterioration in water quality

• Sedimentation as a result of blasting, excavation and spoil disposal, vegetation clearance

• Deterioration of groundwater quality from blasting and tunnel boring

• Develop WQMP prior to any site preparation and construction works

• Develop WQMP prior to operation

Spill Prevention and Response Plan (SPRP)

• To define the requirements and procedures to be followed during the handling and storage of chemicals, lubricants, solvents, oil and fuel throughout the Project as well as the prevention and response to land-based spills.


• Pollution caused by improper materials handling and storage

• Contaminated material generated from fuel spills and leaks

• Develop construction SPRP prior to any site preparation and construction works

• Develop operational SPRP prior to operation

Blasting and Explosives Management Plan (BEMP)

• A BMP is a risk control plan used in explosive blasting. It aims to ensure blasts do not harm people in the area and limit damage to the environment.

• A BMP is the recommended method for planning safe use of explosives.

• Risk of blasting activities resulting in accidents, injuries, or noise and vibration that cause damage or result in a nuisance


Spoil Management Plan (SMP)

• To define the requirements that will be implemented to manage monitor any potential negative risk and impacts to the environment, workers or the community resulting from the excavation/blasting, handling, transportation and disposal of spoil.

• Dust as a result of excavation, blasting and transportation of earthen materials

• Landslide from stockpiling, vegetation removal, excavation and blasting

• Erosion and sedimentation from the flow of rainwater into the Jhelum River

• Landscape and landuse changes, diversion of tributaries at disposal site #1 and #4

• Prior to site any site preparation and construction

Excavation and Slope Stability Plan (ESSP)

• To define requirements to protect slopes during excavation and engineer final slopes employing GIIP.

• Landslide from stockpiling, vegetation removal, excavation and blasting

• Impacts from reservoir level changes

• Construction of access roads and loss of vegetation

• Prior to any excavations works or road access works

Sediment and Erosion Control Plan (SECP)

• Provides the basis for KPCL and the EPC contractor to manage and control erosion caused by construction and operation activities and to

• Erosion and sedimentation from the flow of rainwater into the Jhelum River

• Prior to any site preparation and




minimise impacts on water quality and aquatic habitat erosion and sedimentation. Refer to Appendix A.

• Loss of storage capacity of the reservoir as a result of sedimentation

• Changes to downstream sediment transport regime and river morphology

construction works

• Prior to construction

• Develop operational SECP prior to operation

Chance Finds Procedure • Project-specific procedure that outlines what will happen if previously unknown heritage resources, particularly archaeological resources, are encountered during project construction or operation.

• Damage to unrecorded archaeological and cultural heritage features


Biodiversity Management and Action Plan (BMAP)

• The BMAP will provide details on the implementation of the mitigation measures presented below, as well as details of other actions identified following stakeholder consultation.

– Measures to Prevent the Spread of Non-native and Invasive Species

– Terrestrial Habitat Restoration and Creation

– Mitigation Measures for Terrestrial and Riparian Animal Species

– Monitoring

• IFC PS6 requirements (Paragraph 20) in relation to legally protected areas will be examined and actions identified as part of the BMAP.

• The BMAP will also define the requirements of the Habitat Removal and Restoration Plan (HRRP).

Construction

Terrestrial habitats and flora:

• Loss and degradation of terrestrial and riparian habitat

• Introduction or spread of non-native invasive species

Terrestrial and riparian fauna:

• Habitat loss/degradation

• Disturbance (presence of people, artificial lighting and noise)

• Injury or death owing to construction works (including trapping in deep excavations) and increased traffic

• Temporary habitat fragmentation

• Changes in hydrology and water quality

Aquatic habitats and species Reach A:

• Changes in water quality (increase in turbidity)

Aquatic habitats and species Reach B:

• Permanent loss of habitat obstruction to fish movement

Aquatic habitats and species Reaches C to E:

• Changes in water quality

• Changes in flow (both quantity and variability)

• Temporary loss of habitat


• Implemented throughout construction and operation (up to 10 years)

• Live document to be updated once per annum




Operation

Terrestrial habitats and flora:

• Permanent loss of habitat under the footprint of the reservoir

• Dust deposition and run off from increased vehicle movements

• Permanent habitat fragmentation (low scale)

Terrestrial and riparian fauna:

• Permanent loss of habitat under the footprint of the reservoir

• Permanent habitat fragmentation (low scale)

• Increased disturbance, noise, dust

• Increased risk of road kills

• Changes in environmental flows, increase in water level along the reservoir, and obstruction of movements for riverine species

Aquatic habitats and species Reach A

• Creation of a reservoir

Aquatic habitats and species Reach B

• Physical barrier

Aquatic habitats and species Reach C:

• Changes in water quality (temperature, sediments)

• Changes to the flow regime

Aquatic habitats and species Reach D:

• Changes in water quality (temperature)

• Changes in water quality (chemicals due to pollution events)

• Changes in water quality (sediments transport)

• Changes to the flow regime (high flow season)

Aquatic habitats and species Reach E:

• Changes in water quality (temperature)

• Changes in water quality (chemicals due to pollution events)




• Changes in water quality (sediment transport)

• Changes to the flow regime (low flow season)

Ecological Management Plan (EMP)

• The EMP will cover construction only. The objective is to protect biodiversity for the construction phase of the Project in the Project area. The EMP will detail the EPC contractor’s commitments to managing and monitoring impacts on flora and fauna.

• Refer to construction impacts for BMAP • Prior to any site preparation and construction works

• Restoration will start once construction is complete at individual sites and prior to operation

Habitat Removal and Restoration Plan (HRRP)

• In accordance with the BMAP, the HRRP will set out the minimum requirements in relation to the clearance and restoration of natural habitats, and the removal, storage and reinstatement of soil.

• Guide the means by which KPCL and the EPC contractor will minimise a project’s area of disturbance, create a stable landscape, and restore land and vegetation of disturbed areas.

• A key objective of the rehabilitation and landscaping works is to restore disturbed land and vegetation so they are at least equivalent to their pre-existing condition, with self-sustaining vegetation and minimal visual disturbance.

• The Plan will be based in part on baseline conditions that existed prior to project disturbance, as defined in the ESIA.

• Visual impact and loss of amenity

• Sedimentation and erosion

• Habitat removal


• To be implemented throughout the construction phase

• Objectives and demonstration of implementation to be evidenced prior to operation

Health and Safety

Occupational Health and Safety (OHS) Plan

• Plan to implement a safe working environment, procedures and culture during the construction phase. Further policies / procedures to be developed if need identified through site audits.

• OHS risks, including:

– exposure to physical hazards from use of heavy equipment including cranes

– trip and fall hazards

– exposure to dust, noise and vibrations

– falling objects

– exposure to hazardous materials; and exposure to electrical hazards from the use of tools and machinery

– working around large water bodies;

– working at height, with live power equipment and lines

– exposure to electro-magnetic fields (EMFs).

• System in place prior to construction, additional plans and policies developed as needed

• Develop operational OHS plan prior to operation




Site Security Management Plan

• To ensure that the Project protects the health, safety and security of people and communities within the area of influence from any negative impacts related to the Project.

• Increase in traffic during the construction phase

• The hydropower plant as a security target

• Influx of workers and interaction with communities

• Prior to any site preparation and construction works and maintain throughout operational phase

Emergency preparedness and response plan (EPRP)

• Preparation of the EPRP is a requirement of IFC PS1 to cover potential emergencies during the construction, operation and decommissioning of the Project. The EPRP will form part of the wider suite of plans to be implemented by the KPCL EHS department. An EPRP has been prepared in Appendix B.


• Accidental and emergency situations during construction, such as cofferdam failure

• Accidental and emergency situations during operational phase such as floods, abnormal operating regime, etc.

• Develop construction phase EPRP prior to any site preparation and construction works

• Develop operational phase EPRP prior to operation

Worker Accommodation Plan (WAP)

• To ensure that all Project accommodation areas are designed, constructed and maintained as healthy, clean and pleasant locations for workers to live in.

• Hygiene, safety and security risks

• Cultural conflict risks between the host community and the migrant labour force

• Prior to construction of the worker accommodation.

• Maintained throughout the Project lifecycle

Social

RAP (and policy framework)

• Ensure that resettlement affected people’s standard of living, security of tenure and livelihoods is at least restored or improved, so that resettlement is used as a development opportunity.

• Land acquisition with physical displacement

• Land acquisition with economic displacement

• Severance affecting nomadic activities


Stakeholder Engagement Plan

• Describes the means by which the Karot Project will ensure continuous engagement with affected people and other interested parties.

• Updated when there are significant changes to the Project, such as change in phase or identification of new stakeholders.

• Broad community support

• Project awareness in the community

• Information disclosure

• Prior to construction and maintain throughout the operational phase

Worker Grievance Mechanism

• Formalised process by which grievances can be raised by the workforce during construction and operation and to allow structured investigation by KPCL to review the validity, responsibility and response / action.

• Improvement of workers’ rights and welfare • Prior to construction and maintain throughout the operational phase

Community Grievance Mechanism

• Formalised process by which grievances can be raised by the local community and staff during construction and operation and to allow structured investigation by KPCL to review the validity, responsibility and response / action. Outlined in SEP.

• Ensure community welfare






Retrenchment Plan • Minimise the impact of job losses on workers and communities. • Large scale loss of jobs • Six months prior to collective dismissal during the operation phase

Gender Strategy • The gender strategy will aim to:

– Raise gender awareness of the different roles and responsibilities within the community, the economy and agricultural production

– Implement a gender mainstreaming component in all Project related plans and programmes

– Suggest practical and measurable gender actions and targets to be achieved as a result of the Project and related programmes.

• Employment generation



Recruitment Policy • To create more employment opportunities for local people. • Enhance local employment opportunities

• Livelihood opportunity for displaced people


Human Resources (HR) Policy

• Equity in local employment benefits / minimise social conflict. Prohibit the use of child and forced labour / promote non-discrimination and equal opportunities. Special measures to promote equal employment opportunities across ethnicities and women.

• Improve employment benefits and rights in line with GIIP


Skills Training Programme

• To develop local skills creating more employment opportunities for local people.

• Enhance local employment opportunities

• Livelihood opportunity for displaced people

• Within six months of construction commencing

Community Investment Plan (CIP)

• To help mitigate the potential adverse impacts of Project-induced in-migration and to share Project benefits more fully with local communities. The CIP must be implemented in partnership with local and regional government authorities, local leaders, NGOs and civil society bodies which have local ties with communities.


• Project induced in-migration

• Within six months of construction commencing and maintain throughout the operational phase

Influx Management Strategy

• Avoid and mitigate the effects of project-induced migration in partnership with regional government and civil society.

• Linked closely to CIP

• Project induced in-migration • Prior to construction and maintain throughout the operational phase

Local Content Strategy • To help promote the participation of national companies, local businesses and local workers in the service and equipment procurement opportunities.


• Employment generation


Workers’ Code of Conduct

• To provide a minimum standard of conduct that is expected from all workers.

• Ensure worker and community welfare





Labour Commitment • To govern the treatment of workers employed by KPCLs EPC contractor and their subcontractors.

• Ensure correct treatment and welfare of workers




22

3.1 Overview

This ESMP has been developed in line with the policies, plans and procedures described in the China

Three Gorges South Asia Investment Limited (CSAIL) framework Environmental and Social Management

System (ESMS). CSAIL is an investment holding company that will acquire, develop, build, own, and

operate renewable power generation projects in Pakistan and other countries. CSAIL has established a

framework ESMS as a part of the CSAIL corporate management system. It includes CSAIL’s EHS policy,

EHS objectives, and procedures to manage environmental, health and safety, and social (ESHS) risks at

all stages of a project’s life cycle.

It is the responsibility of each project company affiliated with CSAIL to establish its own ESMS to define the

ESHS principles, objectives, and protection measures that ensure the Project does not cause

unacceptable impacts. Contractors in turn will adopt the Project Company’s ESMS; however, the CSAIL

Project Company retains ultimate responsibility for the EHS performance of all contractors.

This ESMP will be updated and/or revised as necessary to address the prevailing conditions.

Responsibilities for implementation of identified mitigation or management actions are outlined in the

ESMP and fall to KPCL and/or the EPC contractor. It will be the responsibility of KPCL and their Owners

Engineer (OE) to oversee and monitor the implementation of relevant ESMP elements by the EPC

contractor and sub-contractors that may be employed. KPCL through the OE will monitor, audit and assess

the compliance of the EPC contractor’s implementation of the relevant aspects of this ESMP during the

construction phase and ensure that corrective actions are taken when necessary to maintain EHS

performance in line with international standards and GIIP.

The EPC contractor and KPCL will be required to transpose the measures and principles of this framework

document into a Construction ESMP (CESMP) and Operational ESMP (OESMP). KPCL will be responsible

for ensuring the Project complies with mitigation measures outlined within this document for the operational

phase.

Implementation of the framework ESMS is presented in Figure 3.1.

3 Institutional Arrangements



22

Figure 3.1: CSAIL framework ESMS structure

Source: CSAIL ESMS Manual 2014 and updated by Mott MacDonald

The framework ESMS has been developed to comply with IFC’s PSs and GIIP. It articulates CSAIL’s

overarching EHS policies, EHS objectives and principles, procedures, and sustainable measures to

achieve sound and sustainable EHS performance.

A number of framework EHS management plans have been developed as part of the CSAIL ESMS (refer to

IFC Performance

Standards

CTG Environmental and Social

Management System

Good International

Industry Practice

CSAIL E&S Policy and ESMS

CSAIL Frameworks for E&S

Management Plans

CSAIL Frameworks for E&S

Management PlansKPCL E&S Policy and ESMS

Karot HPP Environmental and

Social Management and

Monitoring Plan

(E&S management plans)



20

Table 3.1). Policies, plans and procedures are needed for all potential impacts that could cause significant

adverse impacts in the absence of mitigation or other action. KPCL and the EPC contractor will use these

framework plans to develop project specific plans for the Project incorporating the requirements identified

in the ESIA and elaborated in Section 4.



21

Table 3.1: CSAIL Framework Management Plans

ID Framework Management Plan

- CSAIL EHS Policy

- CSAIL ESMS Manual

FM-01 Contractor management plan framework

FM-02 Stakeholder engagement plan framework

FM-03 CESMP framework

FM-04 Biodiversity management-action plan framework

FM-05 Blasting & Explosives Management Plan Framework

FM-06 Dam Safety Review Procedure Framework

FM-07 Emergency Preparedness and Response Plan Framework

FM-08 Erosion Control Plan Framework

FM-09 Hazardous Materials Management Plan Framework

FM-10 Noise and Vibration Control Plan Framework

FM-11 Site Rehabilitation and Landscaping Plan Framework

FM-12 Spill prevention and response plan Framework

FM-13 Waste Management Plan Framework

FM-14 Water Quality Management Plan Framework

FM-15 Operational ESMP (OESMP) Framework

FM-16 Culture heritage management procedure Framework

FM-17 Site Security Management Framework

FM-19 Occupational health and safety plan Framework

3.2 Construction

The Project Sponsors are CSAIL. The Project Company set up to deliver the Project is KPCL;Figure 3.2

demonstrates the interactions between KPCL, CSAIL and the EPC contractor.

3.2.1 KPCL EHS Management

KPCL will establish an Environmental and Social Development Cell (ESDC) in collaboration with their

Owner’s Engineer under its ESMS, in order to handle the environmental and socio-economic matters

during the proposed project. The ESDC will not be part of the proposed project organisation, and will

provide advisory services to the project and other departments. Initially, the ESDC will consist of H&S,

Environment and Social Managers of relevant qualification and experience. The strength can be increased

in the future as required.

Separate to the ESDC a Grievance Redress Committee (GRC) will be established when it is not possible

for KPCL to adequately address a grievance. The GRC will consist of members of the community, KPCL

and the Government (preferable from the Revenue Department responsible for land acquisition).



22

KPCL, through the ESDC, will coordinate with regulatory agencies like EPA AJK and Punjab and other

stakeholders who may want to send their own teams to monitor the project activities. ESDC will also inform

all employees of the details of protection and necessary care and appropriate action in accordance with the

Environmental and Social Management Plan approved by the Lender.

For the compliance implementation of the ESMP, under the KPCL ESMS, there will be one H&S Manager,

one Environment Manager and one Social Manager (depute upon commencement of field work to provide

technical assistance in implementation of the environment and resettlement plans and to coordinate with

the Owner’s Engineer environment team who will be responsible for compliance implementation and

monitoring of ESMP and reporting during the construction period). The Owner’s Engineer will be

responsible for monitoring EPC contractor’s compliance to the environmental issues listed in the ESMP.

The KPCL E&S Department will work in close cooperation with ESDC on the day-to-day activities of ESMP

and the RAP implementation.

The EPC contractor has responsibility for development and implementation of all project EHS management

plans in line with the findings and recommendations of the ESIA and ESMP. This will include development

of a formal EHS Policy reflecting the principles of the IFC Performance Standards.



Figure 3.2: KPCL organogram illustrating roles and responsibilities regarding environmental and social compliance during construction phase

Source: Provided by KPCL and modified by Mott MacDonald



24

Table 3.2: KPCL ESMS Department - Key Roles and Responsibilities

Role Number Responsibility Location Construction Operation

Environmental Manager

1 Compliance reporting on EHS issues to the Deputy Detector

[TBC] � �

H&S Manager 1 Compliance reporting on Health and Safety issues to the Deputy Director

[TBC] � �

Social Manager

1 Technical expert tasked to implement the RAP

[TBC] � �

Support staff [TBC] Community liaison, environmental reporting and monitoring

[TBC] � �

Other [TBC] [TBC] [TBC] [TBC] [TBC]

3.2.2 EPC Contractor EHS Management

The EPC contractor will be encouraged to adhere to the principles of ISO 14001:2004 and OHSAS

18001:2007 or equivalent, if not already accredited. These standards place strong emphasis on the need

for continuous improvement of the EHS management systems and resultant EHS management

performance.

The EPC contractor will be required to agree to the following actions:

� Develop a project specific CESMP and elaborate other parallel sub plans

� Implement the requirements of the mitigation activities in the construction ESMP

� Provide a construction site layout plan that identifies key activity area including laydown,

accommodation and parking etc. prior to commencement of works

� Produce detailed method statements relating to key activities that include specific reference to

requirements of the plans contained herein during the Project progression

� Provide all training necessary to oversee and implement ESMP requirements

� Be responsible for producing comprehensive suite of EHS management and coordination procedures

� Identify a full time person on site with dedicated EHS responsibilities to oversee works on site.

The EPC contractor will be required to be responsible for sub-contractor(s) performance, including sub-

contractor(s) adhere to the requirements of the CESMP. All sub-contractor(s) will be required to have

dedicated EHS staff to implement the CESMP and to monitor and manage this on an on-going basis. The

sub-contractor(s) staff will be required to liaise closely with the EPC contractor EHS staff including the

provision of monthly reports and participation in weekly construction review meetings, for example.

It is recommended that, as a minimum, the following roles are established by the EPC contractor:



25

Table 3.3: Key EPC contractor EHS staffing

Role Number Responsibility Comment

General Manager

(Unit: PMD)

1 Overall responsibility for EHS performance of Project contracted works, including sub-contractor(s).

Construction Manager

(Unit: PMD)

1 Responsible for practical implementation of EHS requirements at site and for onsite EHS performance.

EHS Expert

(Unit: QES Department)

1 Monitoring and reporting of project EHS performance. EHS regulatory interface.

Detailed in the following section

Environment Officer


1 Management and monitoring of CESMP plans implementation and environmental issues and performance

Detailed in the following section

Social Officer (Community Liaison Officer (CLO))

1 Management and monitoring of social issues and performance, Contractor community liaison officer

To work closely with the KPCL CLO

H&S Officer


3 Management and monitoring of CESMP plans implementation and report health and safety issues to the EHS Expert

3.2.2.1 EPC contractor EHS Expert

The EPC EHS Expert will report directly to the General Manager and be responsible for reporting on

overall EHS performance. This will include identifying and managing EHS risks and monitoring key

performance indicators (KPIs). The EHS Expert will need to work to co-ordinate efforts based on inputs

from the Environment Officer and assist in the allocation of staff with the skills for applying the CESMP on

site. It is envisaged that the EHS Expert will:

� Ensure that the Environment Officer and designated staff are adequately qualified to understand and

implement the CESMP

� Nominate personnel to assist the Environment Officer as required

� Be responsible for communications with KPCL and other Project management with regard to

environmental issues and non-compliances.

3.2.2.2 Environment Officer

The EPC contractor Environment Officer will be required to nominate a person(s) to be appointed to take

the primary responsibility for day-to-day implementation of the CESMP and parallel management plans.

The formal job description would be generally in accordance with the elements provided below.

The nominated person will carry out the following responsibilities:

� Take prime responsibility for practical implementation of the environmental management;

� Oversee and ensure the implementation of the CESMP and parallel management plans (with support

from the EPC contractor EHS Expert and Construction Manager and ensure all contractors and sub-

contractors are in compliance with the CESMP requirements

� Review and report performance to the EPC contractor Construction Manager and KPCL



26

� Review sub–contractors environmental protection/mitigation measures to ensure compliance with the

CESMP

� Report on a daily basis any CESMP non-compliances to the EPC contractor Construction Manager

� Carryout regular environmental awareness sessions and assist personnel in applying environmental

standards on site

� Conduct regular audits/inspections to check that committed impact mitigation measures are being

implemented

� Act as the first point of contact on environmental matters for the EPC contractor, for the government

authorities, other external bodies and the general public.

There are certain criteria that the EPC contractor Environment Officer will be required to have knowledge

and experience in, including:

� An understanding of the international standard techniques of environmental management

� Familiarity with local environmental legislation and the likely developments in this field

� Practical operation of environmental monitoring techniques

� Ability to summarise environmental data in order to produce concise and conclusive reports

� Hold the confidence to enforce strict, but pragmatic, environmental control procedures and to motivate

the construction staff to a high level of environmental awareness

� Minimum of five years practical experience on construction sites.

3.3 Operational

The proposed organisational structure for the operational phase will be largely similar to that proposed for

the construction phase as shown in Figure 3.1. An operational phase ESMS will be developed in line with

the requirements of the CSAIL ESMS framework and aligned to the principles of ISO 14001.



27

4.1 Overview

As discussed in Section 3, this document has been prepared to incorporate the principles of the CSAIL

ESMS. Table 2.2 summarises the key policies, plans and procedures required for the Project for both the

construction and operation phases, which were determined through the ESIA process, and identifies the

impacts they are designed to address.

Sections 4.2 to 4.33 elaborate on all the relevant plans or procedures identified in Table 2.2, which must be

adhered to during construction and operation of the Project. These mitigation measures have been

developed in line with the IFC PS and GIIP and where appropriate, reference has been made to the EHS

framework management plans detailed in the CSAIL ESMS, which describe the required contents of the

management plans to be developed further by KPCL and the EPC contractor. The interactions between

each policy, plan and procedure is provided in Figure 4.1.

4 Policies, Plans and Procedures



28

Figure 4.1: ESMP interactions between policies, plans and procedures




29

4.2 Construction and Operational Environmental and Social Management Plans

An overarching CESMP will be prepared in accordance with the requirements of the IFC and CSAIL FM-

03. It will provide guidance on EHS management approach to be adopted by KPCL, the EPC contractor

and sub-contractors for all activities undertaken throughout the construction phase of the Project.

The CESMP details the control steps necessary to reduce EHS impacts through the entire construction

phase of the Project, identifying as a minimum:

� A description of the works

� Regulatory requirements

� Site organisation and management

� Roles and responsibilities

� Review, reporting and auditing procedures

� Mitigation and protection measures

� Monitoring requirements

� Training requirements

� Emergency response plans

� Method statements (where applicable).

It will be supplemented by various separate sub-plans and procedures (detailed in the following sections)

which will be developed to address key EHS aspects identified during the ESIA process for which detailed

control procedures and define associated responsibilities for implementation by KPCL and its EPC

contractor.

The EPC contractor will develop the CESMP and associated sub plans; KPCL and/or third party approved

by IFC will review and approve the documents. KPCL are ultimately responsibility for its implementation.

Both CESMP and similarly for the operational phase, an overarching OESMP will be prepared in prior to

the operation of the Project in accordance with IFC PS1 and CSAIL FM-15. The structure and objectives of

the report will largely be the same as the CESMP. KPCL will be responsible for ensuring the Project

complies with mitigation measures outlined within this document for the operational phase. The OESMP

and associated sub plans will be required to undergo review and approval by a third party approved by

IFC.

4.3 Traffic Management Plan

A framework TMP has not been prepared as part of the CSAIL ESMS; however, the ESIA has identified

that a Construction TMP (CTMP) will be required for this Project. The CTMP will be prepared in line with

national legislation, guidelines and international requirements.

The measures outlined below are required to ensure that all relevant policies and standards are met by the

Project. These measures will be developed further by the EPC contractor when developing the CTMP:



30

� Concrete mixing plant located at dam site, in least sensitive areas, limiting traffic movements

associated with concrete delivery to site access roads

� Provision of bus/minibus services for personnel living in nearby settlements

� Repair to damaged road surfaces and other road infrastructure

� Road maintenance fund to leave a useful asset for communities after the construction phase

� Provisions to secure Guijjar access across the river bank

� Regular inspection and maintenance of roads used by the Project

� Management regime to address and mitigate effects of landslides on access routes

� Driver training for HGV drivers and refresher course every six months for Project drivers

� Speed restrictions for project traffic travelling through communities (to be agreed with National Highway

Authority)

� Pedestrian awareness programme along the main site access route from Islamabad

� Schedule deliveries and road movements to avoid peak periods and times

� Temporary signage

� Flagmen will be provided when construction traffic will affect public roads

� Details of abnormal load escort proposals

� Community liaison scheme to facilitate formal communication channel between EPC contractor and

community

� Route planning to avoid or minimise disturbance to sensitive receptors (hospitals, schools, etc.)

� Strict enforcement of TMP requirements, with possibility of dismissal for violations.

� Liaison with the Provincial Highway Department of the Punjab province regarding the management

regime which specifically deals with landslides on access roads

The following monitoring provisions will be included as part of the CTMP:

� KPCL to review EPC contractors CESMP and CTMP to ensure continuity with commitment in this

ESMP

� Daily vehicle checks

� Reporting on monitoring and KPIs to be provided to National Highway Authority (NHA), for example:

– Number of complaints relating to traffic and transport

– Reporting of accidents and statistics by EPC contractor to KPCL

� Monthly monitoring/ review meetings to be held between KPCL/ EPC contractor and NHA

� Six monthly road condition reports.

KPIs include:

� Speed limits of vehicles, traffic congestion on main roads near project sites

� Truck conditions and maintenance

� Vehicular accident records

� Vehicle safety signals (flares, warning lights, reflectors), fuelling procedures, loading/off-loading

procedures

� Driver training records

� Log of maintenance activities

� Log of complaints relating to traffic and transport.



31

4.4 Site Waste Management Plan

A construction SWMP will be developed by the EPC contractor in accordance with the CSAIL Waste

Management Plan Framework FM-13, IFC Performance Standard 3: Pollution Prevention and Resource

Efficiency and IFC General EHS Guidelines: Environmental, section 1.6 “Waste Management”.

Various waste streams are anticipated during the construction phase, such as spoil, concrete, timber and

domestic waste. Spoil is the most significant waste stream during the construction phase and as such a

dedicated Spoil Management Plan will be developed. During the construction phase, the EPC contractor

will apply the following general waste management requirements to all site activities:

Material use

� Best practice waste management begins with waste prevention and minimisation, re-using materials on

site wherever possible; the most significant opportunity in the construction phase is with respect to

excavated spoil

� Instituting good housekeeping and operating practices, including inventory control to reduce the

amount of waste resulting from materials that are out-of-date, off-specification, contaminated,

damaged, or excess to plant needs

� Instituting procurement measures that recognise opportunities such as ordering the correct amount of

materials to be delivered when needed, reducing the amount of packaging used by suppliers and

establishing a take back system with suppliers

� Seeking ways to reduce raw material consumption through efficiency audits in the operational phase

� Substituting raw materials or inputs with less hazardous or toxic materials wherever economically and

technically feasible

Segregation

� Wastes will be appropriately segregated in designated storage areas, such that hazardous and non-

hazardous wastes are not mixed and to allow for recycling and reuse where appropriate

� Hazardous waste (such as oils, lubricants, batteries, chemicals and medical waste) will be segregated

from other waste types to avoid cross contamination

Storage

� All wastes generated shall be correctly identified and stored pending collection/transfer for reuse,

recovery, recycling or disposal in an environmentally sound manner

� Designated storage areas are likely to include the waste dumping yard, which is located on middle

zone of the disposal yard at left bank upstream gully

� The waste storage areas will be located on areas of impermeable hard standing to prevent leaching of

any contaminants should spillage or leakage occur

� All skips to have a suitable cover

� Liquid wastes/oil/chemicals to be stored in tanks or drums located in bunded areas which can hold

110% of the capacity of the largest tank or drum or, for multiple drum storage, 25% of the total volume

of material stored

� Install temporary sediment basins, where appropriate, to capture sediment-laden run-off from site



32

� Store hazardous waste in closed containers away from direct sunlight, wind and rain in designated

storage areas

� Provide adequate ventilation where volatile wastes are stored

� Provide readily available information on chemical compatibility to workers including labelling each

container, demarcation of the area (eg on a facility map/site plan)

� No underground storage tanks or underground piping of hazardous waste to be included in the Project

design

Handling

� Handling and storage shall be carried out by trained staff

� Spill response equipment will be made available and maintained in areas where hazardous wastes

may be spilt and an appropriate number of site personnel will be trained in spill response techniques

� Prepare and implement spill response and emergency response plans to address any accidental

release and leakage

�

� Each waste shipment will be assigned a unique waste consignment number. The EPC contractor Site

Manager is responsible for ensuring that a register is kept at site recording all waste shipments leaving

the site and their disposal destination

� A Waste Transfer Note will accompany all waste consignments from the construction site to the

disposal destination

Disposal

� Project landfill sites will be appropriately engineered with an impervious protective membrane and a

support layer of clay to prevent ground contamination, and it will be equipped with a leachate

collection/processing area.

� Offsite waste treatment or disposal facilities used will be appropriately permitted, or if not available

based on the most suitable site on consultation with the Environmental Protection Agency (EPA)

� The EPC contractor Site Manager will not release the waste if there is concern about the standard of

transport or destination of the waste

� Disposal of any medical waste must be undertaken at licensed facilities

Monitoring and inspection related to waste management during construction activities will be conducted for

the duration of the Project construction phase, and as a minimum will include

� Records of waste volumes generated by the site and indicate the final disposal option for each waste

stream

� Records of consignment and waste transfer notes

� Weekly site walkover inspection to monitor effectiveness of the SWMP

� Quarterly audit of waste management practices

KPCL will be required to develop an operational SWMP prior to the operation of the HPP, in line with the

CSAIL Waste Management Plan Framework FM-13, IFC Performance Standard 3: Pollution Prevention

and Resource Efficiency and IFC General EHS Guidelines: Environmental, section 1.6 “Waste

Management”, as well as relevant policy and legislation in Pakistan.



33

The plan will contain:

� The establishment of a waste management hierarchy philosophy that considers prevention, reduction,

reuse, recovery, recycling, removal and finally disposal of wastes

� A map showing each waste storage location for the Project

� A description of each waste generated by the operation of the facility, the appropriate handling

methodology, the correct approach for storage and the correct route for removal/disposal off site

� Staff training requirements with respect to waste handling procedures

� Waste generation data collection for each waste stream by volume, according to the EWC. This will

include the proportion of each waste stream going for reuse, recycling or disposal; any unusual waste

volumes will be investigated

� Any waste monitoring as deemed to be necessary

� An audit schedule which details the frequency of waste management audits and those responsible for

undertaking them

� A section related to continuous improvement and corrective actions where audit findings can be

recorded and incorporated into the waste management procedure; this will also highlight any new and

feasible reuse or recycling opportunities which may arise over time

� A mechanism by which to routinely track waste consignments from the originating location to the final

waste treatment and disposal location

� The correct procedure for reporting any environmental incidents related to waste

� The specific regulatory reporting requirements as they relate to waste

In addition, KPCL will commit to:

� Keeping waste carriers’ licences on site.

� Complete in full all transfer and consignment notes related to waste uplifts, including an accurate

description of the waste and be signed by the producer and carrier before waste leaves the site

4.5 Noise and Vibration Control Plan

A Noise and Vibration Control Plan will be developed and implemented by the EPC contractor in

accordance with the CSAIL FM-10 framework, the IFC PS2 and 3, World Bank Group General EHS

Guidelines on Noise Management and World Bank Group EHS Guidelines for Mining.

The plan will include the following measures:

� Planning activities in consultation with local communities so that activities with the greatest potential to

generate noise are planned during periods of the day that will result in least disturbance

� Using noise control devices, such as temporary noise barriers and deflectors for impact and blasting

activities, and exhaust muffling devices for combustion engines

� Avoiding or minimising project transportation through community areas

� Unnecessary revving of engines will be avoided and equipment will be switched off when not in use

� Internal haul routes will be kept well maintained

� Plant and vehicles will be sequentially started up rather than all together

� Use of effective exhaust silence systems or acoustic engine covers as appropriate

� Plant will always be used in accordance with manufacturers’ instructions



34

� Care will be taken to site equipment away from noise-sensitive areas

� Where possible, loading and unloading will also be carried out away from such areas

� Regular and effective maintenance by trained personnel will be undertaken to keep plant and

equipment working to manufacturers specifications

� Screening e.g. noise barriers and bunds will be used as appropriate

� Vibration barriers can provide limited attenuation and will be used as appropriate

� Procedures for handling noise and vibration complaints

� Advance notification of at least 24hrs to all sensitive receptors during critical phases of construction

and during blasting events

� Blasting should be limited to daytime works only

General noise control measures have been included within the E2V2 Design document provided as part of

the bid proposal commitments to the EPC contractor. Section 9.3.4 - Noise Control notes the following

commitments:

� The low-noise equipment and technology shall be selected, and the equipment’s maintenance and

curing shall be strengthened, meanwhile, the vibration damping base is employed to lower the noise

and operation noise

� Reasonably arrange the construction time from night: 22:00～next day: 7:00 and strictly control the

open-air blasting and work by comprehensive processing plant so as to reduce the influence on

constructors in the periphery

� In the villages or construction campsite where the vehicles go by, set up the traffic signboard or

warning board, limit the time speed of vehicle and avoid vehicle’s’ noises influencing adjacent residents

and constructors

Construction noise and vibration levels shall be monitored and assessed:

� Generally as set out in ISO 1996 ‘Acoustics –Description, measurement and assessment of

environmental noise –Part 2: Determination of environmental noise levels’ (2007)

� At monthly intervals throughout construction, but not at pre-arranged times

� As and when required, during critical phases of construction, i.e. when possible exceedance of the

Project noise criteria is anticipated

� In response to reasonable noise complaints being received

� At locations representative of sensitive receptors in the vicinity

� For blasting activities each and every blast shall be monitored by the blasting contractor at high risk

receptors

Furthermore it is recommended that prior to commencement of construction works, a detailed pre-

construction building condition survey of identified at risk buildings, and structures i. the Shine within the

Project site shall be conducted by a suitably qualified engineer. The survey shall include, but not be limited

to, the following:

� Existing condition of buildings, services or structures, including existing levels of any aesthetic damage

or structural damage

� Record (including photographs) of the major features of the buildings, services and structures including

location, type, construction, age and present condition, including defects

� Foundation type of the buildings, services or structures



35

� Preparation of a report recording the findings of the survey. A copy of each report shall be forwarded to

the EPC contractor EHS Expert and kept on file

� Re-survey of buildings, services and structures, which are the subject of complaints or if the vibration

criteria limits have been exceeded and there is potential for damage to occur

Within six months of completion of the Project construction, a detailed post construction condition survey of

the same building, services and structures shall be conducted and a report prepared.

4.6 Air Quality Management Plan

The EPC contractor will be required to implement an Air Quality Management Plan in line with the

requirements of IFC EHS General Guidelines on Air Emissions and Ambient Air Quality.

The Plan will include the following mitigation measures:

� Minimising dust from material handling sources, such as conveyors and bins, by using covers and/or

control equipment (water suppression, bag house, or cyclone)

� Minimising dust from open area sources, including storage piles, by using control measures such as

installing enclosures and covers, and increasing the moisture content

� Dust suppression techniques, such as applying water or non-toxic chemicals to minimise dust from

vehicle movements

� Land clearing, removal of topsoil and excess materials, location of haul roads, tips and stockpiles, and

blasting will be planned with due consideration to meteorological factors (eg precipitation, temperature,

wind direction and speed) and location of sensitive receptors

� Water spraying and surface treatment (eg hygroscopic media such as calcium chloride and soil

natural–chemical binding agents) of roadways and exposed stockpiles using a sprinkler system or a

”water-mist cannon”

� Open burning of solid waste will not be allowed

� Exposed surfaces of stockpiled materials will be covered or vegetated

� A simple, linear layout for materials-handling operations to reduce the need for multiple transfer points

will be designed and installed

� Dust emissions from drilling activities will be controlled at the source by dust extractors, collectors, and

filters, and wet drilling and processing will be adopted, whenever possible

� Dust emissions from processing equipment (eg crushers, grinders, screens) will be adequately

controlled through dust collectors, wet processing, or water spraying; dust control applications will

consider the final use of extracted material (eg wet-processing stages are preferred when wet materials

or high water contents would not negatively affect their final use)

� Use of mobile and fixed-belt transport and conveyors will be preferred to hauling the material by trucks

through internal roads, where possible (enclosed rubber-belt conveyors for dusty materials are

recommended in conjunction with cleaning devices)

� Procedures to limit the drop height of falling materials will be adopted

� Internal roads will be adequately compacted and periodically graded and maintained if they are not

tarmacked



36

� Regardless of the size or type of vehicle, fleet owners/operators will need to implement the

manufacturer recommended engine maintenance programs

� Drivers will be instructed on the benefits of driving practices that reduce both the risk of accidents and

fuel consumption, including measured acceleration and driving within safe speed limits

� Impose and signpost a maximum-speed-limit of 15mph on surfaced and 10mph on unsurfaced haul

roads and work areas

– At locations where blasting will be carried out, the World Bank Group EHS Guidelines for

Construction Materials Extraction provide the following specific guidance with respect to blasting,

which will need to be incorporated within the CESMP:

– Alternatives to blasting, such as hydraulic hammers or other mechanical methods, where possible

– If blasting is necessary, planning of the blasting (arrangement, diameter, and depth and direction

of blast holes) will need to be implemented

– The correct burning of the explosive, typically composed of a mixture of ammonium nitrate and

fuel oil, will need to be ensured by minimising the presence of excess water and avoiding incorrect

or incomplete mixing of explosive ingredients

� Blasting activities to be carried out in accordance with the Blasting and Explosives Management Plan

Figure 4.2: Construction study area




37

The monitoring requirements for the Plan will be undertaken as follows:

� Owner’s Engineer and EPC contractor EHS Expert to keep a log and undertake daily visual checks and

any dust complaints

� Owner’s Engineer and EPC contractor to undertake bi-weekly visual checks of construction vehicles.

(violation to be reported only)

� EPC contractor to maintain servicing records for all vehicles

� KPCL to review EPC contractor’s servicing records at beginning of contract and thereafter on six

monthly basis for those longer term contracts lasting more than six months

4.7 Water Quality Management Plan

The EPC contractor will be required to prepare a water quality management plan prior to construction, in

line with the CSAIL ESMS framework water quality management plan (CSAIL FM-14), IFC PS3 and the

EHS General Guidelines.

The measures outlined below are required to ensure that all relevant policies and standards are met by the

Project; these measures will be developed further by the EPC contractor when developing the water quality

management plan.

Sewage wastewater

� There will be no discharge of any sewage wastewater to surface waters without primary treatment in

accordance with limits outlined within the Project construction permit

� Water discharged from the waste water treatment plant will meet National Environmental Quality

Standards

� The wastewater streams from temporary and permanent toilet facilities and kitchens located within

Project area will be disposed of either once treated, or using septic tank and soakaways

Construction waste water discharge from construction sites (including sanitary waste water)

� Site construction compounds away from sensitive water features to avoid pollution (waste or sediment)

or erosion

� Water containing silt will not pumped directly into any surface water bodies

� Install waste water treatment plant and treat construction waste water

� Settlement ponds to collect run-off from the construction site (from washing aggregate and/or storm

water) to allow suspended solids settle prior to discharge and to be located close to the wash plant

� Sediment settlement ponds will also be installed for drainage channels that capture run off from the

spoil piles and on site to minimise suspended sediment entering the river system.

� Other waste water streams will be treated by settling ponds/sludge flocculation prior to discharge into

the Jhelum River.

� Settlement ponds to be drained periodically, and the resulting consolidated material will be removed

mechanically

� Appropriate use of buffer zones to capture excess debris to minimise rock debris entering the river

system

� Use of slope stability, tree-planting schemes to limit overland runoff on steep slopes



38

� Best practice measures to control vehicle wash discharges, including wheel washes and plant washing

facilities are securely constructed with no overflow

� Wash water is to be reused on site wherever possible.

� Suitable provision is to be made for the storage and handling of concrete wash water, the washing out

of concrete mixing plant or ready mix concrete lorries so that washings do not flow into any drain, any

watercourse, or seep underground. Wash water is to be stored and allowed to evaporate in a

settlement pond.

Spills

� The EPC contractor should refer to, and implement the pollution prevention procedures outlined in the

Spill Prevention and Response Plan (detailed in Section 4.11)

Groundwater

� The EPC contractor will through their community liaison officers review any complaints received from

local communities with regards to impacts on water resources. Where these impacts have potentially

resulted from construction activities suitable remediation measures will be undertaken by the EPC

contractor

During construction, the EPC contractor will be required to monitor:

� Water quality sampling upstream and downstream of the works, on a monthly basis. Samples to be

tested for a standard suite of parameters based on the most stringent of the applicable national NEQs

standards and IFC General Guidelines as set out in Table 4.1.

Table 4.1: Water quality parameters

Pollutant Unit IFC Guideline value NEQs standard (maximum allowable)

pH pH 6 - 9 6-9

Biochemical oxygen demand (BOD)

mg/l 30 80

Chemical oxygen demand (COD)

mg/l 125 150

Total nitrogen mg/l 10 -

Total phosphorus mg/l 2 -

Oil and grease mg/l 10 10

Total suspended solids (TSS)

mg/l 50 200

Total coliform bacteria MPNb/100 ml 400a -

a Not applicable to centralised, municipal, wastewater treatment systems which are included in EHS Guidelines for Water

and Sanitation.

b MPN = Most Probable Number

Post construction, the water quality management plan will be adapted to meet the management and

monitoring requirements for the operation phase. KPCL will be responsible for the development and



39

implementation of the plan and will be required to monitor the same parameters as above, but it may be

acceptable to reduce the frequency to quarterly.

4.8 Spill Prevention and Response Plan

A spill prevention and response plan must be prepared in line with the requirements of IFC PS1 and CSAIL

FM-12 for the construction and operation of the Project.

The following spill prevention measures will be undertaken by the EPC contractor Environment Manager,

with assistance as necessary from the EPC contractor Environment Officer:

� Establish a complete inventory of hazardous materials (chemicals, oils, paints and fuels etc) stored on-

site so that in the event of a spill, information is available on volumes present

� Maintain copies of Material Safety Data Sheets (MSDS) for all hazardous materials held on-site so that

in the event of a spill information is available on potential risks, both to nearby receptors and the health

and safety of construction workers

� Ensure the appropriate storage and transfer requirements are in place at site

� Undertake regular inspections of equipment and facilities to check for leaks or faulty equipment. This

includes checking for dents and rust

The EPC contractor will ensure that appropriate spill response equipment is located wherever fuel and

chemicals are stored, used or otherwise managed including at the following locations:

� At all fuel and chemical storage facilities, including no’s 18 and 20 (refer to Appendix C which shows

the areas used temporarily during construction (green) in comparison to the permanent Project

features (orange)

� At re-fuelling points

� In vehicles used to transport chemicals and fuel

As a minimum, the following spill response equipment will be held and maintained by the EPC contractor

on site such that it can be deployed to the spill scene:

� Absorbent pads

� Dry granular absorbent

� Appropriate Personal Protective Equipment (PPE)

� Chemical resistant storage drums

� Sandbags

� Shovels made or coated with polyethylene (non-sparking material)

� Corrosion resistant pump

� Hoses

� Warning tape, traffic cones or temporary barricade fencing

Used spill response supplies and contaminated soils or materials must be disposed of in accordance with

the site waste management plan.



40

The type of response to be mounted in a spill event is determined by the size of the spill and an

internationally recognised three tier system will be adopted.

Splashes, drips and spills

� Response to splashes, drips and spills from leaking plant, vehicles and equipment will be immediate

and will be undertaken by the EPC contractor’s personnel involved in the incident. All site personnel

will be trained in response and clean-up procedures for Tier 1 spills

� EPC contractor’s personnel will place wastes generated as a result of the spill clean-up in a clearly

labelled containers for storage

� The EPC contractor Environment Officer will complete a Spill Incident Report using a Spill Incident

Report sheet and submit this to the EPC contractor EHS Expert

Large bulk fuel or liquid chemical storage tank spills

� In the event of a large bulk fuel or liquid chemical storage tanks spill, attendant personnel will

immediately notify the EPC contractor EHS Expert and EPC contractor Environment Officer using the

site emergency notification procedures

� On the advice received from the EPC contractor EHS Expert, the EPC contractor Site Manager will

determine the necessity or otherwise of initiating additional spill response including:

– Enlisting spill response teams for other contractors onsite

– Emergency Services (firefighting team, ambulance, police)

� The tier 2 response team will place solid and liquid wastes generated during clean-up in suitable

containers

� A Spill Incident Report sheet will be completed as for Tier 1 spills

Monitoring and inspection related to spill prevention and response during construction activities will be

conducted for the duration of the Project construction phase, including weekly walkovers and refuelling

compliance checks.

4.9 Materials Handling and Storage Plan

A framework Materials Handling and Storage Plan has not been prepared as part of the CSAIL ESMS;

however, the ESIA has identified that a Construction Materials Handling and Storage Plan will be required

for the Project. The plan will be prepared by the EPC contractor in line with national legislation, guidelines

and GIIP.

The plan will identify storage areas to be established during the construction phase and will require these

to be specifically designed giving due consideration to the following requirements:

� Located away from sensitive receptors

� Not at risk from theft or vandalism

� Protection from the elements

� Easily accessible in a safe manner

� Well ventilated

� Unlikely to be damaged



41

� Bunded and with spill kits provided close by (as necessary for hazardous liquids)

The construction and operational procedures will include reference to the control measures in order to

minimise the likelihood of incidents associated with materials storage, handling and use. This will include

the following:

� Identification of the necessary bunding and spill kit requirements

� Details of the correct procedure for handling and storing any hazardous materials

� A map showing the material storage locations

� Vehicle and equipment fuelling to only be undertaken in designated areas on impermeable surfaces

with adequate spill protection in place

� Training requirements (as necessary) with respect to materials handling procedures, use of PPE, spill

procedures and emergency response procedures

� The correct procedure for reporting any environmental incidents related to spills/leakages

4.10 Blasting and Explosives Management Plan

The Blasting and Explosives Management Plan (BEMP) will be prepared by the EPC contractor in

accordance with the following international guidance (World Bank Group General EHS Guidelines and

World Bank Group EHS Guidelines for Mining) and CSAIL frameworks (CSAIL FM-05) as well as national

legislation (Pakistan Explosives Act (1894)).

Key principle of the BEMP will be to avoid blasting where possible. Clear reasons and need for blasting

and use of explosives must be demonstrated over and above use of mechanical removal. In the even

blasting is required the procedures outlined in the BEMP will be implemented. Permits for the purchase

and transport of explosives will also need to be obtained.

The BEMP will meet the following requirements:

� Explain the objectives of the blast

� Identify hazards and risks, including control and/or mitigation

� Identify site-specific requirements

� Use of low energy explosives for blasting areas of low overburden

� Control the blast process from design to initiation and in the event of a misfire

� Comply with the approval/contract specifications

� Ensure safety of the public, site personnel and surrounding properties

� Implement a review process to ensure that the objectives are met

Mitigation measures for blasting include the following

� Identify and document risks through appropriate risk assessment

� Develop and maintain safe blasting procedures

� Security arrangements in place, such as access to authorised persons only and secured area with

guarded gate

� Ensure shot firers are licensed

� Train personnel in explosives products and blast design



42

� Develop and implement procedures to check training and competency

� Set up exclusion zones

� Use appropriate firing method and types of explosives

� Use low energy explosives for blasting in areas of low overburden

� Scheduling of traditional drilling/blasting during the drier months to avoid overloading of the sediment

transport capacity of the river.

� Pre-construction building condition survey of identified at risk buildings

� Use of temporary noise barriers and deflectors where appropriate

� Blasting should only take place during the day time

As regards monitoring, a BEMP will be prepared by the shot firer before every blast and after consulting

those involved in the blast. Records will be kept on environmental conditions of the blast, details of fly rock,

incidents or complaints, results and any proposed modification to the blast plan or future blasts.

4.11 Spoil Management Plan

A framework Spoil Management Plan has not been prepared as part of the CSAIL ESMS; however, the

ESIA has identified that one will be required for this Project. The Spoil Management Plan will be prepared

by the EPC contractor in accordance with national legislation, guidelines and international requirements for

the construction phase of the Project.

Storage

� Topsoil will be segregated from sub-soil and covered to prevent dust / wind borne emissions

� The EPC contractor will ensure that all temporary spoil waste disposal sites adjacent to excavation

areas are engineered such that they allow for the sorting and grading of spoil, removal of excess

waters through filtration, and are covered to prevent dust emissions

� Spoil disposal site #1 will be used for temporary storage of reusable spoil

� Spoil disposal site #4 will be used for the temporary storage of reusable topsoil for

reinstatement/rehabilitation works

� The EPC contractor will ensure that spoil wastes will not be mixed or contaminated with any other type

of waste generated on site

Disposal design requirements:

� 4 spoil disposal sites identified

– #1: Located at the site of a nullah (tributary) to the Jhelum River downstream of the dam. Also used

as material stocking area.

– #2: Located within the reservoir upstream of the dam; the site will sit on top of the upstream part of

the dam and will be inundated following reservoir filling; its toe is just downstream of the intake of

the left diversion tunnel.

– #3: Near Tulla village

– #4: Located at the site of a nullah to the Jhelum River upstream of the dam. Also used as landfill.

� Spoil area flood control standards range from twenty year return period to 100 year return period and

will be subject to review to ensure adequate protection during the life of the Project



43

� Spoil areas surface drainage designed to cope with ten-year return period

� Design of spoil area slopes for dynamic and static cases.

� Water retaining structures used as appropriate to protect spoil areas from surface flows

� Interception drains and drainage ditches around spoil areas and within body of spoil areas during

construction

� Slope protection engineering applied to final spoil slopes – topsoil and planting within structural

rhombus grid on slope surface

� Create non-engineered slope profiles which can be integrated into the natural topography

� Spoil areas to be progressively exposed as needed to avoid vegetation removal of large areas without

drainage and erosion measures in place.

� If earthworks restricted to dry season, stockpiles and spoil areas will be sealed and protected during

wet season.

� The EPC contractor will develop specific method statement and risk assessment for each spoil waste

disposal site.

� Topsoil will be reused on site upon re-instatement and landscaping of cut / excavated areas

The following monitoring requirements will be required during construction:

� Daily inspections by the site manager

� Routine inspections by the EPC contractor EHS Expert on a weekly to fortnightly basis

� Record volumes of spoil generated for spoil production and stockpiling daily and report monthly

4.12 Excavation and Slope Stability Plan

An Excavation and Slop Stability Plant (ESSP) must be prepared and implemented during both the

construction and operational phase. Both the EPC contractor and KPCL will be responsible for the

implementation of the plan during different phases of the project.

The mitigation measures outlined below are required to ensure that suitable protection is provided to

stability of slopes during excavation. Excavation activities are one of the major components of the

construction of this project and detailed plans and engineering measures will be required to avoid impacts.

These measures will be developed in detail by the EPC contractor when developing the ESSP.

Detailed mitigation has been provided in the ESIA and will be further elaborated in the ESSP. As a

minimum the ESMP will implement the following mitigation measures:

� Use of bagged earth retaining walls (sandbags) as temporary blocking protection to prevent erosion

� Removal of the overburden deposits at the dam site that are currently considered unstable

� Spoil areas to be progressively exposed as needed to avoid vegetation removal of large areas without

drainage and erosion measures in place.

� Without proper justification to the contrary, cutting and removal of the soil/rock mass will be performed

from upper to lower portion to maintain the slope stability

� Without proper justification to the contrary the excavation work will only be carried out during dry

season.

� Plant new trees and vegetation in the areas subjected to erosion.



44

� Monitor soil erosion at set intervals and after every significant rainfall and run-off event.

� Other measures will be employed as needed including straw bales, silt fences, stilling ponds, erosion

protection matting and bio-engineering.

� Materials will be sealed prior to rainfall.

� Site restoration will be performed as soon as disturbance in a given area is complete (not waiting until

completion of the construction works).

� Design of cut slopes for seismic actions (static and dynamic analyses)

� After the excavation of slope, timely sealing and protective measures will be adopted for soft rock slope

surface

� Geological work (assessing conditions encountered) will continue throughout construction with an

estimated 60 man years input

� Temporary works will be designed to be safe, reliable, and adequate for all loads and uses

� Other measures will be employed as needed including straw bales, silt fences, stilling ponds, erosion

protection matting and bio-engineering

� Site restoration will be performed as soon as disturbance in a given area is complete (not waiting until

completion of the construction works)

� Monitoring regime for inspecting for effects of erosion / performance of control measures

� Place interception and drain ditches on upper side of all excavation side slopes

� EPC contractor is responsible for proper maintenance of all Project roads being used during the entire

construction period including removal of slides, road surface repair and drainage system cleaning and

modification

� Landslide risk assessment will be performed covering all project components to determine probability

of hazard/impact being realised, unacceptable risks to be mitigated through design of appropriate

support or monitoring regime

� The final cut slopes will be treated with adequate drainage, slope protection works to increase stability

against surface runoff and infiltration of water

� After the excavation of slope, timely sealing and protective measures will be adopted for soft rock slope

surface

� Perform analysis of the effect of water level fluctuation on the stability of the slopes in which the rocks

are sensitive to water content changes

� Erodible rock slopes will be protected with measures such as shotcrete and drain holes and reinforced

with rock bolts or dowels

� Further study will be performed to better determine the likelihood of reservoir induced seismicity

impacting project structures, roads and communities

� Monitoring increase in seismicity due to reservoir activities. Appropriate mitigation measures to change

operations if problem is detected.

� Create non-engineered slope profiles on the spoil disposal sites which can be integrated into the

natural topography, while maintaining slope stability

During and prior to start of operational phase the following measures will be implemented:

� ESMP will require a pre-filling survey of the reservoir margins to identify areas of unstable slopes or

unconsolidated materials within the oscillation zone. If the surveys show it is needed, unstable areas

will be stabilised to avoid landslides and excess erosion into the reservoir



45

� Additional surveys will be performed for landslide/erosion-prone areas between minimum operating

level (MOL) and full supply level (FSL) periodically during operation (bi-monthly for first two years and

following every flushing drawdown, frequency beyond two years will be determined based on

monitoring observations but provisionally bi-annual basis from years 2-10); refer to Section 9.5.3

� Plant new trees and vegetation in the areas subject to erosion

� Road greening (slope vegetation)

� Monitor soil erosion at set intervals and after every significant rainfall and run-off event.

4.13 Sediment and Erosion Control Plan

A Sediment and Erosion Control Plan (SECP) has been prepared and is included in Appendix A. The

development of this plan will also take into consideration any actions identified in the development of a

Catchment Management Plan for the basin to manage and control sediment and erosion.

4.14 Chance Finds Procedure

A ‘chance finds procedure’ in line with IFC PS8, the World Bank’s Physical Cultural Resources Policy

Guidebook and GIIP will be developed and implemented for all groundworks during construction, with the

exception of tunnelling involving drill and blast or tunnel boring. KPCL will consult with the relevant

authorities to ensure that the procedure is acceptable to them and that it complies with local and national

regulations.

If any unexpected finds are encountered during earthworks or excavation works the following mitigation

approaches will be employed by the Project:

� Work will be immediately stopped in the area

� The find(s) will be demarked and protected via fencing / blocking off and the site manager and Project

Environment Officer will be contacted

� The cultural authority will be informed in order to seek guidance and specialist advice for management

of the find(s) and how best to proceed, given its nature and extent

� All finds will be recorded

The EPC contractor Environment Officer will submit a Chance Find Report to the KPCL’s Environment

Manager within one day of the find. This will record as a minimum the following information:

� Date and time of the discovery

� Location of the discovery

� Description / photo of the Physical Cultural Resources

� Estimated weight and dimensions of the find

� Temporary protection that has been implemented (if any)

The Chance Find Report will be submitted any other concerned parties as agreed with the Federal

Department of Archaeology, and in accordance with national legislation.



46

4.15 Biodiversity Management and Action Plan Framework

A project specific Biodiversity Management and Action Plan (BMAP) will be drafted at least one month

before construction to allow for actions to be implemented. KPCL will appoint a reputable NGO or

independent consultant to prepare and oversee the implementation of the BMAP and to undertake the

monitoring and some other activities that require more specialist skills.

A framework BMAP has been prepared and is included in Appendix D in order to ensure the Project:

� Implements the mitigation and monitoring in the ESIA

� Complies with national legislation and policy requirements

� Complies with lender and other international requirements

� Addresses the concerns and expectations of the stakeholders

� Implements best practice and sustainable solutions

4.16 Ecological Management Plan

The Ecological Management Plan (EMP) is the responsibility of the EPC contractor and will be developed

in line with the BMAP and the CESMP. Mitigation and monitoring measures will as a minimum include

those presented for the construction phase in the BMAP and will be in accordance with applicable

international and lender standards and GIIP.

Specifically the plan will address the following to minimise impacts on ecology:

� Prohibit off-road driving

� Reduce and control artificial lighting

� Check for nesting birds before vegetation clearance

� Protect excavation and trenches and monitor for any trapped wildlife

� Install road signs to highlight the risk of collision with animals and limit speed

� Implement measures to prevent the introduction and spread of non-native and invasive species of fish.

To ensure the biodiversity of the project area is protected, the CEMMP and EMP will include the following

as a minimum:

� Details of the environmental staff to be hired by the EPC contractor and their responsibilities with

regard to the implementation of mitigation measures and the biodiversity monitoring during

construction.

� Details of the local NGO or consultancy, and the specialists that will undertake some of the activities

that require specialist and local knowledge.

� Description of the biodiversity monitoring methods and sites to be used during construction.

� Measures to prevent the introduction and spread of non-native invasive species during construction

� On-site habitat restoration

� Prohibit off-road driving

� Reduce and control artificial lighting

� Check for nesting birds before vegetation clearance

� Protect excavation and trenches and monitor for any trapped wildlife



47

� Install road signs to highlight the risk of collision with animals and limit speed

� Implement measures to prevent the introduction and spread of non-native and invasive species of fish.

� All workers engaged in the Project will be made aware of the environmental and ecological sensitivities

(natural habitats and threatened and protected species) of the region, the Project site and their own

actions particularly relating to the avoidance of disturbing wildlife. Staff will be provided with relevant

information through staff induction, toolbox talks, leaflets and office posters.

4.17 Habitat Removal and Restoration Plan

A HRRP will be produced by the EPC contractor and reviewed by a qualified ecologist before the start of

construction.

The BMAP will provide more guidance but the HRRP is likely to include the following practices:

� Soil removed from construction sites will be stored and used in the restoration.

� Habitats affected temporarily during construction will be restored/reinstated on a ‘like-for-like or better

principle’, using the species recorded during the baseline surveys (native species only). A coherent

record of the state of the site throughout the period of construction is to be maintained.

� The tree inventories undertaken by PES in June/July 2014 and the tree inventory by the Forest

Department will be used to inform the habitat restoration, along with the habitat/land-use map prepared

for the ESIA (Volume II, Chapter 7).

� All species used in the habitat restoration will be native. No introduction of non-native plant species will

be allowed. Specifically avoid introduction of non-native carp species.

� Spoil deposit sites will be also planted with native vegetation and measures to control soil erosion will

be implemented.

� The vegetation under the footprint of the reservoir can be either cleared before flooding or it can be left

in situ. The latter option may create good habitat for aquatic species, but the rotting vegetation and

organic matter can result in temporary deterioration of water quality and lead to the production of

greenhouse gas in certain conditions. This aspect will be investigated in more detail in the BMAP and

recommendations will be provided for the most appropriate option.

� Where restoration of natural forest is not possible on site (eg under the footprint of the permanent

structures), similar habitat will be created off-site.

� Remove vegetation from footprint of reservoir and save for fuel by local population to reduce harvesting

for fuel in remaining woodland

� Store soils carefully to protect fertility for reuse at the end of the Project construction

� Preserve the seedbank from the areas which will be flooded for reuse in natural regeneration at the

end of construction

� Minimise vegetation removed and protect vegetation to be retained during the construction of the new

roads

To ensure the habitats restored on-site or created off site are established successfully, they will be

maintained and monitored for at least five years after construction by KPCL.



48

4.18 OHS Plan

An OHS plan is required to identify preventive and protective measures to protect the health and safety of

workers on site. The Plan will be produced in line with the following national and international

requirements:

� Labour code of Pakistan

� IFC PS2 – Labour and Working Conditions

� World Bank Group EHS Guidelines

� Workers’ Code of Conduct

� CSAIL ESMS Frameworks related to OHS, EPRP, blasting, hazardous materials, spill prevention,

water quality, waste management

The Health and Safety chapter of the ESIA (Volume 2, Chapter 16) identifies in more detail the relevant

content of the OHS Plan. It will be prepared and read in accordance with the Emergency Preparedness

and Response Plan (refer to Appendix B).

The OHS Plan will be in place before construction activities begin and will be applicable to construction,

operation and decommissioning phases. Each major contractor will be required to have their own OHS

Plans. KPCL will review and approve the EPC contractor’s plan and the EPC contractor will review and

approve all other contractor’s plans and procedures to ensure compliance with KPCL ESMS and health

and safety requirements and contractual clauses (including commitment to this ESMP). Monitoring of the

plans and procedures will be undertaken monthly and a progress report produced quarterly.

Both the Project labour commitment and workers’ code of conduct refer to provision, training and

appropriate use of PPE. Contractors are responsible for providing the necessary PPE and training on it.

The workers are required to keep the PPE in good condition and use it as trained.

Monitoring requirements for the OHS plan include the following:

� The EPC contractor and other Project employers will be obligated to hire staff responsible for

supervising occupational health and safety and worker accommodation on a daily basis.

� OHS monitoring results will be reported in monthly health and safety reports. At a minimum, this

monitoring will need to cover: number of workers and contractors at site, hours worked, total number of

lost workdays resulting from accidents, fatalities, lost time accidents, medical treatment and first aid

cases, near misses from unsafe acts or conditions, and OHS trainings.

KPCL will need to ensure independent monitoring of health and safety issues. KPIs to ensure the

successful implementation of the Plan include:

� Monthly monitoring and reporting of accidents, injuries, lost-time incidents, near misses and community

interactions on health issues

� First aid room use statistics

� OHS target accident rate of zero

� Monthly summaries of toolbox talk topics and coverage



49

4.19 Site Security Management Plan

A Site Security Management Plan will be developed to safeguard worker and community security, in line

with the following requirements:

� IFC PS4 – Community Health, Safety and Security

� IFC EHS General Guidelines on Community Health and Safety (CHS)

� United Nation’s Code of Conduct for Law Enforcement Officials, and the United Nation’s Basic

Principles on the Use of Force and Firearms by Law Enforcement Officials

� CSAIL ESMS FM-17 Site Security Management Plan Framework

The health and safety chapter in the ESIA (Volume II, Chapter 16) identifies the components of the security

plan which will aim to:

� Safeguard site personnel and property through equipment and processes

� Ensure standard training for all security staff

� Identify deterrents to theft, break-in, sabotage, cyber threats and terrorism attacks

Provisions in the Plan will be made to ensure:

� Key construction areas and Project elements will be fenced off/enclosed

� Explosives and chemicals will be isolated and protected

� Location of signage around site perimeter is identified through risk assessment process.

� Clear site access procedures

� Site induction is undertaken by every member of staff

� Training and vetting of security personnel

� Emergency Preparedness and Response Plan (EPRP) will be implemented

� Involvement of health and emergency service providers in developing and drills for EPRP

� Blasting and Explosives Management Plan will be prepared

KPIs and monitoring requirements include:

� Description / photographs of fencing / signage around site perimeter

� Security company licenses

� Documentation to show vetting and training of security personnel

� Site registry identification system

� Site induction procedure

Security Contractor will develop and implement the plan with the EPC contractor prior to and during

construction. Monitoring of the plan will be undertaken monthly and quarterly reports will be prepared.

4.20 Emergency Preparedness and Response Plan

An EPRP has been prepared and is included in Appendix B.



50

4.21 Worker Accommodation Plan

The WAP describes the minimum national legislative requirements plus the applicable international and

Project requirements relevant to the facility standards and management of labour accommodation. Prior to

the construction works, KPCL, the EPC contractor and any other appointed contractors responsible for

providing worker’s accommodation will commit to:

� Meeting the requirements set out in the guidance note by IFC and EBRD on workers’ accommodation:

processes and standards (2009). In particular, the provision of accommodation will meet international

good practice in relation, but not restricted, to the following:

– Practice for charging for accommodation

– Provision of minimum amounts of space for each worker

– Provision of sanitary, laundry and cooking facilities and potable water

– Location of accommodation in relation to the workplace

– Any health, fire, safety or other hazards or disturbances and local facilities

– Provision of first aid and medical facilities

– Heating and ventilation

� Workers freedom of movement to and from the employer-provided accommodation will not be unduly

restricted

� Sharing and implementing the Workers’ Code of Conduct

Monitoring requirements of the WAP will comprise quarterly labour accommodation inspections until

regular identification of no problems, then labour inspections can become six monthly.

4.22 Resettlement Action Plan

A RAP has been prepared (refer to ESIA Volume VI) which is designed to ensure that resettlement

affected people’s standard of living, security of tenure and livelihoods is at least restored or improved, so

that resettlement is used as a development opportunity. The RAP has been developed in line with IFC PS1

and IFC PS5 guidance notes.

KPCL has responsibility for implementing the RAP. Monitoring requirements will include:

� Regular internal monitoring reports based on RAP

� Audit compliance with RAP

� Resettlement completion report

The completion of RAP implementation is required prior to any vegetation clearance.

4.23 Stakeholder Engagement Plan

A SEP has been prepared (refer to ESIA Volume VII) which is designed to Manage stakeholder and

community relations, expectation, and grievances through consultation and disclosure mechanisms. The



51

SEP has been developed in line with national legislation3, IFC PS1, 2 and 5, the CSAIL ESMS FM-02

Stakeholder Engagement Plan Framework and the Workers’ Code of Conduct.

KPCL has overall responsibility for ensuring meaningful consultation and broad community support

throughout the Project lifecycle; however, the EPC contractor will be lead on stakeholder engagement

activities during construction for project performance; KPCL during the operation.

Monitoring of the SEP includes:

� Consultation logs

� Grievance logs

� Annual updating of SEP

� Six monthly community liaison and stakeholder engagement reports by EPC contractor during

construction

� Annual sustainability reporting by KPCL during operation

4.24 Labour Grievance Mechanism

A labour grievance mechanism has been developed as part of the Project Workers’ Code of Conduct and

Labour Commitment and in line with IFC PS2, these documents are provided as appendices E and F

respectively. The mechanism addresses labour grievances appropriately and on a timely basis to avoid

negative labour incidents.

KPIs to measure the effectiveness of the labour grievance mechanism include:

� Distribution and employee knowledge of labour grievance mechanism

� Labour grievance mechanism log

� Number, type and resolution timeframe of labour grievances

� No lost time because of labour strikes, disputes or incidents

It will be a requirement of the grievance mechanism that the following is undertaken:

� Six monthly toolbox talks on labour grievance mechanism

� Six monthly summary of use of labour grievance mechanism

4.25 Community Grievance Mechanism

A community Grievance Mechanism has been prepared and is included in the SEP (ESIA Volume VII).

4.26 Retrenchment Plan

To minimise the impact of collective dismissals, KPCL will be required to prepare a retrenchment plan in

line with IFC PS2 to be developed six months prior to collective dismissals during the operation phase. A

retrenchment plan would only be required during the operation phase where collective dismissals of

3 Pakistan Environmental Protection Act of 1997



52

workers that have not completed their contracts are required. For example, if the project suffered losses

and has to reduce its workforce.

4.27 Gender Strategy

A gender strategy will be developed by KPCL within three months of the loan agreement signing to ensure

that women are able to access the benefits of the Project. The strategy will be developed in line with IFC

PS1, 2 and 5 and should:

� Raise gender awareness of the different roles and responsibilities within the community, the economy

and agricultural production

� Implement a gender mainstreaming component in all Project related plans and programmes

� Suggest practical and measurable gender actions and targets to be achieved as a result of the Project

and related programmes, including:

– Including women in financial literacy training activities

– Include women in employability training activities

– Having an accommodation area for women only for international women visiting the site

The strategy will be reviewed quarterly. KPIs include:

� Labour profile to include gender disaggregated information

� Reporting on women only sessions for training activities

4.28 Recruitment Policy

In order to create more employment opportunities for local people, KPCL will be required to develop and

implement a recruitment and procurement policy in accordance with national legislation, IFC PS2 (Labour

and Working Conditions) and the Project Labour Commitment.

The plan should include:

� A clear definition of what is meant by the term “local”4

� Regular reporting of labour profile

� An employment officer and office set up

� Disclosure of recruitment and procurement policies

� Preferential hiring of displaced people

Monitoring and KPIs of the plan are as follows:

� Functioning and staffed EPC contractor employment office

� Evidence of disclosed recruitment and procurement policies, including at least 10 recruitment fairs

� Percentage of local and Pakistani employee

� Displaced people hiring statistics: Number, village of origin, duration of contract, position

4 For this Project, it is recommended that local be defined as the three districts: Rawalpindi, Kotli, and Sudhnoti



53

4.29 Human Resources Policy and Procedures

To avoid inappropriate and unfair employment conditions, a HR Policy will be developed by the EPC

contractor (prior to and during construction) and KPCL (prior to and during operation), in line with labour

codes of Pakistan, IFC PS2, the Project Labour Commitment and the Project Workers’ Code of Conduct.

Reference should also be made to the WAP.

KPCL and EPC contractor’s HR Policy and Procedures will require as a minimum:

� Project workers with contract of employment

� Job descriptions for all roles

� Payment of wages and bonuses on time

� Labour grievance mechanism

� HR files and systems with: applications showing non-discrimination and equal opportunity; signed

contracts with working conditions and benefits defined; leave requests; timekeeping records; payment

records; other relevant information

� At end of contracts workers provided with a summary of service and training activities

Monitoring of labour rights will be undertaken by KPCL, EPC contractor and third party, as follows:

� Monthly reporting by all Project employers on labour statistics including profile, hours worked and lost,

overtime use, labour incidents, etc.

� Quarterly labour rights monitoring reports by EPC contractor during construction

� Labour rights monitoring reports by KPCL and third party

� Six monthly toolbox talks on labour rights

4.30 Skills Training Programme

In order to develop local skills, the following skills training programmes will be developed by KPCL:

� Employability skills training programme, which will be provided by EPC contractor free of charge to

participants within first six months of contract

� Trade skills programme, provided by EPC contractor free of charge to participants within first year of

contract

KPIs on the development and implementation of a skills training programme include:

� 500 local people, including three nominated by each resettlement affected household, undergo a five

day employability skills training

� 250 people including displaced people receive accredited vocational training skills

� Displaced people to be part of a mentoring programme during their three month probationary period

� Records of training for local residents (name, type of training, village of origin, etc.)

� Number of trainees starting and completing courses; course evaluations

� Skills development reports will be required at months three, six, nine and 12



54

4.31 Community Investment Plan (CIP)

KPCL will be required to develop a CIP, which ensures the Project benefits are shared more fully with local

communities. Firstly, a needs assessment should be undertaken to determine what the priorities are for the

community and how money will be dispersed. This should be undertaken in consultation with community

leaders and stakeholders. Second, establishment of a CIP is undertaken in four stages:

� Establish a framework for the programme

� Identify the partners

� Establish CIP Committee headed by the Social Officer to identify and manage activities

� Implement activities (action the plan)

� Monitor, assess and report on progress

KPIs could include:

� The number of people benefitted by the initiative

� Sum of money donated, raised or contributed

� Number of voluntary hours committed by the Project Company (eg hours spent by project staff

educating children at a local school)

� Number of sub-projects developed and completed

� Community engagement – number of participants reached

KPCL will be required to produce a CIP and establish the Committee within six months of construction

commencing, KPCL will also be required to monitor its implementation and review the plan on a yearly

basis in consultation with the CIP committee.

4.32 Influx Management Strategy

An influx management strategy will be developed by KPCL which aims to avoid and mitigate the negative

effects of project-induced migration. The influx management strategy will include consideration of the

following measures, to be undertaken in consultation and in partnership with regional government (key

stakeholders will be spatial planners) and civil society:

� Organising Project recruitment and employment to minimise potential workers going to the Project site

� Ring-fencing community investment funds for spatial planning and to support local initiatives to address

greater demand for social and community services and infrastructure

� Holding influx forums every year during construction to bring together stakeholders and service

providers to create awareness of influx status, share monitoring data, identify lessons learned, and

disseminate good practice

� Supporting financial management through providing financial management seminars to workers, and

consulting with Government to promote presence of banking and micro finance services for local

entrepreneurs and small and medium businesses

The strategy should refer to and be closely aligned with the CIP.

Monitoring requirements will include:



55

� Functioning and staffed EPC contractor employment office

� Disclosed recruitment and procurement policies

� Labour profiles

� Skills training

� Population and census data for the Area of Influence

� Yearly project induced in-migration strategy evaluation report with case studies

KPCL will contract a service provider to produce annual monitoring and evaluation report on influx

management.

4.33 Local Content Strategy

KPCL will be required to develop a local content strategy, which measures in the procurement policy that

help promote small and medium local enterprises5. Options for the strategy could include: unbundling

procurement requests into smaller work packages; providing tender documentation in local languages and

free of charge; organising longer contract periods to justify acquisition of capital equipment; providing

longer deadlines to assist small and medium enterprise response; waiving or lowering performance bond

requirements for local companies; using serial contracts or framework agreements; setting aside contracts

or specific work packages that are only directed to local companies; providing price preference as part of

the tender evaluation; and requesting tenders in local currency.

KPIs of the local content strategy include:

� Development and maintenance of a database of manufacturers, consultants, companies and

contractors who can provide goods and services6

� Analysis of which products and services can best be addressed by local and national companies7

� Brochure distributed that provide basic information on the Project, a summary of the main local content

commitments, and contact information for local SMEs and interested parties to register their

capabilities or get more information on prequalification activities

� EPC contractor to have a designated staff member to liaise with local companies and implement the

local content strategy

Monitoring requirements of the local content strategy include:

� Six monthly reports on construction contracts let with relevant data such as analysis of country of origin

of company, size of contract, type of service, one off or routine

� Annual operational reports on contracts as above

5 Guidance available at http://www.engineersagainstpoverty.org/documentdownload.axd?documentresourceid=23

6 At a minimum the database needs to be alphabetical by company and include the company’s location, contact, main activities and

category of services

7 The EPC contractor should begin local content efforts by focusing on goods and services where there is low risk and local and

national companies can provide goods and services on a routine and internationally competitive basis.



56

5.1 Introduction

Effective reporting is essential for rendering an ESMP (and associated ESMS) of practical value. Routine

independent auditing provides the necessary impetus for continual improvement. Without these two

fundamental elements, such systems simply degenerate into data collecting exercises. Performance

monitoring, reporting and auditing will be carried out to ensure compliance with the requirements of this

ESMP, commitments in the ESIA and overall ESMS. The following provides an outline approach which is

aligned to the requirements of ISO 14001.The final scope and format of all reports proposed herein will be

agreed with the Lenders prior to them being required and produced. Furthermore, each of these reports

will be submitted to the Lenders for review and disclosure.

5.2 Adaptive Management

The plans contained herein will adopt an “adaptive management” approach throughout the life cycle of the

Project. The creation of the plans at the outset is a fluid process with the management objectives and

performance indicators tailored to the current design and objectives of the Project. The ESMP utilises to

the extent possible existing project knowledge to fully address the actual EHS impacts of the Project at the

time and allow flexibility in EHS management decisions made on the Project.

To ensure adaptive management of the ESMP the following actions will be implemented:

� The ESMP will be reviewed and amended in accordance to the Project design and status as it evolves.

Key information about any changes to project description will be regularly reviewed (monthly) and site

visits undertaken by KPCL EHS staff to identify the true impacts of the Project

� Evaluation of the effectiveness of measures included in the ESMP will be undertaken on a regular

basis as the Project evolves through construction, operation and decommissioning of the Project

Evaluation will be undertaken through on-going communication with the EPC contractor and

construction sub-contractors, stakeholders and lenders supplemented by site audits and monitoring

data review to identify weaknesses and / or gaps in the management plans. The ESMP will be changed

and / or updated accordingly to ensure appropriate, robust and effective EHS management

commensurate to the scale of the Project through its lifetime.

5.3 Monitoring and Reporting

5.3.1 The EPC Contractor Monthly Internal Reports

The EPC contractor will undertake on a weekly basis, compliance monitoring of the construction sub-

contractors EHS activities as per the IFC EHS Guidelines and this ESMP.

The EPC contractor will prepare a monthly report for issue to the Owner’s Engineer. These reports should

normally be no more than one or two pages in length, to summarise the following:

� Progress in implementing the ESMP and management plans

� Findings of the monitoring programmes, with emphasis on any breaches of the control standards,

action levels or standards of general site management

5 Reporting Requirements



57

� Outstanding Non-Compliance Reports (NCRs)

� Summary of any complaints by external bodies and actions taken/to be taken

� Relevant changes or possible changes in legislation, regulations and international practices.

Any breaches of the acceptable standards specified by law/construction permits and/or this ESMP will be

reported to the Owner’s Engineer, using a NCR Form.

5.3.2 KPCL’s Monitoring of Construction Activities

The Owner’s Engineer will undertake on a monthly basis, compliance monitoring of the EPC contractor’s

EHS activities as per the IFC EHS Guidelines and this ESMP. Internal audits will be undertaken within two

months of commencement of construction and thereafter every three months focussing on the

performance of the implementation of this ESMP.

Any breaches of the acceptable standards specified by law/construction permits and/or this ESMP through

monitoring of the EPC contractor and sub-contractor(s) will be reported using a NCR Form. A copy of each

completed NCR (whether prepared by the EPC contractor or otherwise) will be held on file by KPCL’s EHS

department, to be replaced by the reply copy when it is received. A record of corrective actions must also

be made and tracked to their completion.

5.3.3 KPCL’s Monitoring of Operational Activities

The EHS impacts that will occur during the operation phase have been assessed through the national EIA

process and through the ESIA (Volume II). Impacts will be managed and monitored through the

commitments outlined in this ESMP. KPCL’s EHS Director will prepare annual reports for issue to the

lenders summarising progress against implementation of KPCL’s ESMP obligations throughout the

operational phase. This will include full reporting of monitoring results where relevant.

5.3.4 KPCL’s External Reporting for Regulatory Compliance

A register of all necessary external stakeholder reporting requirements under Pakistan Legislation and for

regulatory compliance purposes will be developed where appropriate. The frequency of reporting, the

required reporting format and the person(s) responsible for producing the report (along with any necessary

specialist service providers/constructors required to assist for data collection or interpretation purposes) is

to be noted in the register.

KPCL will need to ensure that all the necessary reports are produced and submitted in a timely fashion in

order to achieve on-going regulatory compliance throughout the life of the Project. Meeting regulatory

reporting requirements also forms part of the scope for any internal audits and management reviews.

Specifically the AJK EPA requires projects to establish an Environmental Monitoring Committee, the terms

of which and reporting mechanism are to be agreed with the EPA.



58

5.3.5 Lenders Reporting Requirements

During the construction phase, KPCL will undertake quarterly reporting to the Lender’s, based on their

monthly monitoring results as a project requirement. Operational monitoring will initially be undertaken on a

six month basis in the first two years, and there after subject to agreement by Lender’s on an annual basis

throughout the loan period.

5.4 Annual Independent Audits and Lenders Reviews

5.4.1 Independent Monitoring

The IFC PS1 guidance notes state that Projects require an independent environmental and/or social expert

to verify project monitoring information. During the construction phase and as a minimum, throughout the

first year of the operations, arrangements will be made by KPCL for an industrial environmental

management specialist to carry out an independent annual audit of the existing practices against the

requirements of the ESMP. The key objectives of the audit will be as follows:

� Report on the practical implementation of the ESMP and progress since the last visit

� Establish feasible improvement objectives for completion before the next visit

These audits will be used to re-examine the continued appropriateness of the ESMP and to provide advice

on any updates required. Attention will be given to lessons learnt in the light of experience. In particular,

consideration will be given to the monitoring programmes in place to determine whether their purpose has

been served and they can therefore be terminated or reduced in frequency.

Monitoring of social issues will be important, especially with regards to worker management, workers’

terms and conditions, OHS, and grievances. External monitoring will need to verify that the Project

commitments to worker’s rights are implemented, in particular with regards to:

� Use of child labour

� Payment of minimum wages and overtime

� Not taking any action to prevent employees from exercising their right of association and their right to

organise and bargain collectively

� Ensuring no workers are charged fees to gain employment on the Project

� Implementation of plans, procedures and training for occupational health and safety

� Non-discrimination and equal opportunity

� Meaningful use of the labour grievance mechanism

� The existence of human resource policies, job descriptions, written contracts

� Provision of information to labour force regarding rights and working conditions

� Employee training activities

Annual monitoring reports of any independent advisor should be made available for public disclosure on

KPCL website and IFC website.



59

6.1 Indicative Budget

The overall indicative ESMP budget up to and during construction totals [TBC]m USD prior to the

commissioning and operation of the Project. Thereafter, an indicative ESMP budget for the operational

phase of [TBC]m USD over 30yrs has been set aside; although the duration of monitoring may not require

to be extended over 30yrs.

The ESMP budget is organised around the following areas:

� Company Level EHS Management, Co-ordination and Communication

� ESMP Compliance Monitoring

� KPCL Environmental Monitoring

� Ecological Management, Monitoring and Enhancement

� Construction Social Management

Table 6.1shows its distribution over the different areas and over the key development periods of

construction and early years of operation. The table also outlines the nature of the activities included.

Table 6.1: Indicative ESMP budget (USD)8

ESMP Budget Construction Operation

Per Year (USD) Total (USD) Per Year (USD) Total (USD)

Company Level EHS Management, Co-ordination and Communication

550,000

External ESMP Compliance Monitoring (first 5 years of construction)

50,000 [TBC]

Implementing Ecological Mitigation, Management, Monitoring and Enhancement

Environmental Flow Monitoring and Assessment (duration 3 years)

100,000 300,000

Biodiversity Action Plan (10yrs) [TBC] [TBC] [TBC] [TBC]

Ecological Monitoring and Maintenance Plan (30yrs)

[TBC] [TBC] [TBC] 1,500,000

Implementing Social Management Plans

Resettlement Action Plan [TBC] [TBC] [TBC] [TBC]

Community Investment Programme (first 5 years from 2016)

200,000 1,000,000

Community Investment / Benefit Sharing (35yrs)

[TBC]

8 Detailed budgets will be established during the preconstruction phase

6 ESMP Budget



60

6.2 Reallocation of Funds / Update of Budgets

A number of costs have been estimated on the basis of the information available at the time of the

preparation of the ESIA documentation. It is expected that the cost associated with some measures may

change. Although a provision was always made when the budget was prepared, it is possible that budgets

allocated prove to be either under-estimated or over-estimated. KPCL will propose twice per year an

update of the overall EHS budget with suggestions on ways to reallocate funds. These suggestions will be

presented to Lenders for review.



61

Appendices

Appendix A. Sediment and Erosion Control Plan ____________________________________________________ 62 Appendix B. Emergency Preparedness and Response Plan ___________________________________________ 63 Appendix C. Temporary and Permanent Project Components __________________________________________ 64 Appendix D. Biodiversity Management and Action Plan Framework ______________________________________ 66 Appendix E. Workers’ Code of Conduct ___________________________________________________________ 74 Appendix F. Labour Commitment ________________________________________________________________ 75

720MW Karot Hydropower Project Pakistan Volume IV - Environmental and Social Management Plan

350133/PHR/ENS/1/B July 2015 Karot HPP ESMP

61

Appendix A. Sediment and Erosion Control Plan

720MW Karot Hydropower Project

Sediment and Erosion Control Plan

July 2015


350133 WCD WAM 001 A

C:\Users\max36630\AppData\Roaming\OpenText\OTEdit\EC_EUNAPiMS\c1593679891\Karot HPP SECP RevA_Draft_MKP.docx

31 July 2015





July 2015


Mott MacDonald, Demeter House, Station Road, Cambridge CB1 2RS, United Kingdom

T +44 (0)1223 463500 F +44 (0)1223 461007 W www.mottmac.com

350133/WCD/WAM/001/A 31 July 2015 Karot HPP ESIA, SECP

720MW Karot Hydropower Project Sediment and Erosion Control Plan


A July 2015 M Piggott A Warren

A Warren S Hickman

A Warren Draft








Chapter Title Page

1 Introduction 1

1.1 Introduction ________________________________________________ Error! Bookmark not defined. 1.2 Scope ____________________________________________________________________________ 2 1.3 Construction Activities _______________________________________________________________ 2 1.4 Potential Impacts ___________________________________________________________________ 2 1.5 Distribution and Review ______________________________________________________________ 3

2 Relationship to Other Plans and Related Documents 4

2.1 Environmental Management Systems Overview ___________________________________________ 4 2.2 Additional Management Plans/Documents ________________________________________________ 4

3 Policy and Control Standards 5

3.1 Introduction ________________________________________________________________________ 5 3.2 National Legislation and Requirements __________________________________________________ 5 3.3 International Requirements ___________________________________________________________ 5 3.3.1 Overview _________________________________________________________________________ 5 3.3.2 IFC General EHS Guidelines for Construction and Decommissioning ___________________________ 6

4 Roles and Responsibilities 7

4.1 Overview _________________________________________________________________________ 7 4.2 KPCL/OE Roles ____________________________________________________________________ 7 4.2.1 KPCL Project Manager / OE Chief Engineer ______________________________________________ 7 4.2.2 KPCL EHS Manager_________________________________________________________________ 7 4.2.3 OE Environmental Manager ___________________________________________________________ 7 4.2.4 KPCL EHS Officer(s) ________________________________________ Error! Bookmark not defined. 4.2.5 KPCL Community Liaison Officer _______________________________________________________ 8 4.3 Contractor Roles ___________________________________________________________________ 8 4.3.1 Contractor Site Manager _____________________________________________________________ 8 4.3.2 Contractor EHS Manager _____________________________________________________________ 8 4.3.3 Contractor EHS Officer _______________________________________________________________ 8 4.3.4 All Contractor Personnel ______________________________________________________________ 9 4.4 Sub-Contractors ____________________________________________________________________ 9

5 Control Measures 10

5.1 Construction Phase ________________________________________________________________ 10 5.2 Operational Phase _________________________________________________________________ 10

6 Verification and Monitoring 13

6.1 Monitoring, Reporting and Auditing Requirements _________________________________________ 13 6.2 Inspections _______________________________________________________________________ 14

Contents



6.3 Auditing _________________________________________________________________________ 14 6.4 Non-Compliance Management ________________________________________________________ 14

7 Training 15

8 Reporting 16

8.1 Introduction _______________________________________________________________________ 16 8.2 Internal __________________________________________________________________________ 16 8.2.1 Contractor ________________________________________________________________________ 16 8.2.2 KPCL/OE ________________________________________________________________________ 16 8.3 External _________________________________________________________________________ 16

Appendices 17

Appendix A. Reservoir Sedimentation and Flushing __________________________________________________ 18 A.1 Introduction _______________________________________________________________________ 19 A.2 Review of sediment and sedimentation information ________________________________________ 19 A.3 Relevant reservoir characteristics _____________________________________________________ 19 A.4 Sediment yield ____________________________________________________________________ 22 A.5 Suspended sediment particle size _____________________________________________________ 22 A.6 Reservoir sedimentation _____________________________________________________________ 23 A.7 Sediment management _____________________________________________________________ 24 A.8 Effectiveness of sediment flushing _____________________________________________________ 25 A.8.1 Long term capacity ratio _____________________________________________________________ 25 A.8.2 Sediment flushing conditions _________________________________________________________ 25 Appendix B. Construction Site Inspection Checklist __________________________________________________ 27


350133/WCD/WAM/001/A 31 July 2015 Karot HPP ESIA, SECP 1

1.1 Overview

The purpose of this Sediment and Erosion Control Plan (SECP) is to define the requirements and

procedures to be followed during the Karot Hydropower Project (Project) construction phase and produced

to address the residual impacts during the operational phase.

This plan describes the minimum national legislative requirements plus the applicable international and

project requirements relevant to the Project, as set out in the Environmental and Social Impact

Assessment (ESIA) and Environmental and Social Management Plan (ESMP).

The SECP should be developed in conjunction with the suite of ESMP sub-plans, which define detailed

control measures and procedures to be adhered to during the construction phase in relation to key

potential environmental and social impacts identified in the project ESIA and ESMP. The overarching

ESMP should provide additional guidance on generic processes outlined within each of the sub-plans such

as training and monitoring.

The plan addresses potential erosion and sediment incidences during the construction phase from:

� Increased surface erosion from disturbed areas through the removal of vegetation and surface soil;

� Erosion from uncontrolled surface run off

� Erosion from excavations and associated spoil

� Sedimentation from construction works within river bed

� Increased erosion from the use of construction vehicles

The plan addresses the residual potential erosion and sediment incidences during the operational phase

from:

� Loss of storage capacity over time

� Effectiveness of the proposed sediment flushing regime

� Downstream channel readjustment due to Karot HPP when combined with Mangla Reservoir water

level fluctuations associated with operation of the Mangla HPP

Details of the existing sediment regime and the expected effectiveness of reservoir sediment management

activities (sediment flushing) are included in Appendix A.

The plan describes the minimum national legislative requirements plus the applicable international and

project requirements relevant to the Project and the actions to be implemented to meet these requirements

during the construction phase of the project.

It is the responsibility of Karot Power Company (Pvt.) Ltd (KPCL) and its Owner’s Engineer (OE) to ensure

that the requirements of this plan are implemented by all KPCL/OE staff, its Contractor(s) and their sub-

contractors throughout all construction activities for the Project.

It is the responsibility of the Contractor to develop and implement appropriate environmental management

plans or procedures that reflect the requirements of this plan prior to the commencement of their respective

construction activities.

1 Introduction



1.2 Scope

The procedures outlined within this plan are required to be adopted across all components of the Project.

This includes:

� All infrastructure components of the Project

� Workers accommodation

� Laydown and storage areas

� Tunnels, adits, and spoil disposal sites

� Miscellaneous construction sites which could include offices etc

� Development of access roads, bridges and 500kV transmission line

� Reservoir strengthening and vegetation clearance

� Construction material extraction

� Associated transport movements

It is the responsibility of the Contractor to comply with the requirements outlined within this plan for all work

included within their scope of works.

1.3 Construction Activities

Key construction activities that could result in erosion and sedimentation are:

� Soil stripping

� Vehicular movements over unpaved surface

� Creation of cuts in hillside and access roads

� Temporary stockpiles of soil, spoil and other earthen materials

� Spoil waste disposal (temporary and permanent)

� Drilling and blasting

� Dam foundations and in river works

� Creation of intakes

� Powerhouse excavation, foundations and in-river works

1.4 Potential Impacts

Potential erosion and sediment impacts from construction activities may include:

� Deposition of dust on surfaces where it may cause damage and/or lead to a need for increased

cleaning or repair

� Aesthetic effects which arise from visible airborne dust plumes and from deposits of dust on surfaces

� Potential adverse health effects including eye, nose and throat irritation from excessive inhalation of

fine particles

� Impacts on vegetation from dust deposition

� Sedimentation of drainage systems resulting in turn in impacts to water quality, ecology and /or

drainage control

� Impacts on residential sensitive receptors, including impacts on living areas and general amenities

� Complaints from the public relating to dust or emissions



� Sedimentation of watercourses resulting in contamination and impacts on ecology and downstream

water users

1.5 Distribution and Review

KPCL/OE will distribute controlled copies of this plan to all Contractors at all sites within the Project

implementation area.

A controlled copy of the plan should be held centrally within KPCL’s main office in Islamabad.

The plan will be reviewed at least annually by KPCL/OE and upon any major change in project activities to

ensure that the scope of requirements and responsibilities contained within the plan are applicable and

sufficiently incorporated.



2.1 Environmental and Social Management System Overview

The overall Environmental and Social Management System (ESMS) for the Project is described in the

Environmental and Social Management Plan (ESMP). This SECP is a sub-plan of the overarching ESMP

and provides detailed control procedures to be followed during the construction phase.

Management procedures identified in this Plan will form management guides that clearly identify required

environmental management actions for reference and implementation by KPCL/OE, its Contractor(s) and

all sub-contractors.

2.2 Additional Management Plans/Documents

This SECP is particularly linked to the following plans/documents:

� Air Quality Management Plan

� Water Quality Management Plan

� Ecological Management Plan

� Site Waste Management Plan

� Traffic Management Plan;

� Blasting and Explosives Management PlanHabitat Removal and Restoration Plan

2 Relationship to Other Plans and Related Documents



3.1 Introduction

The erosion and sediment control procedures identified within this plan will be implemented by both

KPCL/OE and its Contractors to meet national and international requirements This section identifies both

the national and international requirements that are required to be met at all times in relation to erosion and

sediment control.

3.2 National Legislation and Requirements

The Construction Permit once received may include specific conditions regarding water quality (including

sedimentation) which will have to be adhered to. The procedures and requirements of this Plan are to be

reviewed and updated on receipt of the Construction Permit.

Key national policies related to water include the National Environmental Policy (2005), the National

Sanitation Policy (2006), the National Drinking Water Policy (2009) and the National Climate Change

Policy (2012). The most significant legislation is the Pakistan Environmental Protection Act (1997) and

further guidelines and legislation based on it:

� Section 12 of the Pakistan Environmental Protection Act (PEPA) (1997):

– Requires that “No proponent of a development project shall commence construction or operation

unless he has filed an IEE or, where the project is likely to cause an adverse environmental effect,

an EIA, and has obtained from the Federal Agency approval in respect thereof.”

� National Environmental Quality Standards (NEQS), 1993:

– Section 11 and Section 15 of PEPA (1997) prohibits any emissions or discharges in excess of the

NEQS which determine limit values or maximum allowable concentrations for parameters of waste

effluents, ambient air, motor vehicles’ exhaust gases and drinking water quality amongst other

pollutants.The NEQS are applicable to pollutant discharges irrespective of the type of source and

location.

This legislation is complemented on provincial and regional level by the following acts:

� Punjab Environmental Protection Act, 1997 (amended as the Punjab Environmental Protection Act

2012);

� Environmental Protection Act of Pakistan-administered Kashmir, 2000;

� Pakistan-administered Kashmir EPA Review of IEE and EIA Regulations, 2009.

3.3 International Requirements

3.3.1 Overview

Construction will be carried out in accordance with the following international standards and guidelines:

� International Finance Corporation (IFC): Policy and Performance Standards on Social and

Environmental Sustainability

� IFC General Environmental, Health and Safety (EHS) Guidelines, April 2007, as applicable

3 Policy and Control Standards



3.3.2 IFC General EHS Guidelines for Construction and Decommissioning

The General EHS Guidelines for construction and decommissioning state that:

“Soil erosion may be caused by exposure of soil surfaces to rain and wind during site clearing, earth

moving, and excavation activities. The mobilization and transport of soil particles may, in turn, result in

sedimentation of surface drainage networks, which may result in impacts to the quality of natural water

systems and ultimately the biological systems that use these waters. Recommended soil erosion and water

system management approaches include:

� Sediment mobilization and transport

� Clear run off management

� Road design

� Disturbance to water bodies

� Structural (slope) stability”

Erosion and sediment controls identified in this plan to be carried out by the Contractor are in accordance

with measures identified with the guidelines.



4.1 Overview

Erosion and sediment control activities, as defined in this plan are the responsibility of KPCL/OE, its

Contractors and sub-contractors. The staffing structure of KPCL/OE and Contractors are detailed below.

Overall roles and responsibilities are outlined in the ESMP with the key responsibilities for erosion and

sediment controls outlined in this section.

The Contractors and their sub-contractors will be responsible for implementing their own management

plans or procedures in line with the relevant national and international requirements and in line with the

requirements of this plan. KPCL/OE will be responsible for overseeing the performance of the Contractors

through monitoring and site inspections and verifying they meet the appropriate requirements.

4.2 KPCL/OE Roles

4.2.1 KPCL Project Manager/OE Chief Engineer

� Responsible for management of Contractors

� Overall responsibility to ensure sufficient resources are available for the implementation of the erosion

and sediment control measures across all construction activities as described in this plan

� Overall responsibility to ensure appropriate corrective actions is implemented as a result of any

identified non-compliances or environmental incidents related to erosion or sedimentation

4.2.2 KPCL Environment Manager

� Reporting environmental performance (including erosion and sedimentation management aspects) to

the Project Director and external bodies such as financing parties and governmental bodies

� Ensure, on an on-going basis, that the requirements of this plan are communicated via formal training

programmes to all personnel engaged in work on behalf of KPCL

� Define appropriate corrective actions to be implemented as a result of any identified non-compliances

or environmental incidents related to erosion and sedimentation and provide project-wide advice to

ensure consistent approach and outcomes are achieved

� Assist Community Liaison Officer as necessary in responding to any complaint or incident related to

erosion and sedimentation involving the public

� Work with Contractors to ensure all reasonable steps are taken to minimise erosion and sedimentation

from project activities

� Assist with the implementation of the erosion and sediment control options

� Undertake annual review (and updates as necessary) of this plan

4.2.3 OE EHS Expert

� Compile monthly EHS reports (including erosion and sedimentation aspects) and inform the KPCL

EHS Manager

� Monitoring project compliance with the requirements of this plan and reporting performance monthly to

the KPCL EHS Manager

� Undertake routine (at least every three months) audits of the implementation of this plan across the

Project

4 Roles and Responsibilities



4.2.4 KPCL Community Liaison Officer

Act as KPCL primary point of contact for local communities should they have any complaints relating to

erosion and sedimentation.

4.3 Contractor Roles

4.3.1 Contractor Site Manager

� Overall responsibility for practical implementation by Contractor and sub-contractor staff of all

requirements and commitments described in this plan

� Liaising with the Contractor EHS Manager to ensure effective erosion and sediment management at

site

� Liaising with the Contractor EHS Manager to ensure appropriate corrective and preventative actions

are defined as a result of any identified non-compliances or environmental incidents related to erosion

and sedimentation and ensure implemented at site

� Ensure sufficient resources are available to implement erosion and sediment control measures on site

as described in this plan

� Ensure that all personnel under his/her management control are trained in all aspects of erosion and

sediment control, relevant to their work activities

4.3.2 Contractor EHS Expert

� Conduct review of existing site plans/procedures and update them as necessary to incorporate any

additional requirements contained within this plan

� Ensure, on an on-going basis, that the requirements of this plan are communicated via formal training

programmes to all site personnel

� Monthly reporting of EHS performance (including erosion and sediment aspects) to the Contractor Site

Manager and OE Environmental Manager

� Provide assistance and advice to sub-contractors to fulfil the requirements of this plan

� Review and assess data from inspections, monitoring and reporting

� Liaise with relevant organisations as necessary

� Review sub-contractors procedures to ensure compliance with this plan

� First point of contact for the contractor to government bodies and other external bodies

4.3.3 Contractor Environment Officer

� Nominated person to take primary responsibility for the day-to-day implementation of this plan

� Conduct erosion and sediment control training and toolbox talks

� Monitor of wildlife and habitats particularly relating to potential impacts from erosion and sedimentation

from the construction phase

� Provide assistance and advice to site workers and engineers to fulfil the requirements of this plan

� Conduct daily / weekly EHS site inspections, to include inspection of erosion and sediment control

provisions in place

� Report results of inspections and documentation reviews to the Contractor EHS Manager

� Ensure that appropriate erosion and sediment control measures are implemented and maintained on

site in line with this plan for operations under their control



� In the event of identified potential or incidents, report via incident form and implement appropriate

corrective or preventative actions as necessary

4.3.4 All Contractor Personnel

� Following procedures and actions listed in this plan when undertaking site work

� Inform Contractor EHS Expert of any erosion or sedimentation issues as they arise

4.4 Sub-Contractors

It is the responsibility of the Contractor Site Manager to ensure that all sub-contractors implement the

requirements of this plan.



5.1 Construction Phase

Erosion and sediment control procedures are presented in this section for managing the following:

� Wind-blown erosion

� Dewatering and surface runoff

� In-river excavation and filling works

� Attrition through vehicle movements

Project control measures and responsibilities for the implementation of the measures associated with

erosion and sediment control are outlined in Table 5.1 below. These control measures have been

developed in line with mitigation measures described in the ESIA and the ESMP undertaken for the project

as well as international requirements identified within the IFC Guidelines.

The procedures outlined are the measures required to ensure that the relevant policy and standards are

met by the Project. These procedures should be diseminatated to all construction personnel during specific

training programmes to ensure appropriate understanding.

5.2 Operational Phase

Erosion and sediment control procedures during the operational phase are presented in this section for

managing the following:

� Sedimentation in the reservoir area

� Downstream channel readjustment

Operational Project control measures and responsibilities for the implementation of the measures

associated with erosion and sediment control are outlined in Table 5.1 below. These control measures

have been developed in line with mitigation measures described in the ESIA and the ESMP undertaken for

the project as well as international requirements identified within the IFC Guidelines. Details of the

anticipated reservoir sediment management regime to manage the residual risk of sedimentation are

provided in Appendix A.

5 Control Measures

11 350133/WCD/WAM/001/A 31 July 2015 Karot HPP ESIA, SECP


Table 5.1: Erosion and Sediment Control Procedures

No Action Responsibility Timing

General Requirements

1 Complete a site map showing the location of all erosion control practices to be deployed at site, including access points, existing and proposed grades (with slope direction), roads, drains, run-off patterns, plus details of any surface water bodies and building locations.

Contractor EHS Officer (s) Prior to construction

Wind-Blown Erosion

2 Vegetation will be cleared only immediately prior to construction works commencing to minimize the area of disturbance and reduce the chance of wind-blown erosion.

Contractor EHS Expert and Contractor Environment Officer

At all times 3 Construction activities will be phased to minimise the area of disturbance at one time

4 Following completion of construction, the construction area will be stabilized and re-vegetated (where possible) before disturbing adjacent sites

5 All stockpiles will be covered with plastic (or other impervious covering). Contactor personnel At all times

6 Where works are in close proximity to surface water bodies, install sediment fence(s) along the low downwind side of the construction sites. This is only required where construction sites are located within 500 metres of water bodies.

Contractor EHS Officer(s) At all times

7 All onsite storage facilities will be covered to prevent erosion by the wind. Contactor personnel At all times

8 Habitats will be fully reinstated, including all temporary work sites and access roads as soon as construction is complete in line with requirements of the Ecological Management Plan.

Contractor EHS Expert and Contractor Environment Officer

Following construction

9 Dedicated site access roads will be covered with hard standing. Contractor Environment Officer Following construction

Dewatering and Surface Runoff

10 Ensure site drainage systems are in good working order and remain blockage free. Contractor Environment Officer At all times

11 Site drainage designed to cope with a 1in 10 year return period as a minimum.

Contractor Site Manager and EHS Expert

Prior to construction

12 Minimize the use of impermeable surfaces on site. At all times

13 Ensure that accumulation of materials along transport routes and on vehicles used to transport spoil, earth etc. is avoided.

At all times

14 Divert water from higher ground around the project site and appropriately stabilise any drainage channels. Install stabilised interceptor drains which run across the site along the contour and down the slope perpendicular to the contours; use gabion weirs were required to a 1 in 20 to 1 in 100 year flood control standard as set out in the Spoil Management Plan.

Prior to construction

12 350133/WCD/WAM/001/A 31 July 2015 Karot HPP ESIA, SECP


No Action Responsibility Timing

15 Establish sedimentation ponds at all excavation sites and concrete crushing and batching plants. Sediment ponds shall allow for the temporary retention of drainage water and treatment prior to discharge into natural water course. Sediment ponds should be engineered and drawings provided to KPCL EHS Manager and OE Chief Engineer for approval.


Construction of ponds shall take place prior to topsoil stripping or any other construction activity upstream and prior to the commencement of operation of crushing and batching plants

16 Use silt traps, i.e. hay bales and/or silt fences were required to remove sediment from uncontrolled run off.

Contractor Personnel As required

In River Works

17 Minimise and where possible avoid crossing of rivers and construction activities taking place directly within river bed to reduce increasing sedimentation of river through installation of suitable temporary river crossings that do not obstruct river flow.

Contractor Site Manager Prior to in river construction works 18 Where works take place within the river bed, river to be diverted and protected from

excavation/filling to reduce impact of sedimentation in river.

19 All permanent crossings and changes to river banks to incorporate bank and river-training works are to avoid river bank erosion and associated increases in sediment load.

Attrition Through Vehicle Movements

20 All vehicles and mobile plant will use designated roads unless authorised by the HSE Officer.

Contractor Personnel At all times 21 Keep all construction equipment to designated areas to control soil compaction.

22 All access roads within the site will be gravelled to minimise erosion as opposed to hard standing due to the length and number of roads.

Sedimentation of the reservoir area

23 Plan timings of sediment flushing to meet hydrological conditions and in coordination with upstream and downstream users and community leaders.

Operating Contractor/KPCL As required

24 Operation of flushing gates to be limited to allow gradual reservoir drawdown in coordination with KPCL dam safety manager.

Operating Contractor As required

Downstream Channel Readjustment

25 Co-ordination of flushing period with Mangla HPP impounding regime to control release of sediment to replicate existing sediment regime and flows as closely as possible.

Operating Contractor/KPCL

At all times during operation

26 Minimise and where possible avoid sediment flushing during low flow season October – April.

Low flow season October – April.



6.1 Monitoring, Reporting and Auditing Requirements

Monitoring and inspection related to site erosion and sediment control from construction activities will be

conducted for the duration of the Project construction phase. These requirements, along with associated

responsibilities and reporting requirements are outlined in Table 6.1 below.

Table 6.1: Emissions and Dust Control Monitoring, Reporting and Auditing Requirements

Aspect Frequency Responsibility Reporting Comments

Daily site walkover, inspection of erosion and sediment control activities, including material storage areas.

Daily Contractor Environment Officer

Record in site diary,

complete environmental register or incident report in the event of non-compliance and appropriate actions that need to be undertaken

-

Weekly site walkover, erosion and sediment control activities, including material storage areas.

Weekly Contractor Environment Officer and KPCL Environment Manager

Completed site inspection checklist, any non-compliance issues will be elevated to Contactor EHS Manager and KPCL Environment Manager.

Complete environmental register or incident report in the event of non-compliance and appropriate actions that need to be undertaken

-

Approval of sedimentation pond locations and design

In each instance


Drawings and map of sediment ponds to be provided to OE Chief Engineer and OE EHS Expert for approval.

-

Erosion and sedimentation related environmental incidences or non-conformance

As they arise Contractor - All staff

Environmental incidents to be immediately reported to Contractor Environment Officer.

All incidents are to be recorded.

-

Contractor EHS reporting to KPCL

Monthly Contractor EHS Manager and Environment Officer

Monthly EHS Report to KPCL EHS Manager(s)

-

KPCL EHS reporting requirements to lenders

Quarterly OE EHS Expert Submission of quarterly reports

-

KPCL audit of erosion and sedimentation management and effectiveness of this plan

Quarterly OE EHS Expert and KPCL Environment Manager

Audit report to be prepared. Report to include any recommendations and actions for improvement as applicable

-

6 Verification and Monitoring



6.2 Inspections

Daily visual inspections of the construction site will be undertaken and recorded in the site diary. In addition

weekly environmental inspections using appropriate inspection checklists will be conducted. Minimum

requirements of the weekly inspection checklist are provided in Appendix B.

6.3 Auditing

The activities of Contractor and their staff during the construction activities will be audited on a regular

basis by KPCL/OE to verify compliance with the overarching ESMP and the requirements of this SECP.

Audits will be conducted every three months by staff appropriately trained in inspection and environmental

auditing techniques such as ISO 14001 (Environmental Management Systems).

6.4 Non-Compliance Management

In the event that erosion and/or sedimentation is recorded to be a problem at any location, or there are

complaints from the community or other external parties due to erosion or sedimentation, works will be

suspended while the Contractor EHS Expert conducts an investigation into the issue and ensures relevant

pollution control measures are implemented.

In the event of erosion or sedimentation being recorded, the investigation will determine if the incident was

due to inappropriate implementation of control measures, checks will be made to see whether the workers

involved had received adequate training.

During the investigation the Contractor EHS Expert will refer to the project Community Grievance

Mechanism in any cases where community complaints are raised.

If deficiencies are identified in the prevention of erosion and sedimentation and non-compliances with the

environmental requirements and objectives of this Plan are observed, an environmental incident report will

be completed as described in the ESMP and relevant actions/mitigations will be enforced. This will be

agreed with the Contractor and OE EHS Experts.

Details of all non-compliances and corrective actions taken will be included in the monthly EHS reports as

issued to KPCL/OE and the Lenders.

Where required the Community Liaison Officer will coordinate any discussion with the public where the

incident affects or potentially affects members of the public.



KPCL/OE will verify that all Contractor staff has received the same level of training so that the procedures

identified within the Plan are carried out by all staff working on the construction phase. Training of

KPCL/OE and Contractor staff will be conducted by a suitably qualified person at the project site induction.

In addition the Contractor EHS Expert will use weekly toolbox talks and refresher training to address

specific issues.

The Contractor EHS Expert will ensure that all construction personnel and contractors are aware and

trained in the content of this plan and their responsibilities therein. The training will include the following

key aspects:

� Increasing awareness of the potential erosion and sedimentation incidences that could occur during the

construction of the project, this will include the appropriate control methods

� Appropriate mitigation measures and responsibilities of Contractor personnel during the construction

phase

� All staff will be trained in the relevant reporting actions to be taken should there be a erosion or

sedimentation non-compliance during the construction of the project

� All staff will be trained in relevant notification and reporting requirements, as applicable to their role

� All staff will be trained in relevant inspection and auditing techniques, as applicable to their role

Training records will be managed and maintained in a training log.

7 Training



8.1 Introduction

KPCL/OE and the Contractor will be responsible for ensuring reporting requirements are fulfilled. The Plan

will be reviewed (by the Contractor and/or KPCL) at least annually, and whenever there is a significant

change in project or site conditions, or when it is determined that any mitigation measure is or may be

insufficient to achieve its purpose. It will be revised when necessary to update or improve water

management and when it is determined necessary to ensure compliance with applicable standards and

good international practice.

The following sections identify the reporting requirements.

8.2 Internal

8.2.1 Contractor

The Contractor is responsible for the following internal EHS reporting requirements:

� Daily erosion/sedimentation inspections to be reported in site diary

� Weekly erosion/sedimentation inspections to be reported using site inspection checklist

� Monthly EHS reports to KPCL/OE, monthly reports will include the following:

– Weekly inspections reports and checklists

– Number of non-compliances (if any)

– Details of any corrective actions (if any)

– Number of erosion and/or sedimentation complaints (if any)

– Training conducted for all Contractor staff

– Details on toolbox talks relevant to this SECP

8.2.2 KPCL/OE

KPCL/OE is responsible for the following EHS reporting requirements to be reported to KPCL management

on a monthly basis:

� Number of non-compliances incidences (if any)

� Number of complaints relevant to erosion / sedimentation (if any)

� Details of any corrective actions (if any)

� Summary of training conducted for all Contractor staff

� Summary of any issues from weekly site inspection reports and any audits undertaken

KPCL/OE will also undertake three monthly audits of construction activities and record any findings within

audit reports.

8.3 External

KPCL/OE will provide relevant monitoring reports to the Environmental Protection Agency as required;

further details on discharges to water and water quality are addressed within the Water Quality

Management Plan.

8 Reporting



Appendices

Appendix A. Reservoir Sedimentation and Flushing __________________________________________________ 18 Appendix B. Construction Site Inspection Checklist __________________________________________________ 27



Appendix A. Reservoir Sedimentation and Flushing



A.1 Introduction

This appendix provides:

� Sedimentation information;

� The sediment yield characteristics for the catchment area;

� The suspended sediment characteristics at the project site;

� The impact of reservoir sedimentation; and

� The countermeasures proposed for managing sedimentation.

A.2 Review of sediment and sedimentation information

The main references that provide information on sediment yield, sedimentation and sediment management

of the reservoir are:

� 720MW Karot hydropower Project Feasibility Report Volume 4 – Sedimentation Study Report,

September 2009 – SMEC/MAES/EGC;

� Yangtze Three Gorges Technology & Economy Development Co., Ltd (TGDC) - Design Report for

Karot 720MW hydropower project, 2014.

A.3 Relevant reservoir characteristics

The proposed design for the dam development is to provide a normal top water level of +461m which is

approximately 75m above the natural river bed level at the dam site. The reservoir will extend

approximately 27km upstream, excluding backwater effects. There are proposals for future hydropower

development with Azad Pattan HPP proposed at a site 27km upstream from Karot dam. The stage-area-

storage relationship for the reservoir is shown in Figure A.1.

A plan of the reservoir at top water level is shown in Figure A.2.



Figure A.1: Reservoir stage-area-storage characteristics



Figure A.2: Plan of reservoir at top water level

At the top water level of +461m the gross reservoir storage estimated by SMEC was 165Mm3. The EPC

Contractor has estimated a lower gross capacity of 152 Mm3 at this elevation. The minimum operating level

has been determined by the EPC Contractor as +451 m and the equivalent storage estimated as 103Mm3.

Hence the operational live storage, according to the EPC Contractor, is 49 Mm3 and the dead storage is

103Mm3. The mean flow into the reservoir has been estimated as 819m

3/s. This is equivalent to a mean

annual inflow volume of approximately 26,000Mm3, more than 150 times the gross reservoir volume. In

hydrological terms of the ratio of the reservoir volume to mean annual runoff, the proposed reservoir can

be considered ‘small’.



A.4 Sediment yield

Specific information on sediment is principally sourced from two gauging stations, one at Azad Pattan

upstream of the project site (catchment area 26,485km2) and one at the Karot site (catchment area

26,677km2). The small difference in catchment area between the two sites allows for data for both sites to

be applied with suitable minor adjustment. The EPC Contractor gives the catchment area at Karot as

26,700km2.

SMEC/MAES/EGC found that the total average sediment inflow to the reservoir will be 36.07Mt/yr on the

basis of 34 years’ of data, leading to significant sedimentation of the reservoir within 15 years without

sediment control measures. The suspended sediment load has been estimated as 31.4Mt/yr and an

estimate of 15% (4.71Mt/yr) has been allowed for the bedload.

A density of 69 lb/ft3 (1.1 g/cm

3) is proposed by SMEC such that the total volumetric yield per annum is

32.6Mm3 (reported by TGDC as 33.07Mm

3). The design report indicates a higher total annual yield of

36.64Mt (31.86Mt suspended silt). The stated specific density of 1.1g/cm3 appears to be on the low side of

typical values which normally range from 1.0g/cm3 for clayey sediment to 1.8g/cm

3 for pure silica sand. As

a result it is possible that the volumetric sediment yield has been overstated. If this is the case it would

have a positive effect in terms of sediment impact.

The provision of 15% for bed load is a reasonable figure for sediment transport in this region although a

higher fraction cannot be discounted. Recent studies for the Azad Pattan Project adopted 15% for bedload.

Studies by WAPDA for the raising of Mangla Reservoir indicated a bedload provision of 10%. Actual

measurement of bedload on large rivers is difficult to implement and actual bedload is often determined

through studies of actual sedimentation rates at reservoirs. It must be recognised that there may be

significant annual variations arising from, for example, landslide activity within the valley. The monsoon

season floods will be a dominant influence on the rate of sedimentation such that any extreme flood events

after impoundment could dramatically reduce the available live storage within a single year.

The sediment yield from a catchment area of 26,677km2 is the equivalent of an average erosion rate of

1.2mm per year.

A.5 Suspended sediment particle size

Sediment sampling at the dam site has determined that the split between sand, silt and clay particles is

38%, 44% and 18% respectively. It is noted that the distribution is significantly different from the

percentages given for Azad Pattan (11%, 64%, 25%) with a markedly higher percentage of sand size

particles. In the event that the true distribution at the dam site has a lower percentage of sand, similar to

the records for Azad Pattan, this would have a beneficial effect on sedimentation impact. A smaller fraction

of sand-sized particles would reduce deposition at the head of the reservoir within the live storage such

that more particles would be carried further into the reservoir and deposited as bottomset deposits.



A.6 Reservoir sedimentation

When a reservoir is constructed the significant reduction in flow velocity over the length of the reservoir

causes sediment particles to drop out of suspension. The sediment deposits consolidate and reduce the

amount of volume available for water storage. It is a common misconception that when a reservoir is first

impounded, the dead storage must become filled with sediment before the reservoir operation is affected.

Although over 60% of the gross storage of Karot Reservoir cannot be used for generation, live storage will

be depleted, even in the first year of operation, on account of the bed load and coarse suspended

sediment particles forming foreset slope deposits at the top end of the reservoir. The great majority of the

finer deposits will be carried further downstream into the reservoir where they will settle out to form

bottomset deposits. The foreset deposits will extend over time downstream until, without sediment

management, they will reach the dam at which point all of the useable storage will be depleted. In the case

of the Karot Reservoir the rate of live storage depletion will be readily determined by the location of the

foreset slope on the downstream side of the foreset deposits. The reservoir is very narrow: there will be no

significant lateral deposition of coarse sediments.

The effectiveness of the reservoir in trapping sediment is referred to as the trap efficiency. A number of

methods are available to determine the efficiency based on a wide range of reservoir sedimentation

studies. The Karot Reservoir, being very long and thin in plan, will maintain relatively higher through flow

velocities and hence lower particle detention times than other reservoirs of the same capacity. This means

that trap efficiency estimates are likely to overestimate the rate of reservoir sedimentation. The EPC

Contractor has estimated rates of storage loss as shown in Table A.1. This shows that the live storage

volume would largely stabilise after 20 years, losing approximately 60% of the live storage for generation, if

sediment management measures are not implemented.

Table A.1: Contractor estimate of reservoir storage loss through sedimentation without sediment flushing

SMEC estimated an initial trap efficiency of 40% using the Churchill Method, this efficiency reducing to

about 15% after 15 years. After 15 years of operation, SMEC estimate a reduction in gross reservoir

storage from 165Mm3 to 20 Mm

3 (88% loss) compared to the 81% loss estimated by the EPC Contractor. A

very significant percentage of the gross storage will be depleted after 15-20 years of operation without

some form of sediment management practice.

Years from first impoundment

Total storage loss (Mm3)

Loss of dead storage (Mm3)

Loss of live storage (Mm3)

Remaining live storage (Mm3)

Sediment elevation at dam

(m)

10 105 87 18 31 406.30

20 123 95 28 21 429.10

30 124 95 29 20 429.24

40 125 95 30 19 429.75

50 126 96 30 19 430.68



A.7 Sediment management

There are a wide range of sediment management strategies that can be considered. Over a catchment

area of over 26,000km2 it is not realistic to expect significant returns from investments in soil conservation

practices to reduce the sediment yield. Future reservoir developments upstream are planned and if

implemented such developments will have a beneficial effect in trapping sediment before it reaches the

Karot Reservoir. Such developments have the potential to delay the need for active measures to preserve

reservoir storage but eventually it is clear that such measures will become necessary. A very significant

proportion of the reservoir storage will be lost within the first 10 years of operation when upstream

reservoirs might still be planned or under construction.

The Karot Reservoir is long, thin and hydrologically small. As such the design for periodic sediment

removal by flushing is appropriate. This is an economical and efficient means of partially restoring the

original capacity, particularly if the flushing operations can be sequenced to coincide with other

maintenance activities such that the period of hydropower downtime is not increased. It is far more

effective than, for example, dredging. Hydraulic methods used in many countries to preserve reservoir

capacities are sediment routing during floods, drawdown flushing, reservoir emptying and flushing, and

density current venting. In many cases flushing sediment through a reservoir has been practiced

successfully. Reservoir flushing is ideally suited to reservoirs with small capacity: annual inflow volume

ratios, where seasonally high inflows are available, and where the reservoir valley is relatively narrow and

steep. The Karot Reservoir is very narrow and reasonably steep.

Flushing will be instigated by opening large, low bottom outlet gates at the dam during a period of high

water inflow (i.e. during the monsoon season). The high inflow rate is important:

� So that the scouring and transport of sediment from the reservoir is effective

� To mitigate downstream impacts of sediment release

� To allow the reservoir to be quickly refilled once flushing is complete

Figure A.3: Sediment flushing past a dam



As shown in Figure A.3, sediment flushing commences with the scouring of sediment close to the dam.

Sediment is progressively scoured in an upstream direction until riverine conditions exist in equilibrium

over the full length of the reservoir. Importantly, the most effective phase of the flushing is towards the end

of the operation when deposits are removed from within the live storage elevation zone.

Flushing is only effective if the reservoir can be drawn down close to the river bed level at the dam. In the

case of the Karot project this equates to the spillway approach channel invert level. If high scouring

velocities cannot be maintained, deposition will occur in the vicinity of the spillway. This may have a

detrimental effect on the power intakes.

A.8 Effectiveness of sediment flushing

The Sediment Balance Ratio (SBR) considers the quantities of sediment entering the reservoir compared

with the quantities that might be flushed through the dam. It is an indicator of the potential successfulness

of flushing sediment. A value in excess of one is required for flushing to be potentially feasible, although it

is only one indicator. It does not take into account the economics of flushing for example.

Regular flushing is likely to become necessary in the medium-long-term. If flushing was carried out at five

year intervals over a period of two days, the SBR is estimated as 3.4, well above unity, so flushing is

expected to be successful if flushed for an adequate duration. Having drained the reservoir down to +446

m the reservoir could potentially refill in less than a day. The EPC Contractor has indicated a maximum

rate of refill of 10 m per day, so the filling time would be 1.5 days in practice.

A.8.1 Long term capacity ratio

The long-term capacity ratio (LTCR) is the ratio of the storage which can be maintained by flushing to the

initial reservoir storage capacity. Given the very narrow width of the reservoir, there is no doubt that the

LTCR is high: i.e. the majority of the live storage should be potentially sustainable by reservoir flushing.

A.8.2 Sediment flushing conditions

The EPC Contractor has proposed that sediment flushing be carried out when the inflow rate is between

1,400m3/s and 2,100m

3/s. No explanation is given for setting a limit on the maximum flow rate but this may

be related to the design hydraulic capacity of the flushing facilities.

The two flushing gates are 9m-wide and 10m-deep and set with the invert at +423m. The “sediment

flushing control level” is stated as + 446m for a design maximum flushing flow of 2,100m3/s which appears

to reasonably represent the water level required to pass 2,100 m3/s through the two bottom outlets.

The reservoir cross sectional area immediately upstream of the flushing gates below elevation +446 m is

estimated at over 4,000m2 (129m effective bed width at +423m with 1V:2.5H sideslopes). Under the

maximum flushing discharge the average flow velocity through this section would be approximately 0.5m/s.

This is significantly lower than at a typical reservoir section in the upper part of the reservoir where the



section area would typically be about 600m2 (50m natural bed width and sideslopes at 1V:4H) giving an

average velocity of 3.5m/s during flushing. The impact of this would be to transport and then deposit the

coarse sediment fraction close to the dam such that flushing is less effective in the lower part of the

reservoir storage. However this will mainly affect the dead storage rather than the live storage so should

not be significant in terms of hydropower operation. Additional low level capacity would mitigate this effect.

In the event of a reservoir emergency, the reservoir will be drained as quickly as possible. Unconsolidated

sediments within the downstream section of the reservoir which cannot be flushed due to the limited

hydraulic capacity of the flushing gates could become unstable, slump towards the flushing channel and

partially block the valley. If this occurs during the dry season it could have a significant impact on the ability

to empty the reservoir effectively.



Table B.1: Site Inspection Checklist

Control Measure Compliant (Yes/No) Comment

Has a site map showing all erosion control practices been produced and made accessible to all workers?

Are construction works taking place in a phased approach?

Are all stockpiles covered with plastic or other impervious materials?

Where works are in close proximity to surface water bodies, have sediment fence(s) along the low downwind side of the construction sites been installed?

Are all onsite storage facilities covered?

Have habitats been fully reinstated after each construction phase has been completed?

Are all site drainage systems in good working order and blockage free?

Has water from higher ground been diverted?

Have adequate sediment ponds been installed at all main excavation sites?

Have in river works involved diverting river water or creating bridges to minimise sedimentation?

Are all construction vehicles and mobile plant using designated roads?

Have temporary access roads been installed as appropriate?

Are all access roads within the Project Area gravelled?

Appendix B. Construction Site Inspection Checklist



62

Appendix B. Emergency Preparedness and Response Plan


Emergency Preparedness and Response Plan

July 2015

350133 001 B

C:\Users\max36630\AppData\Roaming\OpenText\OTEdit\EC_EUNAPiMS\c1591647916\350133 - Karot Dam - Emergency Preparedness Plan

30 July 2015





July 2015

Mott MacDonald, 10 Temple Back, Bristol, BS1 6FL, United Kingdom

T +44 (0)117 906 9500 W www.mottmac.com

350133///001/B 30 July 2015

720MW Karot Hydropower Project Pakistan Emergency Preparedness and Response Plan


A

26/05/2015 N R Kempton A L Warren A Warren Framework

B

30/07/2015 N R Kempton A Warren A Warren Final






350133///001/B 30 July 2015


Chapter Title Page

1 Introduction 1

1.1 Purpose of the Emergency Preparedness and Response Plan ________________________________ 1 1.2 Maintenance of the Emergency Preparedness Plan ________________________________________ 2 1.2.1 Review of the Emergency Preparedness Plan _____________________________________________ 2 1.2.2 Exercising the Emergency Preparedness Plan ____________________________________________ 2 1.2.3 Incident Management Training _________________________________________________________ 2

2 Project Description 4

2.1 Project Overview ___________________________________________________________________ 4 2.2 Project Location ____________________________________________________________________ 4 2.3 Project Details _____________________________________________________________________ 5

3 Identification and Evaluation of Potential Emergencies 7

3.1 Identification of Potential Emergencies___________________________________________________ 7 3.1.1 Potential Emergencies _______________________________________________________________ 7 3.1.2 Possible Dam Failure Modes __________________________________________________________ 7 3.1.3 Means of Identification ______________________________________________________________ 10 3.2 Evaluation of Potential Emergencies ___________________________________________________ 11 3.3 Designation of Responsible Persons ___________________________________________________ 11

4 Preventative Action 13

4.1 Aim of Preventative Actions __________________________________________________________ 13 4.1.1 Sources of Equipment ______________________________________________________________ 13 4.1.2 Stockpiling Supplies and Materials _____________________________________________________ 14

5 Trigger Events and Implementation of Emergency Plan 15

5.1 Trigger Events ____________________________________________________________________ 15 5.1.1 Embankment Instability _____________________________________________________________ 15 5.1.2 Embankment Overtopping ___________________________________________________________ 15 5.1.3 Gate Failure or Maloperation _________________________________________________________ 15 5.2 Implementation of Emergency Plan ____________________________________________________ 16 5.2.1 Notification Procedures _____________________________________________________________ 16 5.2.2 Communications Plan_______________________________________________________________ 16 5.2.3 Communications Systems ___________________________________________________________ 17 5.2.4 Warning Notification ________________________________________________________________ 17 5.2.5 Declaring an Emergency ____________________________________________________________ 18 5.3 Response to an Emergency __________________________________________________________ 19 5.3.1 Access to Site _____________________________________________________________________ 19 5.3.2 Response during Periods of Darkness __________________________________________________ 19 5.3.3 Response during Periods of Adverse Weather ____________________________________________ 20 5.3.4 Emergency Power Sources __________________________________________________________ 20

Contents

350133///001/B 30 July 2015


5.3.5 Inundation Maps ___________________________________________________________________ 20 5.3.6 Emergency Actions_________________________________________________________________ 20 5.4 Post-flood actions __________________________________________________________________ 21 5.4.1 Rescue and Relief Plan _____________________________________________________________ 21 5.4.2 Health Facilities ___________________________________________________________________ 22

Appendices 23

Appendix A. Communications Plan_______________________________________________________________ 24 A.1 Framework for Communication Plan ___________________________________________________ 24 A.2 Control Rooms ____________________________________________________________________ 24 A.3 Identification of Areas at Risk _________________________________________________________ 24 A.3.1 Most Vulnerable Properties __________________________________________________________ 24 A.3.2 Flood Extent Maps _________________________________________________________________ 25 A.3.3 Notification _______________________________________________________________________ 26 A.4 Key Contact Details ________________________________________________________________ 27 Appendix B. Scheme Drawings _________________________________________________________________ 28 B.1 As-Built Drawings __________________________________________________________________ 28 Appendix C. Dam Break Modelling _______________________________________________________________ 29 C.1 Overview ________________________________________________________________________ 29 C.2 Inundation Maps ___________________________________________________________________ 29


350133///001/B 30 July 2015 Karot HPP ESIA, EPRP

1

1.1 Purpose of the Emergency Preparedness and Response

Plan

The purpose of this Emergency Preparedness and Response Plan is to

identify and detail actions to be implemented should situations arise

that cause, or have the potential to cause, a large uncontrolled release

of impounded water which has the potential to harm persons and

property downstream.

An Emergency in the context of this plan is defined as a condition of a

serious nature which poses endangerment to persons, property or dam

safety thereby triggering immediate actions to reduce the probability of

or to reduce the impacts of, a failure. An emergency in this case might

comprise, amongst other things, events such as:

� A failure of the dam structure

� An abrupt structural failure of the spillway structure or gate(s)

� Flood flows in the river of sufficient magnitude to cause significant

downstream flooding due to spillway gate operation

� The uncontrolled release of water from an upstream dam, leading to

overtopping of the dam and potential failure of the dam through

erosion

The objective of this plan is to aid the timeliness and effectiveness of

carrying out appropriate actions during a potential emergency or

emergency situation.

This plan has been prepared to follow international practice and World

Bank ‘Operational Policy 4.37 – Safety of Dams’, utilising the World

Bank ‘Regulatory Frameworks for Dam Safety, 25069’ as far as

practicable for an ‘on-site’ plan for dealing with incidents directly

associated with the dam. It does not include for off-site planning

arrangements which would cover actions by the state and national

governments to assist in bringing any incident under control.

Dam failures have historically caused considerable loss of life in many

countries around the world. The consequences of a dam failure

depends on many factors, notably the nature of the dam-breach flood,

which is related to the type and height of dam, the volume of

impounded water released and the proximity and nature of hazards

(persons, properties and infrastructure) in the zone of inundation

downstream of the dam.

1 Introduction



2

1.2 Maintenance of the Emergency Preparedness Plan

1.2.1 Review of the Emergency Preparedness Plan

This plan is intended to be a live document, regularly reviewed and

updated, at least once annually and following all exercises to reflect any

changes in roles, responsibilities, contact names, etc. and to reflect any

changes to the dam or associated structures or the areas at risk which

would impact the modes of failure, trigger events or emergency actions.

It is essential to review the completeness and effectiveness of the plan

and to consider whether any additions or changes to the plan could be

made to improve the emergency prevention or response. Modifications

can be considered under the following headings:

� Structure details

� Failure modes

� Trigger levels

� Communications;

� Incident response type

� Incident response times

� Interaction with appropriate authorities

1.2.2 Exercising the Emergency Preparedness Plan

It is important that an emergency plan is tested, reviewed and

developed through periodic exercises. This will help to ensure that the:

� Data is accurate

� Trigger mechanisms and levels are reasonable

� Communications are effective

� Hazard warnings (through village mosques and local radio stations)

to the public are effective and sufficient

� Response procedures are proportional to the hazard posed and are

efficient and effective

1.2.3 Incident Management Training

All senior operations staff should review the emergency preparedness

plan and be aware of the actions required if trigger events are met. A

trigger event is a circumstance or set of circumstances under which

actions should be taken. Staff should be fully involved in any exercises

so that their roles and responsibilities are clear should it become

necessary to implement the plan. Staff should be provided with

feedback on their performance and re-trained as appropriate.



3

Numbered control copies of the emergency preparedness plan should

be kept by those responsible for implementing the plan in event of an

emergency.



4

2.1 Project Overview

The Karot Hydropower Project (Karot HPP or the Project) is a proposed

run-of-river hydropower scheme to be built across the Jhelum River in

Pakistan. The primary purpose of the project is to provide for

hydropower generation although in practice the reservoir development

will also allow for some degree of flood flow regulation for the river

reach downstream of the dam.

2.2 Project Location

The Project is located on the border between the Punjab Province and

Azad Jammu and Kashmir near the village of Karot in the Kahuta Tehsil

of the Rawalpindi District of the Punjab Province and the village of

Hollar in the Sehnsa Tehsil of the Kotli District of Azad Jammu and

Kashmir (AJK); approximately 50km South-East of Islamabad. The dam

site is accessible via the Rawalpindi-Sehnsa Road from Beor, and is

situated approximately 950m upstream of the Karot Bridge. This bridge

is currently part of the Rawalpindi-Sehnsa Road and connects Karot

village on the right river bank with Hollar village on the left river bank.

Figure 2.1: Project Location and Access Routes


2 Project Description



5

Karot HPP will be part of a cascade of hydropower projects, located

upstream of the existing Mangla Dam and downstream of the proposed

Azad Pattan, Mahl and Kohala Hydropower Projects, which are

currently all at the Feasibility stage.

Figure 2.2: Position of the Karot HPP in relation to other large hydropower schemes on the Jhelum River

Source: KPCL

2.3 Project Details

The Project is a run-of-river hydropower scheme on the Jhelum River

comprised of a 95.5m high dam, intake, power tunnels and penstocks,

surface powerhouse, spillway, transmission equipment, new bridges

and roads and a number of associated safety and control features.

The primary components of the Project are:

� A 95.5m high dam at the Karot village on the Jhelum River

� Powerhouse with four turbines with 720MW of installed capacity

� Gated spillway structure, separate from the dam

� Re-routing works and a new road bridge for the main Rawalpindi-

Sehnsa Road

� An overhead line for export of power to a 500kV transmission line

that will be built by the Pakistan Government independently of the

Project



6

The reservoir created by the dam will extend approximately 27km

upstream and have a volume of 152million cubic meters (Mm3) at the

full supply level (FSL) of 461meters above sea level (mASL). The

powerhouse will be located approximately 650m downstream of the

dam crest and 300m upstream of the existing Karot Bridge. The

proposed Project is located in mountainous terrain and a deep gorge.

Figure 2.3: Project Layout showing key details

Source: KPCL (labels and contours of the original riverbed added by Mott MacDonald)

New road

bridge



7

3.1 Identification of Potential Emergencies

3.1.1 Potential Emergencies

A Potential Emergency, referred to in this plan, relates to any situation

relating to the dam or associated structures which have the potential to

develop into an Emergency situation.

It is considered an Emergency situation if:

� Failure of the dam or spillway structures is considered imminent

� Where there is a risk of large uncontrolled flows being released into

the downstream watercourse with the potential to threaten life or

property

� There are natural extreme flood events which are to be passed

through the spillway with the potential to threaten life or property

An emergency situation can therefore arise through a dam breach or

structural failure of associated works, and it can also occur through a

major flood event without a dam or structural breach.

Failure of the headrace tunnels or other pressurised hydropower works

would result in a significant uncontrolled release of water. However, the

rate of water released into the river downstream is not likely in itself to

have the potential to cause significant flooding.

3.1.2 Possible Dam Failure Modes

The successful early identification of potential emergencies and

appropriate preventative action can reduce the likelihood of a situation

developing into an emergency situation. It can also aid in reducing the

threat to life and property if the situation does develop into an

emergency situation.

To assist in this early identification process the possible modes of a

dam breach and structural failure have been identified and grouped as

follows:

� Stability of Main Dam

� Seepage, Uplift and Piping

� Scour

� Gate Failure or Maloperation

� Dam Overtopping and Erosion

� Seismic Failure

� Terrorism / War

3 Identification and Evaluation of Potential Emergencies



8

3.1.2.1 Stability of Main Dam

As a new design and construction project it can be anticipated that

stability failure of the main dam through slope instability, deformation of

the crest due to settlement or sliding on the foundation is very unlikely

to occur under normal service conditions. However this is still possible.

There is potential for the structural performance to deteriorate over time

and as for any large hydraulic structure, future monitoring of the dam

and all of the other associated structures will be important for its

continued safety.

A sliding failure on the plane of the foundation would lead to a rapid

release of water past the dam as sliding failure is only likely when there

is a significant difference in head across the dam.

It is possible that during extreme flood events the water level

downstream of the dam would raise significantly compared to that

upstream of the dam and as such the risk of sliding failure is averted.

A slope failure on the downstream shoulder, or significant settlement of

the dam could lead to overtopping of the dam and failure by erosion of

the downstream shoulder.

3.1.2.2 Seepage, Uplift and Piping

Seepage under that dam or associated tunnels and structures could

cause a piping failure whereby the foundation or surrounding material

deteriorates through erosion from seepage flows. Loss of support within

the foundation and at the toe could lead to instability of the downstream

shoulder, collapse of the crest and erosion by overtopping.

The potential for seepage, uplift and piping is greatest when there is a

large head differential across the structures and this can usually be

managed, at least partly, through sufficient management of reservoir

levels.

Piezometers can be installed to indicate changes in uplift pressures

within the dam foundation.

A failure due to piping or by uplift is not likely to cause failure of a large

section of the spillway structure as any failure will act to reduce the

head differential and reduce the potential for failure of adjoining bays.

Gate operation failure could increase the risk of piping failure.



9

3.1.2.3 Scour

Inadequate stilling facilities can lead to scour downstream of the

overflow and outfall structures which could undermine the associated

structures leading to a loss of support and structural failure. The

structure geometry should normally be capable of withstanding the

scour effects associated with normal operations and releases.

Nevertheless, identifying problems due to scour can be difficult. Failure

by scour is not likely to lead to widespread failure of the dam structure

but has the potential to affect associated structures leading to structural

distress and, potentially, failure.

3.1.2.4 Gate Failure or Maloperation

A gate failure is most likely to be associated with deterioration of the

material. Catastrophic failures are unusual. A gate failure will only

cause uncontrolled release of water via the associated gate opening

and spillway chute. Multiple simultaneous gate failures are very unlikely

to occur. Failure to open one or more gates during a flood could lead to

failure of the dam or spillway structure through overtopping in an

extreme flood event. The risk of gate operation failure can be mitigated

through independent and backup power supplies and control systems.

Endangerment and damage downstream of dams has been known to

occur due to human error where one or more large spillway gates are

opened unexpectedly and without authorisation. This risk can be

partially mitigated through appropriate control systems to counter the

risk of accidental operation.

3.1.2.5 Dam Overtopping and Erosion

The dam and spillway will be designed for an extreme flood of a specific

frequency. A return period of 5,000 years is proposed for the safety

check flood. Floods of greater severity will pose a threat to dam safety.

If the dam does not have sufficient freeboard then overtopping during

an extreme event is possible by a combination of high water levels and

steady strong winds. Overtopping is most likely where the freeboard is

inadequate or where the construction of the uppermost portion of the

dam is weakest.

Overtopping weakens the dam by eroding the crest and the

downstream face. A loss of downstream support to the core wall will

lead to failure of the core wall, collapse of the crest and failure of the

dam by progressive erosion.



10

Failure of a dam section may lead to extensive flooding of the

downstream river valley. However it is likely that in a flood event where

dam overtopping occurs, the protected area may already have

experienced some degree of flooding.

3.1.2.6 Seismic Failure

The dam design will take into account susceptibility to seismic damage,

and as such it should be anticipated that catastrophic failure due to

seismic activity is unlikely. A major seismic event could cause structural

or operational problems with the dam and associated structures or

mechanisms. A seismic event of sufficient magnitude could lead to dam

instability, settlement and loss of freeboard, or damage to spillway

gates for example. A significant seismic event will inevitably affect

safety-critical equipment, power supplies or structures.

3.1.2.7 Terrorism / War

Acts of terrorism or war could conceivably cause significant damage to

the dam or the associated structures. The impact would depend on the

extent of the damage and the prevailing reservoir water level.

3.1.3 Means of Identification

Under normal operating conditions there are no common modes of

failure that would cause a significant and sudden release of impounded

water past the dam into the downstream reach and cause

endangerment to life or property.

It is anticipated that the safety of the dam and associated structures will

be routinely assessed through visual inspection, surveys and review of

the installed instrumentation at the structures as well as through

independent safety review. If the routine visual inspections or review of

instrumentation data identifies any change which can be linked to any

of the potential failure modes then further detailed inspections,

monitoring and preventative action may be required as advised by the

responsible persons.

The passing of design flood flows is considered to be a much more

likely source of downstream flooding and endangerment to life or

property. The extent and impact of any associated flooding would

depend on the:

� Return period of the design flood

� Impounded water level at the time of flood



11

The responsible persons are to continuously monitor meteorological

data to make an assessment of incoming flows to determine whether a

significant pass on flow is to be expected.

3.2 Evaluation of Potential Emergencies

If during visual inspection or review of instrumentation data the

responsible persons identify a potential emergency, it is vital that an

assessment of the identified problem is undertaken immediately by the

responsible persons. It is essential to ensure that the responsible

persons undertaking the assessment have appropriate knowledge and

experience relating to the identified problem.

Swift and appropriate evaluation of a potential emergency will provide

an opportunity to carry out preventative actions to reduce the likelihood

of the situation deteriorating into an emergency situation.

The evaluation procedure must be clearly defined and should include

analysing the severity of the existing situation and determining the

probable and worst case development of the situation. It should also

include recommendations as to the appropriate preventative actions

which can be undertaken, a likely timeframe and at what stage

declaring an emergency situation is likely to be required. Preventative

actions may be undertaken before the full evaluation is complete, if

required, but these are only to be undertaken on instruction from the

Head Responsible Person.

Additional resources such as aids, instructions and provisions for

interpreting information and data should be identified and detailed in

this section following the detailed design and construction stages.

3.3 Designation of Responsible Persons

It is necessary to designate the persons responsible for identifying and

evaluating any potential emergency as previously described. This would

normally be staff of the owner or their representative. However, if the

owner does not have adequate technical expertise the responsibility

may need to be assigned by the owner to other organisations or

individuals. There should be an appropriate number of responsible

persons to ensure that continuous coverage is provided with the

required level of expertise.



12

The persons responsible for identification and evaluation of potential

emergencies should include, but are not limited to:

Table 3.1: Responsible Persons

Role Name Contact Number

Head Responsible Person TBC on appointment of Operational Contractor

Reservoir Operation Officer TBC on appointment of Operational Contractor

Dam Safety Officer TBC on appointment of Operational Contractor

Spillway Operations Officer TBC on appointment of Operational Contractor

Hydropower Plant Operations Officer TBC on appointment of Operational Contractor

These roles are to be further determined and detailed by the owner

over the project implementation period and discussed when appointing

the operational contractor. The name and contact details for the

identified responsible persons are to be included by the owner upon

appointment and regularly reviewed and updated to maintain accuracy

of the list.



13

4.1 Aim of Preventative Actions

The purpose of preventative actions are, once alerted to a problem, to

prevent the problem developing into a potential emergency situation or

an emergency situation. They can also be to reduce the impact

resulting from an emergency situation if ultimately it cannot be

prevented.

Regular day-to-day visual inspections, monitoring and operation as

previously discussed are required for early identification of arising

issues and therefore reduce the likelihood of an emergency situation

occurring. However this is not included as a preventative action in this

document.

Preventative actions can include, but are not limited to:

� Drawing down the reservoir water level

� Closing of valves and gates to stop continued scour damage

� Installation of stop logs in front of failing spillway gates

� Crest works to remove low spots

� Creation of bunds or material piles to prevent flooding or damage to

key areas

4.1.1 Sources of Equipment

To assist in the effective and timely response in carrying out

preventative actions, the resources likely to be required to prevent

failure should be identified and clearly listed prior to construction

completion. The availability, location and quantity of these resources

should be identified locally and recorded in Table 4.1. The required

resources should include:

� Plant

� Equipment

� Materials

� Supplies

The contact details for arranging the supply of these items is to be

included clearly in the Key Contact Details table of the Communications

Plan in Appendix A.

4 Preventative Action



14

4.1.2 Stockpiling Supplies and Materials

The location and availability of any stockpiled materials, plant and

supplies for emergency use should be identified and accurately

recorded in Table 4.1, including the quantity available. These stockpiles

must remain for the use of a preventative action only, and should be

regularly checked and maintained to ensure availability for immediate

use.

Table 4.1: Detail of Resources available to the operation contractor in the event of potential of full emergency

situation at the dam site.

Resource Quantity Units Location Date last checked

Machines

Equipment

Material

Labour



15

5.1 Trigger Events

5.1.1 Embankment Instability

Embankment instability is most likely to arise during flood conditions

when there is a significant head differential across the embankment.

Signs of embankment instability can include:

� Differential settlement of the embankment crest

� Cracks in the crest or on the faces of the embankment

� Slumping or signs of mass rotation

� Leakage close to the downstream toe or on the downstream face of

the embankment

Routine surveillance activities should be targeted to observe any of

these features. Additional surveillance should be instigated during any

flood events. Any signs of discrepancy should be reported to the

responsible person.

5.1.2 Embankment Overtopping

Crest level surveys should be carried out to regularly monitor the

available freeboard on the dam. Critical areas should be identified by

the responsible person and closely monitored during any extreme flood

event. It is difficult to estimate whether an embankment will fail due to

overtopping as the probability depends on many factors. However it

would be prudent to assume that any dam section that is expected to

overtop, or is overtopping, should be treated as if complete failure is

imminent and contingency plans put in place as appropriate to

safeguard persons and property downstream.

Embankment overtopping might typically be expected due to:

� Extreme hydrological flooding from the catchment area

� Geomorphological flooding within the catchment area (eg a

landslide into the valley forming a natural dam which then

breaches)

� Dam failure at an upstream reservoir

� Structural problems giving loss or potential loss of freeboard

5.1.3 Gate Failure or Maloperation

Structural failure or accidental opening of large spillway gates would

result in an uncontrolled release of water into the downstream

watercourse. The resulting flows are not considered to pose a

5 Trigger Events and Implementation of Emergency Plan



16

significant flood threat to communities downstream, however they may

impact on individuals. This risk is mitigated through design and

operational protocols. Any unauthorised release of water through a gate

would be treated as a trigger event and reported to the responsible

person.

5.2 Implementation of Emergency Plan

5.2.1 Notification Procedures

Notification procedures are an important part of any emergency plan.

The procedure document an agreed format for communication of

potential or emergency situations to the downstream population.

Extreme flood events or significant seismic events will greatly increase

the chance of an uncontrolled escape of water and such events would

be appropriate reasons for raising a warning.

Effective communication is an essential element in successfully

implementing an emergency plan. Typically there are two levels of

notification:

� Warning: circumstances indicate that there may be a need for

evacuations in the specified areas. Preparatory actions are to be

taken in accordance with the communications plan.

� Emergency (or a warning followed by an emergency): immediate

evacuation is required of specified areas and emergency actions

taken.

The notification of a potential emergency, or full emergency, to the

downstream communities and emergency response services is

essential in reducing the impact of a failure. It is vital that the procedure

is followed to ensure the correct communication reaches the

appropriate persons within a suitable period of time.

A framework for the notification procedure is included within the

Communications Plan in Appendix A.

5.2.2 Communications Plan

The framework for a communications plan has been developed to

promote effective communication between those best placed to assess

the risk of flooding and those best placed to arrange for alerting the

downstream population, arranging evacuations and other necessary

actions.



17

The communication plan is included in Appendix A and must be further

developed over the project implementation period and actively

managed by the relevant authorities on a regular basis.

The plan should include the names and full contact details for relevant

officials. These personnel should review the plan and acknowledge

their associated responsibilities. The plan should include suitable and

adequate cover arrangements so that there is a back-up contact person

in the event that the main contact is unavailable at the time of the

incident. The Emergency Plan Holder should be formally identified. This

is the person responsible for ensuring the contact names and numbers

are kept up to date and that new appointees are cognisant of their

responsibilities.

5.2.3 Communications Systems

Full details of the existing and proposed communications systems

which are to be used during the notification procedure should be

included in this section. This is to be further developed over the project

implementation period and should include, but is not limited to:

� Designation of an emergency line, to be kept clear and used only

for reporting emergencies

� Portable radios, including number, location and station for key dam

operations staff

� Means for communication during power failure and back-up

provisions in the event of telephone system failure

� Location of phones to be used for the notification procedure

5.2.4 Warning Notification

A system for ensuring the communication of a ‘Warning’ that is

considered credible and clearly understood by the downstream

population prone to adverse effects of flooding shall be established and

included in the Communications Plan during the project implementation

period. This may include the installation of warning/siren towers at key

locations coupled with training sessions for the local communities so

that the warnings are clearly understood.

A clear methodology shall be framed to communicate warnings in the

shortest possible time.

The responsible person shall inform the District Coordination Officer

(DCO) immediately of any situation at the dam and provide the required



18

details. Upon receipt of this information the DCO shall contact the

appropriate Tehsil Assistant Commissioners (AC’s) informing them

about the forecast of the impending danger, its nature and expected

time of occurrence.

The DCO shall also formally alert the concerned departments of other

agencies. This formal information may be in any agreed form, such as

via telephone/SMS or by a radio/wireless signal, written communication

etc. and is to be duly documented.

The AC’s shall endeavour to ensure the warnings or notification of an

emergency reach the at risk populations. This may be through any

means available, but may include:

� Contacting ‘village heads’ (Lambardar) if available

� Announcements via Radio, TV, Police Wireless System and

Mosques

� Sending an official to the identified areas

� Arranging for notification via SMS to local communities

The most vulnerable communities shall be given priority to receive the

information.

In downstream communities the announcements should be repeatedly

made using loudspeakers and communication systems in mosques,

informing about the expected event and associated risks. Consideration

should also be given to the use of SMS mobile phone messaging for

dissemination of announcements.

It is important that the most vulnerable areas are promptly informed

about any expected event. For this purpose, if required the Lambardar

or another nominated responsible person could be issued with

radios/wireless sets during the monsoon period. These radios/wireless

sets can be given in the custody of the responsible ‘Village Heads’.

Alternatively, any other communication system in place can be used by

the DCO's office to communicate with remote areas effectively and

efficiently.

5.2.5 Declaring an Emergency

The risk of flooding can be forecast by the Meteorological Department.

It is normal practise for the Meteorological Department to inform the

responsible provincial government about any event that may cause

damage to lives and property in the area.



19

Based on discharge data received from the Meteorological

Department’s flood warning centre, a forecast in respect to the probable

river flows that are likely to be expected should be prepared by the

provincial government at least 7 days ahead.

Upon being informed by the provincial government, the Provincial

Disaster Management Authority would inform the DCO, who would

declare emergency in the District and inform all Government

Functionaries and Armed Forces would be put on high alert. All field

staff and concerned agencies will be informed accordingly.

Warning systems should be used to provide warnings to residents that

are close to the dam or within the potential inundation area. These

details should be fully understood and detailed.

5.3 Response to an Emergency

5.3.1 Access to Site

The primary route to access the main dam site by road is via the Karot

Bridge. It has been determined that it is likely that during a breach

situation or passage of the design flood flows, this bridge may become

unpassable and will be susceptible to structural damage or completely

destroyed. The secondary access route will be via the newly installed

bridge. This is expected to be the only road access during and following

a full breach scenario; there are currently no separate existing

pedestrian bridges.

The only other means of access to the dam site would be by helicopter.

5.3.2 Response during Periods of Darkness

This section should identify and detail any additional procedures or

resources required for response during periods of darkness. This is to

include areas without lighting indoors and underground as well as

during the night and should consider the consequences of a power

failure.

This should include, but is not limited to:

� Identification of items available for emergency power and their

location

� Additional items required to carry out monitoring or preventative

actions, such as:



20

– Backup lighting systems, with their own power source

– Mobile lighting for response teams

� Communication and notification methods

5.3.3 Response during Periods of Adverse Weather

This section should address any differing or additional procedures and

additional resources required for emergency response under adverse

weather conditions, including extremes of cold, snow or storms. This

should include, but is not limited to:

� Provision of suitable shelter from the elements and clothing for

those responding to a potential situation or emergency

� Specialist plant items for carrying out preventative action or

evacuation

� Provision of suitable shelter for those evacuated

5.3.4 Emergency Power Sources

Details of the location and operation of any emergency power source

should be identified and included, including the contact details for the

key person to contact to arrange connection, if required.

5.3.5 Inundation Maps

Inundation maps are included in the appendices to aid the local

authorities in developing an effective evacuation plan.

5.3.6 Emergency Actions

The actions required under the emergency plan will vary according to

the nature of the emergency and the location of the emergency. It is

impossible to foresee all possible types of emergency. However in the

case of the dam structure the plan should provide for specific actions in

dealing with an imminent or actual breach of the dam. Actions may

include:

� Opening of the overflow gates and scour facilities (if not already

open) to reduce the impounded level upstream of the dam

� Emergency repairs to the embankment crest to restore freeboard

� Emergency construction of flood embankments

� Demarcation/prioritisation of areas requiring evacuation

� Consideration of safe, effective evacuation routes

� Resourcing of identified relief centres for displaced persons



21

Suitable officials for implementing evacuations should be identified.

These should include representatives of:

� The technical team assessing risk

� The local community or communities

� Law enforcement

� Evacuation support liaison

� A medical officer

Guidance to affected residents may include:

� Listening to the radio, mosques and for sirens for advance

information

� Disconnection of electrical equipment and removal of any valuable

items to a high level within the house as far as possible

� Move vehicles, farm animals and any moveable goods to a higher

location

� Keep sources of water pollution (eg insecticides) above anticipated

floodwater levels

� Turn off any services

� Travel to the identified relief centre as quickly as possible

� Avoid deliberately entering floodwaters

5.4 Post-flood actions

If flooding occurs actions will be needed to deal with the damage after

the flood has subsided. Actions might include:

� AC’s requesting rescue and relief services from appropriate

persons, such as: Rescue 1122, Civil Defence or the National Army

� Support for evacuees to provide food, fuel and shelter

� Securing potable water supplies to affected areas, basic sewage

treatment and sanitation facilities

� Prevention of looting of properties belonging to displaced people

� Re-establishment of power supplies and other services as

appropriate

� Recovery and identification of dead bodies

� Recovery of dead livestock

� Immunisation to prevent the outbreak of waterborne diseases

� Other medical support facilities

5.4.1 Rescue and Relief Plan

At village level, a list of schools/institutions for use as relief camps shall be prepared, indicating approximate capacity as well as the person in charge. This information should be gained in partnership with the appropriate AC’s.



22

Table 5.1: Rescue and Relief Plan

No. Village / Area Population Name of

Relief Camp

Nearest Health

Facility Distance (km) Committee

5.4.2 Health Facilities

A list of health facilities shall be prepared giving location, telephone

number and name of key person at the facility.

Table 5.2: List of public health facilities

No Location Name Contact Name Telephone Details



23

Appendices

Appendix A. Communications Plan _______________________________________________________________ 24 Appendix B. Scheme Drawings __________________________________________________________________ 28 Appendix C. Dam Break Modelling _______________________________________________________________ 29



24

A.1 Framework for Communication Plan

The following plan has been developed as a framework only, and

details must be added and periodically reviewed and revised, as

necessary, to address any changing conditions.

A.2 Control Rooms

A 24-hour Control Room shall be established in the office of the DCO

immediately upon receipt of information from the provincial government.

A daily situation report shall be provided to this control room by all Local

Response Teams.

AC control rooms shall be established upon receipt of instruction to do

so from the DCO.

A.3 Identification of Areas at Risk

A.3.1 Most Vulnerable Properties

The table below lists the identified properties and communities that are considered most vulnerable to flooding during an emergency event. The properties and communities listed are those along the Jhelum River between the proposed Karot HPP dam site and the downstream Mangla Reservoir. This list may not be exhaustive and is to be reviewed and updated following discussions with the local communities.

Table A.1: Most Vulnerable Properties

Associated Rainy day failure Flood Extent Map Location Description Comments

Figure 4.2A Right bank, Karot Village (3 no.) Affected properties likely to be relocated during resettlement.

Figure 4.2A Left Bank, Hollar Village (4 no.) Affected properties likely to be relocated during resettlement.

Figure 4.2A Right Bank, Immediately South of Karot Village

(6 no.) Affected properties. Potentially to be relocated during

resettlement.

Figure 4.2A Right bank, 5km downstream of Karot Village

(1no.) Isolated property

Figure 4.2B Right Bank, Banahal Village Various properties affected in community

Figure 4.2B Left Bank, Thalarajwali Village Various properties affected on outskirts of community

Figure 4.2C Left Bank, 5km downstream of Pallal Mallahan

Isolated low lying property at confluence with Mangla reservoir.

Appendix A. Communications Plan



25

A.3.2 Flood Extent Maps

Maps of the affected properties, communities and areas have been

prepared and show the extent of the Probable Maximum Flood (PMF),

‘Sunny Day’ and ‘Rainy Day’ failure scenarios, as fully explained in the

‘Dam Break Analysis’ document. These maps should be updated and

continually reviewed to include details of road network and community

changes.

A full set of Inundation maps is included in Appendix C. The overview

‘worst case’ rainy day failure extent map identifying the potentially

affected property is included as follows:

Figure A.1: Rainy Day Failure Extents Map

Source: Mott MacDonald (included in full in Appendix C).



26

A.3.3 Notification

Flood Warnings shall be distributed from the Meteorological

Department to the local population as shown in the figure below. For

flood warnings arising from incidents at the dam site, the identified

responsible person is to inform the relevant DCO and provide all

required information as requested.

Figure A.2: Flow Diagram showing the existing and proposed distribution process of a flood warning

Figure A.2 must be regularly reviewed and updated to ensure the

warning is fully and efficiently distributed to the local community.

Meterological Department or National Disaster

Management Authority (PDMA

Relavent Provincial Disaster Management Authorites

(PDMA)

Relevant District Co-ordination Officer's (DCO's) Offices

Relevant Assistant Commissioners (AC)

Communities, via suitable agreed media.

Dam Operations

Responsible Person



27

A.4 Key Contact Details

The contact details for key persons are listed below. This list should

include any persons responsible for dam operations or emergency

response and is to be kept as a separate controlled sheet and regularly

updated and circulated as required. This list is to be populated during

the project implementation stage and upon appointment of the

operational contractor.

Until the following table can be populated with operational staff details,

the design team’s details have been included in their place. These

should be replaced with operational staff details as soon as they have

been appointed.

Table A.2: Key Contact Details

Name Designation Phone No. E-mail

Mr. Bilal Hasham Assistant Commissioner (Kahuta), Rawalpindi

051-3311232 [email protected]

Mr. Ansar Hayyat Assistant Commissioner (Sehnsa), Kotli-Sattian

051-3356100 TBC

Zeng Guoshun General Manager of Karot Management Department


Shen Yang E&S Deputy Manager of Karot Management Department


TBC Manager of Quality and Safety Department

TBC by Contractor TBC

Chen Yongjian Manager of Construction Entity I 0313-8509928 [email protected]

Du Yibin Manager of Construction Entity II 0315-8708737 [email protected]

Dai Gang Contact person of E&S Multiple Office




28

B.1 As-Built Drawings

This section is to include the package of As-Built scheme drawings

including general site plans and visualisations. ‘For Construction’

drawings should be included until ‘As-Built’ drawings are available.

This section includes the following Scheme Drawings:

Table B.1: EPRP As-Built Drawing Package

Drawing No. Drawing Title Revision

Table B.1 is to be completed to reference the included scheme

drawings.

Appendix B. Scheme Drawings



29

C.1 Overview

The dam break modelling procedure is fully detailed in document:

� ‘720MW Karot Hydropower Project – Dam Break Analysis’

Two breach scenarios have been considered in the analysis:

� ‘Sunny Day Failure’- Failure of the dam resulting in the uncontrolled

release of all impounded water

� ‘Rainy Day Failure’- Failure of the dam resulting in the uncontrolled

release of all impounded water, plus the inflows resultant from the

Probable Maximum Flood (PMF) design flood event

These failure scenarios have been compared with the flooding

associated with natural weather events and the operational level of

Mangla Reservoir.

The results show that only isolated properties would be at risk in the

event of failure of the dam on both a sunny day and during an extreme

flood event. Furthermore the number of properties potentially affected

by a dam break scenario is very small in relation to the size of the dam

development, particularly when considered within the international

context.

C.2 Inundation Maps

This section includes the following Inundation extent maps:

Table C.1: Inundation Maps

Drawing No. Drawing Title Revision

Figure 4.1 PMF Flood Extents 1

Figure A.1a PMF Flood Extents – North Section 1

Figure A.1b PMF Flood Extents – Middle Section 1

Figure A.1c PMF Flood Extents – South Section 1

Figure 4.2 Rainy Day Failure Extents 1

Figure 4.2A Rainy Day Failure Extents – North Section 1

Figure 4.2B Rainy Day Failure Extents – Middle Section 1

Figure 4.1C Rainy Day Failure Extents – South Section 1

Figure 4.3 Sunny Day Failure Extents 1

Figure 4.3A Sunny Day Failure Extents – North Section 1

Figure 4.3B Sunny Day Failure Extents – Middle Section 1

Figure 4.3C Sunny Day Failure Extents – South Section 1


Appendix C. Dam Break Modelling



63

Figure C.1: Areas used temporarily during construction (green) compared to the permanent Project features (orange)

Source: Mott MacDonald based on information received from KPCL

Appendix C. Temporary and Permanent Project Components

64 350133/PHR/ENS/1/B July 2015 Karot HPP ESMP


Figure C.2: Areas used temporarily during construction (green) in comparison to the permanent Project features (red)

Source: Mott MacDonald based on information received from KPCL



65

D.1 Introduction

This document includes a framework for Karot HPP Biodiversity Management and Action Plan (BMAP).

This project-specific BMAP will be drafted at least one month before construction to allow for actions to be

implemented. Construction of the site camp and access roads are planned for December 2015 and

therefore the BMAP will be drafted by November 2015. KPCL will appoint a reputable NGO or independent

consultant to prepare and oversee the implementation of the BMAP and to undertake the monitoring and

some other activities that require more specialist skills.

The following sections reflect the structure of typical BMAP and guidance is provided on what each section

should include.

D.2 Rationale and Scope of the BMAP

D.2.1 Why is the BMAP Needed

The Project is located mainly in natural habitat, which is not classified as critical habitat (refer to Chapter

10 in the ESIA and the Critical Habitat Assessment in Appendix F in Volume III of the ESIA). The

preparation of a Biodiversity Action Plan (BAP) is required when the project is located in critical habitat,

and is recommended in natural habitat. A Biodiversity Management Plan (BMP) is highly encouraged in

both natural and critical habitats (IFC, 2012b). This BMAP will include measures and actions that are

addressed in a BAP and a BMP.

This section of the BMAP will refer to any provincial and national requirements if they specifically require or

recommend the preparation of a BAP, BMP or BMAP.

D.2.2 Aims and Objectives of the BMAP

The aim of the BMAP will be to demonstrate no net loss in natural habitats. The BMAP will include a set of

actions for the conservation and enhancement of biodiversity in the Project area. The BMAP will ensure

the Project:

Implements the mitigation and monitoring in the ESIA

Complies with national legislation and policy requirements

Complies with lender and other international requirements

Addresses the concerns and expectations of the stakeholders

Implements best practice and sustainable solutions

D.2.3 Formulation of the BMAP

The BMAP will be prepared in line with IFC PS6 and IFC Guidance Note 6, the CSAIL Biodiversity

Management (Action) Plan Framework (CSAIL, 2015) and other international guidance (eg IPIECA, 2005).

The BMAP actions will be devised in line with the mitigation hierarchy, ie avoid, reduce (minimise), remedy

Appendix D. Biodiversity Management and Action Plan Framework



66

(restore) and offset. Any biodiversity offsetting measures will be identified and developed following IFC

PS6 requirements, and guidance published by the Business and Biodiversity Offsets Programme (BBOP).

The BMAP will have specific objectives and actions, with targets, indicators and responsibilities for each

action. The BMAP will be an overarching document that is intended to be used by KPCL and EPC

contractor environmental managers. Some actions in the BMAP will need to be translated into more

detailed plans (see Section 8.2 below), or more specific method statements for different construction

activities. The responsibilities will be specified in the BMAP.

D.2.4 Stakeholder Consultation

Stakeholder consultation is an integral component in the formulation of a BMAP. It is essential to engage

with stakeholders to gather opinions on the biodiversity baseline, project impacts, conservation priorities

and implementation of actions. A limited number of stakeholders were consulted as part of the ESIA, but

additional and more specific stakeholder consultation will be required to inform the BMAP.

Stakeholders will be identified and categorised first, then a stakeholder influence/interest analysis should

be undertaken.

D.2.5 Study Area

The study area of the BMAP will be described and presented on a map. The relationships with the ESIA

Area of Influence and the Discrete Management Unit used in the Critical Habitat Assessment will be

clarified.

D.3 Legal, Regulatory, Permitting and Third Party Requirements

This section will present a summary of the following relevant frameworks:

International biodiversity and nature conservation conventions and policies that apply to the projects

and which have been signed by Pakistan

National and provincial legislation and policy on biodiversity and nature conservation

Planning and permitting requirements

CSAIL and KPCL environmental and biodiversity policies and frameworks

IFC Performance Standards

A summary of these frameworks is presented in the ESIA, but this should be updated and made more

specific as part of the BMAP.

D.4 Biodiversity Baseline

This section will present a summary of the biodiversity baseline relevant to the Karot HPP Project based on

literature review, field surveys and consultation with experts. The baseline in the ESIA will be updated and



67

summarised, with focus being on protected areas and habitats and species of global or national

conservation importance.

Additional surveys and monitoring are likely to be undertaken before the start of construction and the

BMAP baseline will incorporate this. It is important to note that the study area of the BMAP is likely to be

larger than the ESIA AoI and therefore additional baseline (desktop study and surveys) will be required for

the remaining part of the BMAP study area that was not covered in the ESIA.

D.5 Current Biodiversity Threats and Project Impacts

This section will summarise the current threats on the protected areas, sensitive habitats and species of

conservation concern in the BMAP study area (which will be larger than the Project area). Threats

identified in the ESIA include deforestation, hunting and poaching of wildlife, overfishing, invasive species,

sedimentation and decrease in water quality because of erosion in the catchment etc. These threats will be

documented further in the BMAP.

A brief summary of the Project impacts on protected areas, sensitive habitats and species of conservation

concern will be provided in this section.

D.6 Priorities for Biodiversity Conservation

The BMAP will need to focus on habitats and species that require special management rather than

considering all biodiversity in the study area. The priorities for the BMAP will be established in consultation

with stakeholders and experts and will include the following amongst others:

Murree-Kotli Sattian-Kahuta National Park

All natural forests even if it is currently degraded

River habitat

Threatened species at global regional or national levels (e.g. Mahasheer, pangolin, common leopard,

smooth-coated otter)

Endemic and restricted-range species (fish and herpetofauna in particular)

Migratory species (vulture species)

D.7 BMAP Actions

D.7.1 Overview

This section will identify and describe conservation actions for the BMAP priorities (see section 6 above) to

ensure the systematic implementation of the mitigation hierarchy. In addition to the measures defined by

the mitigation hierarchy, the BMAP will also include ‘Additional Conservation Actions’, for example awareness raising and education of local communities, research and monitoring, biodiversity enhancement

measures etc.



68

The following sections present a summary of the main actions that will be developed in the BMAP.

Additional actions are likely to be identified following the baseline update and stakeholder consultation.

D.7.2 ESIA Biodiversity Mitigation

The following mitigation presented in the ESIA will be further developed in the form of concrete actions in

the BMAP:

Aquatic Habitats and Species

Management Control

Environmental Flows and Hydropeaking Management

Fish movement: provision of fish pass, fish bypass, catch and release programme

Hatchery Breeding Programme

Commercial Fish Protection Measures

Habitat Enhancement

Terrestrial Animal Species

Noise Reduction

Reduction and Control of Artificial Lighting

Ban on Hunting and Poaching

Mitigation for Breeding, Foraging and Wintering Birds

Terrestrial Habitats and Flora

Measures to avoid or minimise adverse impacts on sensitive habitats

Restore habitats temporarily affected by construction and spoil deposits (also see Habitat Removal and

Restoration Plan)

Investigate options and design any offsetting required for terrestrial habitats and species

D.7.3 Introduction and Spread of Non-Native and Invasive Species

Nine terrestrial non-native and invasive plant species have been recorded in the AoI. The EPC contractor

will monitor these species during construction and will identify and report new invasive species establishing

in the Project areas during construction. Other species known to be invasive in Pakistan and globally (refer

to Lowe et al., 2000) will be also monitored if they are recorded on the construction sites. A local botanist

will be employed to undertake the monitoring or will be contacted to confirm the identification of invasive

species.

IFC PS6 (IFC, 2012a) includes best practice measures with regard to Alien Invasive Species (AIS). In the

absence of industry specific guidance, construction and operational activities on this Project will comply

with international guidelines on the prevention and management of alien invasive species (AIS) (IPIECA &

OGP, 2010). Preventative, control and monitoring measures will need to be implemented as explained in

the guidance above.



69

D.7.4 Support for the Murree- Kotli Sattian-Kahuta National Park

This national park was designated in 2009 by the Punjab Fisheries and Wildlife Department, but the

boundaries, reasons for designation and conservation objectives are not defined.

KPCL will provide support to the above department and WWF Pakistan for all or some of the following

activities:

Capacity building for Punjab Fisheries and Wildlife Department

Funding of one position in WWF Pakistan to deal with the national park and/or Jhelum River

Define the boundaries of the national park, establish conservation objectives and prepare management

plan for the park

Implement protection and enhancement measures for the national park and employ wardens

Manage lands under KPCL control to meet the conservation objectives that are ultimately established

for the national park, within the constraints of necessary construction activities until commissioning and

then operation and maintenance activities throughout operations

D.7.5 Awareness Raising and Education

The awareness raising and educational programmes that KPCL will sponsor will be described in detail in

the BMAP. The conservation importance of native species and their threats will be explained along with the

services provided by the local ecosystems and biodiversity, and the threats posed by invasive species of

plants and animals (especially invasive fish and plants) to native biodiversity. The programmes will also

include measures to reduce overgrazing and soil erosion. KPCL will sponsor an ecology module in local

secondary schools and will provide two university fellowships for local students to study ecology, fisheries

and/or engineering. Women students will be encouraged.

D.7.6 Biodiversity Monitoring

Monitoring of certain biodiversity features will be undertaken during construction and for a number of years

post-construction. An indicative programme for this monitoring is provided in Chapter 10 of the ESIA

Volume III, with more detail to be provided in the BMAP.

A long-term biodiversity monitoring and evaluation programme and methodology will be included in the

BMAP in order to demonstrate no net loss for natural habitats (where feasible). The biodiversity values that

will be monitored as part of the BMAP will include the following as a minimum:

Threatened fish species: Tor putitora

Endemic fish species: Bagarius bagarius

Other indicator or commercially important fish species: Clupisoma garua, Schizothorax plagiostomus,

Cyprinus carpio (invasive)

Water quality

Smooth-coated otter and common otter

Diversity of river meso-habitats

Threatened mammal species: pangolin and common leopard



70

Egyptian vulture

Endemic reptile species: Rohta’s gecko, slender blind snake, Ahsan’s worm snake

D.8 BMAP Implementation

D.8.1 Responsibilities, Partnerships and Programme

KPCL will implement a local NGO or environmental consultancy to lead on the implementation of the

BMAP. The EPC contractor and a number of stakeholders will need to be involved as partners for the

implementation of some actions. At least one stakeholder workshop will be organised for the BMAP and

this should help establish partnerships for the BMAP implementation.

A clear programme and responsibilities for the BMAP implementation will need to be agreed and included

in this section of the BMAP. The internal and external responsibilities will be presented in the form of an

organogram. Besides, KPCL will ensure that the BMAP is integrated into the company management

systems and processes.

The BMAP will identify any training requirements for staff and managers of KPCL and/or contractors,

including who will be responsible for conducting the training and who must be trained in what skills.

D.8.2 Relationships with Other Plans

Jhelum River Basin BAP

It is intended that a Jhelum River Basin BAP (Jhelum BAP) is o prepared given that several hydropower

projects are planned on this river. The Jhelum BAP will be prepared by a reputable independent

consultant, with funding from all hydropower developers in the area of concern (including KPCL), and in

partnership with the relevant Government departments. Karot BMAP and subsequent updates will take into

consideration the decisions made and actions implemented in the Jhelum BAP.

Habitat Removal and Restoration Plan (HRRP)

A HRRP will be produced by the EPC contractor and reviewed by a qualified ecologist before the start of

construction. The HRRP will set out the minimum requirements in relation to the clearance and restoration

of natural habitats, and the removal, storage and reinstatement of soil. The HRRP can be an independent

document or can be included in the CESMP/EMP (see below). The BMAP will provide more guidance on

how the HRRP will be produced.

Construction Environmental Management and Monitoring Plan

The EPC contractor will prepare a Construction Environmental and Social Management Plan (CESMP)

before the start of vegetation clearance and construction. This plan will comprise a series of plans,



71

including an Ecological Management Plan (EMP). The EPC contractors EMP will be developed in line with

the BMAP.

Catchment Management Plan

KPCL will contribute to the preparation and implementation of a Catchment Management Plan (CMP)

together with other hydropower developers on Jhelum River, the Forest Departments and Environment

Protection Agencies of Punjab and Pakistan-administered Kashmir, and the local communities. This plan

will cover the areas along the new Karot reservoir, dam and downstream; up to the tail of Mangla Dam

reservoir.

Measures to control soil erosion will form a significant component of the CMP and will also include the

following measures:

Undertake geotechnical survey and monitoring of affected areas

Planting of vegetation on the slopes affected by erosion (include maintenance and monitoring of

plantation)

Implement slope stabilisation techniques

Reduce the grazing pressure on the eroded slopes through fencing

Raise awareness of local communities

Other Plans

As stated in the CSAIL BMAP Framework, other plans that are or may be related to the BMAP include:

Waste management plan

Water quality management plan

Site rehabilitation and landscaping plan

Emergency preparedness and response plan

Hazardous materials management plan

Spill prevention and response plan

Stakeholder engagement plan

D.9 Monitoring, Evaluation and Improvement

It is recommended that an independent NGO or environmental consultancy is employed by KPCL to

monitor and evaluate the implementation of the BMAP. BMAP indicators and performance will be reviewed

against objectives. The actual objectives and targets will periodically be reviewed. To improve any

discrepancies between BMAP objectives and performance, recommendations will be made for actions to

be modified where required.

The BMAP will include provisions for the periodic inspection/monitoring of the biodiversity mitigation. For

verification and monitoring, the BMAP will specify (CSAIL, 2015):

The precise activities and measures that are needed to mitigate potential impacts

The sites at and the timing during which mitigation measures will be applied



72

The measurable/observable criteria by which implementation of biodiversity protection mitigation will be

judged successful, and when they will be considered complete

The frequency of inspection and monitoring

The required qualifications of persons who will conduct the monitoring and inspection

Records that must be kept and the person responsible for keeping the records

Reports that will be prepared, to whom the reports are to be submitted for review, and the length of

time records will be kept

The BMAP will describe what actions will be taken, and by whom, if inspection/monitoring results show that

the biodiversity management practices do not meet applicable requirements, including the requirements of

the BMAP itself. The BMAP will also identify the level within KPCL and CSAIL to which violations of

requirements and/or failures of mitigation measures to achieve their goals must be reported.

The BMAP will be updated at least once per year during the construction period and five years into

operation (2015-2020) to incorporate:

Changes in the Project design and/or construction schedule

Significant findings of the ongoing biodiversity monitoring

Changes in the baseline and cumulative impacts because of other development projects

Changes in the national legislation and/or lender requirements

New or different expectations of stakeholders

D.10 Reporting, Communication and Verification of BMAP Performance

To verify the outcomes and progress of the BMAP implementation, internal and external reporting will be

specified in the BMAP. External reporting may be requested by the lenders and/or national/provincial

regulatory bodies.

Stakeholders also will be kept informed about the BMAP outcomes and this can in the form of leaflets,

posters, workshops, internet, newspapers etc. A communication strategy will be developed and included in

this section of the BMAP.

The BMAP will include a clear internal reporting mechanism for the BMAP implementation to ensure the

information is available to company managers, environmental managers/officers, and other staff

concerned.



73

Appendix E. Workers’ Code of Conduct

Karot Project Workers’ Code of Conduct

This Code of Conduct is to govern the behaviour of workers employed by Karot Power Company (Pvt) Ltd (KPCL) and all its contractors and subcontractors during the construction of the Karot Hydropower Project (the Project).

Non-compliance with this Code of Conduct may result in disciplinary measures.

The Code of Conduct will be reviewed annually, taking into consideration any relevant complaints by communities or by workers against other workers.

General Responsibilities:

• All workers must work towards maintaining good relations with each other and with the communities near

to the Project

• Workers will respect the cultural norms of the local community

• All workers are forbidden to possess or consume alcohol during working hours

• The use of drugs or medicines must be authorized by the physician on site

• Workers must use the designated access routes between the site and accommodation

• All workers are forbidden to smoke except in specified areas

• All workers must comply with the occupational health and safety plan at all times

• All workers must wear personal protective equipment appropriate to the task they are undertaking

• All workers must report accidents, incidents and potentially unsafe situations and practices to a senior

member of staff

• All workers must report defective or unsafe equipment to a senior member of staff

• All workers must be aware of and adhere to the site emergency preparedness and response plan

• All workers must report unethical or fraudulent behaviour

• Bullying or harassment amongst the workforce is not acceptable and will not be tolerated

• All workers are required to be prudent in their use of resources especially water and electricity

• Workers will avoid unnecessary damage to land, crops, trees, structures and any property privately owned

by people in the local area

• All workers are forbidden from keeping pets in the camps, such as dogs, cats, birds or any other animal

from the local environment

• Hunting and poaching are forbidden

• It is forbidden to cut trees in the local area

• Collection of natural resources from the local area is forbidden. This includes firewood, timber, water,

plants or animals of any kind

• All workers must stop works and notify their Supervisor on site if archaeological pieces, such as pottery or

other historical artefacts, are found

• All workers must dispose of and remove adequately any waste on site in accordance with the waste

management plan

• All workers are forbidden to carry guns or any other type of weapon

• Visitors to the workers’ accommodation will not be allowed

Driving to, from and on and the construction site:

• Vehicles must always be driven in accordance with the Traffic Management Plan

• Vehicles must not use routes other than those designated in the Traffic Management Plan.

• Project drivers are not authorised to carry passengers other than Project workers

• The Project’s designated speed limits must not be exceeded

• Drivers will adhere to dust suppression measures outlined in the Project’s Environmental and Social

Management Plan

Karot Project Workers’ Code of Conduct

Declaration

This Workers’ Code of Conduct has been explained to and / or read by me. I understand that I must behave in accordance with the Workers’ Code of Conduct at all times during my employment on the Karot Hydropower Project.

Name: ________________________________________________________________

Employer:______________________________________________________________

Employee number:_______________________________________________________

Signed:______________________________________________Date:______________



74

Appendix F. Labour Commitment

Karot Project Labour Commitment �

This Project Labour Commitment is to govern the treatment of workers employed by Karot Power Company Ltd’s (KPCL) contractors and subcontractors on the construction and operation of the Karot Hydropower Project (the Project)

1.

Compliance with the Labour Commitment will be monitored throughout construction and operations by KPCL. The Labour Commitment will be reviewed as necessary based on the results of monitoring and grievances raised by workers. Any company working on the Project will allow monitors to confirm implementation of this commitment through: a review of human resource records, timekeeping and payroll systems; interviews with workers; inspections of accommodation; and, interviews with human resource and other management staff.

�

��This Labour Commitment applies to all workers who are employed on the core business processes of the Project, without which

the Project could not continue, for a duration of one month or more.�

Karot Project Labour Commitments

KPCL commits to working with companies, contractors and service providers who uphold labour rights. In practice

this means that KPCL expects its employment partners to:

• Adhere to national labour and employment laws.

• Implement and adhere to the International Finance Corporation’s Performance Standard 2 on Labour and

Working Conditions.

• Treat workers with respect.

• Provide workers with contracts and information so that the working terms and conditions are transparent and

understood. At a minimum, contracts will detail: wages and benefits, wage deductions, hours of work,

overtime arrangements and overtime compensation, breaks, rest days, leave, probation period and contract

end notification periods.

• Cap overtime at two hours a day or twelve hours a week.

• Allow the formation of workers’ organisations. Respect workers’ representatives and the terms of any

collective bargaining agreements. Do not prevent or take action against workers who organise. Liaise with

workers’ representatives as necessary.

• Hire, promote and compensate workers solely based on their ability to do the job. If local workers are

qualified and available, prioritise them for jobs. Encourage women and men to apply for jobs. Ensure migrant

workers are afforded the same rights and treatment as other workers Give workers equal access to training,

tools and opportunities for advancement.

• Pay wages on a timely basis at least every month. Pay at least minimum wage. Ensure equal remuneration

for men and women workers for work of equal value.

• Provide a workplace that is free from harassment by management and by other workers

• Provide workers with a safe and healthy work environment, including efforts to manage inherent work risks

and hazards. Follow the health and safety plan. Provide induction, toolbox talks and ongoing training to

ensure proper use of personal protective equipment and training. Allow employees the right to remove

themselves from hazardous situations.

• Allow workers to retain their identity documents including passport.

• Do not require any fees to be paid by workers to obtain employment on the Project or to the company over

the last twelve months. If there is evidence of paid fees, reimburse them.

• Ensure access to a transparent process for workers to express concerns and file labour grievances, including

anonymous complaints about work related issues.

• Do not employ forced labour or trafficked persons, or exploit child labour.

• Provide transportation to and from site that is safe, maintained in working condition, and is readily accessible.

If applicable, provide accommodation that is appropriate for its location and is clean, safe and meets

international standards (typified by the International Finance Corporation’s guidance note on workers’

accommodation).

• Develop and implement a retrenchment plan if any large layoffs are anticipated.�