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Environmental and Social Monitoring Report Project Number: 51051-001 January–March 2021 May 2021 Thailand: Chonburi Natural Gas Power Project Prepared by Gulf SRC Company Limited for Asian Development Bank. The environmental and social monitoring report is a document of the borrower. The views expressed herein do not necessarily represent those of ADB's Board of Directors, Management, or staff, and may be preliminary in nature. In preparing any country program or strategy, financing any project, or by making any designation of or reference to a particular territory or geographic area in this document, the Asian Development Bank does not intend to make any judgments as to the legal or other status of any territory or area.
REPORT ASIAN DEVELOPMENT BANK JAPAN BANK FOR INTERNATIONAL COOPERATION MIZUHO BANK, LTD. BANGKOK BANK PUBLIC COMPANY LIMITED SUMITOMO MITSUI BANKING CORPORATION EXPORT-IMPORT BANK OF THAILAND Gulf SRC 2,500 MW Combined Cycle Power Plant Project Lenders’ Technical Advisor Quarterly Environmental and Social (E&S) Monitoring Report No. 9 [January 1st 2021 to March 31st 2021] 127000407 10 May 2021 Revision 0
Lenders’ Technical Advisor Quarterly Environmental and Social (E&S) Monitoring Report No. 9
Page 1
Project Project No.
Gulf SRC 2,500 MW Combined Cycle Power Plant 127000407
Project
Revision Date
Revision 0 10 May 2021
Address
AFRY (Thailand) Ltd.
Vanit II Bldg., 22nd Floor, Room No. 2202-2204,
1126/2 New Petchburi Road, Makkasan,
Rajchthewi, Bangkok 10400 THAILAND
Phone
+66 2 108 1000 (THAILAND)
Contact
Mr.Mark Wilson
Mobile
+66 2 108 1000
E-mail
Mark.wilson@afry.com
Client
ASIAN DEVELOPMENT BANK
JAPAN BANK FOR INTERNATIONAL COOPERATION
MIZUHO BANK, LTD.
BANGKOK BANK PUBLIC COMPANY LIMITED
SUMITOMO MITSUI BANKING CORPORATION
EXPORT-IMPORT BANK OF THAILAND
Report
Lenders’ Technical Advisor Quarterly Environmental and Social
(E&S) Monitoring Report No. 9
[January 1st 2021 to March 31st 2021]
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NOTICE
It is the good faith and belief of AFRY (Thailand) Ltd (“AFRY” or the “LTA”) that the estimates and
conclusions contained in this report are reliable. However, the LTA does not warrant or guarantee
their accuracy. Use of the report and its estimates shall, therefore, be at the user’s sole risk. Such
use shall constitute a release of the LTA from and against any liability in connection with such
use, whether liable for special, indirect or consequential damages, whether such liability is
asserted to arise in contract, negligence, strict liability or other theory of law.
This document has been prepared for Asian Development Bank, Japan Bank for International
Corporation and Bangkok Bank Public Company Limited in relation to the 2,500-megawatt
combined cycle natural gas fired power plant project of Gulf SRC Company Limited in Hemaraj
Eastern Seaboard Industrial Estate, Chonburi Province in Thailand (the “Project”).
AFRY acknowledges and agrees that Asian Development Bank, Japan Bank for International
Cooperation (the international arm of Japan Finance Corporation), and Bangkok Bank Public
Company Limited, and certain other lenders of the Project accepted by the LTA from time to time
(hereinafter jointly the “Lenders”) are entitled to and will rely on this report. The LTA consent to
making this report available to the Lenders is subject to and on the understanding that before
receiving and relying on this report, each Lender has as set out in the Engagement Agreement
signed between the LTA, Gulf SRC Company Limited, Independent Power Development Company
Limited and Bangkok Bank Public Company Limited on July 2018 concerning the LTA’s
engagement (“Engagement Agreement”) either itself signed the Engagement Agreement or
confirmed and accepted in writing that it is aware of, understands and agrees to the scope of the
LTA’s engagement and the liability as well as other terms and conditions which may apply as set
out in the Engagement Agreement and without limitation confirms that it unconditionally agrees
to be bound by the terms of the said Engagement Agreement (including without limitation clauses
9.7 and 11) and any limitations of or exceptions to liability included for the benefit of the LTA,
and subject to the below conditions.
All the above-mentioned Lenders hereby entitled to rely on this report acknowledge and agree
that, prior to any issue becoming litigious, all disputes arising out of or in connection with the
report shall be channelled through one Lender only.
The Lender may not use the contents of this report for any purpose other than:
a) the provision of financial accommodation to Gulf SRC Company Limited in connection with the
Project including disclosing it to external accountants, auditors or lawyers for said purpose on the
basis that they do not rely on the report and keep it confidential;
b) if required by mandatory law or in accordance with an official directive or request of a
governmental authority or agency for its internal purposes which, if not having the force of law,
compliance is in accordance with good practice of responsible banks or financial institutions on
the basis that they do not rely on the report and keep it confidential; or
c) in connection with any litigation or proposed litigation concerning the report.
The opinions and forecasts contained in this report have been prepared in good faith, with
reasonable care and due diligence based on reasonable assumptions. However, no opinion or
forecast in this report is, or should be, relied upon as a promise or representation of the future.
Actual results may be different from the opinion contained in this report, as anticipated events
may not occur as expected and the variation may be significant.
All the above mentioned Lenders hereby entitled to rely on this report acknowledge and agree
that monetary damages may be an insufficient remedy for the LTA if the recipient or Lender
breaches the conditions of disclosure listed in paragraphs a) to c) above and in addition to any
other remedy which may be available in law or equity, the LTA may seek injunctive relief to
prevent any actual or threatened breach of the conditions of disclosure and to compel specific
performance of those conditions of disclosure.
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EXECUTIVE SUMMARY
Gulf SRC Company Limited (“GSRC” or the “Owner”) is developing Gulf SRC 2,500 megawatt
(“MW”) Combined Cycle Power Plant (“CCPP”) project in Hemaraj Easter Seaboard Industrial
Estate (“HESIE”), Sriracha District, Chonburi Province, approximately 140 km east of Bangkok.
Natural Gas will be transported to GSRC through a new 2.5 km long gas pipeline (“Interconnecting
Pipeline”) now constructed for the Project. EGAT have constructed a 10.9 km overhead
transmission line to connect GSRC’s switchyard with EGAT’s Pluak Daeng Substation. Raw water
to GSRC will be supplied by East Water via the installed Hemaraj Raw Water Pipeline.
This is the ninth Quarterly Environmental & Social (“E&S”) Monitoring Report of AFRY (the Lenders
Technical Advisor) and covers the period from January 1st, 2021 to March 31st, 2021.
AFRY would like to thank the Owners and EPC Contractor for their valuable support during the
virtual site visit and for providing the documentation requested to prepare this report.
Health and Safety
The key OHS statistics for the construction monitoring period are 2,081,004 safe man hours
accumulated for the Power Plant Area and Raw Water Pond Area. There were 7 HSE incidents and
131 hazard observations for the Power Plant Area and Raw Water Pond Area. The ratio for number
of safety officers to number of workers is one safety officer per 50 workers which is considered to
be sufficient.
Labour and Working Conditions and Security
The number of workforce personnel as of March 25th, 2021 is 2,037 male workers and 565 female
workers.
Welfare facilities at the Project site includes rest shelters, toilet/bathroom facilities, drinking water
stations and medical facilities which continue to be adequately managed. Hygiene/cleanliness and
the welfare facilities at the workers camp also continue to be adequately managed.
At the workers camp there are a sufficient number of rooms (1,684) for the total number of
persons residing (1,887) i.e. no more than 2 adults to a room.
In general, the hygiene/cleanliness of the workers camp is considered to be adequate in all zones
and the facilities (toilets, bathing and medical) continue to be adequately managed. As part of
the COVID-19 preventative measures the workers camp continues to have dedicated area for new
workers and area of quarantine in case any of the residents are found to have COVID-19
symptoms.
There were no workers grievances / suggestions recorded during the construction monitoring
period.
Stakeholder Engagement
The Environmental Impact Monitoring Committee meeting was held on January 22nd, 2021. The
LTA understands no grievances were reported by the committee members during the meeting.
The Minutes of the Meetings have been requested from the Owner but they are yet to be received.
The Owner reported no stakeholder grievances for the construction monitoring period. A notice
board detailing contact details for complaints or suggestions remains in place at the entrance to
the Project site. The Owner also uses the mobile communication/social media application known
as Line for receiving grievances/concerns via a community group established on the Line
application which has been shared with community representatives. The LTA recommends that
the Owner establishes a Community Relations Activity Register to document community concerns
which aren’t grievances. This should include concerns raised by the community through social
media and those directly made to the Owners Community Relations team
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Environmental and Social Monitoring
The EHS capacity (resources) observed for this construction monitoring period and the training
undertaken was considered to be sufficient. The Owner and Contractor continue to implement
specific HSE procedures and programs, this includes implementing COVID-19 prevention
methods.
It is AFRY’s opinion that the Project was operating in compliance with the Project E&S
requirements during the construction monitoring period.
In addition to establishing the Community Relations Activity Register an additional Corrective
Action for this period is for the Owner to update the Schedule 3 - Environmental and Social
Monitoring Compliance Report (July to December 2020) to address the comments of the LTA and
ADB shared with the Owner prior to and during the virtual site visit.
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Contents
1 Introduction ....................................................................................................... 9
1.1 Project Description ............................................................................................. 9
1.2 Role of AFRY.................................................................................................... 13
1.3 Objectives of the Report .................................................................................... 13
1.4 Construction Monitoring Period ........................................................................... 14
1.5 Project Participants ........................................................................................... 14
1.6 Virtual Site Visit Agenda .................................................................................... 14
1.7 Reports Reviewed............................................................................................. 15
2 Health And Safety ............................................................................................. 16
2.1 Overview ........................................................................................................ 16
2.2 Health and Safety Statistics ............................................................................... 16
2.3 Fatalities......................................................................................................... 19
2.4 Accident / Incident Reporting ............................................................................. 19
2.5 HSE Staff ........................................................................................................ 20
2.6 Low Risk Issues ............................................................................................... 20
3 Labor And Working Conditions And Security ...................................................... 21
3.1 Workforce Profile and Recruitment ...................................................................... 21
3.2 Welfare Facilities at Project Site .......................................................................... 21
3.3 Workers Grievance Mechanism ........................................................................... 23
3.4 Workers Camp and Transportation ...................................................................... 23
3.4.1 Workers Camp .................................................................................... 23
3.5 Transportation ................................................................................................. 25
3.6 Security .......................................................................................................... 25
3.6.1 Project Site and Block Valve Station........................................................ 25
3.6.2 Workers Camp .................................................................................... 25
4 Stakeholder Engagement .................................................................................. 26
4.1 Engagement Activities and CSR .......................................................................... 26
4.2 Stakeholder Grievance Mechanism ...................................................................... 26
5 Environmental And Social Monitoring ................................................................ 27
5.1 EHS Capacity (Resources and Training) ................................................................ 27
5.1.1 EHS Capacity (Resources) ..................................................................... 27
5.1.2 EHS Training....................................................................................... 27
5.2 EHS Licenses, Permits, Authorizations and Compliance Status .................................. 28
5.3 EHS Management System and Implementation Status ............................................ 29
5.3.1 EHS Policies ........................................................................................ 30
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5.3.2 Organisational Structure and Staffing ...................................................... 30
5.3.3 HSE Procedures and Programs ............................................................... 30
5.3.4 Training Requirements.......................................................................... 32
5.3.5 EHS Monitoring and Reporting ............................................................... 32
5.4 Compliance with EHS National Laws and Regulations .............................................. 32
5.4.1 Construction Environmental Monitoring ................................................... 32
5.4.2 Ambient Air Quality .............................................................................. 32
5.4.3 Noise ................................................................................................. 33
5.4.4 Wastewater from Workers ..................................................................... 33
5.4.5 Waste ................................................................................................ 36
5.5 Compliance with ESIA/EMP, ADB Safeguards, IFC Performance Standards and IFC EHS
Guidelines ....................................................................................................... 38
5.5.1 IFC EHS Guidelines .............................................................................. 71
5.5.2 Land Acquisition and Involuntary Resettlement ......................................... 72
5.6 Associated Facilities .......................................................................................... 72
5.6.1 Hemaraj Raw Water Pipeline.................................................................. 72
5.6.2 500 kV Overhead Transmission Line........................................................ 72
6 Corrective Action Plan....................................................................................... 74
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Figures and tables
Figures
Figure 1-1 Location of GSRC Project Site ......................................................................... 9
Figure 1-2 Project Area within HESIE ............................................................................ 10
Figure 1-3 Interconnecting Pipeline Start Point and End Point............................................ 11
Figure 1-4 Proposed Alignment of the 500 kV Overhead Transmission Line (Red Line) ........... 11
Figure 1-5 Alignment of Hemaraj Raw Water Pipeline(Yellow Line) ..................................... 12
Tables
Table 2-1 HSE Statistics 1 ........................................................................................... 16
Table 2-2 HSE Statistics 2 ........................................................................................... 17
Table 2-3 HSE Incidents ............................................................................................. 17
Table 2-4 HSE Staff for the Power Plant Area and Raw Water Pond Area ............................. 20
Table 3-1 Workforce Number ....................................................................................... 21
Table 3-2 Labour Protection Act Requirements and Compliance for Welfare Facilities ............. 22
Table 3-3 Owner Workers Camp Checklist ...................................................................... 24
Table 5-1 EHS Training During the Construction Monitoring Period ..................................... 27
Table 5-2 Status of EHS Related Permits ....................................................................... 28
Table 5-3 Status Approval for Interconnecting Pipeline..................................................... 29
Table 5-4 Status of EHS Polices.................................................................................... 30
Table 5-5 Status of Existing HSE Procedures and Programs for the Power Plant .................... 30
Table 5-6 Water Quality Monitoring Results at the Project Site .......................................... 34
Table 5-7 Water Quality Monitoring Results at the Workers Camp ...................................... 35
Table 5-8 Waste Monitoring Results .............................................................................. 37
Table 5-9 Status of Project Against Project E&S Standards of the ESIA/EMP......................... 38
Table 5-10 Project Compliance with IFC EHS Guidelines ................................................... 71
Table 6-1 Corrective Action Plan for the Construction Monitoring Period (January to March 2021)
............................................................................................................. 75
Appendices
Appendix 1 – Virtual Site visit Photos ...................................................................... 76
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GLOSSARY OF TERMS
ADB Asian Development Bank
CSR Corporate Social Responsibility
E&S Environmental and Safety
EHS Environmental, Health and Safety
EMP Environmental Management Plan
EPC Engineering, Procurement and Construction
ESIA Environmental and Social Impact Assessment
GT Gas Turbine
HESIE Hemaraj Easter Seaboard Industrial Estate
HSE Health, Safety and Environment
IFC International Finance Corporation
JBIC Japan Bank for International Cooperation
LTS Lenders’ Technical Advisor
MHPS Mitsubishi Hitachi Power Systems Project (Thailand)
MOI Ministry of Interior
MW Megawatt
OHS Occupation Health and Safety
ONEP Office of Natural Resources and Environmental Policy and Planning
PPA Power Purchase Agreement
SCOD Schedule Commercial Operation Date
SPS Safeguard Policy Statement
WBG World Bank Group
WHO World Health Organisation
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1 Introduction
1.1 Project Description
Gulf SRC Company Limited (“GSRC” or the “Owner”) is developing Gulf SRC 2,500 megawatt
(“MW”) Combined Cycle Power Plant (“CCPP”) project in Hemaraj Easter Seaboard Industrial
Estate (“HESIE”), Sriracha District, Chonburi Province, approximately 140 km east of Bangkok.
The site location is shown in Figure 1 1 and location within the HESIE is shown in Figure 1-2
Figure 1-1 Location of GSRC Project Site
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Figure 1-2 Project Area within HESIE
GSRC is being developed on an IPP basis and a 25-years Power Purchase Agreement (“PPA”) has
been signed with EGAT. The Commercial Operation Date (COD) of Unit 1 was achieved on of Unit
1 was achieved on March 31st, 2021. The Schedule Commercial Operation Date (“SCOD”) Unit 2,
Unit 3 and Unit 4 are October 1st, 2021, March 31st, 2022 and October 1st, 2022 respectively.
Natural Gas is transported to GSRC through a new 2.5 km long 28 inches diameter gas pipeline
(“Interconnecting Pipeline”) which is now fully constructed. The Interconnecting Pipeline connects
to the power plant from PTT’s 5th pipeline. The Interconnecting Pipeline start point and end point
is shown in Figure 1-3
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Figure 1-3 Interconnecting Pipeline Start Point and End Point
EGAT will build a new 10.9 km long 500 kV double circuit 4 x 1272 MCM ACSR Overhead
Transmission Line to connect GSRC’s switchyard with EGAT’s Pluak Daeng Substation. The 500 kV
Overhead Transmission Line is considered an “associated facility” in accordance with Asian
Development Bank (“ADB”) Safeguard Policy Statement (“SPS”) 2009 and the International
Finance Corporation (“IFC”) Performance Standards 2012 as this facility will not be funded as part
of the Project. The alignment of the 500 kV Overhead Transmission Line from the GSRC’s
switchyard to EGAT’s Pluak Daeng Substation is shown in Figure 1-4 (red line).
Figure 1-4 Proposed Alignment of the 500 kV Overhead Transmission Line (Red Line)
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Raw water to GSRC is supplied by East Water at a maximum flow rate of 63,000 m3/day. East
Water is managing the raw water supply source within the eastern region area of Thailand. GSRC
will have three raw water ponds located adjacent to the power plant area. The GSRC raw water
ponds have a total capacity of 189,000 m3. The Hemaraj Raw Water Pipeline to supply the raw
water during construction and operation is also considered an associated facility under ADB SPS
2009 and the IFC Performance Standards 2012. The alignment of the Hemaraj Raw Water Pipeline
is shown by the yellow line in Figure 1-5
Figure 1-5 Alignment of Hemaraj Raw Water Pipeline(Yellow Line)
Wastewater from GSRC will be discharged back into the wastewater discharge of HESIE at an
interface point located north west of the power plant.
GSRC will consist of four separate power blocks, all consisting of one gas turbine, one steam
turbine and one HRSG in a 1-1-1 single shaft arrangement. The gas turbine (“GT”) model selected
for GSRC is MHPS M701JAC gas turbine.
GSRC will be cooled through the user of an indirect “recirculating” wet cooling water system using
mechanical draft cooling towers.
GSRC will use natural gas as primary fuel with diesel oil used as back-up fuel.
The Engineering, Procurement and Construction (“EPC”) arrangement for GSRC consists of the
following contracts:
· The Supply Contract between Gulf SRC Company Limited (“GSRC” or the “Owner”) and
Mitsubishi Hitachi Power System, Ltd, as Supplier, for design and engineering services
performed outside of Thailand and for the supply of equipment and materials to be imported
into Thailand date February 8th, 2018;
· The Construction Contract between Gulf SRC Company Limited (“GSRC” or the “Owner”) and
the consortium of Mitsubishi Hitachi Power Systems Project (Thailand) Company Limited
(“MHPS-PTC”) and Sino-Thai Engineering and Construction Public Company Limited (the
“Contractor”) dated February 8th, 2018; and
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· The Coordination Agreement between the Owner, the Supplier and the Contractor (the
Supplier and the Contractor are jointly referred to as the “EPC Contractor”) dated February
8th, 2018.
For design review and construction management purpose for the EPC contract, GSRC has entered
into an Owner’s Engineer agreement with Black and Veatch. For construction site supervision
(including environmental & safety), GSRC has entered into an Owner’s Engineer agreement with
EGAT.
The Notice to Process for the EPC contractor was issued on December 3rd, 2018, with the Limited
Notice to Proceed issued in July 2018.
The financial close for GSRC was achieved in Q4/2018.
1.2 Role of AFRY
AFRY (Thailand) Ltd. (“AFRY” or the “LTA”) has been appointed in the role of Lenders’ Technical
Advisor for the construction and operating and maintenance phases of the Project up to the third
year of the operational phases of all Units.
During this time the LTA will monitor the progress of GSRC and advise the Lenders in all technical,
management and environmental and social (“E&S”) issues that may have a material effect on the
financial standing and success of GSRC. During the construction period the LTA will make
quarterly site visits and meetings with the Owner and relevant parties.
1.3 Objectives of the Report
The objectives of the quarterly E&S monitoring are as follows:
· To assess the Projects compliance with the following Project E&S standards during
construction:
- Applicable Thailand Laws, legislation and regulations;
- ADB SPS (2009);
- World Bank Group (“WBG”) General Environmental, Health and Safety (“EHS”)
Guidelines (2007);
- WBG EHS Guidelines for Thermal Plants (2008);
- IFC Performance Standards (2012)1 , including:
§ PS1: Assessment & Management of Environmental & Social Risks &
Impacts;
§ PS2: Labour and Working Conditions;
§ PS3: Resource Efficiency and Pollution Prevention;
§ PS4: Community Health, Safety, and Security;
§ PS5: Land Acquisition and Involuntary Resettlement;
§ PS6: Biodiversity Conservation and Sustainable Management of Living
Natural Resources;
§ PS8: Cultural Heritage.
- Japan Bank for International Cooperation (JBIC) Guidelines for Confirmation of
Environmental and Social Considerations, 2015.
1
FC PS7 (Indigenous Peoples) is not considered applicable to the Project
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· To review the implementation of the mitigation and monitoring programmes specified in
the Environmental Management Plan (“EMP”) developed as part of the Environmental and
Social Impact Assessment (“ESIA”) for ADB dated October 2018;
· To review the status of EHS management onsite, including the Company’s EHS
Management System, procedures and training and to identify areas for improvement;
· To review the Projects EHS records and compliance with respect to the site specific
management system by the Owners, EPC Contractor and sub-contractors;
· To provide objective reports to the Lenders confirming compliance and if not, recommend
corrective actions, as appropriate to the Project during construction.
1.4 Construction Monitoring Period
This E&S Monitoring Report is the ninth Quarterly E&S Monitoring Report of the LTA and covers
the period from January 1st, 2021 to March 31st, 2021. The report is based on inputs received
from the Owner, the EPC Contractor and discussions held via virtual site visit (due to the COVID-
19 pandemic) on April 22nd, 2021.
1.5 Project Participants
This virtual site visit was attended by the following LTA representatives:
· Mr. Mark Wilson (LTA’s Senior Environmental Consultant);
· Mr. Ilkka Lassila (LTA’s Project Manager);
· Mr. Pramual Numsong (LTA’s Senior Project Engineer); and
· Mr. Tanawat Chaiwatanarat (LTA’s Senior Project Engineer).
1.6 Virtual Site Visit Agenda
Discussions and interviews were undertaken with representatives of GSRC, EGAT and the EPC
Contractor. The following topics were discussed for the construction monitoring period and
findings are presented in this report.
· Safety Statistics;
· Safety Incidents and Reports;
· Environmental Compliance;
· Environmental Monitoring;
· EHS Management Plans;
· EHS training;
· Stakeholder engagement and grievance records;
· EHS capacity (resources);
· Updates to COVID-19 prevention measures/emergency plan;
· Land acquisition/completion of payment status for remaining plots of the NTF. Any
ongoing landowner/community grievances concerned with the NTF;
· Review of comments on ADB E&S Monitoring Compliance Report July to December 2020.
There were no consultations undertaken with communities during the virtual site visit due to the
COVID-19 pandemic.
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1.7 Reports Reviewed
The relevant Project documents pertaining to E&S have also been reviewed. This was aimed at
understanding the ongoing implementation, record maintenance, internal monitoring and
reporting and mandatory regulatory compliances required for the Project.
The following documents were reviewed by AFRY for this construction monitoring period:
· GSRC Progress Technical Reports, January 2021, February 2021 and March 2021;
· EGAT Progress Technical Report for NTF, January 2021, February 2021 and March 2021;
· Lenders Technical Advisor, Quarterly Construction Monitoring Site Visit Presentation
(EHS), April 22nd, 2021;
· Lenders Technical Advisor, Quarterly Construction Monitoring Site Visit Presentation (Site
Progress), April 22nd 2021;
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2 Health And Safety
2.1 Overview
Occupational Health and Safety (“OHS”) for the Power Plant continues to be principally managed
through the Health, Safety and Environment (“HSE”) Management Plan (GSRC-ST-MPS-G/S-
0988) Revision C1.
Other HSE Procedures implemented are described in Section 5.3.3.
2.2 Health and Safety Statistics
The Health and Safety statistics for the Power Plant for this construction monitoring periods are
shown in Table 2-1 and Table 2-2. The Health and Safety statistics are no longer shown for the
Interconnecting Pipeline since the works are completed.
A description of the HSE incidents are provided in Table 2-3.
Table 2-1 HSE Statistics 1
Power Plant
Man-Power Total Man-Hours Record 2,081,004
Data
Accident / TIRR Report table (3 (0)
Incident days or more
Records absence from
work)
Lost time (0.5 (0)
days or more
absence from
work)
First Aid (Medical Treatment at Site) 0
Property Damage 0
Potentially Serious Incident 7
Source: Lenders Technical Advisor, Quarterly Construction Monitoring Site Visit Presentation (EHS), 22nd April 2021.
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Table 2-2 HSE Statistics 2
Item Number
A: Fatalities 0
B: Lost time incidents (including vehicular) 0
C: Incidents and near-misses 7
D: Hazard observations 131
E: Total number of lost workdays resulting from 0
incidents
F: Total person-hours worked this reporting period 2,081,004
G: Incident during this reporting period 7
(Note: Incidence = total lost workdays/total hours 0
worked)
H: Lost Time Injury Frequency Rate 0
(Number of lost time accidents x 1,000,000 total 0
person-hours worked – lost workdays per million
hours worked)
J: Lost Time Severity Rate 0
(Total Lost workdays x 1,000,00 hours/total 0
person-hours worked – lost workdays per million
hours worked).
K: Security Loss 0
Source: Lenders Technical Advisor, Quarterly Construction Monitoring Site Visit Presentation (EHS), 22nd April 2021.
Table 2-3 HSE Incidents
HSE Incident Date Corrective Action Status
Fire fighting system - Corrective Actions: Closed
was activated
· Stop fuel oil unloading;
during fuel oil
· Stop fire fighting
unloading.
system;
· Check for water
contamination in oil
transport truck.
Preventative Actions:
· Work in commissioning
area retraining;
· Lessons learned to all
supervisors;
· Supervisor safety talk.
Steel bar fell from - Corrective Actions: Closed
scaffolding in HRSG
· Stop work;
building #2 striking
a workers shoulder.
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HSE Incident Date Corrective Action Status
· Check scaffolding
condition and rectify
immediately.
Preventative Actions:
· Scaffolding supervisor
to recheck scaffolding
condition before
starting work;
· Safety talk;
· Restrict areas under
which work at height
activities are being
performed and provide
watchman.
Scaffolding pipe fell 29th January 2021 Corrective Actions: Closed
from mobile
· Stop work and prohibit
scaffolding striking
work with scaffolding
workers resulting in
with red tag.
injury.
Preventative Actions:
· Safety stand down for
scaffolding team;
· Retraining of
scaffolding team;
· Scaffolding condition to
be checked prior to use
Intermediate bulk 2nd February 2021 Corrective Actions: Closed
container (IBC)
· Stop work in area;
explosion at
· Chemical cleaning.
HRSG#2.
Preventative Actions:
· Review and revise
procedure/method
statement JSA for safe
work condition;
· Install and setup new
drain system;
· Measure ambient
conditions by gas
detector for toxic gas
and flammable every 1
hour.
HRSG manholes 1st February 2021 Corrective Actions: Closed
opened during start
· Check condition of all
of Gas Turbine
manholes;
· Restart Gas Turbine.
Preventative Actions:
· All commissioning work
(outage work) will be
list for all of job and all
work in list will be
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HSE Incident Date Corrective Action Status
completed before start
up plant;
· Conduct safety walk
down before starting
activities.
Condensate Water 1st February 2021 Corrective Actions: Closed
Flushing Leakage
· Stop condensate pump
and check condition
before restart.
Preventative Actions:
· Cross check with
construction and
commissioning team
before starting the
system.
Ring main pipe F/F 17th February 2021 Corrective Actions: Closed
broken by a
· Stop work;
backhoe.
· Pumping the water in
area for repaired pipe;
· Standby by fire truck in
area for emergency
case during pipe repair.
Preventative Actions:
· Before start excavation
work related parties
will verify UG system
and inform to
excavator.
· Submit excavation
permit as early as
possible(at least 1 day
earlier)
2.3 Fatalities
There were no fatalities reported during the construction monitoring period.
2.4 Accident / Incident Reporting
The accident / incident reporting procedure is specified in the HSE Management Plan. It specifies
that all accidents and incidents shall be reported to the HSE Managers of the EPC Contractor who
will take the necessary steps in investigating and adopting corrective measures. Immediate
reporting is required in the case of the following:
- Personal Injuries;
- Damage to Property or Equipment;
- Near Miss Incident; and
- Environmental – Non-conformance Report.
The incidents / accidents which occurred during the construction monitoring period as described
in Table 2-3 have been documented and recorded.
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2.5 HSE Staff
The HSE staff of Sino-Thai and MHPS-PTC responsible for HSE management/supervision in the
Power Plant Area and Raw Water Pond Area are shown in Table 2-4. The ratio for number of safety
officers to number of workers is one safety officer per 50 workers which is considered to be
sufficient.
In addition, the Owner currently has an EHS Manager and EHS Officer. EGAT also has a dedicated
HSE Manager.
Table 2-4 HSE Staff for the Power Plant Area and Raw Water Pond Area
Position Number of Staff
Senior Officer Management Level 3
Safety Officer Professional Level 7
Safety Officer Technical Level 50
Nurse 2
Myanmar Translator 1
Source: Lenders Technical Advisor, Quarterly Construction Monitoring Site Visit Presentation, 22th April 2021.
2.6 Low Risk Issues
There were no low risk issues identified during the construction monitoring period.
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3 Labor And Working Conditions And Security
3.1 Workforce Profile and Recruitment
The number of male workers and female workers as of March 25th, 2021 is shown in Table 3-1.
The number of STECON male workers comprise 79% of the workforce, while the number of female
workers comprise 21% of the workforce.
Table 3-1 Workforce Number
Company Number of Male Workers Number of Female Workers
Owner 60 7
EGAT 36 5
MHPS-PTC 122 9
STECON 1,513 397
STECON 288 143
Subcontractors
STECON 18 2
Subcontractors –
Security
STECON 0 2
Subcontractors -
Nurse
Total 2,037 565
3.2 Welfare Facilities at Project Site
The welfare facilities at the Project site comprises of the following:
· Toilet/bathroom facilities. There are 231 toilets installed in the Project site (181 male
toilets and 50 female toilets). According to GSRC Progress Technical Report - EIA
Checklist Report male workers comprise of 2,573 persons and female workers comprise
of 550 persons as of March 10th, 2020. The ratio of toilet/bathroom to number of workers
complies with the ESIA and The Ministry of Interior (“MOI”) ministerial law No. 63 (BE
2551) issued under the Building Control Act BE 2522 requirement of at least one (1) toilet
for 15 workers or less, two (2) toilets for 40 workers or less, three (3) toilets for 80
workers or less, and additional one (1) toilet for additional 50 workers;
· Sufficient number of drinking water tanks with water analysis complying to the Thailand
drinking water standards;
· Four (4) main rest shelters in the Power Plant Area and One (1) rest shelter in the Raw
Water Pond Area;
· Medical facilities including ambulance. Two (2) qualified nurses are employed by the
Project and are based on site 7 days per week (8:00am to 5:00pm).
The applicable requirements of the Labour Protection Act B.E. 2541 concerning welfare facilities
and Project compliance during the construction monitoring period is shown in Table 3-2.
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Table 3-2 Labour Protection Act Requirements and Compliance for Welfare Facilities
Requirement Project Compliance at the Project Site
Section 96 “In a place of The Project has established a Welfare Committee as of 1st
business with fifty Employees June 2019 comprising of five (5) employee representatives
or more, an Employer shall whose remit also covers the welfare facilities.
arrange for the establishment
MHPS has appointed one (1) welfare auditor (male) and two
of a welfare committee at the
(2) designated welfare officers representatives (female) to
place of business, comprising
monitor labor and welfare requirements. The welfare auditor
of at least five Employee
and officers are identified in the EPC Contractor
representatives”. The welfare
organizational chart.
committee duties are
described in the Land Safety Induction material includes details of the welfare
Protection Act and the officers and the methods of communication.
employer must hold a meeting
with the welfare committee
every 3 months and whenever
half of its members requests a
meeting.
The Company shall arrange Based on the number of toilet/bathroom facilities described
the following: in Section 3.2 the Project is complying with these
requirements.
Clean drinking water and
restrooms as follows: Raw water supplied by HESIE and drinking water supplied in
tankers. Drinking water analysis report provided on each
≤ 15 employees: 1 restroom,
tanker to show compliance with Thailand drinking water
1 toilet, 1 drinking point;
standards.
≤ 40 employees; 1 restroom,
2 toilers, 1 drinking point;
≤ 80 employees; 1 restroom,
3 toilets, 2 drinking point.
Over 80 employees: for every
additional 50 employees;
additionally, 1 restroom, 1
toilet, 1 drinking point.
First aid service and medical Two (2) permanent nurses are employed by the Project and
supplies for employees injuries adequate first aid facilities are still located at the medical
or sickness. facilities and within the first aid kits provided in the
construction areas. Ambulances to transport workers to
If the company has more than
hospital are located onsite.
10 employees it must have a
first-aid kit (including e.g.
scissors, cotton, alcohol 70%,
medicines, etc.) available at
the work place.
In case of industrial work
place, the following additional
facilities have to be provided:
For the place with more than
100 employees, a ward with
one bed, 1 permanent nurse
and 1 doctor who visits
occasionally;
For the place with more than
1,000 employees, a ward with
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Requirement Project Compliance at the Project Site
2 beds, 2 permanent nurses, 1
doctor who is scheduled to
visit regularly at least for 2
hours, and transportation to a
hospital.
3.3 Workers Grievance Mechanism
There were no workers grievances / suggestions recorded during the construction monitoring
period.
3.4 Workers Camp and Transportation
3.4.1 Workers Camp
There are currently sufficient rooms (1,684) for the current total number of persons residing
(1,887) i.e. no more than 2 adults to a room.
Workers Camp Living Conditions
Based on the photographs observed, the hygiene/cleanliness of the workers camp is considered
to be adequate in Zones 1, 2 and 3 of the workers camp.
The Owner and Contractor continues to undertake monthly inspections at the workers camp and
no non-compliances against the Owners Camp Checklist shown in Table 3-3 have been reported
during the construction monitoring period.
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Table 3-3 Owner Workers Camp Checklist
Item Action
1 Dimension of the room, total area should be not less than 9 m2 (width greater
than 2 metre and height greater than 2.4 metre), with personal space not less
than 3 m2 /person.
2 If the building is longer than 45 m in width, then there need to be a 2.5 m gap
between buildings, along the building depth.
3 Natural ventilation. Room is equipped with door or ventilation with total area of
not less than 10% of the room area, excluding the door and window.
4 Number of toilets are sufficient for the total residents residing at the camp.
5 Separate bathing area and toilet. Separated male and female toilets.
6 The waste generated shall be managed in accordance to the law. Wastewater
discharge shall not impact persons surrounding the workers camp.
7 When areas of the camp area are occupied by more than 10 people, basic medical
kits shall be made available. Emergency contact number of the nearest health
care centre needs to be displayed.
8 Electrical wire and equipment should be in good condition and a protection
system in place. The installation needs to follow the standard code for outdoor
(THW, MEA TYPE A) and indoor (300V 70oC VAF).
9 An appropriate number of fire extinguishers should be installed and of the correct
type.
10. An appropriate emergency alarm system should be installed, covering all of the
workers camp.
11. There should be sign placed at the workers camp entrance to inform that the
workers camp is a residential area.
12 Fencing should be in place to secure the workers camp with a designated
entrance and exit.
13. There should be warning signs prohibiting drug usage.
14. For every 10 persons residing at the workers camp one camp watchman needs
to be allocated to ensure the camp operates in accordance with the site rules.
Workers Camp Welfare Facilities and Amenities
The following is observed concerning the welfare facilities at the workers camp:
· 154 toilets are now installed in the workers camp (98 male toilets and 56 female toilets)
and number of males residing comprises of 1,360 persons and number of female workers
residing comprises of 527 persons as of March 21st, 2021. Ratio of toilet/bathroom to
number of workers complies with the ESIA and The MOI ministerial law No. 63 (BE 2551)
issued under the Building Control Act BE 2522 requirement of at least one (1) toilet for
15 workers or less, two (2) toilets for 40 workers or less, three (3) toilets for 80 workers
or less, and additional one (1) toilet for additional 50 workers;
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· Based on photographs, the bathrooms and toilets were found to be of good hygiene with
privacy. Regular inspections/cleaning of the facilities continues;
· Medical facilities. Adequate medical/first aid facilities are still in place. The Project site
nurses are still used to attend any medical matters at the workers camp;
· As part of the COVID-19 preventative measures the workers camp continues to have a
dedicated area for new workers and area of quarantine in case any of the residents are
found to have symptoms of COVID-19.
Wastewater Treatment System
Wastewater from the workers camp continues to be discharged to an onsite wastewater treatment
system comprising of an aerated pond and sedimentation pond. The wastewater treatment
system remains at a capacity based on a maximum number of 3,200 persons residing at the
workers camp during the construction period and wastewater rate of 200 litres/person/day. The
wastewater treatment system was observed to be in good condition.
Water quality monitoring continues to be undertaken at a sampling location adjacent to the
sedimentation pond prior to discharge on a monthly basis and the results are provided in
Section 5.
3.5 Transportation
The Contractors continue to be transported to site by shuttle buses. The shuttle buses are able
to accommodate up to 25 persons. The location of the pickup point for the transportation remains
an approximate 5 to 10 minute walk from the workers camp.
3.6 Security
3.6.1 Project Site and Block Valve Station
Security continues to be provided by the security contactor GIANT. Site Security Plan Rev A has
been approved by the Owner and is still considered to be appropriate.
The security contractor continues to monitor the control points and the Project site 24 hours per
day. The security guards work 12 hours per day on a shift basis. The security guards continue
to be positioned at the following locations:
· Main entrance gate at Power Plant Area. Dayshift is two (2) security guards and nightshift
is (two) 2 security guards.
· Emergency gate at Power Plant.
· Main office area: No Security guard for dayshift and one (1) security guard positioned at
night shift; and
· Raw Water Pond area: One (1) security guard positioned at day shift and one (1) for night
shift.
The number of security guards required continues to be reviewed periodically and shall be
increased if necessary.
3.6.2 Workers Camp
The Site Security Plan also includes security rules and regulations for the workers camp. Security
is provided 24 hours per day at the workers camp entrance. Security guards continue to monitor
the incoming/ outgoing of people and vehicles at the main entrance gate.
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4 Stakeholder Engagement
4.1 Engagement Activities and CSR
The Environmental Impact Monitoring Committee meeting was held on January 22nd, 2021. The
LTA understands no grievances were reported by the committee members during the meeting.
The Minutes of the Meetings have been requested from the Owner but they are yet to be received.
4.2 Stakeholder Grievance Mechanism
The Owner reported no stakeholder grievances for construction monitoring period. A notice board
detailing contact details for complaints or suggestions remains in place at the entrance to the
Project site. The Owner also uses the mobile communication/social media application known as
Line for receiving grievances/concerns via a community group established on the Line application
which has been shared with community representatives. The LTA recommends that the Owner
establishes a Community Relations Activity Register to document community concerns which
aren’t grievances. This should include concerns raised by the community through social media
and made directly to the Owners Community Relations team.
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5 Environmental And Social Monitoring
5.1 EHS Capacity (Resources and Training)
5.1.1 EHS Capacity (Resources)
The EHS staff employed for the construction monitoring period are described in Section 2.5. The
EHS capacity observed at site for this construction monitoring period is considered to be
appropriate.
The HSE Committee continues to meet every month to review the overall safety at site and
develop guidelines to improve E&S.
5.1.2 EHS Training
The EHS training undertaken during the construction monitoring period is shown in Table 5-1.
The LTA considers the training to be appropriate based on the construction activities.
The gender based violence training continues to be incorporated into the safety induction and re-
inductions.
Table 5-1 EHS Training During the Construction Monitoring Period
No. January 2021 February 2021 March 2021
Safety 83 247 195
Induction
Training
Safety 21 117 230
Induction
Training (Re-
Induction)
PTW Worker 83 247 195
Working at 79 235 187
Height
Rigger 0 0 0
Hot Working 6 11 0
Fire Watch 6 12 0
Job Safety 0 0 0
Analysis
Supervisor 0 0 0
Training
Scaffolding 1 0 27 20
Scaffolding 2 0 0 0
First Aid 0 0 0
Basic Fire 0 0 0
Fighting
Lifting 0 0 0
Supervisor
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No. January 2021 February 2021 March 2021
Banks Man 0 0 0
Confined 2 17 41
Space
Hazard 83 247 195
Observation
Commissioning 124 376 209
Training
Safety 0 0 214
Training of
COD
Source: 2021-01, 2021-02, 2021-03 GSRC Progress Technical Report_CC
The following EHS training also continued as reported in the previous construction monitoring
period:
· Contractor provides Safety Talks two times per week for all workers; and
· Daily tool box talks for all workers.
5.2 EHS Licenses, Permits, Authorizations and Compliance Status
The status of the EHS related permits are provided in Table 5-2
Table 5-2 Status of EHS Related Permits
No. Permits Authorization Authority Status
1 EIA Power Plant Office of Natural Approved December
Resources and 2nd, 2015
Environmental Policy and
Planning (ONEP)
2. EIA Gas Pipeline Office of Natural Approved October 5th,
Resources and 2017
Environmental Policy and
Planning (ONEP)
3. EIA Power Plant Office of Natural Approved August 23rd,
(Amendment) Resources and 2018
Environmental Policy and
Planning (ONEP)
4. Report of Environmental Office of Natural Ongoing. Owner
Mitigation Measures and Resources and required to submit
Monitoring Programs Environmental Policy and mitigation and
during construction and Planning (ONEP) monitoring reports to
commissioning. ONEP every 6 months
during construction.
The report for July
2020 to December
2020 was submitted to
ONEP in January 2021.
5. Registration of Plant Industrial Works Registration will be
Pollution Control System Department (IWD) after COD.
Supervisor prior to
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