eia of engro powergen limited 450 mw rlng ccpp at pqa, karachi sep 29, 2015 by hagler bailly...

Hagler Bailly Pakistan

Engro Powergen Limited 450 MW RLNG CCPP Port Qasim Authority, Karachi

Environmental Impact Assessment

Final Report

HBP Ref.: R5A05ENP

September 29, 2015

Engro Powergen (Pvt.) Limited

Karachi

EIA of Engro Powergen Limited 450 MW RLNG CCPP

Port Qasim Authority, Karachi

Hagler Bailly Pakistan Executive Summary R5A05ENP: 09/29/15 ii

Executive Summary

Engro Powergen Limited (EPL) is planning to develop a 450 megawatt (MW) re-gasified

liquefied natural gas (RLNG) combined-cycle power plant (CCPP) (the “Project”) at Port

Qasim, Karachi. EPL has initiated an Environmental Impact Assessment (EIA) study to

assess the likely environmental and socioeconomic impacts that may result from Project

activities and to mitigate any potential negative impacts. The EIA process and the report

will meet national regulations, the regulatory requirements of the Government of Sindh

(GoS), and the relevant International Finance Corporation (IFC) guidelines.

EPL has acquired the services of Hagler Bailly Pakistan Pvt. Ltd. (HBP) to carry out the

EIA study for the proposed Project.

Project Setting

The Project will utilize 37 acres (15 hectares or 150,000 m2) of land in an empty plot

owned by EPL in the Port Qasim Authority (PQA) Industrial Estate (the “Project-site”).

PQA is located, approximately, 45 kilometers (km) southeast of the city of Karachi

(Exhibit 1). The geographical coordinates of the proposed Project-site are 67° 22'

41.185" E, 24° 47' 28.324" N.

Engro Zarkhez (EZ) and Engro Polymer and Chemicals Limited (EPCL) are located to

the west and immediately adjacent to the Project-site. Lotte Chemicals Pakistan (LCP) is

located, approximately, 500 m to the east.

A custody transfer station (CTS), built by Engro Elengy Terminal Ltd (EETL), will be

located outside the southwest corner of the EPCL facility. The CTS is the point where

incoming flow of natural gas from EETL to the Project-site will be metered. Natural gas

will be transported from the CTS to the Project-site via an underground pipeline which

will traverse along either outside the southern boundary wall of the existing EPCL and

EZ complex or outside the western and northern boundary wall of the same complex.

The power plant will include gas turbines based on a combined-cycle configuration with

heat recovery steam generators (HRSGs) and steam turbines. Total water requirements

for the Project will be 1201 m3/hr which will include requirements for feed water make-

up and for potable, service and sanitary purposes.

The creek is located on the northwestern edge of the Indus delta system which is

characterized by long and narrow creeks, mud flats and the mangroves forest ecosystems.

In either case, an outfall channel will be constructed which will also extend from the

southern edge of the Project-site to the Gharo Creek. For more details on Project setting

and location, a Project location and setting map is provided as Exhibit I.



Hagler Bailly Pakistan Executive Summary R5A05ENP: 09/29/15 iii

Exhibit I: Project Location and Setting



Hagler Bailly Pakistan Executive Summary R5A05ENP: 09/29/15 iv

Project Outline

The Project development encompasses a 450 MW RLNG-based CCPP with dual fuel gas

turbines. Produced electric power by the plant will be transmitted to the national grid via

a power evacuation point located within the Project-site.

RLNG will be used as the main firing fuel for the CCPP which will be supplied by EETL

prior to the CTS. The daily requirement of RLNG is estimated to be 60 million standard

cubic feet per day (MMSCFD). High Speed Diesel (HSD) will be stored on-site and used

as a backup fuel.


heat recovery steam generators (HRSGs) and steam turbines. Total water requirements

for the Project will be 1,071 m3/hr which will include requirements for feed water make-

up and for potable, service and sanitary purposes.

Cooling water will be obtained by extracting sea water from the creek located south of

the Project-site. A water intake channel will be built between the plant and Gharo Creek

traversing through empty industrial plots south of the Project-site. Sea water will be

treated using a reverse-osmosis (RO) water filter plant.

Effluent streams, made up of discharge from the cooling-water process and the RO

treatment plant, will be discharged through an effluent channel into the Badal Nullah,

west of the Project-site. From here, the effluent will eventually flow into the Gharo

Creek. All effluent discharged into the creek will be compliant with both the Sindh

Environmental Quality Standards (SEQS) and IFC standards for industrial effluents

discharged into the sea.

RLNG used by the Project is expected to have a low heating value of 1,050 British

thermal units per standard cubic feet (btu/scf) and its composition, in terms of molecular

percentage, will be as follows:

Nitrogen –1.5 %

Methane –85.6 %

Ethane –7.8 %

Propone –2.9 %

Butane –1.9 %

Pentane –0.3 %

Impurity in the natural gas is expected to be Hydrogen Sulfide with value of 5 milligram

per normal cubic meter (mg/Nm3)

Gas-fired plants generally produce negligible quantities of particulate matter (PM) and

sulfur oxides (SOx), and levels of nitrogen oxides (NOx) are about 60% of those from

plants using coal (without emission reduction measures). Natural gas-fired plants also

release lower quantities of carbon dioxide, a greenhouse gas.

The Project is estimated to be constructed within 26 to 28 months from financial close.

Exhibit II illustrates the Project layout on a map.



Hagler Bailly Pakistan Executive Summary R5A05ENP: 09/29/15 v

Exhibit II: Project Layout



Hagler Bailly Pakistan Executive Summary

R5A05ENP: 09/29/15 vi

Statement of Need

Pakistan is suffering from an acute energy crisis. The unreliable power supply is affecting

the productive end-uses of power due to which the direct and multiplier benefits of

productive activities are foregone and the economy incurs a loss. Taking into account the

crippling power shortages in the country, the Government of Pakistan has signed an

agreement with the State of Qatar for the import of Liquefied Natural Gas (LNG) which

is a cheaper and environmentally-friendly fuel for power generation as compared to

diesel and furnace oil. Utilizing this opportunity, EPL has taken an initiative to install the

proposed Project to positively contribute to the country’s energy supply mix.

The development of the proposed Project will add 450 MW of electric power to the

national grid. The power generated by the Project would be supplied to various sectors

that are currently being affected by the power shortages and bridge part of the energy

shortfall facing the country. This, in turn, will have a positive impact on the country’s

economy through increase in gross domestic product (GDP). The impact will last through

the life of the Project.

Regulatory Requirements

The proposed RLNG CCPP is subject to the pertinent legislative and regulatory

requirements of the Government of Pakistan, the Government of Sindh (GoS) and

International Finance Corporation (IFC). The legal statutes that have been reviewed

include the Pakistan Environmental Protection Act, 1997 (PEPA 1997), Sindh

Environmental Protection Act, 2014 (SEPA 2014), Sindh Environmental Protection

Agency (Review of Initial Environmental Examinations (IEE) and Environmental Impact

Assessment (EIA)) Regulation, 2014 (IEE-EIA Regulations 2014), the National

Environmental Quality Standards (NEQS), 1993, Sindh Environmental Quality Standards

(SEQS) for Ambient Air Quality 2014.

In addition, the Project will also comply with the IFC’s Environmental Health and Safety

(IFC EHS) Guidelines 2007 and IFC’s Performance Standards (IFC PSs) on

Environmental and Social Suitability 2012 and their subservient guidelines and standards.

Description of the Environment

Field Surveys and Data Collection

The existing physical, biological and socioeconomic conditions of the surrounding areas

of the Project are described in the EIA report. This information was collected from field

surveys, previous EIAs conducted in the Project area and other published literature.

Ambient air quality sampling for the EIA of the proposed Project was conducted from

March 4–6, 2015. A socioeconomic baseline survey was undertaken by HBP’s social

team from March 13–16, 2015, which covered 16 settlements within a 10 km radius

around the Project-site.

Appropriate standard scientific methods were used for each component of the study and

are described in the sections covering the respective components. For all spatial

information, Global Positioning System (GPS) was used to mark the sampling sites. The

GPS data was then used to produce maps using geographical information system (GIS)

software.




R5A05ENP: 09/29/15 vii

Data regarding the existing soil and water quality, and the ecological resources of the

Gharo Creek was collected from recent EIAs conducted by HBP in the vicinity of the

Project-site including the EIA of Port Qasim Electric Power Company (PQEPC)

2×660 MW Coal Power Plant (CPP); the EIA for the replacement of four furnace oil-

fired boilers with coal-fired boilers at Karachi Electric (K–Electric) Power Station and

the EIA of a coal fired power plant at Fauji Fertilizer Bin Qasim Limited (FFBL).

Ambient Air Quality

Key observations from air quality results from samples collected at two locations for the

proposed Project:

At sampling point ENPA1, located in northeast of the Project-site, the average

ambient air concentrations of SO2, NO2, NO, CO, O3, TSP, PM10 and PM2.5 are

15.9 μg/m3, 12.1 μg/m3, 19.2 μg/m3, 1.5 mg/m3, 8.5 μg/m3, 310 μg/m3, 125 μg/m3

and 25.6 μg/m3 respectively. All values are within the limits prescribed by the

SEQS and EHS guidelines prescribed by IFC for 24-hour average time ambient

air quality concentrations.

At sampling point ENPA2, located 5 km east of the Project-site, the average


12 μg/m3, 7 μg/m3, 12 μg/m3, 1.1 mg/m3, 4.6 μg/m3, 232 μg/m3, 102 μg/m3 and

22.4 μg/m3 respectively. All values are within the limits prescribed by the SEQS

and EHS guidelines prescribed by IFC for 24-hour average time ambient air

quality concentrations.

Overview of Creeks in the Port Qasim Authority Area

The Indus River delta covers an area of about 600,000 hectares and is characterized by 16

major creeks and innumerable minor creeks, dominated by mud flats, and fringing

mangroves. The coastal morphology is characterized by a network of tidal creeks and a

number of small islands with sparse mangrove vegetation, mud banks, swamps, and

lagoons formed because of changes in river courses. The Gharo Phitti Creek System

consists of three creeks: Gharo Creek, Kadiro Creek and Phitti Creek. All three are

connected in a series starting from Gharo Creek at the north-eastern end to the Phitti

Creek at the south-western end.

At Gharo Creek, 56 km from the Phitti Creek entrance, the tides are almost half of the

mean sea tides at the entrance. The Mean Higher High Water (MHHW) to Mean Lower

Low Water (MLLW) range is about 2.4 m at the port complex while the peak tide over

diurnal range is about 3.5 m. The flow pattern within this large, relatively deep and

generally stable creek system around Port Qasim is strongly influenced by tides and the

presence of extensive inter-tidal flats.

Physio-Chemical Parameters of Major Creeks in PQA

The surface water temperature, salinity and density show some variation within the major

creeks of PQA. The annual seawater temperature ranges from 21.0 °C–25.0 °C. Water

temperatures in tidal channels in the Indus Delta creeks have been reported to be 19 °C in

January and 30 °C in June. Seawater salinity ranges from 33.4 – 39.2 parts per thousand

(ppt) (or Practical Salinity Units, PSU). Seawater density in the PQA creek system ranges

from 1.025 – 1.030 kg/m3.




R5A05ENP: 09/29/15 viii

Heavy Metal Analysis in Fish, Crab and Shrimp Tissues

Fish tissue sampling to detect the presence of heavy metals in fish, crabs and shrimps in

the Gharo Creek was conducted in 2014. Analysis of the edible tissues of fish, crab, and

shrimp showed that Antimony, Cadmium, Mercury, Nickel and Silver were below the

Level of Reporting (<0.05 mg/kg). The concentration of Arsenic was between 0.80-

3.55 mg/kg, the concentration of Copper was between 1.21-41.0 mg/kg. Lead

concentrations ranged between 0.09-0.24 mg/kg while Zinc concentrations were between

11.3– 57.2 mg/kg. The levels of heavy metals observed in the fish tissues were within the

limits prescribed by the Food and Agriculture Organization (FAO) for edible fish.

Mangrove habitat

The Project is located near PQ which is part of the Indus Delta. The Indus Delta supports

the seventh largest mangrove forest system in the world. In the Indus Delta mangrove

ecosystem, eight species of mangroves have been reported out of 70 species known to

occur in the tropical forests of the world. The Avicennia marina is the dominant species

of the mangroves in the Indus Delta. All other species are rare and have disappeared from

most part of the Delta due to adverse environmental/ecological conditions. Out of 70

mangrove species worldwide 11 species (16 percent) have been placed on the IUCN Red

List. The Avicennia marina is the dominant species of the mangroves in the Indus Delta.

About 60 percent of the mangroves are over 3 m in height.

Mudflats Habitats, Surface and Burrowing Animal Forms

Benthic community: This community includes the microbes: detritus feeders, small and

large herbivores, and small and large carnivores. In the mangrove ecosystem, the benthic

community of the adjacent shallow water is a subject of interest. Here, the microbes

decompose the plant litter into organic detritus - a fundamental commodity for the

transfer of energy from lower to higher trophic level.

Mudflat habitats: Coastal areas and the intertidal region is a complex area where the

division between land and sea is unclear. Coastal intertidal areas have a diverse range of

communities that inhabit muddy/clay shores. Patchy mangrove ecosystem supported the

epifaunal communities in the surveyed area.

At low tide, when a large part of muddy substrate is exposed, crabs, mudskippers and

birds are seen in large numbers picking up their food which includes worms and different

animals left behind and exposed by the receding tide.

Marine Invertebrate Species: The marine invertebrates play an important role in mixing

the organically enriched bottom sediments and are the key linkages in transferring the

energy from lower trophic level to the next higher trophic level in the food chain. The

marine invertebrate communities reported from the Project site and vicinity are

characteristic of fine sediments from muddy to clayey. Dominant communities reported

include Fiddler Crab Uca sp., Mud Skippers Boleophthalmus spp and Telescopium spp

assemblages as well as annelid (Polychaete) worms, bivalve mollusks, Pinnotherid crabs

and Cerithium sp.

Conservation Status: None of the marine invertebrates species reported from the Project

site and vicinity are threatened or included in the IUCN Red List of Threatened Species.




R5A05ENP: 09/29/15 ix

Moreover, their distribution is not limited to any specific site or habitat type, and their

distribution is widespread.

Coastal Marine Fish Fauna

Over 180 species of fish have been reported from the Indus Delta. The abundance of fish

fauna varies from season to season. There are a number of settlements of fishermen along

the creeks of Indus Delta which depend on the fisheries resources of these creeks.

Benthic Fish Community

Benthic fish community includes detritus feeders, small and large herbivores, and small

and large carnivores. In the mangrove ecosystem, the benthic community of the adjacent

shallow water is a subject of interest. Here, the microbes decompose the plant litter into

organic detritus - a fundamental commodity of system energy. At low tide, when a large

part of muddy bottom is exposed, crabs, mudskippers and birds are seen in large numbers

picking up their food which includes worms and different animals left behind by the

receding tide.

Pelagic Fish Community

This community includes powerful swimmers, which are exclusively carnivore in nature

like predaceous fishes, mullets, croakers, snappers, carangids breams, perches, and sea

snakes. In the mangrove ecosystem the predaceous fish forms are often small in size and

easily wander among the mangroves at high tide. Subsistence fishing and recreational

fishing takes place in the vicinity of the Port Qasim Area (PQ Area) during ebb and flow

tides but commercial fishing is very limited.

Artisanal Crab Fishery

Local fishing community members fish for mud crabs Scylla serrata during low tide. The

mud crab, burrows in mudflats in close proximity to the mangrove plantation. The locals

excavate the soft mud with bare hands or a hooked iron rod is used which is inserted into

the mud crab dwelling during the exposed mud flats at low tide. The crabs are caught

from their habitats and kept alive in moist gunny bags.

Conservation Status: None of the fish or crab species reported off the coast of PQ Area

are threatened or included in the IUCN Red List.

Marine Mammals and Turtles

Dolphins are marine mammals that have been sighted in the Indus deltaic region and in

the PQ Area. However, there is no published information available with regards to the

number of Cetaceans that visit the PQ Area. Marine mammals prefer the deep waters of

the ocean and are very rarely seen in the shallow waters of coastal areas.

Two turtle species have been reported from the marine waters off the coast of Sindh.

Olive Ridley Turtle Lepidochelys olivalea is listed as Vulnerable in the IUCN Red List

and included in Appendix I of the CITES Species List while the Green Turtle Chelonia

mydas is listed as Endangered in the IUCN Red List 2014, and included in the

Appendix I of the CITES Species List. However, neither of these species has been

reported from the PQ Area and are not known to use the coast line south of the Project

site or vicinity for breeding or nesting. During ecological surveys conducted in the

Project vicinity in March 2014, the survey team did not find any turtles, turtle remnants




R5A05ENP: 09/29/15 x

or turtle tracks on the muddy shores at the locations sampled. No turtle nest was

observed. This is because turtles prefer sandy beach substrates instead of muddy

substrates found near the Project-site.

Conservation Status: No threatened marine mammal or turtle species has been reported

from the coastal areas in Project-site and vicinity.

Socioeconomic Environment

A field survey to collect data on the socioeconomic conditions prevailing in the Study

Area was conducted from March 13–16, 2015, covering 16 settlements within a 10 km

radius around the Project-site. The locations urban, semi-urban and rural settlements

covered during the field survey are shown in Exhibit III.

Information on the socioeconomic conditions prevailing within the Study Area was

collected through a combination of settlement-level surveys and focus-group interviews.

To determine the socioeconomic condition for both the genders residing the Study Area,

data was collected from both male and female members of the society.

The information was obtained from both male and female key informants including

literate people, representatives of local government, town management officers and

community leaders with knowledge of the socioeconomic conditions of their

communities.

The summary of the results of the socioeconomic survey of the communities are

presented in Exhibit IV. The detailed results are provided in the EIA report.




R5A05ENP: 09/29/15 xi

Exhibit III: Location of Urban, Semi-Urban and Rural Settlements within the Study Area



Hagler Bailly Pakistan Executive Summary R5A05ENP: 09/29/15 xii

Exhibit IV: Summary of the Socioeconomic Conditions in the Study Area

Socioeconomic Aspect Survey Result

Estimated number of households 26,281

Estimated population 172,720

Type of housing Urban and Semi Urban Masonry Adobe

100% –

Rural Masonry Adobe

75% 25%

Estimated number of educational institutions

97 (84 in urban and semi urban and 13 in rural settlements)

Estimated number of health facilities 20 (including private clinics, one health center by Fauji Fertilizer Bin Qasim Limited, one 100 bed hospital in PSM Town, and GoS facilitated dispensaries)

Major transportation route National highway (N-5), connecting the Study Area to Karachi city located to its west

Major source of water Keenjar lake, located in Thatta, to the east of the Study Area, at an approximate geodesic distance of 45 km. Water is supplied to the settlements through Karachi Development Authority (KDA) pipeline and PSM water supply pipelines

Stakeholder Consultations

As part of the scoping phase to identify potential impacts of the Project, stakeholder

consultations with communities were held from March 13–16, 2015, whereas institutional

stakeholder consultations were held on March 18 and 19, 2015. Community consultations

were conducted in settlements located around the PQA within a 10 km radius from the

proposed Project-site. Institutional consultations were held with industries located in the

PQA and with non-governmental organizations (NGOs) specializing in the field of

ecology and nature-conservation.

The EIA report provides a summary of the concerns, expectations and feedback shared by

the stakeholders. It also provides a complete record of the consultations in one of its

appendices.

The list of institutional stakeholders consulted is provided in Exhibit V and the locations

of both the community and institutional stakeholders consulted are shown on a map in

Exhibit VI.



Hagler Bailly Pakistan Executive Summary R5A05ENP: 09/29/15 xiii

Exhibit V: List of Institutions and Industries Consulted with

Consultation Location and Date1

Stakeholder Consultation Location Date Consulted

Pakistan Steel Mills (PSM) Arabian Sea Country Club, PQA, Karachi

Mar 18, 2015

Tuwairqi Steel Mills (TSM)

Engro Polymer and Chemicals Limited (EPCL)

Engro Zarkhez

The stakeholder confirmed receipt of invitation letter for consultation at the Arabian Sea Country Club, however, they did not attend the consultation session.

K-Electric

Lotte Chemical Pakistan Ltd

Port Qasim Authority

Linde Pakistan Limited

Port Qasim Electric Company

Arabian Sea Country Club

Siddique Sons

ASG Metals Limited

The World Conservation Union (IUCN) IUCN Office, 1 Bath Island, Clifton, Karachi

Mar 19, 2015

World Wildlife Fund (WWF) WWF Office, 46-K, PECHS, Shara-e-Faisal Karachi

Mar 19, 2015

1 The stakeholders were consulted during the scoping consultation visits carried out for 225 MW RLNG CCPP (the initial design of the Project). These stakeholders were consulted again to discuss the change in the Project design from 225 MW to 450 MW. The background information document (BID), shared with the stakeholders for the updated design is attached at Appendix E of this report. The main objective for

consulting the stakeholders again was to record their concerns associated with the updated design.



Hagler Bailly Pakistan Executive Summary R5A05ENP: 09/29/15 xiv

Exhibit VI: Locations of Community and Industrial Stakeholders Consulted



Hagler Bailly Pakistan Executive Summary R5A05ENP: 09/29/15 xv

Environmental Impact Assessment and Mitigation Measures for the Proposed Project

An in-depth assessment of the following potential impacts was carried out; these were

identified as having medium or high significance in a scoping exercise carried out and

included in the EIA report.

Impact 5 – Habitat degradation, and thus damage to aquatic species, in the Gharo

Creek as a result of direct physical damage or decrease in water quality from

turbidity from the construction of the intake and outfall channels.

Impact 7 – Employment and livelihood generated for skilled and semi-skilled

personnel hired during the construction of the Project.

Impact 11 – Gaseous emissions from the Project during the operation phase may

result in the deterioration of ambient air quality beyond the limits prescribed by

SEQS and IFC EHS guidelines.

Impact 15 – Habitat degradation and thus damage to aquatic species in the Gharo

Creek from increased concentration of brine discharged in the Project effluent

during operation.

Impact on Marine Ecological Resources from the Construction of Intake and Outfall Channels extending into the Gharo Creek

Marine life consisting of marine benthic invertebrates, phytoplankton, zooplankton, crabs

and fish will suffer direct physical damage from construction works in the Gharo Creek.

However, such damage will be limited only to the site of the construction works. On the

other hand, turbidity generated from the construction works may spread a few meters

away from the construction site and result in ill health effects and changes in abundance

and diversity of marine ecological resources in the Gharo Creek. This alteration in the

sediment levels in the water is likely to change the nature and diversity of benthic and

pelagic marine communities, such as decline of density, species abundances or biomass.2

The marine benthic invertebrates and fish fauna in the vicinity of the construction

activities are likely to suffer negative impacts caused primarily by smothering of benthic

invertebrate and clogging of gills of the fish species.

Similarly, construction works will lead to the short-term decline in the abundance and

diversity of fish, crabs and crustaceans. None of the fish, crab or crustacean species is

included in the IUCN Red List 2014 and are abundantly found in other parts of the coast.

In addition, the fish and to some extent the other species are likely to avoid disturbance

and move to a less disturbed area. However, it is recommended that the construction

activities not be carried out during the spawning period of coastal fish (July/August) to

avoid any long-term harm to the species. In addition, it is recommended that all measures

outlined in the Environmental Management Plan for Project construction and operation

be implemented to ensure minimal pollution of marine waters. These include:

2 Amjad,S and Moinuddin Khan 2011 Marine Ecological Assessment for LNG Terminal at Port Qasim.

Pak.J. Eng. Technol.Sci Vol 1. No.2 74-85.



Hagler Bailly Pakistan Executive Summary R5A05ENP: 09/29/15 xvi

Debris netting to be applied around the sides of the construction site of

intake/outfall channels to prevent any materials or debris falling into the creek.

To contain any other debris generated, a layer of terram (or any geosynthetic

material) will be laid across the platform at the beginning of each shift and

removed at the end of the shift ensuring all debris resulting from the works is

restricted from entering the marine environment.

Waste materials generated during the construction of the intake and outfall

channel shall be trapped and collected on the temporary works platform for

appropriate disposal off site.

The proposed paint system for underwater structures will have a low VOC content

and fast curing times.

Changes in Abundance and Diversity of Marine Flora and Fauna caused by Discharge of Effluent into the Creek

Once the Project becomes operational, effluent streams made up of discharge from the

cooling-water process and the RO treatment plant will be discharged into the Gharo

Creek. Higher concentrations of brine from the RO process will have a negative impact

on the marine life in Gharo Creek. This is because the marine flora and fauna consisting

of the marine epifaunal invertebrate species, phytoplankton, zooplankton, fish, crabs and

crustaceans are adapted to ambient saline concentrations. Any change in salt

concentration in the sea water has the potential to cause changes in abundance and

diversity of these ecological resources.

The results of the effluent plume modeling indicate that the brine in the effluent discharge

from the Project into the Gharo Creek will arrive at ambient salinity levels approximately

50 m away from the discharge location.

Therefore, with an increasing distance from the outfall channel, the effluent constituents

will become diluted and even though there may be some harm to some ecological

receptors (individuals of marine epifaunal communities), particularly within a 20 m

radius of the point of discharge into the creek, the species will not suffer any long term

harm.

None of the marine benthic invertebrate species reported from the Gharo Creek near the

Project is included in the IUCN Red List.3 Similarly, no endangered fish species has been

reported from the creek waters near the Project-site and these fish species are abundantly

found in other parts of the coast. There are no mangroves at the Project-site and the

closest mangroves are located 2 km away south of the Project in the Gharo Creek.

Therefore, the impact of brine released from the Project negatively impacting marine life

is not considered significant provided the rest of the effluent is compliant with all other

NEQS and IFC standards for industrial effluents discharged into the sea. It is

recommended that all measures outlined in the Environmental Management Plan for

3 The IUCN Red List of Threatened Species. Version 2014.3. <www.iucnredlist.org>. Downloaded on 02

March 2015.

http://www.iucnredlist.org/



Hagler Bailly Pakistan Executive Summary R5A05ENP: 09/29/15 xvii

Project construction and operation be implemented to ensure minimal pollution of marine

waters.

Impacts on Ambient Air Quality from Stack Emissions during Operational Phase

The results of the air dispersion modeling indicate that concentration of NO2 and CO in

the air when the Plant is in operation will be compliant with the SEQS and IFC EHS

guidelines. It will also comply with the IFC EHS guideline which states that “emissions

from a single project should not contribute more than 25 % of the applicable ambient air

quality standards to allow additional, future sustainable development in the same

airshed.”

Moreover, the contour maps illustrating the incremental pollution values indicate that the

NO2 and CO concentrations as a result of the Project decrease to insignificant levels at a

distance of 1–2 km from the Project-site. Therefore, the impact on air quality in the Study

Area as a result of the Project during operation in any scenario will be of a low

magnitude and will be limited to a small spatial scale.

Assessment of Brine Concentration Profile in the Gharo Creek

Plume modelling for discharges associated with the RLNG CCPP project are based on a

1-D model i.e. along a single channel. Typically in discharges in estuarine situations

along a single channel, tidal pollutant build-up may occur. This is since a single volume

of water travels up and down a channel during ebb and flow currents and pollutants begin

to build up in this volume. This is characteristic particularly of long channels such as that

along which this discharge is occurring (i.e. the Phitti-Kadiro-Gharo Creek system).

Nonetheless, a 1-D approximation with tidal pollutant build up would be an unjustifiably

conservative assumption leading to erroneous results based on the following discussion.

Based on preliminary analysis of water quality being carried out by Hagler Bailly

Pakistan for the Cumulative Impact Assessment of Industrial and Port Developments at

Port Qasim, key observations, particularly related to estuarine dynamics, for the creeks

within the Port Qasim Notified Area are as follows:

The estuary is vertically well mixed (i.e. no salinity or temperature gradients)

possibly due to high turbulence associated with penetration of wind waves, tidal

currents and since there are little freshwater flows in multiple investigated

channels and creeks across the Notified Port Qasim Area (~ 69,000 ha).

The estuary is laterally well mixed (i.e. no major differences in water quality)

along the entire PQ Notified Area (~ 69,000 ha)

Water quality along Port Qasim’s Industrial and Port Zones is of good quality

indicating that there is no pollutant build up.

Little to no contamination of marine sediments, indicating no long term pollutant

build up.

Other than indicating good mixing in the estuary associated with turbulence associated

with wind waves and currents, the observations above indicate that pollutants are flushed

out of the system i.e. the same volume does not remain within the channel, and tidal

pollution build up is not occurring. It is assumed that there is interaction of the volume

with multiple other smaller creeks of the inactive northwestern extent of the Indus Delta



Hagler Bailly Pakistan Executive Summary R5A05ENP: 09/29/15 xviii

such as the Chan Wado and Issaro Creek. A 1-D approximation with tidal pollutant build

up would be unjustifiably conservative. Nonetheless, a 1-D approximation for a dynamic

3-D situation is still considered conservative compared to actual field conditions.

Therefore, based on the current modelling the NEQs will be met well within 100 m of the

point of discharge under conservative modelling conditions.

An additional characteristic of the modelling, is that the model utilized average flow rates

for flood and ebb currents separately to take into account plume extents in different

principal directions during flood and ebb currents.

Generation of skilled and unskilled employment from the construction and operation of the Project

The construction and operation phases of the Project will include various civil, mechanic,

electrical and masonry works which will require a considerable number of workforce to

accomplish the desired job. This will result in opening of various job opportunities for

both skilled and unskilled individuals residing in the Socioeconomic Study Area.

Transparent and fair distribution of these jobs among locals, matching their education and

skill level is expected to enhance the socioeconomic condition existing in the area.

Conclusion

The proposed RLNG CCPP project includes the construction and operation of a new

thermal power plant with gas and steam turbine generators to generate 450 MW of

electric power.

The Project will incorporate state-of-the-art equipment and effluent treatment

technologies to minimize associated wastes and mitigate their adverse impacts on the

physical and socioeconomic environment of the Project area to the maximum possible

levels.

The EIA study has documented all major environmental concerns associated with the

development of the proposed Project. The EIA also documents an EMP which provides

mitigation and monitoring measures for significant environmental impacts on the existing

biophysical environmental of the Study Area.

In view of the findings of the EIA study and assuming effective implementation of the

mitigation measures and monitoring requirements as outlined in the EMP, it can be

concluded that all environmental impacts of the construction and operation of the Project

will be manageable and the Project will comply with national, provincial and

international standards and guidelines including NEQS, SEQS, IFC EHS guidelines and

IFC PSs.



Hagler Bailly Pakistan Contents R5A05ENP: 09/29/15 xix

Contents

1. Introduction ...................................................................................... 1-1

1.1 Project Setting .......................................................................................... 1-1

1.2 Project Outline .......................................................................................... 1-3

1.3 Statement of Need .................................................................................... 1-6

1.4 Analysis of Alternatives ........................................................................... 1-6

1.4.1 No-Project Option ........................................................................... 1-6

1.4.2 Site Selection .................................................................................. 1-6

1.4.3 Fuel Selection ................................................................................. 1-7

1.4.4 Gaseous Emissions ........................................................................ 1-8

1.4.5 Combined Cycle Technology .......................................................... 1-8

1.4.6 Cooling-Water Technology .............................................................. 1-8

1.5 Introduction to the EIA ............................................................................. 1-9

1.5.1 Objectives of the EIA ...................................................................... 1-9

1.5.2 Scope of the EIA ........................................................................... 1-10

1.6 Approach and Methodology .................................................................. 1-10

1.7 Regulatory Requirements ...................................................................... 1-12

1.8 Report Organization ............................................................................... 1-12

2. Legal, Administrative and Policy Framework ............................... 2-1

2.1 Statutory Framework ................................................................................ 2-1

2.1.1 Constitutional Provision................................................................... 2-1

2.1.2 Sindh Environmental Protection Act, 2014 ...................................... 2-2

2.1.3 Sindh Environmental Protection Agency (Review of Initial Environmental Examination and Environmental Impact Assessment Regulations), 2014 ...................................................... 2-4

2.1.4 SEQS, NEQS and IFC Environmental Standards............................ 2-4

2.1.5 Self-Monitoring and Reporting by Industry Rules 2001 ................... 2-7

2.2 Other Relevant Laws ................................................................................ 2-7

2.2.1 Port Qasim Authority Act, 1973 ....................................................... 2-8

2.2.2 Hazardous Substances ................................................................... 2-9

2.2.3 The Forest Act 1927 ....................................................................... 2-9

2.2.4 Factories Act 1934 ........................................................................ 2-10

2.2.5 Labor and Health and Safety Legislation ....................................... 2-10



Hagler Bailly Pakistan Contents R5A05ENP: 09/29/15 xx

2.3 International Law and Multilateral Agreements .................................... 2-11

2.4 IFC Environmental Guidelines and Standards ..................................... 2-13

2.4.1 Project Categorization ................................................................... 2-13

2.4.2 IFC Performance Standards ......................................................... 2-15

2.4.3 IFC Environmental, Health and Safety Guidelines......................... 2-17

3. The Proposed Project Design ........................................................ 3-1

3.1 Project Location and Layout.................................................................... 3-1

3.2 Combined Cycle Power Plant .................................................................. 3-4

3.2.1 GE Industrial Frame Gas Turbine 9F.05 ......................................... 3-6

3.2.2 Siemens SGT5-4000F Industrial Gas Turbine ................................. 3-6

3.2.3 Heat Recovery Steam Generators .................................................. 3-7

3.2.4 Steam Turbines ............................................................................ 3-12

3.3 Gaseous Emission ................................................................................. 3-13

3.4 Water Supply, Recirculating Cooling and Treatment System ............. 3-13

3.4.1 Design Parameters of Water Supply System ................................ 3-13

3.4.2 Water Supply System ................................................................... 3-14

3.4.3 Cooling Water Intake and Wet Recirculating Cooling System ....... 3-16

3.4.4 Antisepsis Measures for Cooling Water System ............................ 3-17

3.4.5 Raw Water Treatment System ...................................................... 3-18

3.4.6 HRSG Evaporator Feed Water System ......................................... 3-20

3.4.7 Chemical Dosing System .............................................................. 3-20

3.4.8 Service Water System .................................................................. 3-21

3.4.9 Potable Water System .................................................................. 3-21

3.4.10 Industrial and Oily Wastewater Treatment System ........................ 3-22

3.4.11 Sewage Treatment System ........................................................... 3-22

3.4.12 Brine Discharge ............................................................................ 3-22

3.5 Power Evacuation................................................................................... 3-23

3.6 Project Staffing ....................................................................................... 3-25

4. Description of the Environment ..................................................... 4-1

4.1 Study Area ................................................................................................ 4-1

4.2 Physical Baseline ..................................................................................... 4-4

4.2.1 Overview ......................................................................................... 4-4

4.2.2 Water Resources in the Study Area ................................................ 4-5

4.2.3 Climate ........................................................................................... 4-5



Hagler Bailly Pakistan Contents R5A05ENP: 09/29/15 xxi

4.2.4 Air Quality ....................................................................................... 4-9

4.3 Ecological Baseline ................................................................................ 4-19

4.3.1 Scope ........................................................................................... 4-20

4.3.2 Basis for Determination of Conservation Status of Species and Performance Standard for Preparation of the Baseline ................. 4-21

4.3.3 Ecological Resources in Project site and vicinity ........................... 4-27

4.3.4 Critical Habitat Assessment .......................................................... 4-36

4.3.5 Ecosystem Services ...................................................................... 4-38

4.4 Socioeconomic Environment ................................................................ 4-38

4.4.1 Scope ........................................................................................... 4-39

4.4.2 Socioeconomic Baseline Survey ................................................... 4-41

4.4.3 Socioeconomic Survey Results ..................................................... 4-45

4.4.4 Urban and Semi-Urban Settlements.............................................. 4-45

4.4.5 Rural Settlements ......................................................................... 4-54

4.4.6 Fishing .......................................................................................... 4-62

4.4.7 Shrine of Shah Hassan ................................................................. 4-66

4.5 Anticipated Developments in the vicinity of the Project ...................... 4-67

4.5.1 2 × 660 MW Coal-Fired Power Plant Port Qasim Electric Power Company ...................................................................................... 4-68

4.5.2 K-Electric Bin Qasim Coal Conversion Project .............................. 4-69

4.5.3 Comparisons of Design Features of the Anticipated Projects with the Proposed Project ............................................................. 4-70

4.5.4 Conclusion .................................................................................... 4-70

5. Stakeholder Consultations ............................................................. 5-1

5.1 Objectives of Stakeholder Consultations ............................................... 5-1

5.2 National Regulations and International Practice for Stakeholder Consultations ........................................................................................... 5-2

5.2.1 Pakistan Environmental Law ........................................................... 5-2

5.2.2 International Practice ...................................................................... 5-3

5.2.3 Good Practice Principles ................................................................. 5-4

5.3 Stakeholder Identification and Analysis ................................................. 5-4

5.4 Consultation Methodology ...................................................................... 5-7

5.4.1 Consultation Material ...................................................................... 5-7

5.4.2 Consultation Mechanism for Institutional Consultations .................. 5-7

5.4.3 Consultation Mechanism for Community Consultations .................. 5-9



Hagler Bailly Pakistan Contents R5A05ENP: 09/29/15 xxii

5.4.4 Documentation and Reporting....................................................... 5-13

6. Scoping of Environmental and Social Impacts ............................ 6-1

6.1 Scoping Methodology .............................................................................. 6-1

6.2 Scoping of Identified Potential Environmental and Social Impacts ...... 6-4

7. Environmental Impact Assessment and Mitigation Measures for the Proposed Project ................................................................ 7-1

7.1 Impact Assessment Methodology ........................................................... 7-1

7.2 Impacts on Ambient Air Quality from Stack Emissions during Operational Phase .................................................................................... 7-2

7.2.1 Objectives ....................................................................................... 7-2

7.2.2 Sources of Emission ....................................................................... 7-2

7.2.3 Modeling Data and Parameters ....................................................... 7-3

7.2.4 Background Concentration of NO2 in Ambient Air........................... 7-4

7.2.5 Modeled Incremental Pollutant Concentrations using AERMOD ..... 7-5

7.2.6 AQ1: Impact on air quality in the PQA airshed from gaseous emissions from the Project during the operation phase. ................ 7-17

7.3 Ecological Impacts ................................................................................. 7-19

7.3.1 EC1: Impact on Marine Ecological Resources from the Construction of Intake and Outfall Channels extending into the Gharo Creek ..................................................................... 7-19

7.3.2 EC2: Changes in Abundance and Diversity of Marine Flora and Fauna caused by Discharge of Effluent into the Creek .................. 7-21

7.3.3 Assessment of Brine Concentration Profile in the Gharo Creek .... 7-21

7.4 Socioeconomic Impacts ......................................................................... 7-26

7.4.1 SE1: Generation of skilled and unskilled employment from the construction and operation of the Project ........................ 7-26

8. Environmental Management Plan .................................................. 8-1

8.1 Purpose and Objectives of the EMP ........................................................ 8-1

8.1.1 Management Approach ................................................................... 8-1

8.1.2 Management Responsibilities ......................................................... 8-1

8.2 Mitigation Plan .......................................................................................... 8-3

8.2.1 Waste Management ........................................................................ 8-3

8.3 Monitoring Plan ...................................................................................... 8-15

8.3.1 Objective of Monitoring ................................................................. 8-15

8.3.2 Performance Indicators ................................................................. 8-15



Hagler Bailly Pakistan Contents R5A05ENP: 09/29/15 xxiii

8.3.3 Environmental Monitoring Plan ..................................................... 8-16

8.3.4 Environmental Records ................................................................. 8-20

8.4 Communication and Documentation .................................................... 8-20

8.4.1 Meetings ....................................................................................... 8-20

8.4.2 Reports ......................................................................................... 8-21

8.4.3 Change-Record Register .............................................................. 8-21

8.5 Change Management ............................................................................. 8-21

8.5.1 First-Order Change ....................................................................... 8-21

8.5.2 Second-Order Change .................................................................. 8-21

8.5.3 Third-Order Change ...................................................................... 8-21

8.5.4 Changes to the EMP ..................................................................... 8-22

8.6 Environmental Training.......................................................................... 8-22

8.7 Construction Management Plan ............................................................ 8-24

8.8 Spill Management ................................................................................... 8-30

8.8.1 Avoiding spills ............................................................................... 8-30

8.8.2 Spill Kits ........................................................................................ 8-30

8.8.3 Responding to spills ...................................................................... 8-31

8.9 Grievance Redress Mechanism ............................................................. 8-31

8.9.1 Framework for Grievance Redress Mechanism ............................ 8-31

8.9.2 Outline of Mechanism for Grievance Redress ............................... 8-32

9. Conclusion ....................................................................................... 9-1

Appendices:

Appendix A: Sindh Environmental Quality Standards and IFC Guidelines

Appendix B: Air Quality Sampling Results

Appendix C: Settlement Questionnaire for Men and Women

Appendix D: Record of Stakeholder Consultations

Appendix E: Background Information Document

Appendix F: AERMOD Description

Appendix G: Sensitivity Analysis



Hagler Bailly Pakistan Exhibits R5A05ENP: 09/29/15 xxiv

Exhibits

Exhibit 1.1: Project Location and Setting ................................................................. 1-2

Exhibit 1.2: Project Layout ....................................................................................... 1-5

Exhibit 2.1: Comparison of NEQS and IFC Guideline Limits for Emission of Key Pollutants from Natural Gas Fired Power Plants ......... 2-5

Exhibit 2.2: Comparison of SEQS and IFC Guideline Limits for Ambient Air Quality 2-5

Exhibit 2.3: Comparison of NEQS and IFC Guideline Limits for Effluent Discharge (mg/l, unless otherwise defined) ............................. 2-6

Exhibit 2.4: Key Environmental Laws in Sindh ......................................................... 2-7

Exhibit 2.5: International Environmental Treaties Endorsed by Pakistan ............... 2-12

Exhibit 3.1: Location of the Proposed Project .......................................................... 3-2

Exhibit 3.2: Project Layout ....................................................................................... 3-3

Exhibit 3.3: Conceptual Process Flow Diagram of a CCPP ..................................... 3-4

Exhibit 3.4: RLNG CCPP Layout ............................................................................. 3-5

Exhibit 3.5: GE 9FA.05 Industrial Gas Turbine ........................................................ 3-6

Exhibit 3.6: Siemens SGT5-4000F Industrial Gas Turbine ...................................... 3-7

Exhibit 3.7: Combined Cycle Utility HRSG .............................................................. 3-8

Exhibit 3.8: HRSG Evaporator ................................................................................. 3-9

Exhibit 3.9: HRSG Economizer ............................................................................. 3-10

Exhibit 3.10: HRSG Superheater ............................................................................. 3-11

Exhibit 3.11: Water Balance Diagram ...................................................................... 3-15

Exhibit 3.12: Quality of Seawater from the Gharo Creek ......................................... 3-16

Exhibit 3.13: RO Process Flow Diagram ................................................................. 3-19

Exhibit 3.14: Raw Water Treatment Process Flow .................................................. 3-20

Exhibit 3.15: Location of K-Electric Transmission Towers outside the Project-site .. 3-24

Exhibit 3.16: Project Staffing ................................................................................... 3-25

Exhibit 4.1: The Study Area and existing Industries around the Project-Site............ 4-3

Exhibit 4.2: Types of Vehicles Observed on Roads near the Project-Site ................ 4-4

Exhibit 4.3: The Badal Nullah and Gharo Creek ...................................................... 4-5

Exhibit 4.4: Seasonal Characteristics of the Climate of Karachi ............................... 4-6

Exhibit 4.5: Average Temperatures (°C) Recorded by Karachi Airport Meteorological Station .......................................................................... 4-7

Exhibit 4.6: Rainfall measured at Karachi Airport Meteorological Station ................. 4-8



Hagler Bailly Pakistan Exhibits R5A05ENP: 09/29/15 xxv

Exhibit 4.7: Mean Wind in the Study Area ............................................................... 4-8

Exhibit 4.8: Wind Rose of the Study Area for the Year 2011 ................................... 4-9

Exhibit 4.9: Major Sources of Air Emissions in the PQA around the Project-Site ... 4-10

Exhibit 4.10: Location of Major Sources of Air Emissions around Project-Site ......... 4-11

Exhibit 4.11: Pollutants Sampled during Field Survey March 4–6, 2015 .................. 4-13

Exhibit 4.12: Description of Ambient Air Quality Sampling Locations ....................... 4-13

Exhibit 4.13: Sampling Locations on Map ................................................................ 4-14

Exhibit 4.14: Baseline Air quality Data from Secondary Sources ............................. 4-15

Exhibit 4.15: Sampling Locations for Baseline Air quality Data from Secondary Sources .............................................................................................. 4-16

Exhibit 4.16: Summary of Air Quality Sampling Results .......................................... 4-18

Exhibit 4.17: Average Concentration of Pollutants around the Project Site .............. 4-19

Exhibit 4.18: Annual Seawater Parameters in PQA Creeks ..................................... 4-23

Exhibit 4.19: Seawater Parameter in the Water Column .......................................... 4-23

Exhibit 4.20: Heavy Metal Concentrations in Sediments of the Gharo Creek .......... 4-24

Exhibit 4.21: Heavy Metal Concentrations in Sediments of the Gharo Creek .......... 4-25

Exhibit 4.22: Concentration of Heavy Metals Observed in the Edible Tissues of Fish, Crab, and Shrimp ....................................................................... 4-26

Exhibit 4.23: Concentration of Heavy Metals Observed in the Edible Tissues of Fish, Crab, and Shrimp ....................................................................... 4-26

Exhibit 4.24: Marine Invertebrate Species reported from the Gharo Creek .............. 4-29

Exhibit 4.25: Fishing in Port Qasim Area. ................................................................ 4-31

Exhibit 4.26: Vegetation Species observed in Port Qasim Area............................... 4-32

Exhibit 4.27: Asian Migratory Bird Flyways .............................................................. 4-35

Exhibit 4.28: Diversity of Bird Fauna at Korangi Phitti Creek System ...................... 4-35

Exhibit 4.29: Results of the Screening Exercise for Potential Socioeconomic Impacts from the Project ............................................ 4-40

Exhibit 4.30: Principal Areas Covered in Questionnaires ......................................... 4-41

Exhibit 4.31: Types of Settlements and their Geographical Coordinates ................. 4-43

Exhibit 4.32: Location of Urban, Semi-Urban and Rural Settlements within the Study Area .......................................................................... 4-44

Exhibit 4.33: Summary of the Socioeconomic Conditions in the Study Area ............ 4-45

Exhibit 4.34: Socioeconomic Profile of Gulshan-e-Hadeed ...................................... 4-46

Exhibit 4.35: Occupational Profile of Gulshan-e-Hadeed ......................................... 4-47

Exhibit 4.36: Spoken Languages in Gulshan-e-Hadeed .......................................... 4-47

Exhibit 4.37: Percentage Share of Ethnic Groups in Gulshan-e-Hadeed ................. 4-48

Exhibit 4.38: Photographs of the Socioeconomic Features of Gulshan-e-Hadeed ... 4-48

Exhibit 4.39: Socioeconomic Profile of PSM Town .................................................. 4-50



Hagler Bailly Pakistan Exhibits R5A05ENP: 09/29/15 xxvi

Exhibit 4.40: Photographs of the Socioeconomic Features of PSM Town ............... 4-50

Exhibit 4.41: Clusters of communities (Goths) within Pipri with Estimated Number of Households and Population .............................. 4-52

Exhibit 4.42: Percentage Share of Ethnic Groups in Pipri ........................................ 4-53

Exhibit 4.43: Spoken Languages in Pipri ................................................................. 4-53

Exhibit 4.44: Photographs of the Socioeconomic Features of Pipri .......................... 4-54

Exhibit 4.45: Demographic Profile of the Surveyed Rural Settlements..................... 4-55

Exhibit 4.46: Percentage of Spoken languages in the Surveyed Rural Settlements. 4-56

Exhibit 4.47: Percentage of Occupations in the Surveyed Rural Settlements .......... 4-56

Exhibit 4.48: Housing Structures in the Surveyed Rural Settlements ....................... 4-57

Exhibit 4.49: View of Shops in the Surveyed Rural Settlements .............................. 4-57

Exhibit 4.50: View of Mosques in the Surveyed Rural Settlements .......................... 4-58

Exhibit 4.51: Water Supply and Storage Resources in the Surveyed Rural Settlements ............................................................... 4-59

Exhibit 4.52: Educational Facilities in the Surveyed Rural Settlements.................... 4-60

Exhibit 4.53: Education Institutions in the Surveyed Rural Settlements ................... 4-60

Exhibit 4.54: Community Health Center ................................................................... 4-61

Exhibit 4.55: Migration Patterns in the Surveyed Rural Settlements ........................ 4-61

Exhibit 4.56: Survey Locations to identify existing Fishing Activities ........................ 4-63

Exhibit 4.57: Photographs of the Fishing Survey ..................................................... 4-64

Exhibit 4.58: Location of Keti Bandar with respect to Study Area ............................ 4-65

Exhibit 4.59: Photographs of the Shrine of Shah Hassan ........................................ 4-67

Exhibit 4.60: Comparison of some Design Specifications between the Proposed Project and PQEPC and K-Electric Projects ....................... 4-70

Exhibit 5.1: Identified Potential Impacts and the Affected or Interested Groups ....... 5-6

Exhibit 5.2: List of Institutions and Industries Consulted with Consultation Location and Date ............................................................ 5-8

Exhibit 5.3: Photographs of Institutional Stakeholder Consultations ........................ 5-8

Exhibit 5.4: List of Communities Consulted in Chronological Order with the Geographical Coordinates of the Consultation Locations ...................... 5-9

Exhibit 5.5: Locations of Community and Industrial Stakeholders .......................... 5-10

Exhibit 5.6: Photographs of Community Consultations .......................................... 5-11

Exhibit 5.7: Summary of Concerns Raised by Communities .................................. 5-14

Exhibit 5.8: Summary of Concerns Raised by Institutions ...................................... 5-15

Exhibit 6.1: Defining Criteria for determining Magnitude, Duration and Spatial Scale of Identified Impact .......................................................... 6-3



Hagler Bailly Pakistan Exhibits R5A05ENP: 09/29/15 xxvii

Exhibit 6.2: Determining Consequence, Probability and Significance Rating of Identified Impacts .............................................. 6-4

Exhibit 6.3: Scoping of Environmental and Social Impacts of the Proposed Project 6-7

Exhibit 7.1: AERMOD Modeling Data and Parameters for Scenario 1 and Scenario 2 (base case) ......................................................................... 7-3

Exhibit 7.2: Background Concentrations of Pollutants in Ambient Air ...................... 7-5

Exhibit 7.3: Model Grid within the Study Area .......................................................... 7-7

Exhibit 7.4: Modeling Results for Incremental Concentrations of CO and NO2 from the Project in Scenario 1 and Scenario 2 .............................. 7-8

Exhibit 7.5: Predicted Annual Incremental Concentration of NO2 (Scenario 1) ........ 7-9

Exhibit 7.6: Predicted 24-hour Incremental Concentration of NO2 (Scenario 1) .... 7-10

Exhibit 7.7: Predicted 1-hour Incremental Concentration of CO (Scenario 1) ........ 7-11


Exhibit 7.9: Predicted Annual Incremental Concentration of NO2 (Scenario 2) ...... 7-13

Exhibit 7.10: Predicted 24-hour Incremental Concentration of NO2 (Scenario 2) ..... 7-14



Exhibit 7.13: Compliance with Ambient Air Quality Guidelines and Standards ......... 7-17

Exhibit 7.14: Modeling results for worst case scenario ............................................ 7-18

Exhibit 7.15: Plume Modeling Input Parameters for Design of Effluent Channel and Flow Characteristics..................................................................... 7-22

Exhibit 7.16: Pollutant Load Dilution with ebb Current ............................................. 7-24

Exhibit 7.17: Pollutant Load Dilution with Flood Current .......................................... 7-25

Exhibit 8.1: Roles and Responsibilities for Environmental Monitoring ...................... 8-2

Exhibit 8.2: Mitigation Plan during Construction Phase ........................................... 8-4

Exhibit 8.3: Mitigation Plan for the Operation Phase ................................................ 8-7

Exhibit 8.4: Waste Management Plan Summary ................................................... 8-14

Exhibit 8.5: Monitoring Plan during Construction Phase ........................................ 8-17

Exhibit 8.6: Monitoring Requirements during Operational Phase ........................... 8-18

Exhibit 8.7: Training Program ................................................................................ 8-23

Exhibit 8.8: Construction Management Plan .......................................................... 8-25



Hagler Bailly Pakistan Abbreviations R5A05ENP: 09/29/15 xxviii

Abbreviations

ADB Asian Development Bank

AFD Acoustic Fish Deterrent

BID Background Information Document

BQPS Bin Qasim Thermal Power Station

BWRO Boiler Water Reverse Osmosis

CCPP Combined-cycle Power Plant

CEMS Continuous Emissions Monitoring System

CIA Cumulative Impact Assessment

CITES Convention on International Trade in Endangered Species

CMP Construction Management Plan

CO Carbon Monoxide

CPP Coal Power Plant

CTS Custody Transfer Station

DLE Dry Low Emission

DWT Dead Weight Ton

EAP Environmental Action Plan

EETL Engro Elengy Terminal Ltd

EHS Environmental, Health and Safety

EIA Environmental Impact Assessment

EMP Environmental Management Plan

EPCL Engro Polymer and Chemicals Limited

EPL Engro Powergen Limited

EZ Engro Zarkhez

FAO Food and Agriculture Organization

FFBL Fauji Fertilizer Bin Qasim Limited

FRR Fish Recovery and Return

GDP Gross Domestic Product

GFP Grievance Focal Person

GIS Geographical Information System Software

GoS Government of Sindh

GPS Global Positioning System

GRC Grievance Redress Committee

HBP Hagler Bailly Pakistan

HC Hydrocarbons

HDF Human Development Foundation

HP High Pressure

HRSGs Heat Recovery Steam Generators

Hz Hertz

IEE Initial Environmental Examination

PS Performance Standards

IFC International Finance Corporation

IP Intermediate Pressure

IUCN International Union for Conservation of Nature

KDA Karachi Development Authority



Hagler Bailly Pakistan Abbreviations R5A05ENP: 09/29/15 xxix

K–Electric Karachi Electric Utility Company

LCP Lotte Chemicals Pakistan

LLWM Low Low Water Mark

LNG Liquefied Natural Gas

LP Low Pressure

LPG Liquefied Petroleum Gas

MBI Marine Benthic Invertibrates

MMSCFD Million Standard Cubic Feet per Day

MPa Mega Pascal

MSDS Material Safety Data Sheets

MW Megawatt

NEQS National Environmental Quality Standards

NOx Nitrogen Oxides

O3 Ozone

Pak-EPA Pakistan Environmental Protection Agency

PCU Public Complaints Unit

PEPA 1997 Pakistan Environmental Protection Act

PM Particulate Matter

PPE Personal Protection Equipment

PPM Parts Per Million

PPT Parts Per Thousand

PQ Port Qasim

PQA Port Qasim Authority

PQEPC Port Qasim Electric Power Company

PSM Pakistan Steel Mills

RLNG Re-gasified liquefied natural gas

RO Reverse-osmosis

SEF Sindh Education Foundation

SEPA 2104 Sindh Environmental Protection Act, 2014

SEPA Sindh Environmental Protection Agency

SEQS Sindh Environmental Quality Standards

SFD Sindh Forest Department

SMART Self Monitoring and Reporting Tool

SO2 Sulfur Dioxide

SPRINT Spray Inter-Cooled Turbine

SPS Safeguard Policy Statement

SR Safeguards Requirement

SS Suspended Solids

SWRO Raw Water Reverse Osmosis System

TSM Tuwairqi Steel Mills

UNEP United Nations Environment Programme

USEPA United States Environmental Protection Agency

WB World Bank

WWF World Wide Fund for Nature



Hagler Bailly Pakistan Introduction

R5A05ENP: 09/29/15 1-1

1. Introduction

Engro Powergen Limited (EPL) is planning to develop a 450 megawatt (MW) re-gasified

liquefied natural gas (RLNG) combined-cycle power plant (CCPP) (the “Project”) at Port

Qasim, Karachi. EPL has initiated an Environmental Impact Assessment (EIA) study to

assess the likely environmental and socioeconomic impacts that may result from Project

activities and to mitigate any potential negative impacts. The EIA process and the report

will meet national regulations, the regulatory requirements of the Government of Sindh

(GoS), and the relevant International Finance Corporation (IFC) guidelines.

EPL has acquired the services of Hagler Bailly Pakistan Pvt. Ltd. (HBP) to carry out the

EIA study for the proposed Project.

1.1 Project Setting

The Project will utilize 37 acres (15 hectares or 150,000 m2) of land in an empty plot

owned by EPL in the Port Qasim Authority (PQA) Industrial Estate (the “Project-site”).

PQA is located, approximately, 45 kilometers (km) southeast of the city of Karachi

(Exhibit 1.1). The geographical coordinates of the proposed Project-site are

67° 22' 41.185" E, 24° 47' 28.324" N.

Engro Zarkhez (EZ) and Engro Polymer and Chemicals Limited (EPCL) are located to

the west and immediately adjacent to the Project-site. Lotte Chemicals Pakistan (LCP) is

located, approximately, 500 m to the east.

A custody transfer station (CTS), built by Engro Elengy Terminal Ltd (EETL), will be

located outside the southwest corner of the EPCL facility. The CTS is the point where

incoming flow of natural gas from EETL to the Project-site will be metered. Natural gas

will be transported from the CTS to the Project-site via an underground pipeline which

will traverse along either outside the southern boundary wall of the existing EPCL and

EZ complex or outside the western and northern boundary wall of the same complex.

The total water requirements of the Project will be met by extracting water from the

Gharo Creek, located to the south of the Project, at a flow rate of 1,201 m3/hr using a

300 mm diameter pipeline with a length of 2.5 km. The water intake velocity will be

2.9 m/s. The intake pipe will be laid 2.5 m below the surface when on PQA land and will

rest on the creek floor once inside the Gharo Creek.

The creek is located on the northwestern edge of the Indus delta system which is

characterized by long and narrow creeks, mud flats and the mangroves forest ecosystems.

In either case, an outfall channel will be constructed which will also extend from the

southern edge of the Project-site to the Gharo Creek. For more details on Project setting

and location, a Project location and setting map is provided as Exhibit 1.1.




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Exhibit 1.1: Project Location and Setting




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1.2 Project Outline

The Project development encompasses a 450 MW RLNG-based CCPP with dual fuel gas

turbines. Produced electric power by the plant will be transmitted to the national grid via

a power evacuation point located within the Project-site.

RLNG will be used as the main firing fuel for the CCPP which will be supplied by EETL

prior to the CTS. The daily requirement of RLNG is estimated to be 60 million standard

cubic feet per day (MMSCFD). High Speed Diesel (HSD) will be stored on-site and used

as a backup fuel.


heat recovery steam generators (HRSGs) and steam turbines. The total water requirement

for the Project is calculated to be 1,201 m3/hr. The makeup water requirement for the

recirculating cooling water system employed for the proposed power plant will be

538 m3/hr.

Cooling water will be obtained by extracting sea water from the creek located south of

the Project-site. A water intake channel will be built between the plant and Gharo Creek

traversing through empty industrial plots south of the Project-site. Sea water will be

treated using a reverse-osmosis (RO) water filter plant.

Effluent streams, made up of discharge from the cooling-water process and the RO

treatment plant, will be discharged through an effluent channel into the Badal Nullah,

west of the Project-site. From here, the effluent will eventually flow into the Gharo

Creek. All effluent discharged into the creek will be compliant with both the Sindh

Environmental Quality Standards (SEQS) and IFC standards for industrial effluents

discharged into the sea.

RLNG used by the Project is expected to have a low heating value of 1,050British

thermal units per standard cubic feet (btu/scf) and its composition, in terms of molecular

percentage, will be as follows:

Nitrogen –1.5 %

Methane –85.6 %

Ethane –7.8 %

Propone –2.9%

Butane – 1.9 %

Pentane –0.3 %

Impurities in the natural gas are expected to be as follows:

Hydrogen Sulfide –5 milligram per normal cubic meter (mg/Nm3)

Gas-fired plants generally produce negligible quantities of particulate matter (PM) and

sulfur oxides (SOx), and levels of nitrogen oxides (NOx) are about 60% of those from




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plants using coal (without emission reduction measures). Natural gas-fired plants also

release lower quantities of carbon dioxide, a greenhouse gas.1

The Project is estimated to be constructed within 26 to 28 months from financial close.

Exhibit 1.2 illustrates the Project layout on a map.

1 International Finance Corporation. Environmental, Health, and Safety Guidelines for Thermal Power

Plants. World Bank Group, 2008.




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Exhibit 1.2: Project Layout




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1.3 Statement of Need

Pakistan is suffering from an acute energy crisis. The unreliable power supply is affecting

the productive end-uses of power due to which the direct and multiplier benefits of

productive activities are foregone and the economy incurs a loss. Taking into account the

crippling power shortages in the country, the Government of Pakistan has signed an

agreement with the State of Qatar for the import of Liquefied Natural Gas (LNG) which

is a cheaper and environmentally-friendly fuel for power generation as compared to

diesel. Utilizing this opportunity, EPL has taken an initiative to install the proposed

Project to positively contribute to the country’s energy supply mix.

The development of the proposed Project will add 450 MW of electric power to the

national grid. The power generated by the Project would be supplied to various sectors

that are currently being affected by the power shortages and bridge part of the energy

shortfall facing the country. This, in turn, will have a positive impact on the country’s

economy through increase in gross domestic product (GDP). The impact will last through

the life of the Project.

1.4 Analysis of Alternatives

The purpose of this section is to provide an analysis of the different alternatives available

with regards to key aspects of the Project. It also considers a No-Project Alternative. The

different aspects analyzed range from the alternatives for the selection of Project-site to

the cooling water technology used.

The comparison of alternatives briefly considers factors related to cost and technological-

reliability; and, environmental impacts and consequences of the alternatives. In this

manner, the objective of this section is to inform decision-makers, stakeholders and the

public regarding key aspects of the Project and how they compare, environmentally and

technologically, with other similar projects.

1.4.1 No-Project Option

Pakistan is going through an acute power shortage and the existing gap between supply

and demand is estimated to be up to 5,000 MW. The proposed Project represents

nearly9 % of the current gap and will utilize cheaper LNG instead of, the more

expensive, diesel and furnace oil, and the more environmentally detrimental coal, to

generate electricity. Thus in the absence of this Project, the gap in power supply and

demand will continue to grow or be replaced with other more expensive and less

environmentally-friendly fuels.

1.4.2 Site Selection

The proposed Project-site is an ideal location for the development of the Project due to

the following reasons:




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Proximity to source of LNG, in this case Port Qasim (PQ) and the Elengy

Terminal

The Project will be located in the PQA close to the site of the EETL where

LNG will be imported and then transferred to consumers using a network of

gas pipelines.

Availability of cooling water

The Gharo Creek is located approximately 600 m south of the Project-site and

will be the source of cooling water for the power plant.

Proximity to transmission network for evacuation of power

Power generated by the Project will be evacuated to the national grid through

an existing transmission grid located in the PQA close to the Project-site.

Proximity to road network for transportation of equipment

The Project-site is located in the PQA which has a network of internal roads

built for traffic related to the construction and operation of industries within it.

The National Highway (N-5) passes close to the PQA connecting it with other

industrial and commercial centers in Karachi and Sindh. In case of importing

equipment and transporting it to the Project-site, the PQA is host to a large

commercial port which is roughly 6 km away from the Project-Site.

Availability of sufficient land

The Project will be spread over 37 acres (15 hectares) of land in an empty plot

owned by EPL in the PQA.

Sufficient distance from population centers;

The PQA is a designated industrial estate with no communities located inside

it.

Away from ecologically sensitive areas

The Project-site is located on an empty and barren land.

1.4.3 Fuel Selection

The Project will utilize imported natural gas as its main fuel. Utilizing imported natural

gas will help reduce pressure on local natural gas resources in the country which are

already short in supply.

Natural gas is also a cleaner burning and flexible alternative to other fossil fuels, and is

used in residential, industrial, and transportation applications in addition to an expanding

role in power production in Pakistan.

Natural gas power plants also have the added advantage that they can be constructed in as

little as 20 months for approximately one third the levelized capital cost for a typical coal

plant.2

2 "Natural Gas." Natural Gas. Center for Climate and Energy Solutions. Accessed April 7, 2015.

http://www.c2es.org/technology/factsheet/natural-gas




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1.4.4 Gaseous Emissions

Among fossil fuels, natural gas is the least carbon intensive and burns efficiently with

fewer air pollutants including nitrogen oxides as nitrogen dioxide (NO2) and carbon

dioxide. The emissions of sulfur dioxide, and mercury compunds are negligible. In its

recommended measures to prevent, minimize, and control air emissions, the IFC

Environmental, Health and Safety (IFC EHS) Guidelines3 advise using natural gas over

oil and coal as it the cleanest and economically available fuel.

Natural gas-fired plants carbon dioxide, a greenhouse gas, in very low quantities,.

However, in these too, thermal plants using natural gas emit less than oil- and coal-based

power plants. Combustion of natural gas emits approximately half as much carbon

dioxide as traditional coal and 33 percent less than oil. 4

1.4.5 Combined Cycle Technology

The Project will comprise of gas turbines based on a combined-cycle configuration with

heat recovery steam generators (HRSGs) and steam turbines. Combined cycle plants are

highly efficient because they combine combustion turbines and steam turbines; the hot

exhaust from a gas-fired combustion turbine is used to create steam to power a steam

turbine. High efficiency combined cycle plants emit less than half the CO2 per megawatt-

hour (MWh) as coal power plants, and operate with a 52–60 percent thermal efficiency

range. A typical natural gas combined cycle power plant has a heat rate (i.e., the amount

of fuel used per unit of electricity generation) that is about one third lower than for a

combustion turbine or gas-fired steam turbine plant.5

1.4.6 Cooling-Water Technology

There are four major types of cooling-water systems: once-through cooling, closed-cycle

wet cooling, dry cooling (direct and indirect), and hybrid systems.6

Once-Through Cooling. Once-through systems withdraw water from a natural

source (typically a lake, river, or ocean), use it to extract waste heat from the

steam cycle, and then return it to the water body at a slightly elevated

temperature.

Closed-Cycle Wet Cooling. Closed-cycle (or recirculating) wet cooling systems

are similar to once-through cooling in that the steam is condensed in a water-

cooled, shell-and-tube steam condenser, but differ in that the heated water is not

returned to the environment. Instead the hot water is conveyed to a cooling

component, typically a wet cooling tower (other options include cooling ponds,

spray-enhanced ponds, spray canals, etc.), where it is cooled and then recirculated

to the condenser.

3 International Finance Corporation. “Environmental, Health, and Safety General Guidelines”, World Bank

Group, Washington, DC, 2007. 4 "Natural Gas." Natural Gas. Center for Climate and Energy Solutions. Accessed April 7, 2015.

http://www.c2es.org/technology/factsheet/natural-gas 5 Ibid. 6 Maulbetsch, John , and Jeff Stallings. "Evaluating the Economics of Alternative Cooling Technologies." -

Power Engineering. http://www.power-eng.com/articles/print/volume-116/issue-11/features/evaluat-economics-alternative-cool-technologies.html (accessed September 26, 2014).




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Dry Cooling. Dry cooling systems reject the heat of condensation directly to the

atmosphere with no consumptive use of cooling water.

Hybrid Cooling. Hybrid cooling systems are intended to exploit the virtues of

both the wet and dry systems. In hybrid systems, both air-cooled and wet cooling

equipment is available for handling the plant heat load as conditions dictate.

As the source of water supply for the Project is seawater from the Gharo Creek,

conservation of water is not an environmental imperative for the Project, nor will it result

in indirect cost savings in the form of ecological services from the volume of water

conserved. Therefore, the suitable choice for a cooling-water system for the Project will

be either the once-through cooling system or the closed-cycle wet cooling system.

Between the two, the former has a lower initial capital cost and requires less space as

there is no need for a cooling tower and other auxiliary cooling equipment which the

closed-cycle wet cooling system requires. However, the once-through system utilizes

considerably more water with higher intake and outfall rates. The cooling water, when

released back into the environment at the outfall, possesses a higher temperature than its

original temperature at intake.

For the proposed project, recirculating water cooling system will be adopted. The system

operation does not result in any significant thermal water discharge into the main water

source (Gharo Creek in this case) as it’s a closed loop system only discharging blow

down discharge for the maintenance of the recirculating path of the water. The blowdown

discharge, due to its negligible quantities, is not expected to raise ambient water

temperature by 3 °C.

1.5 Introduction to the EIA

This EIA is conducted to meet the regulatory requirements of Pakistan contained in Sindh

Environmental Protection Act 1997, its associated rules and regulations and IFC

Environmental Health and Safety (EHS) Guidelines 2007 and Performance Standards

2012.

1.5.1 Objectives of the EIA

The objectives of EIA are to:

Assess the existing environmental conditions of the Project-site and its vicinity,

including the identification of environmentally sensitive areas.

Assess the proposed Project activities to identify their potential environmental

and social impacts, evaluate the impacts, and determine their significance.

Propose appropriate mitigation and monitoring measures that can be incorporated

into the design of proposed activities to minimize any environmentally adverse

effects as identified by the assessment.

Assess the proposed Project activities and determine whether they comply with

the relevant environmental regulations of Pakistan.




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The findings of the EIA have been documented in the form of this report which is to be

submitted to the Sindh Environmental Protection Agency (SEPA) as per regulatory

requirements.

1.5.2 Scope of the EIA

This EIA report evaluates the physical, biological, and socioeconomic impact of the

following:

Construction of the Project;

In- land transportation of construction material and equipment;

Socioeconomic factors including generation of employment, and risk of the proposed

development on the nearby human receptors; and

Operation of the new RLNG CCPP boilers and auxiliaries.

The scope of work for this study consisted of six tasks which were performed during the

assessment and are covered in the following parts of this report:

Task 1: Identification of provincial, national and international standards and

guidelines applicable to the proposed Project development (legal,

administrative and institutional framework provided in Section 2)

Task 2: Collection of baseline information (both primary and secondary) on climate,

water quality, air quality, socioeconomic conditions and biological resources

(discussed in Sections 4 of this report)

Task 3: Scoping of the likely impact of the Project on the biophysical environment

of the surrounding area of Project-site. This section identifies significance of

the impacts. (Section 6)

Task 4: Assessment of the impact of the project on the biophysical environment in

the surrounding area of the Project -site (Section 7)

Task 5: Development of an impact mitigation and monitoring plan for the Project

(Section 8).

1.6 Approach and Methodology

The assessment was conducted with the following objectives:

1. To identify the regulatory requirements that apply to project activities in the

proposed area, in the context of environmental protection, health and safety;

2. To assess proposed project activities in terms of their likely impacts on the

environment during the construction and operation phases of the project, in order

to identify issues of environmental concern; and

3. To recommend appropriate mitigation measures that can be incorporated into the

design of the project to minimize any adverse environmental impacts identified.




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The methodology adopted for the assessment consisted of the following steps:

1. Review of regulatory requirements based on: a) a preliminary assessment of

proposed activities and the Project-site; b) screening of relevant laws to prepare a

list of those that are applicable; and c) review of the laws to identify specific

regulatory requirements.

2. Collection of information on proposed project activities, project design and

schedule, with an emphasis on aspects that have an interface with the natural and

social environment.

3. Secondary literature search to collect environmental data about the Project-site

and its vicinity.

4. Site visits for collection of primary data related to various environmental aspects

of the Project-site and its vicinity.

5. Evaluation of environmental data and proposed project activities to identify

environmental parameters that are likely to undergo significant change due to the

proposed project development.

6. Evaluation of each likely change in order to identify adverse environmental

impacts.

7. Identification and evaluation of measures to mitigate the adverse impacts.

8. A stakeholder consultation to document the concerns of the local community and

other stakeholders, and to identify issues that may require additional assessment

in order to address these concerns.

Baseline Data Collection

Detailed environmental baseline surveys were conducted to collect primary data and

published literature was extensively reviewed to develop biophysical baseline of the

Project-site and its vicinity. In addition to these, the data available with HBP collated

during previous EIA studies conducted in the PQA was also reviewed, and where

appropriate was used, to determine the current environmental and socioeconomic

baseline of the area. Aspects that were covered during the survey included:

Community and socioeconomic indicators

Air quality

Sensitive receptors

Marine ecology

Water quality, and

Soil.

Impact Assessment

Each of the potential impacts identified during the scoping phase was evaluated using the

environmental, socioeconomic, and project information collected. Wherever relevant,

quantitative models were used to predict the potential impact. In general, the impact

assessment discussion covers the following aspects:




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The present baseline conditions

The potential change in environmental parameters likely to be affected by project-related

activities

The prediction of potential impacts

The evaluation of the likelihood and significance of potential impacts

The defining of mitigation measures to reduce impacts to as low as practicable

The prediction of any residual impacts, including all long- and short-term, direct and

indirect, and beneficial and adverse impacts

The monitoring of residual impacts

1.7 Regulatory Requirements

The proposed RLNG CCPP is subject to the pertinent legislative and regulatory

requirements of the Government of Pakistan, the Government of Sindh and International

Finance Corporation. The legal statutes that have been reviewed include the Pakistan

Environmental Protection Act, 1997 (PEPA 1997), Sindh Environmental Protection Act,

2014 (SEPA 2014), Initial Environmental Examinations (IEE) and Environmental Impact

Assessment (EIA) Regulation, 2000 (IEE-EIA Regulations 2000), the National

Environmental Quality Standards (NEQS), 19937, Sindh Environmental Quality

Standards (SEQS) for Ambient Air Quality 2014.

In addition, the Project will also comply with the IFC’s Environmental Health and Safety

(IFC EHS) Guidelines 2007 and IFC’s Performance Standards (IFC PSs) on

Environmental and Social Suitability 2012 and their subservient guidelines and standards.

1.8 Report Organization

Section 1 (Introduction) provides an overview of the project, introducing the project

sponsors, and outlining the scope of this study.

Section 2 (Legal and Policy Framework) briefly discusses existing national policy and

resulting legislation for sustainable development and environmental protection, and then

presents the legislative requirements that need to be followed while conducting an EIA.

Section 3 (The Proposed Project) contains information about key features of the

proposed Project, such as its location, design, construction, operation, products and raw

material requirements, suppliers, power generation, and waste disposal arrangements.

Section 4 (Description of the Environment) documents in detail the existing physical,

biological, and socioeconomic conditions around the Project site and relevant

transportation and access routes.

Section 5 (Public Consultation) presents the objectives and outcomes of the public

stakeholder consultation that was conducted during the EIA.

Section 6 (Scoping of Environmental and Social Impacts) significance of the impacts

(high, medium, low) is determined in this section.

7 Including the latest NEQS rules: National Environmental Quality Standards (Self-Monitoring and

Reporting by Industries) Rules, 2001




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Section 7 (Project Impacts and Mitigation) presents an assessment of the Project’s

impact to the physical, biological, and socioeconomic environment, as well as

recommended mitigation measures.

Section 8 (Environmental Management Plan) facilitates the implementation and

monitoring of the mitigation measures identified in the environmental impact assessment.

Section 9 closes the report with a conclusion of the EIA study conducted for the

proposed Project.



Hagler Bailly Pakistan Legal, Administrative and Policy Framework

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2. Legal, Administrative and Policy Framework

This chapter outlines the legal and regulatory framework governing the EIA and the

environmental performance of the Project. These frameworks include the SEPA 2014,

IFC Procedure for Environmental and Social Review of Projects, IFC PSs and IFC EHS

Guidelines.

2.1 Statutory Framework

The development of statutory and other instruments for environmental management has

steadily gained priority in Pakistan since the late 1970s. The Pakistan Environmental

Protection Ordinance 1983 was the first piece of legislation designed specifically for the

protection of the environment. The promulgation of this ordinance was followed, in 1984,

by the establishment of the Pakistan Environmental Protection Agency (Pak-EPA), the

primary government institution at that time dealing with environmental issues.

Significant work on developing environmental policy was carried out in the late 1980s,

which culminated in the drafting of the Pakistan National Conservation Strategy.

Provincial environmental protection agencies were also established at about the same

time. The NEQS were established in 1993. In 1997, the PEPA 1997 was enacted to

replace the 1983 Ordinance. PEPA conferred broad-based enforcement powers to the

environmental protection agencies. This was followed by the publication of the Pakistan

Environmental Protection Agency Review of IEE-EIA Regulations 2000 which provided

the necessary details on the preparation, submission, and review of IEE and EIA.

2.1.1 Constitutional Provision

Prior to the 18th Amendment to the Constitution of Pakistan in 2010, the legislative

powers were distributed between the federal and provincial governments through two

‘lists’ attached to the Constitution as Schedules. The Federal list covered the subjects

over which the federal government had exclusive legislative power, while the

‘Concurrent List’ contained subjects regarding which both the federal and provincial

governments could enact laws. The subject of ‘environmental pollution and ecology’ was

included in the Concurrent List and hence allowed both the national and provincial

governments to enact laws on the subject. However, as a result of the 18th Amendment

this subject is now in the exclusive domain of the provincial government. The main

consequences of this change are as follows:

The Ministry of Environment at the federal level was abolished. Its functions

related to national environmental management were transferred to the provinces.

To manage the international obligations in the context of environment, a new

ministry—the Ministry of Climate Change—was created at the federal level.

The PEPA 1997 is technically no longer applicable to the provinces. The

provinces are required to enact their own legislation for environmental protection.




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As of now, Punjab, Sindh and Balochistan have enacted their own environmental

protection laws. These provincial laws are largely based on PEPA 1997 and, hence,

provide the same level of environmental protection as the parent law.

Between 1993 and 2010, the Pak-EPA promulgated several rules, regulations, standards,

and guidelines to implement the provisions of the PEPA 1997. The provincial

governments have yet to draft their own instruments. 1

On December 16, 2014, SEPA enacted the Sindh Environmental Protection Agency

(Review of Initial Environmental Examination and Environmental Impact Assessment)

Regulations, 2014 (the “IEE-EIA Regulations”).

The discussion on regulatory requirements applicable to this Project is, therefore, based

on the Sindh law, the SEPA 2014, the Regulations; and, the rules, regulations, standards,

and guidelines developed under the PEPA 1997.

2.1.2 Sindh Environmental Protection Act, 2014

The SEPA 2014 was passed by the Sindh Assembly on February 24, 2014. SEPA 2014 is

the basic legislative tool empowering the provincial government to frame regulations for

the protection of the environment. The act is applicable to a broad range of issues and

extends to air, water, industrial liquid effluent, marine, and noise pollution, as well as to

the handling of hazardous wastes. The following articles of the SEPA 2014 have a direct

bearing on the proposed Project:

Article 11(1): ‘Subject to the provisions of this Act and the rules and regulations

therein, no person shall discharge or emit or allow the discharge or emission of

any effluent, waste, pollutant, noise or any other matter that may cause or likely

cause pollution or adverse environmental effects, as defined in Section 2 of this

Act, in an amount, concentration or level which is in excess to that specified in

Sindh Environmental Quality Standards…’ (please see Section 2.1.3)

Article 11(2): ‘All persons, in industrial or commercial or other operations, shall

ensure compliance with the Environmental Quality Standards for ambient air,

drinking water, noise or any other Standards established under section 6(1)(g)(i)2;

shall maintain monitoring records for such compliances; shall make available

these records to the authorized person for inspection; and shall report or

communicate the record to the Agency as required under any directions issued,

notified or required under any rules and regulations.’

Article 14 (1): ‘Subject to the provisions of this Act and the rules and regulations,

no person shall cause any act, deed or any activity’, including;

(b) disposal of solid and hazardous wastes at unauthorized places as

prescribed;

1 The environmental standards applicable in Sindh are National Environmental Quality Standards (NEQS)

as developed by Pakistan Environmental Protection Agency prior to the 18th Amendment. The only exception is the ambient air quality standards which Sindh Environmental Protection Agency has notified separately.

2 SEPA has yet to issue Sindh Environmental Quality Standards (SEQS). SEPA has only issued standards for ambient air quality notified on August 5, 2014.




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(c) dumping of wastes or hazardous substances into coastal waters and inland

water bodies; and

(d) release of emissions or discharges from industrial or commercial

operations as prescribed.

Article 15 (1): ‘Subject to the provisions of this Act, no person shall operate or

manufacture a motor vehicle or class of vehicles from which air pollutants or

noise are being emitted in an amount, concentration or level which is in excess of

the Sindh Environmental Quality Standards or, where applicable, the standards

established under sub-clause (i) of clause (g) of sub-section (1) of section 6’.

Article 17(1): ‘No proponent of a project shall commence construction or

operation unless he has filed with the Agency an initial environmental

examination or environmental impact assessment, and has obtained from the

Agency approval in respect thereof’

Article 17(2): The agency shall;

a) review the initial environmental examination and accord its approval,

subject to such terms and conditions as it may prescribe, or require submission

of an environmental impact assessment by the proponent; or

(b) review the environmental impact assessment and accord its approval

subject to such terms and conditions as it may deem fit to impose or require

that the environmental impact assessment be re-submitted after such

modifications as may be stipulated or decline approval of the environmental

impact assessment as being contrary to environmental objectives.

Article 17(3): ‘Every review of an environment impact assessment shall be

carried out with public participation and, subject to the provisions of this Act,

after full disclosure of the particulars of the project’.

Article 17(4): ‘The Agency shall communicate its approval or otherwise within a

period of two months from the date that the initial environmental examination is

filed, and within a period of four months from the date that the environmental

impact assessment is filed complete in all respects in accordance with the

regulations, failing which the initial environmental examination or, as the case

may be, the environmental impact assessment shall be deemed to have been

approved, to the extent to which it does not contravene the provisions of this Act

and the rules and regulations’.

Article 20(1): ‘The Agency shall from time to time require the person in charge of

a project to furnish, within such period as may be specified, an environmental

audit or environmental review report or environmental management plan

containing a comprehensive appraisal of the environmental aspects of the project’.

Article 20(2): The report of a project prepared under sub-section (1) shall include:

(a) analysis of the predicted qualitative and quantitative impact of the project as

compared to the actual impact;




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(b) evaluation of the efficacy of the preventive, mitigation and compensatory

measures taken with respect to the project; and

(c) recommendations for further minimizing or mitigating the adverse

environmental impact of the project.

Article 20(3): ‘Based on its review of the environmental audit report, the Agency

may, after giving the person in charge of the project an opportunity of being

heard, direct that specified mitigation and compensatory measures be adopted

within a specified time period and may also, where necessary, modify the

approval granted by it under section 17’.

2.1.3 Sindh Environmental Protection Agency (Review of Initial Environmental Examination and Environmental Impact Assessment Regulations), 2014

The IEE-EIA Regulations, 2014, prepared by SEPA under the powers conferred upon it

by the SEPA 2014, provide the necessary guidelines on the preparation, submission, and

review of Initial Environmental Examinations (IEEs) and Environmental Impact

Assessments (EIAs).

Categorization of projects requiring IEE and/or EIA is one of the main components of the

IEE-EIA Regulations, 2014. Projects have been classified on the basis of expected degree

of adverse environmental impact. Project types listed in Schedule II of the regulations are

designated as potentially seriously damaging to the environment and require EIA, and

those listed in Schedule I as having potentially less adverse effects and require an IEE.

“Thermal power generation over 100 MW” is included in Schedule II (List of Projects

Requiring an EIA) under Category A, “Energy”. The proposed Project falls within the

classification for Schedule II and an EIA has therefore been prepared for it.

2.1.4 SEQS, NEQS and IFC Environmental Standards

At present, only ambient air quality standards for Sindh have been established under the

SEQS. For other parameters, the limits defined by the NEQS will be used as the

regulatory framework for the environmental performance of the Project. In addition to

SEQS and NEQS limits, the assessment of the Project’s environmental performance also

assesses its compliance with the IFC guidelines on emissions and effluent discharge3.

Exhibit 2.1 provides the NEQS limits for emission of key pollutants from natural gas-

fired power plants; Exhibit 2.2 provides the SEQS limits for ambient air quality

concentrations of key pollutants; and, Exhibit 2.3 provides the NEQS limits for

concentrations of pollutants in effluents discharged from industrial units. For comparison,

these exhibits also provide the limits prescribed by the IFC guidelines for the same.

The complete set of ambient air quality standards defined by the SEQS and other NEQS

environmental standards are provided in Section A.1 of Appendix A and the complete

set of IFC EHS Guidelines for Thermal Power Plants is provided in Section A.2 of

Appendix A.

3 International Finance Corporation. "Environmental, Health, and Safety Guidelines for Thermal Power

Plants " World Bank Group, 2008




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Exhibit 2.1: Comparison of NEQS and IFC Guideline Limits for Emission of Key

Pollutants from Natural Gas Fired Power Plants

Parameter Source of Emission NEQS Standards1 IFC Guidelines2

Particulate matter

Natural Gas-fired –3 –

Carbon monoxide

Any 800 mg/Nm3 –

Nitrogen Oxides Gas-fired 400 mg/Nm3 For NDA/DA4: 51 mg/Nm3

Sulfur Dioxide Other plants except power plants operating on oil and coal

1,700 mg/Nm3 –

Notes:

1. For additional parameters and explanation, see complete NEQS in Section A.1 and IFC Guidelines in Section A.2 of Appendix A.

2. IFC EHS also state that “emissions from a single project should not contribute more than 25 % of the applicable ambient air quality standards to allow additional, future sustainable development in the same airshed”

3. A “-” in the third column indicates that no guidelines have been provided for the parameter.

4. NDA = Non-degraded airshed; DA = Degraded airshed

Exhibit 2.2: Comparison of SEQS and IFC Guideline Limits for Ambient Air Quality

Pollutants Time-weighted Average

Sindh Standards (μg/m3)

IFC Guidelines (μg/m3)

Sulfur Dioxide (SO2) Annual Average 80 –

24 hours 120 125

Oxide of Nitrogen as (NO) Annual Average 40 –

24 hours 40 –

Oxide of Nitrogen as (NO2) Annual Average 40 40

24 hours 80 –

Ozone (O3) 1 hour 130 –

Suspended Particulate Matter (SPM) Annual Average 360 –

24 hours 500 –

Respirable particulate Matter PM10 Annual Average 120 70

24 hours 150 150

Respirable Particulate Matter PM2.5 24 hours 75 75

Annual Average 40 35

Lead (Pb) Annual Average 1 –

24 hours 1.5 –

Carbon Monoxide (CO) 8 hours 5,000 –

1 hour 10,000 –




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Notes:

1. For additional parameters and explanation, see complete SEQS in Section A.1 and IFC Guidelines in Section A.2 of Appendix A.

2. A “–“ in the third column indicates that IFC has not provided any guidelines for the parameter or they are to be established by the environmental assessment

Exhibit 2.3: Comparison of NEQS and IFC Guideline Limits for Effluent Discharge

(mg/l, unless otherwise defined)

Parameter NEQS1 (Into Sea)

IFC Guidelines

Temperature increase2 =<3°C –3

pH value 6 to 9 6 to 9

Five-day bio-chemical oxygen demand (BOD) at 20°C 80 –

Chemical oxygen demand (COD) 400 –

Total suspended solids (TSS) 200 50

Total dissolved solids (TDS) 3,500 –

Grease and oil 10 10

Phenolic compounds (as phenol) 0.3 –

Chlorides (as Cl') SC4 –

Fluorides (as F') 10 –

Cyanide total (as CN') 1.0 –

Anionic detergents (as MBAS) 20 –

Sulfates (SO4) SC –

Sulfides (s') 1.0 –

Ammonia (NH3) 40 –

Pesticides 0.15 –

Cadmium 0.1 0.1

Chromium (trivalent and hexavalent) 1.0 0.5

Copper 1.0 0.5

Lead 0.5 0.5

Mercury 0.01 0.005

Selenium 0.5 –

Nickel 1.0 –

Silver 1.0 –

Total toxic metals 2.0 –

Zinc 5.0 1.0

Arsenic 1.0 0.5

Barium 1.5 –

Iron 8.0 1.0

Manganese 1.5 –

Boron 6.0 –

Chlorine 1.0 0.2




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Notes:

1. For additional parameters and explanation, see complete NEQS in Section A.1 and IFC Guidelines in Section A.2 of Appendix A.

2. IFC General Guidelines states that the “temperature of wastewater prior to discharge does not result in an increase greater than 3 °C of ambient temperature at the edge of a scientifically established mixing zone which takes into account ambient water quality, receiving water use and assimilative capacity among other considerations”.

3. A “–” in the third column indicates that IFC has not provided any guidelines for the parameter.

4. Discharge concentration at or below sea concentration (SC).

2.1.5 Self-Monitoring and Reporting by Industry Rules 2001

Under the National Environmental Quality Standards (Self-Monitoring and Reporting by

Industry) Rules 2001 (the ‘SMART’ Rules), industrial units are responsible for

monitoring their gaseous and liquid discharges and reporting them to the relevant

environmental protection agency (EPA). As gas-fired thermal power plants fall under

Schedule I Category B of industrial categorization and reporting procedure for SMART,

the respective environmental monitoring reports are required to be submitted on quarterly

basis to the relevant authorities. The project proponents will report their emission and

effluent to SEPA in accordance with the rules.

2.2 Other Relevant Laws

The scope of environmental law implied by the legal definition of ‘environment’ given in

PEPA 1997 results in numerous laws enacted since the nineteenth century being

classified as environmental laws. These include laws pertaining to forests, water

resources, wildlife, land, agriculture, health and town planning. Laws that may have

relevance to environment with a brief scope of the law and their applicability are listed in

Exhibit 2.4.

Exhibit 2.4: Key Environmental Laws in Sindh

Legal Instrument Scope and Applicability Relevance

The Antiquities Act 1975 and Sindh Cultural Heritage Act 1994

Preservation and protection of antiquities (any object more than 75 years old). Empowers the government to declare any antiquity as protected

There is no protected antiquity at the proposed site of Energy Park or its surroundings. Will apply to any chance find of archaeological resource during excavation

Boiler Act 1923 and Boilers Act (Sindh Amendment) Ordinance 1971

Regulation including safety of boilers (any closed vessel exceeding 23 liters in volume) used for generating steam

Will apply to boilers in the Energy Park

Canal and Drainage Act 1873 and Sindh Irrigation Act 1879

Regulates all surface water bodies (both natural and constructed using public resources).

Not applicable since there are no perennial surface water bodies in the project area of influence

Electricity Act 1910 and Electricity Rules 1937

Regulates production, transmission, distribution, and use of electricity

Applicable to the Project including sections relating to safety.




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Legal Instrument Scope and Applicability Relevance

Forest Act 1927 Regulates forest resources. Empowers the government to declare any forest area reserved or protected.

No relevance as there are no reserve or protected forest in the project area of influence

Land Acquisition Act 1894

Empowers the government to acquire private land for projects of national importance and lays down the acquisition procedure

Resettlement may be required as part of this Project.

Petroleum Act 1934 Regulates import, transportation, storage, production, refining and blending of petroleum products and other flammable substances

Storage of petroleum products at the power plant site will be governed by this law

Sindh Wildlife Protection Ordinance 1974

Empowers the government to take measures for protection of wildlife in the province by declaring setting aside certain areas as national park, wildlife sanctuary, and game reserve, and by declaring certain species as protected.

The Runn of Kutch Wildlife Sanctuary is approximately 14 km from the site.

Sindh Water Management Ordinance 2002

“To provide for the establishment on long term, sustainable and participatory basis, of public systems for the distribution and delivery of irrigation water, the removal of drainage water and the management of flood waters”

Not relevant to the Project.

Mines Act 1923 Regulates mines Not relevant to the Energy Park

Explosives Act 1884

Regulates handling and storage of explosive substances

Applicable to any explosive, petroleum, and any other explosive material that may be used during the project

2.2.1 Port Qasim Authority Act, 1973

This Act provides for the establishment of the PQA, defines its functions, powers and

internal organization and lays down rules relative to management of and navigation in

marine ports and inland waterways ports. The particular sections applicable to the

Project are:

Section 71(B) (2) No Owner, Agent or Master of a vessel, or any industry,

manufacturing establishment, mill, factory or any kind, cargo handling company,

terminal operator, etc,. shall discharge any solid or liquid, waste, oily, noxious

radioactive and hazardous substances, bilge discharges, residues and mixtures

containing noxious solid and liquid wastes, de-blasting of un-washed cargo tanks

and line washing, garbage, emission of any effluent or waste or air pollution or

noise in any amount concentration or level in excess of the National

Environmental Quality Standards, or standards, which may be specified, from

time to time, by the Authority for Port limits.

Section 71(B) (3) Any person contravening the provisions of sub-section (2) shall

be liable to penalty as determined and notified by the authority from time to time




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for each contravention in addition to the charges for cleaning of the Port and

removal of pollution therefrom.

Section 71 (C) (1) No proponent of a project shall commence construction or

operation unless he has filed with this Authority as initial environmental

examination or, where the project is likely to cause an adverse environmental

effect, an environment impact assessment, and has obtained from the authority

approval in respect thereof.

Section 71 (C) (2) The Authority shall: - (a) review the initial environmental

examination and accord its approval, or required submission of an Environmental

Impact Assessment by the proponent; or (b) review the Environmental Impact

Assessment and accord its approval subject to such condition as it may deem fit to

impose, or require that the Environment Impact Assessment be re-submitted after

such modification as may be stipulated.

2.2.2 Hazardous Substances

Article 13 of the Sindh Act 2014 states that ‘Subject to the provisions of this Act, no

person shall import, generate, collect, consign, transport, treat, dispose of, store,

handle or otherwise use or deal with any hazardous substance except—(a) under a

license issued by the Agency; or (b) in accordance with the provisions of any other

law for the time being in force, or of any international treaty, convention, protocol,

code, standard, agreement or other instrument to which Government is a party.’

Hazardous substance is defined in Article 2(xxv) of the SEPA 2014 as “(a) a

substance or mixture of substances, other than a pesticide as defined in the

Agricultural Pesticides Ordinance, 1971 (II of 1971), which, by reason of its chemical

activity or toxic, explosive, flammable, corrosive, radioactive or other characteristics,

causes, or is likely to cause, directly or in combination with other matters an adverse

environmental effect; and (b) any substance which may be prescribed as a hazardous

substance”

To date, SEPA has not prescribed any substance as hazardous nor has it defined the

procedure for licensing. As and when, the procedure is defined and a license for any

particular substance being used at the power plant is required, license will be obtained

by the project Proponent. However, best industry practice and internationally

acceptable guidelines for hazardous substances would be used for the proposed

project.

2.2.3 The Forest Act 1927

The act empowers the provincial forest departments to declare any forest area

reserved or protected. The act also empowers the provincial forest departments to

prohibit the clearing of forests for cultivation, grazing, hunting, removing forest

produce, quarrying, felling, and lopping.

Mangrove plantations enjoy a special legal status under the Forest Act of 1927. An

area of 344,870 ha of mangroves was transferred to the Sindh Forest Department

(SFD) in the year 1958 and declared “Protected Forest” under the Act. In 1973, an




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area of 64,400 ha was transferred by SFD to PQA. However, the areas with PQA

continue legally to be “Protected Forests”.4

2.2.4 Factories Act 1934

Particular sections of the act applicable to this project are:

Section 13(1): Every factory shall be kept clean and free from effluvia arising

from any drain, privy or other nuisance.

Section 14(1): Effective arrangements shall be made in every factory for the

disposal of wastes and effluents due to the manufacturing process carried on

therein.

Section 16(1): In every factory in which, by reason of the manufacturing process

carried on, there is given off any dust or fume or other impurity of such a nature

and to such an extent as is likely to be injurious or offensive to the workers

employed therein, effective m

measures shall be taken to prevent its accumulation in any work-room and its

inhalation by workers and if any exhaust appliance is necessary for this purpose, it

shall be applied as near as possible to the point of origin of the dust, fume or other

impurity, and such point shall be enclosed so far as possible.

Section 16(2): In any factory no stationary internal combustion engine shall be

operated unless the exhaust is conducted into open air and exhaust pipes are

insulated to prevent scalding and radiation heat, and no internal combustion

engine shall be operated in any room unless effective measures have been taken to

prevent such accumulation of fumes therefrom as are likely to be injurious to the

workers employed in the work-room.

Section 20(1): In every factory effective arrangements shall be made to provide

and maintain at suitable points conveniently situated for all workers employed

therein a sufficient supply of whole-some drinking water.

Section 26(1) d(i): In every factory the following shall be securely fenced by the

safeguards of substantial construction which shall be kept in position while the

parts of machinery required to be fenced are in motion or in use, namely – (a)

every part of an electric generator, a motor or rotary convertor.

2.2.5 Labor and Health and Safety Legislation

The Constitution of Pakistan contains a range of provisions with regards to labor

rights, in particular:

Article 11 of the Constitution prohibits all forms of slavery, forced labor and child

labor;

Article 17 provides for a fundamental right to exercise the freedom of association

and the right to form unions;

4 International Union for Conservation of Nature (IUCN) Pakistan. Mangroves of Pakistan–Status and

Management. IUCN, 2005.




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Article 25 lays down the right to equality before the law and prohibition of

discrimination on the grounds of sex alone; and

Article 37(e) makes provision for securing just and humane conditions of work,

ensuring that children and women are not employed in vocations unsuited to their

age or sex, and for maternity benefits for women in employment.

Labor law is controlled at both provincial and national levels with compulsory

employment agreements containing the terms set out by the labor laws. There are

various laws containing health and safety requirements including: Mines Act 1923;

Factories Act 1934; Factories Rules; Hazardous Occupations Rules 1963; Provincial

Employees Social Security Ordinance 1965; and Workmen’s Compensation Act

1923. No single comprehensive piece of legislation deals with occupational or

community safety and health.

2.3 International Law and Multilateral Agreements

International law pertinent to the environment and sustainable development

comprises:

customary international law, which is applicable to all states and results from

general and consistent practice followed by states out of a sense of legal

obligation;

judicial decisions of international courts and tribunals, and the teachings of highly

qualified publicists, including articles by eminent lawyers decisions of the

International Law Commission and other United Nations organizations, decisions

of the conference of parties to a treaty and also decisions and directives of the

European Union; and

treaties (the term “treaty” encompasses “agreements, covenants, conventions,

pacts, protocols, and statutes”) that are generally intended to be implemented

through enactment and enforcement of laws at national levels.

Several declarations profoundly influence accepted international approaches to

environmental management and sustainable development. Declarations are generally

not immediately legally binding, but can acquire the force of international customary

law if they continue to express an international consensus which states adhere to over

time. The key declaration that influences environmental management and sustainable

development is the 1992 Declaration on Environment and Development (or “Rio

Declaration). The Rio Declaration and Agenda 21, which were both products of the

1992 United Nations Conference on Environment and Development, effected the

introduction and/or revision of environmental legislation in countries throughout the

world resulting in the EIA process becoming established as a key tool for

environmental decision making. According to the United Nations Environment

Programme or UNEP (UNEP 2005), many of the Rio Declaration principles are

acquiring the force of international customary law, including: transparency, public

participation and access to information and remedies; precaution, prevention of

environmental harm and polluter pays principles; and good governance.




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Important international environmental treaties that have been signed by Pakistan and

may have relevance to the Project are listed in Exhibit 2.5. They concern: climate

change and depletion of the ozone layer; biological diversity and trade in wild flora

and fauna; desertification; waste and pollution; and cultural heritage.

Exhibit 2.5: International Environmental Treaties Endorsed by Pakistan

Topic Convention Date of Treaty

Entry into force in

Pakistan

Climate change and the ozone layer

United Nations Framework Convention on Climate Change - the primary objective is the stabilization of greenhouse gas concentrations in the atmosphere at a level that would prevent dangerous anthropogenic interference with the climate system.

1992 1994

Kyoto Protocol to the United Nations Framework Convention on Climate Change - enabled by the above Convention on Climate Change. It has more powerful and legally binding measures. It sets binding targets for 37 industrialized countries and the European community for reducing greenhouse gas emissions.

1997 2005

Vienna Convention for the Protection of the Ozone Layer - acts as a framework for the international efforts to protect the ozone layer with a primary objective to protect human health and the environment against adverse effects resulting from human activities that modify or are likely to modify the ozone layer.

1985 1993

International Convention on Oil Pollution Preparedness, Response and Co-operation

1990 1995

Stockholm Convention on Persistent Organic Pollutants - seeks to protect human health and the environment from Persistent Organic Pollutants, which are chemicals that remain intact in the environment for long periods, become widely distributed geographically and accumulate in the fatty tissue of humans and wildlife.

2001 2008

Desertification International Convention to Combat Desertification – with an objective to combat desertification and mitigate the effects of drought. It is supported by international cooperation and partnership arrangements, with the aim of achieving sustainable use of land and water resources and sustainable development in affected areas.

1994 1997




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Topic Convention Date of Treaty

Entry into force in

Pakistan

Biodiversity and the protection of plants and animals

Convention on Biological Diversity – covering ecosystems, species, genetic resources and the field of biotechnology. The objectives are:

conserve of biological diversity;

sustainable use of its components; and

fair and equitable sharing of benefits arising from genetic resources.

1992 1994

Bonn Convention on the Conservation of Migratory Species of Wild Animals - aims to conserve terrestrial, marine and avian migratory species throughout their range. It is concerned with the conservation of wildlife and habitats on a global scale.

1979 1987

Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) - to ensure that international trade in specimens of wild animals and plants does not threaten their survival.

1973 1976

Convention on Wetlands of International Importance especially as Waterfowl Habitat and associated protocols and amendments - to promote conservation and sustainable use of wetlands. The Ramsar List of Wetlands of International Importance now includes almost 1,800 sites (known as Ramsar Sites). There are currently 19 Ramsar sites in Pakistan.

1971 (amended 1987)

1976 (amended 1994)

2.4 IFC Environmental Guidelines and Standards

The EIA process for this Project follows IFC guidelines recommended in the Procedure

for Environmental and Social Review of Projects and those stipulated in the IFC PSs. The

environmental performance of the Project will comply with the IFC General EHS

Guidelines and the IFC EHS Guidelines for Thermal Power Plants.

2.4.1 Project Categorization

IFC’s Procedure for Environmental and Social Review of Projects5 uses three categories

to define a project—A, B, and C—for the purpose of determining the required depth of

the Project’s environmental assessment. These categories are:

Category A: Business activities with potential significant adverse environmental

or social risks and/or impacts that is diverse, irreversible, or unprecedented.

Category B: Business activities with potential limited adverse environmental or

social risks and/or impacts that are few in number, generally site-specific, largely

reversible, and readily addressed through mitigation measures. 5 IFC Environmental and Social Review Procedures. Washington, D.C.: International Finance Corporation,

2009.




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Category C: Business activities with minimal or no adverse environmental or

social risks and/or impacts.

Based on the environmental and social review summaries and summaries of project

information of natural-gas thermal power plants available on the IFC website6, the

proposed Project will be categorized as a Category A project for the purpose of this

study.

Results from the IFC summaries indicated that new natural gas thermal power plants with

installed capacities above 200 MW were mostly categorized as Category A projects.

Category B projects, on the other hand, included new natural gas thermal power plants

below 200 MW and upgrades to existing natural gas power plants to increase installed

capacities by improving plant efficiency, for example, by adding combined-cycle

capability.7

According to IFC guidelines, the environmental assessment for a Category A project

should examine the project’s potential positive and negative impacts, compare them with

those of feasible alternatives (including the “without project” scenario), and recommend

any measures needed to prevent, minimize, mitigate, or compensate for adverse impacts

and to improve performance. For a Category A project, the project sponsor is responsible

for preparing a full report, normally an EIA and for preparing and updating an

Environmental Action Plan (EAP).8

6 "IFC Projects Database." Search IFC Project. Accessed April 3, 2015.

http://ifcextapps.ifc.org/ifcext/spiwebsite1.nsf/$$Search?openform 7 A list of natural gas thermal power plants in IFC’s project summaries included projects developed in the

years 2013 and 2014. Examples of some of the Category A and Category B projects were as follows:

Category A Projects:

Expansion of the existing Kribi power plant in Cameroon from 216 MW (13 natural gas-fired reciprocating engines) to a total of 330MW, by adding 7 engines of the same type equivalent to 114 MW.

A greenfield 341 MW gas based combined cycle power project located at Bibiyana in the Habiganj district in Bangladesh.

Development, design, financing, construction, testing, commissioning, ownership and operation of a 1,260MW green-field natural gas fired independent power plant near Zakho in the Dohuk, Kurdistan, in Iraq.

Category B Projects:

Design, construction, ownership, operation and maintenance of a new 175 MW (gross) gas-fired power plant by Central Termica de Ressano Garcia in Mozambique

Development of a 108 MW gas fired power plant by Regent Energy and Power Limited in Ghorashal, Bangladesh

Expansion of the existing CIPREL natural gas-fired power plant in Côte d’Ivoire by adding 111MW steam cycle capacity to 2 x 111MW open cycle gas turbines, converting them into a combined cycle operation, and (ii) the retrofitting of two gas turbines to Dry Low NOx technology for NOx emissions reduction. The project is expected to enhance the efficiency of the power plant by generating 25.5% more power without the use of any additional gas.

Combined cycle conversion of a gas-fired power plant owned and operated by Dominican Power Partners, LDC. The project will increase DPP’s generation capacity from 210MW to 324MW.

8 IFC Environmental and Social Review Procedures. Washington, D.C.: International Finance Corporation, 2009.




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2.4.2 IFC Performance Standards

The PSs are a part of IFC’s Sustainability Framework9 and have become globally

recognized as a benchmark for environmental and social risk management in the private

sector. In total, there are eight IFC PSs10 as follows:

Performance Standard 1: Assessment and Management of Environmental and

Social Risks and Impacts

Performance Standard 2: Labor and Working Conditions

Performance Standard 3: Resource Efficiency and Pollution Prevention

Performance Standard 4: Community Health, Safety, and Security

Performance Standard 5: Land Acquisition and Involuntary Resettlement

Performance Standard 6: Biodiversity Conservation and Sustainable

Management of Living Natural Resources

Performance Standard 7: Indigenous Peoples

Performance Standard 8: Cultural Heritage

IFC applies PSs to manage social and environmental risks and impacts of a proposed

Project and to enhance development opportunities in its private sector financing in its

member countries eligible for financing. Other financial institutions electing to apply

them to projects in emerging markets may also apply the PSs.

Paragraphs from the IFC PSs applicable to the EIA of the Project are summarized below:

Performance Standard 1 (Paragraph 7)

The risks and impacts identification process will be based on recent

environmental and social baseline data at an appropriate level of detail.

The process will consider all relevant environmental and social risks and impacts

of the project, including the issues identified in Performance Standards 2 through

8, and those who are likely to be affected by such risks and impacts.

The risks and impacts identification process will consider the emissions of

greenhouse gases, the relevant risks associated with a changing climate and the

adaptation opportunities, and potential trans-boundary effects, such as pollution of

air, or use or pollution of international waterways.

9 The Sustainability Framework articulates IFC's strategic commitment to sustainable development and is

an integral part of their approach to risk management. The Sustainability Framework helps IFC’s clients do business in a sustainable way. It promotes sound environmental and social practices, encourages transparency and accountability, and contributes to positive development impacts. Torrance, Michael. IFC Performance Standards on Environmental & Social Sustainability: A Guidebook. Markham, Ont.: LexisNexis, 2012.

10 International Finance Corporation. “Performance Standards on Environmental and Social Sustainability”

World Bank Group, Washington DC, January 2012. Web Link: http://www.ifc.org/wps/wcm/connect/115482804a0255db96fbffd1a5d13d27/PS_English_2012Full-Document.pdf?MOD=AJPERES

http://www.ifc.org/wps/wcm/connect/115482804a0255db96fbffd1a5d13d27/PS_English_2012Full-Document.pdf?MOD=AJPERES

http://www.ifc.org/wps/wcm/connect/115482804a0255db96fbffd1a5d13d27/PS_English_2012Full-Document.pdf?MOD=AJPERES




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Where the project involves specifically identified physical elements, aspects, and

facilities that are likely to generate impacts, environmental and social risks and

impacts will be identified in the context of the project’s area of influence. This

area of influence encompasses, as appropriate:

The area likely to be affected by: (i) the project and the client’s activities and

facilities that are directly owned, operated or managed (including by

contractors) and that are a component of the project; (ii) impacts from

unplanned but predictable developments caused by the project that may occur

later or at a different location; or (iii) indirect project impacts on biodiversity

or on ecosystem services upon which Affected Communities’ livelihoods are

dependent.

Associated facilities, which are facilities that are not funded as part of the

project and that would not have been constructed or expanded if the project

did not exist and without which the project would not be viable.

Cumulative impacts that result from the incremental impact, on areas or

resources used or directly impacted by the project, from other existing,

planned or reasonably defined developments at the time the risks and impacts

identification process is conducted.

Performance Standard 1(Guidance Note 38)

In certain instances, however, it may not be practical or appropriate for the

cumulative impact assessment (CIA) to be performed by the client or individual

project developers: for example

(i) impacts from multiple existing and future third party projects or

developments over a large area that may cross jurisdictional boundaries (e.g.,

watershed, airshed, forest),

(ii) effects that may have occurred or will occur over a longer period of time,

(iii) impacts on specific ecosystem components or characteristics that will

increase significance and/or irreversibility when evaluated in the context of a

series of existing or future third party projects or developments, and not just in

the context of effects associated with the project under review.

In those situations, where cumulative impacts are likely to occur from activities

by third parties in the region and the impacts from the client’s own operations are

expected to be a relatively small amount of the cumulative total, a regional or

sectoral assessment may be more appropriate than a CIA.


For projects that are expected to or currently produce more than 25,000 tonnes of

CO2-equivalent annually, the client will quantify direct emissions from the

facilities owned or controlled within the physical project boundary, as well as

indirect emissions associated with the off-site production of energy used by the

project. Quantification of GHG emissions will be conducted by the client




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annually in accordance with internationally recognized methodologies and good

practice

2.4.3 IFC Environmental, Health and Safety Guidelines

In addition to PSs, the IFC EHS Guidelines11 are technical reference documents with

general and industry-specific examples of Good International Industry Practice. The EHS

Guidelines contain the performance levels and measures that are generally considered to

be achievable in new facilities by existing technology at reasonable costs (please see

Exhibit 2.1, Exhibit 2.2 and Exhibit 2.3 for IFC limits on effluents and emissions).

Application of the EHS Guidelines to existing facilities may involve the establishment of

site-specific targets, based on environmental assessments and/or environmental audits as

appropriate, with an appropriate timetable for achieving them. The documents include

information relevant to combustion processes fueled by gaseous, liquid, and solid fossil

fuels and biomass and designed to deliver electrical or mechanical power, steam, heat, or

any combination of these. The complete set of IFC EHS Guidelines for thermal power

plants is provided in Appendix A.2.

11 International Finance Corporation. “Environmental, Health, and Safety General Guidelines”, World Bank

Group, Washington, DC, 2007.



Hagler Bailly Pakistan The Proposed Project Design

R5A05ENP: 09/29/15 3-1

3. The Proposed Project Design

The Project is a 450 MW RLNG-based CCPP with dual fuel gas turbines. Power

produced by the plant will be exported to the K-Electric grid via a power evacuation

point passing along the boundary limits of the Project-site. The general description and

basic parameters of the proposed Project are discussed in this section.

3.1 Project Location and Layout

The proposed Project is located within the eastern industrial zone of the PQA,

approximately, 45 km southeast of the Karachi city, on the northern bank of the Arabian

Sea. The geographical coordinates of the proposed Project-site are 67° 22' 41.18" E, 24°

47' 28.32" N. The Project will stretch over an area of 37 acres (15 hectares) in an empty

plot owned by EPL in the PQA eastern industrial zone.

Gharo Creek, located approximately 600 m to the south of the Project-site, flowing into

the Arabian Sea, will serve as the major source to fulfill the Project’s water requirements.

The PQA road runs along the southern edge of the Project and will be used for the

transportation of equipment, material and personnel to the Project-site.

EZ and EPCL are located to the west and immediately adjacent to the Project-site. LCP is

located at an approximate distance of 500 m to the east of the Project-site. Exhibit 3.1

illustrates the location of the proposed Project on a map.

A CTS, built by EETL, will be located outside the southwest corner of the EPCL facility.

The CTS is the point where incoming flow of natural gas from EETL to the Project-site

will be metered. Natural gas will be transported from the CTS to the Project-site via an

underground pipeline which will traverse along either outside the southern boundary wall

of the existing EPCL and EZ complex or outside the western and northern boundary wall

of the same complex. The Project layout is provided in Exhibit 3.2.




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Exhibit 3.1: Location of the Proposed Project




R5A05ENP: 09/29/15 3-3

Exhibit 3.2: Project Layout




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3.2 Combined Cycle Power Plant

The Project is based on a CCPP configuration which combines existing gas and steam

technologies into one unit, yielding significant improvements in thermal efficiency over

conventional steam driven power plants. In CCPP, the thermal efficiency is extended to

approximately 52–60 %, by piping the exhaust gas from the gas turbine into a heat

recovery steam generator. However, typically the heat recovered in this process is

sufficient to drive a steam turbine with an electrical output of approximately 45 % of the

gas turbine generator in case of large industrial gas turbine

The CCPP unit consists of an RLNG based system that feeds RLNG at the required

pressure and temperature to gas turbines connected with heat recovery steam generators

(HRSG) and steam turbines. Gas turbines used by the Project will comprise of either one

set of GE’s Industrial Frame Gas Turbine 9F.05 or one set of Siemens SGT5-4000F with

variable inlet guide vanes. Each of these are described in the sections below.

Exhaust from each gas turbine will flow to an HRSG configured with high, intermediate

and low pressure steam systems, including drum, superheater, reheater, and economizer

sections. Steam from the HRSGs will flow to a conventional steam turbine for power

generation. Induced draught cooling towers will be installed where the steam will be

condensed and recirculated into the HRSG. Evaporation losses at the cooling tower will

be made up by supplying water from the Gharo Creek using a300 mm diameter pipeline

with a length of 2.5 km.

A conceptual diagram of a CCPP is provided in Exhibit 3.3, whereas the plant layout is

provided in Exhibit 3.4.

Exhibit 3.3: Conceptual Process Flow Diagram of a CCPP

Source: http://www.tenaskawestmorelandproject.com

http://www.tenaskawestmorelandproject.com/




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Exhibit 3.4: RLNG CCPP Layout




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3.2.1 GE Industrial Frame Gas Turbine 9F.05

The Industrial gas turbine 9F.05 (see Exhibit 3.51) includes turbines with power

generation capacities varying between 293 to 299 MW, meeting customer demands for

clean, reliable, cost-effective power, when fuel costs are a critical consideration, the

9F.05 heavy-duty gas turbine provides our most advanced F-class technology for 50 Hz

applications. With combined-cycle efficiency at more than 60 percent, and with more

than 99 percent running reliability, this turbine is well suited for baseload, cogeneration,

and cycling applications. The basic parameters of the proposed turbine system are as

follows:

Unit Parameters

Simple cycle Net Output 299 MW

Heat Rate (net) 8810 Btu/KWh

Simple Cycle Efficiency (net) 38.7%

Exhaust Energy 1594 MMBTU/hr

Exhaust Temperature 642C

Combined Cycle Efficiency >59%

Exhibit 3.5: GE 9FA.05 Industrial Gas Turbine

3.2.2 Siemens SGT5-4000F Industrial Gas Turbine

The Siemens SGT5-4000F industrial gas turbines (see Exhibit 3.6) includes turbines with

power generation capacities varying between 295 to 307 MW. Siemens proven SGT5-

4000F gas turbine is characterized by high performance, low power generating costs,

long intervals between inspections and service-friendly design. Optimized flow and

cooling add up to the highest gas turbine efficiency levels and the most economical

power generation in combined-cycle applications. Its state-of-the-art technology is based

1 The photograph is taken from General Electric’s official website (https://www.ge-distributedpower.com)

https://www.ge-distributedpower.com/




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on proven design features. The basic parameters of the proposed industrial turbine

system are as follows:

Unit Parameters

Simple cycle Net Output 300 MW

Heat Rate (net) 8532 Btu/KWh

Simple Cycle Efficiency (net) 39.9%

Exhaust Mass Flow 1595 lb/sec

Exhaust Temperature 579 C

Combined Cycle Efficiency >58%

Exhibit 3.6: Siemens SGT5-4000F Industrial Gas Turbine

3.2.3 Heat Recovery Steam Generators

HRSG or heat recovery steam generator2 is a heat exchanger for recovering energy from

a hot gas stream. The HRSG is capable of producing steam which can be utilized in a

process like cogeneration or combined cycle steam turbines.

In CCPPs, the waste heat from the exhaust of the gas turbines, which is considered to be

a very desirable energy source, is recovered and utilized to rotate steam turbines. The

operation of HRSGs is cost-free as it utilizes waste heat and improves efficiency of the

power generation system. The major components of a HRSG include evaporators,

economizers, superheaters, reheaters, integral deaerators and preheaters. A diagram of a

typical combined cycle HRSG is provided in Exhibit 3.7.

2 The description of HRSG is taken from Industrial Application of Gas turbine Committee (IAGT). “Training Session 9:Cogeneration and Combined Cycle Principles Workshop, Introduction to HRSGs” 18th IAGT symposium, 2009.




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Exhibit 3.7: Combined Cycle Utility HRSG

Source: http://www.sapco.ae/

Evaporators

HRSG evaporator or boiler sections act to vaporize water and produce steam in one

component, like the kettle in the kitchen. A bank of finned tubes is extended through the

gas turbine’s exhaust gas path from a steam drum (top) to a lower (mud) drum. Boiler

feed water is carefully supplied at the appropriate pressure to the upper drum below the

water level, and circulates from the upper to lower drum by external down comers, and

from the lower drum back to the upper drum by convection within the finned tubes.

In evaporators, water vaporizes and boils at a constant temperature, known as the

saturation temperature, which is unique for every steam pressure. For multi-pressure

natural-circulation HRSGs, an evaporator is installed for each pressure level. The steam

and gas flow in HRSG evaporator is shown in Exhibit 3.8.

http://www.sapco.ae/




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Exhibit 3.8: HRSG Evaporator

Economizers

The gas temperature leaving an evaporator usually varies from 150–320 C°, depending

upon the steam pressure being produced. If no other heat transfer component is installed

downstream, this remaining energy is wasted. Accordingly, economizers are frequently

installed downstream (with respect to gas flow) of the associated evaporator, and lower

gas temperatures further, thus increasing heat recovery. Economizers are serpentine

finned-tube gas-to-water heat exchangers, and add sensible heat (preheat) to the feed

water, prior to its entry into the steam drum of the evaporator.

Instead of pinch point, the amount of surface area in an economizer is quantified by the

“approach temperature”, i.e. the difference between the feed water temperature leaving

the economizer, and the saturation temperature in the drum to which it is delivered. For

most HRSGs, it is desirable to maintain a discreet approach temperature under all

operating conditions. Typical approach temperatures lie approximately between

–4 to +4 C°. The feed water flow through an HRSG economizer is illustrated in

Exhibit 3.9.




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Exhibit 3.9: HRSG Economizer

Superheaters

While the evaporator produces dry-saturated steam, this is rarely acceptable for large

steam turbines, and is frequently not the appropriate condition for process applications. In

these cases, the saturated steam produced in the evaporator is sent to a separate serpentine

tubed heat exchanger referred to as a superheater, which is located upstream (with respect

to gas flow) of the associated evaporator. This component adds sensible heat to the dry

steam, superheating it beyond the saturation temperature.

The superheater can consist of either a single heat exchanger module or multiple heat

exchanger modules. The final steam outlet temperature will vary depending upon the gas

turbine exhaust and/or duct burner conditions, unless controlled.

For single modules, a temperature controlling de-superheater can be located outside the

HRSG, to adjust the final outlet temperature.

If two superheater modules are installed, the temperature controlling de-superheater is

generally mounted between the two discreet modules, i.e. inter-stage attemperation,

allowing more precise steam temperature control and eliminating the risk of having water

droplets enter the steam turbine. The flow of dry steam and superheated steam through a

superheater is illustrated in Exhibit 3.10.




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Exhibit 3.10: HRSG Superheater

Reheaters

Reheaters are a heat transfer component similar to superheaters, and are employed in

advanced multi-pressure power generation cycles. They accept superheated or semi-

saturated steam at a low pressure from a steam turbine after its first section of expansion,

and re-superheat or “reheat” the steam back towards the original superheater’s outlet

temperature. Accordingly, reheaters are generally interspersed among the superheater

sections in the HRSG, so that the same outlet temperatures can be achieved.

Integral Deaerators

All power plant cycles employ a deaerator to control oxygen levels in the feed water.

Heating steam is provided to strip oxygen from the condensate falling through the

pressurized deaerator’s tray systems. Normally, this deaerating steam is a parasitic loss

from such a cycle. In some HRSG’s, the deaerator can instead be mounted on the HRSG

in the final portions of its gas path, with a finned or bare tube bank extended into the gas

stream. The pegging steam is produced from the tube bank and provided directly to the

deaerator mounted above. The result is decreased stack temperature, i.e. improved heat

recovery, and decreased piping and equipment cost.

Preheaters

Typically, preheaters are located at the coolest end of the HRSG gas path, and absorb

energy from the gas stream to preheat liquids such as condensate, makeup water,

water/glycol mixtures or proprietary heat exchange fluids, e.g. Dowtherm. The most

common application is to preheat condensate prior to entry into the deaerator, which

reduces the amount of deaeration steam required.




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3.2.4 Steam Turbines

A steam turbine utilizes thermal energy from the pressurized steam produced by HRSG

system employed in a CCPP.3 The thermal energy from the steam is absorbed by the

rotors of a generator which in turn converts the thermal energy to mechanical energy

(steam driven rotary engine).

Steam turbine operation is based on Rankine Cycle––a process which describes how

steam operated heat engine generates power––with four key stages;

1. Pressurize

2. Heat

3. Expand

4. Condense

The HRSGs in the CCPP pressurize and heat steam, while turbines, on the other hand,

receive heat from the steam and make it expand and condense. Depending on the final

design configuration, the turbines may consist of High Pressure (HP), Intermediate

Pressure (IP) and Low Pressure (LP) turbines.

High Pressure (HP) Turbine: steam enters the HP turbines through nozzles, where

mechanical energy is generated by the steam passing over the series of fixed and rotating

blades. Fixed bales on the stator guide steam through the rotor blades, causing the rotor to

run. The steam here expands and cools as it passes over the blades.

Reheat: steam may then be sent to the HRSGs again through a dedicated reheat system.

This raises the temperature of the steam back to the inlet temperature without changing

its pressure. The steam is again directed to the intermediate pressure (IP) turbines through

nozzle.

IP Turbine: the reheated steam enters the IP turbine where from where it is directed

towards the low pressure (LP) turbine through a cross over pipe.

LP Turbines: steam from the cross over pipe enters the center of the LP turbine at a much

reduced pressure (as compared to steam entering HP turbine). Steam expands out in both

directions along the IP blades. By the last set of blades, the steam loses enough energy

that it is no longer superheated.

Condenser: the condenser rapidly cools the steam leaving the LP turbine. As the steam

condenses, it reduces it volume to a considerable range creating a vacuum. This vacuum

draws steam through the LP turbine, extracting more mechanical power.

Generator: the turbine extracts power simultaneously from HP, IP and LP rotors. The

shaft is coupled directly to the generator. This outputs three phase power to a step up

transformer transmitting electric power to the grid.

3 The functioning of the steam turbine is explained from Joshua Lowndes. “Steam Turbines Fundamental” Western Australia Power Industry, Perth, Australia.




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3.3 Gaseous Emission

The major source of air pollution during the operation phase of the Project will be

emissions from the HRSG and bypass stacks from the combustion of natural gas in the

combustion turbines. The main pollutant generated will be nitrogen oxide as nitrogen

dioxide (NO2).

The Project will produce more than 25,000 tons of CO2-equivalent annually. Therefore,

in compliance with the requirements of PS 3 Paragraphs 7 and 8, EPL will quantify direct

emissions from the facilities owned or controlled within the physical project boundary.

Quantification of GHG emissions will be conducted by EPL annually in accordance with

internationally recognized methodologies and good practice such as the estimation

methodologies provided by the Intergovernmental Panel on Climate Change.

3.4 Water Supply, Recirculating Cooling and Treatment System

The Project will comprise of a wet recirculating cooling water system with

mechanical/induced draught cooling towers utilizing sea water from the Gharo Creek.

The cooling water intake system and adopted treatment technologies are discussed in the

sections below.

3.4.1 Design Parameters of Water Supply System

The water supply system is designed to meet the CCPP cooling water; HRSG feed water

and miscellaneous water requirements. Some of the basic parameters of the water supply

system are:

Average ambient temperature of water 30 °C

Ambient minimum temperature of water 5 °C

Ambient maximum temperature of water 47.6 °C

Design cooling water (CW) temperature 30 °C

Total water intake rate 1,071 m3/hr




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For potable, service and other water uses 11 m3/hr

CW flow rate into cooling tower 1,005 m3/hr

CW temperature into cooling tower 41.3 °C

Air inlet wet bulb temperature 25.0 °C

Current approach temperature 5.6 °C

Current range temperature 10.8 °C

Cycles of concentration 4

Make-up water requirement 670 m3/hr

3.4.2 Water Supply System

A water intake system will be in place to meet the cooling water requirements, HRSG

make-up water requirements and water for construction and sanitary purposes of the

CCPP. The total water requirement of the power plant, will be 1,071 m3/hr including

670 m3/hr of make-up water. The water requirements will be fulfilled by extracting water

from Gharo Creek.

Raw water pre-treatment and desalination system will be employed to treat the extracted

sea water and then supplied as cooling water, HRSG makeup water and water for

miscellaneous uses in the CCPP.

Water intake and outfall structures will be constructed to facilitate the flow of raw water

to the plant and discharge effluents and thermal water back into the Gharo Creek.

The water balance flow diagrams for the Project is provided in Exhibit 3.11. The water

quality for available raw seawater determined in initial testing is provided in

Exhibit 3.12.




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Exhibit 3.11: Water Balance Diagram




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Exhibit 3.12: Quality of Seawater from the Gharo Creek

Parameter Seawater

pH 7.59

Total dissolved solvents (TDS) (mg/l) 42,575

Total suspended solids (mg/l) 19.868

Total Alkalinity (mg/l) 160.06

Chloride (mg/l) 22,989

Sulfate (mg/l) 2,949

Total hardness (mg/l) –

Methyl orange alkalinity (mg/l) –

Bacteria (cfu/ml) –

3.4.3 Cooling Water Intake and Wet Recirculating Cooling System

In wet recirculating systems the warm cooling water is typically pumped from the

condenser to a cooling tower, which uses air to dissipate the heat directly to ambient air

by evaporation of the water and heating the air. The cooled water is then recycled back to

the condenser.

Because of evaporative losses, a portion of the cooling water needs to be discharged from

the system––known as blowdown–– to prevent the buildup of minerals and sediment in

the water that could adversely affect performance. For a wet recirculating system, only

makeup water needs to be withdrawn from the local water body to replace water lost

through evaporation and blow down. As a result, plants equipped with wet recirculating

systems have relatively low water use, but high water consumption, compared to once

through systems.

The proposed Project will employ mechanical draught cooling towers which rely on

motorized fans to draw air through the tower structure and into contact with the water.

The water intake system will extract sea water from Gharo Creek at a flow rate of

1,071 m3/hr using a 2.5 km long intake pipe with a diameter of 300 mm and a water

intake velocity of 2.9 m/s. The intake pipe will be laid 2.5 m below the surface when on

PQA land and will rest on the creek floor once inside the Gharo Creek.

The seawater intake pipe will be equipped with both physical and chemical treatment

systems to prevent intake, entrapment and growth of aquatic flora and fauna at the mouth

of the opening of the pipe. The water pump house, located to the south of the main

building will be an open layout structure.

As per designed flow direction, the pump house will have steel gates, traveling vertical

trash rack and traveling screen to prevent flow of aquatic species and sediments into the

cooling water system. The distribution room and control room layout will be combined

with the circulating pump room with each circulating pump outlet equipped with a




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hydraulic valve to control water intake. The cooling water pumps would require 1000 kW

of power.

In order to prevent the water hammer effect4 during emergency power outages, the

cooling water intake system will be equipped with a hydraulic butterfly valve at each

cooling water pump. The valves will be installed to maintain the pressure at the outlet of

the valve at 0.6 Mega Pascal (MPa).

The traveling screens, employed to prevent the flow of aquatic species and sediments into

the cooling water system will be equipped with washing pumps. Three washing pumps

for six traveling screens will be installed. The washing pumps will operate automatically,

triggered by the difference in water levels between the screens. The trapped and washed

dirt accumulated by the combined action of traveling screens and washing pumps will be

removed manually. The design mesh size of this system will be 6.43 mm2.

The design parameters of the wash pump are as follows:

Capacity 120 m3/hr

Head 55 m

Motor power 30 kW

Voltage 380 v

The cooling water from the CW pump house will be supplied to the main power block

through a water supply pipeline with a diameter of 1.4 m and flow rate of 1.95 m/s.

3.4.4 Antisepsis Measures for Cooling Water System

To prevent the accumulation of salt and corrosion of electrical and civil structures from

the sea water, the following measures will be taken:

Trash rack antiseptic protection: an antiseptic protection coating will be applied to

the water intake pipeline. The water intake pipeline will be made of nickel-

chromium caste iron. Under maximum water level flow conditions, the antiseptic

coating and sacrifice anode catholic protection will be adopted to prevent

corrosion of the intake pipeline.

Traveling screen antiseptic protection: antiseptic coating will be applied on rail

and mesh. In addition, sacrificial-anode-cathode protection will also be employed

to protect traveling screens from corrosion.

Cooling water pump antisepsis measures: the pump will be encased in

ASTM A743 CF3MN grade stainless steel coating. The coating is well known for

its corrosion resistant properties and is widely utilized for the equipment prone to

high level corrosion.

The outlet pipe of cooling water pump, made of steel, will be coated with an

antiseptic material and employed with sacrificial-anode-cathode protection to

resist corrosion.

4 Water hammer (or, more generally, fluid hammer) is a pressure surge or wave caused when a fluid (usually a liquid but sometimes also a gas) in motion is forced to stop or change direction suddenly (momentum change).




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Hydraulic butterfly valve will be made up of nickel-chrome alloy caste and will

be coated by an antiseptic material to avoid corrosion.

Additional pumps and underground pipelines will also be coated with anti-

corrosion material to prevent corrosion.

3.4.5 Raw Water Treatment System

Raw water from the creek will pass through a set of filters and clarifiers to filter

suspended solids. The filtered raw water will serve as feed water for raw water

desalination system. Two clarifiers and filters each with the capacity to treat 350 m3/hr,

one concentration pool to store and treat 40 m3/hr of raw water and one dehydrator with a

design capacity 10 m3/hr will be employed in the system to pre-teat raw water before

feeding it to the raw water desalination system. Two 175 m3/hr raw water reverse

osmosis plants and two 225 m3/hr ultrafiltration units will be employed at the power plant

to filter and desalinize the extracted raw water.

The seawater reverse osmosis system (SWRO) (see Exhibit 3.11) is designed to

desalinize––remove salts and other minerals––from the raw water. The desalinized water

from SWRO will be supplied to the CCPP as cooling water for power plant operations,

boiler make up water and makeup water for industrial use and firefighting system. The

SWRO system through its reverse osmosis (RO) technology will desalinize the extracted

raw water.

The general description a RO process is provided below.

Reverse Osmosis Process Description5

In the RO process, water from a pressurized saline solution is separated from the

dissolved salts by flowing through a water-permeable membrane. The permeate (liquid

flowing through the membrane) is encouraged to flow through the membrane by the

pressure differential created between the pressurized feed water and the product water,

which is at near-atmospheric pressure. The remaining feed water continues through the

pressurized side of the reactor as brine.

In practice, the feed water is pumped into a closed container, against the membrane, to

pressurize it. As the product water passes through the membrane, the remaining feed

water and brine solution becomes more and more concentrated. To reduce the

concentration of dissolved salts remaining, a portion of this concentrated feed water-brine

solution is withdrawn from the container. Without this discharge, the concentration of

dissolved salts in the feed water would continue to increase, requiring ever increasing

energy inputs to overcome the naturally increased osmotic pressure.

A reverse osmosis system consists of four major components/processes which are

described below. The process flow diagram of the RO process is provided in

Exhibit 3.13.

5 International Environmental Technology Center. “Source Book of Alternative Technologies for Freshwater Augmentation in Latin America and Caribbean, Chapter 2.1: Desalination by Reverse Osmosis,”, United Nations Environmental Program in collaboration with Unit of Sustainable Development and Environment, General Secretariat, Organization of American States, Washington D.C., 1997.




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1. Pretreatment: The incoming feed water is pretreated to be compatible with the

membranes by removing suspended solids, adjusting the pH, and adding a

threshold inhibitor to control scaling caused by constituents such as calcium

sulfate.

2. Pressurization: The pump raises the pressure of the pretreated feed water to an

operating pressure appropriate for the membrane and the salinity of the feed

water.

3. Separation: The permeable membranes inhibit the passage of dissolved salts

while permitting the desalinated product water to pass through. Applying feed

water to the membrane assembly results in a freshwater product stream and a

concentrated brine reject stream. Because no membrane is perfect in its rejection

of dissolved salts, a small percentage of salt passes through the membrane and

remains in the product water. Reverse osmosis membranes come in a variety of

configurations. Two of the most popular are spiral wound and hollow fine fiber

membranes. They are generally made of cellulose acetate, aromatic polyamides,

or, nowadays, thin film polymer composites. Both types are used for brackish

water and raw water desalination, although the specific membrane and the

construction of the pressure vessel vary according to the different operating

pressures used for the two types of feed water.

4. Stabilization: The product water from the membrane assembly usually requires pH

adjustment and degasification before being transferred to the distribution system

for use as drinking water. The product passes through an aeration column in

which the pH is elevated from a value of approximately 5 to a value close to 7. In

many cases, this water is discharged to a storage cistern for later use.

Exhibit 3.13: RO Process Flow Diagram




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3.4.6 HRSG Evaporator Feed Water System

The desalinized raw water will be supplied to the HRSG evaporator/boiler water reverse

osmosis (BWRO) system (see Exhibit 3.11). The treated evaporator feed water will pass

through a set of cation and anion exchangers to remove dissolved solvents in the raw

water. For further absorption of dissolved material, the water will be passed through a

mixed bed, from where it will be transferred and stored in demineralized water storage

tanks. The evaporator feed water treatment system will be designed to treat 57 m3 of

water per hour. The water, after treatment, will be transferred through the network of

water supply pipelines to different parts of the CCPP. The desalinized raw water will

have conductivity not more than 0.2 micro Siemens per centimeter (uS/cm) at 25 C° and

silica content not more than 20 ug/lit. The flow diagram presenting the treatment process

adopted to desalinize and demineralize raw water is provided in Exhibit 3.14.

Exhibit 3.14: Raw Water Treatment Process Flow

3.4.7 Chemical Dosing System

In order to maintain the pH of the water to prevent corrosion of the water supply and

treatment system and network, one ammonia dosing device will be employed. The

ammonia will be added in the raw water stored in two tanks, prior to its supply to the

main CCPP buildings. Five pH meters will be installed at different points on the route of

water intake and supply system to continuously monitor the pH of the raw water. In order

to remove the oxygen from the raw water, oxygen scavengers––a chemical substance




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added to the water to remove or deactivate dissolved oxygen––will be continuously fed to

the boiler feed water supply line. In addition to this, one phosphate dosing system and

five phosphate measuring meters will also be installed to continuously monitor dissolved

phosphates in the raw water.

A separate chemical dosing system for auxiliary boilers, with same specifications as

mentioned above, will be equipped to continuously monitor the quality of feed water

supplied to the auxiliary boilers. The chemical system will ensure the optimum values of

the dissolved oxygen and chemicals in the water to prevent corrosion.

Another centralized monitoring system to sample and analyze water and steam

temperature and pressure will be placed. This system will ensure the attainment of design

temperature and pressure of both steam and water before transferring it from high

temperature high pressure rack to low temperature low pressure rack. The cooling water

for the power plant will be supplied through the low temperature low pressure rack.

3.4.8 Service Water System

The service water requirements will be met by obtaining desalinated raw water from the

raw water desalination system. Service water pond will be constructed for the Project.

The water stored in the pond will not only meet service water requirements (sanitation

and washing), but will also provide water for the firefighting system.

The service water pond will have a design volume of 400 m3 (dimensions ‘L×W×H’ in

meters 16×8×3.5).

The water from the service pond will be supplied as gas turbine island wash water and for

miscellaneous purposes including vegetation and to the Project staff and firefighting

system via service water pump.

The design parameters of the service water pump are provided below:

Volume 1 m3/hr

Flow (discharge, Q) 25 m3/hr

Head (H) 50 m

Motor Power 15 kW

Voltage 380 v

3.4.9 Potable Water System

The potable water requirements will also be met through the desalinized raw water. The

potable water will be stored in potable water pond with the build volume of 200 m3. The

water will be supplied through a frequency conversion velocity modulation distribution

water system. This system will ensure to the supply of potable water at desired frequency

and velocity as and when required.

The system includes two main water pumps and one small capacity steady-pressure

pump. The three employed pumps works in vertical multistage configuration. The two

main water pumps have design discharge of 20 m3/hr while the small capacity steady-

pressure pump will facilitate discharge up to 5 m3/hr. The pumped water will be

transferred to the users with the help of a specially laid potable water supply pipeline

with the diameter of 5–10 m.




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3.4.10 Industrial and Oily Wastewater Treatment System

The industrial oily wastewater treatment system for the Project is designed to treat the

generated industrial and oily effluents produced from the Project. The wastewater will be

collected and stored in respective wastewater storage ponds. The storage ponds will be

equipped with pH meters to monitor the pH of the industrial and oily effluents.

The industrial wastewater, from storage pond, will be transferred to the coagulation tanks

and reaction tanks, from where the clarified and treated waste water will enter

neutralization basin. The waste water, from neutralization basin will be pumped via

clarified water pump to the reusable water pond or to the water outfall channel. The

sludge from the coagulation pond will be pumped to the dehydrator via sludge pump

from where it will be loaded on Lorries and transported outside the Project-site for

disposal. The treated industrial wastewater will be directed to the schedule pit through a

pipeline from where it will be discharged into the sea.

The oily wastewater effluent will be treated in an oily wastewater treatment plant from

where it will be transferred to the scheduled pit before being discharged into the sea.

The discharged industrial waste water will comply with NEQS and IFC EHS guidelines

for waste water effluents.

The discharged industrial waste water will have the following characteristics:

Volume 11 m3/hr

pH ranging between 6–9

SS ≤ 50 mg/l

Fe ≤ 1 mg/l

CODCr ≤ 150 mg/l

BOD5 ≤ 80 mg/l

3.4.11 Sewage Treatment System

The sanitary sewage water will be collected through the network of sewage pipelines

collecting sewage at various locations within the Project-site. The collected sewage will

be treated before being discharged to the Gharo Creek. The sewage treatment system will

have a design capacity of 3 m3/hr. The sewage treatment system will ensure that the

discharge effluents meet the NEQS and IFC EHS guidelines for the effluent discharge.

The expected effluent quality after treatment is provided below:

pH: between 6–9

CODcr: ≤ 150mg/L

Concentration of dissolved Iron: ≤ 1.0mg/L

BOD5: ≤ 80mg/L

Suspended Solids: ≤ 50mg/L

3.4.12 Brine Discharge

The brine generated from the desalination of sea water and wastewater from industrial

and oily wastewater treatment plants will be discharged into the sea through a pipeline




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from the scheduled pit. The total volume of the discharged wastewater will be

726.6 m3/hr including; 670 m3/hr brine from raw water treatment plant, 56.6 m3/hr from

industrial, potable and oily wastewater treatment plants.

Wastewater will be discharged through an effluent channel into the Badal Nullah.

Exhibit 3.2 illustrates two possible routes of the effluent channel from the Plant-site to

the Badal Nullah. EPL will put up warning signs in Urdu and English along a section of

the Badal Nullah to prevent accidental use of the effluent water.

3.5 Power Evacuation

The proposed RLNG CCPP is designed to generate450 MW of electric power. The

generated power will be transmitted to the K-Electric grid through a 220 kV switch yard

within the plant. Two 220 kV transmission towers will be constructed by K-Electric

outside the Project-site (Exhibit 3.15). The maximum transmission capacity of the

transmission lines will be between 1500–1700 MVA at 40°C to minimize the

transmission loss. The electric power, through the national grid will then be dispatched to

designated load centers in the country.




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Exhibit 3.15: Location of K-Electric Transmission Towers outside the Project-site




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3.6 Project Staffing

The proposed Project will require significant workforce during its construction and

operation phases. Most of the labor including both skilled and unskilled personnel will be

required during the construction phase of the Project. However, operation phase of the

Project will offer a small number of unskilled employments.

Social augmentation is one of the Project’s focal rationales which will be pursued by

giving 60 percent jobs to the local communities, matching their education and skill level,

during construction phase of the Project. While during operation phase, which is

stretched over the lifecycle of the CCPP, the employment will be provided on merit.

Exhibit 3.16 provides the estimated figures for the workforce required construction and

operational stages of the project.

Exhibit 3.16: Project Staffing

Project Stage Skilled Labor (number of required persons)

Unskilled Labor (number of required persons)

Construction 600 1500

Operations 70 40



Hagler Bailly Pakistan Description of the Environment

R5A05ENP: 09/29/15 4-1

4. Description of the Environment

The existing physical, biological and socioeconomic conditions of the surrounding areas

of the Project are described in this section. This information was collected from field

surveys, previous EIAs conducted in the Project area and other published literature.


March 4–6, 2015. A socioeconomic baseline survey was undertaken by HBP’s social

team from March 13–16, 2015, which covered 16 settlements within a 10 km radius

around the Project-site.

Appropriate standard scientific methods were used for each component of the study and

are described in the sections covering the respective components. For all spatial

information, Global Positioning System (GPS) was used to mark the sampling sites. The

GPS data was then used to produce maps using geographical information system (GIS)

software.

Data regarding the existing soil and water quality, and the ecological resources of the

Gharo Creek was collected from recent EIAs conducted by HBP in the vicinity of the

Project-site including the EIA of Port Qasim Electric Power Company (PQEPC)

2×660 MW Coal Power Plant (CPP)1; the EIA for the replacement of four furnace oil-

fired boilers with coal-fired boilers at Karachi Electric (K–Electric) Power Station2 and

the EIA of a coal fired power plant at Fauji Fertilizer Bin Qasim Limited (FFBL) 3.

4.1 Study Area

The description of the environment in this section focuses on an area where potential

impacts from the Project are most likely to extend. The identification of this area was a

result of a desk-based screening study conducted early in the EIA process with the

objective of identifying potential impacts from the construction and operation of the

Project using available information on Project location and design. According to the

screening study, the spatial scale of the identified potential impacts would cover the

followings main geographical areas:

The Project-site and the industries in its immediate vicinity which may be affected

from noise, fugitive dust emissions and traffic during the construction of the

Project.

The airshed in and around the PQA where gaseous emissions from the Project

will have an impact on air quality when the Project becomes operational.

1 Hagler Bailly Pakistan (HBP), March 2014, Environmental Impact Assessment of PQEPC’s 2×660 MW

Coal Power Plant, Bin Qasim, Karachi, Port Qasim Electric Power Company, Karachi. 2 Hagler Bailly Pakistan (HBP). (2013), Environmental Impact Assessment of Bin Qasim Coal Conversion

Project, Islamabad. 3 Hagler Bailly Pakistan (HBP). (2014). EIA of CPP Project Bin Qasim Fertilizer Complex. Islamabad.




R5A05ENP: 09/29/15 4-2

The communities living in settlement immediately outside the PQA which may

find opportunities for gainful employment during the construction and operation

of the Project.

The coast south of the Project-site at the Gharo Creek where ecological resources

may be impacted from effluent discharge during the operation of the Project and

where any existing fishing activities may be hindered from the construction and

operation of the effluent outfall channels.

Therefore, the Study Area delineated to be the focus of physical, biological and

socioeconomic baseline information covers the following areas and is illustrated on a

map in Exhibit 4.1.

Area within a 10 km radius of the Project-site which covers the PQA and

settlements around it; and

The part of the shoreline south of the Project-site from PQ extending east of the

Project-site.




R5A05ENP: 09/29/15 4-3

Exhibit 4.1: The Study Area and existing Industries around the Project-Site




R5A05ENP: 09/29/15 4-4

4.2 Physical Baseline

4.2.1 Overview

The general topography of the proposed Project-site is flat and the land around the

Project is a designated industrial area. Pakistan Steel Mills (PSM) lies approximately

4 km northwest of the Project while the K-Electric Power Station is located to its

southwest. The EZ and EPCL are located immediately to the west of the Project-site

while the bulk of the remaining major industries in PQA are located towards the

northeast. Exhibit 4.1 illustrates the locations of the major industries in the vicinity of the

Project-site.

PQ is located at a distance of, approximately, 5 km west of the Project site. PQ was built

in 1980 and is operated by the PQA. Access from the sea is via a 45 km long channel

called Phitti Creek. The channel has been dredged to a depth of 14 meters. Initially, PQ

was constructed for PSM, located in close proximity to the port. Berths and terminals at

PQA are capable of receiving vessels of up to 75,000 Dead Weight Ton (DWT).

Presently there are 10 berths/terminals (including an Oil Terminal, Liquefied Petroleum

Gas (LPG) Terminal, Iron Ore/Coal Terminal, Container Terminal and Multi-purpose

terminals) at PQ with a total capacity of 33 million tons. There are 8 additional berths

planned for construction, increasing the port capacity to 83 million tons.

The business model of the PQA is based on attracting private sector investment for

development of its industrial zones by leasing and renting the land to the investors.

Electricity at the port is supplied by the Pakistan national grid system (supplied by K-

Electric) which is presently unable to meet the demands in Karachi resulting in frequent

power cuts.

Since the Project-site is located in an industrial zone, various types of vehicles can be

observed on the roads in the Study Area. Exhibit 4.2 lists the types of vehicles seen on

the roads near the Project-site. 4

Exhibit 4.2: Types of Vehicles Observed on Roads near the Project-Site

Class Types Included

Cars Sedans, coupes, and station wagons primarily used for carrying passengers. Includes both privately owned cars and taxis

Pickups Two-axle, 4-wheeled vehicles, other than passenger cars

Bikes Two wheeled vehicles

Buses Vehicles manufactured as traditional passenger-carrying buses with two axles and six wheels. Includes conventional buses as well as minibuses with seating capacity of 30 or more passengers

Trucks Vehicles on a single frame, having two to six axles , used for carrying goods (each axle type was separtely counted)

Tractor Tractors and tractor lorries

Other Three wheeled vehicles and animal drawn carts

4 Hagler Bailly Pakistan (HBP). (2013), Environmental Impact Assessment of Bin Qasim Coal Conversion

Project, Islamabad.




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4.2.2 Water Resources in the Study Area

The main surface-water resources in the vicinity of the Project are the creeks of the

Arabian Sea, namely, Gharo Creek, 600 m south of the Project-site. The Arabian Sea is

the only major surface water body in the region. It is bordered on the north by Pakistan

and Iran, on the west by the Arabian Peninsula, and on the east by the western coast of

India. Section 4.3.2 provides an overview of the creeks in the PQA and provides data on

the water and sediment quality of the Gharo Creek.

There is also a natural rainwater drain running approximately 1 km west of the Project-

site, Badal Nullah, which flows into the Gharo Creek from the north (Exhibit 4.3).

Exhibit 4.3: The Badal Nullah and Gharo Creek

The submerged coastline 600 m south of the Project-site overlooking Gharo Creek

Badal Nullah flowing 1 km west of the Project-site into the Gharo Creek

Badal Nullah flowing from the northerly direction

4.2.3 Climate

Climate is the average course or condition of the weather at a place usually over a period

of years as exhibited by temperature, wind velocity and precipitation. The climate at the

Study Area can be broadly categorized as having a hot and dry summer, and mild winter

with heavy, sporadic, rainfall during the monsoon season.

Broadly speaking, there are four seasons in Pakistan. These seasons are defined on the

basis of temperature and the changes associated with the monsoon season. The southwest




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monsoon is a wind system that prevails from April to October in the Indian Ocean, and is

characterized by a reversal in wind direction during the remaining months; and, heavy

rainfall over most of the Indian Subcontinent. Within Pakistan, considerable variation is

found in temperature and monsoonal changes. Thus, the specific characteristics and

duration of seasons depend on geographic location. The general characteristics of the

season near the Project-site and surrounding areas are described on the basis of the

weather station closest to it.

There is a weather station at Karachi Airport at 24°54'2.47"N 67°10'6.39"E,

approximately 25 km northwest of the plant site. The climatic description of the area

presented in this section is based on the 30-year climatic data of Karachi Airport weather

station from 1961 to 1990. The hottest months are between mid-March to June in which

the maximum average monthly temperature exceeds 40 °C. The winters are mild with

temperature dropping to 6 °C in January. Karachi receives approximately 217.3 mm of

rain annually. Almost 80 % of the rain is concentrated in the monsoon season.

The characteristic climatic feature of the four seasons of Karachi is presented in

Exhibit 4.4. Monthly temperature, rainfall and wind data are provided in Exhibit 4.5 to

Exhibit 4.7, whereas Exhibit 4.8 provides a wind rose of the Study Area based on the

weather data for 2011.5

Exhibit 4.4: Seasonal Characteristics of the Climate of Karachi

Season Temperature Rainfall Wind

Summer (Mid-March to Mid-June)

The summer is hot with temperature increasing from 26.2 °C in March, rising up to 40 °C in June.

There are less frequent rain showers in summer with no more than 1 or 2 rainy days in summer. Average total amount of rain in summer is around 10 mm

The wind speed in summer is variable. It is around 2.5 m/s in March and rises upto 18 m/s in April and drops to 4 m/s for the rest of the season. The direction mostly remains blowing from West

Monsoon (Mid-June to mid-September)

The temperature in monsoon remains high but relatively lower than summer and oscillates around 32 °C.

Almost 80 % of the yearly rain occurs in the monsoon with July and August being the wettest month.

The wind direction in the monsoon is mostly blowing from East.

Post-Monsoon Summer (Mid-September to November)

The average temperature post monsoon drops and average minimum temperature may reach 12 °C in November.

The post-monsoon period remains mostly dry and rainfall in November is around 1.8 mm.

The wind speed in September is around 3.7 m/s and drops to 1.4 m/s in November.

5 Meteorological data of the Study Area for the year 2011 was purchased from Lakes Environmental

(www.weblakes.com), a Canada based vendor, providing modeled meteorological data for any location in the world. This data was used for the dispersion modeling of the pollutants from the proposed Project for the EIA.

http://www.weblakes.com/




R5A05ENP: 09/29/15 4-7

Season Temperature Rainfall Wind

Winter (December to mid-March)

The winter is mild with January being the coolest month where average minimum temperature falls to 6 °C.

Like the other seasons, except monsoon, there is little occasional rainfall. The rainfall in winter is less than 50 mm.

The wind speed in the winter season increases from 1.4 m/s in December to 2.6 m/s in March. The wind direction for most part winter season is blowing from North-East and changes its course to blowing from West in early March

Exhibit 4.5: Average Temperatures (°C) Recorded by Karachi Airport

Meteorological Station

Month Mean of Monthly Highest Recorded* Lowest Recorded*

Maximum Minimum Value Date Value Date

Jan 29.1 6.1 32.8 16/1965 0 21/1934

Feb 32.0 7.7 35.0 29/1960 2 11/1950

Mar 36.1 12.2 39.0 26/1977 8 2/1939

Apr 40.1 17.7 44.0 16/1947 13 5/1940

May 41.5 22.2 48.0 9/1938 18 9/1960

Jun 40.1 25.4 47.0 18/1979 22 3/1940

Jul 37.5 25.0 42.0 3/1958 22 22/1938

Aug 35.5 23.9 41.7 9/1964 23 12/1933

Sep 37.4 22.7 43.0 30/1951 18 30/1950

Oct 39.3 16.1 43.0 1/1951 10 30/1949

Nov 35.6 11.2 38.5 1/1986 6 29/1938

Dec 31.0 6.8 33.9 8/1963 2 30/1932

Annual 36.3 16.4 48.0 9-May-38 0 21 JAN 34

* Highest and lowest recorded temperatures are based on data collected at the Karachi meteorological station since it was established in 1928 (Source: Pakistan Meteorological Department)




R5A05ENP: 09/29/15 4-8

Exhibit 4.6: Rainfall measured at Karachi Airport Meteorological Station

Month Mean Monthly (mm)

Wettest Month* Mean Number of Rainy Days

Value (mm) Year

Jan 6.0 66.8 1976 0.5

Feb 9.8 96.0 1979 0.6

Mar 11.7 130.0 1967 0.4

Apr 4.4 52.8 1935 0.3

May 0.0 33.3 1933 0.0

Jun 5.5 85.9 1936 0.7

Jul 85.5 429.3 1967 2.6

Aug 67.4 359.4 1944 2.5

Sep 19.9 315.7 1959 0.7

Oct 10.0 98.0 1956 0.1

Nov 1.8 83.1 1959 0.2

Dec 4.4 63.6 1980 0.7

Annual 217.3 745.5 1944 9.4

* Based on data collected at the Karachi station since it was established in 1928

** ‘Rainy day’ is defined as a day on which at least 0.1 mm of rain is recorded

Source: Pakistan Meteorological Department

Exhibit 4.7: Mean Wind in the Study Area

Month Wind Speed (m/s) Wind Direction (Blowing from)

Jan 1.5 NE

Feb 1.9 VRB

Mar 2.6 W

Apr 18.7 W

May 4.2 W

Jun 4.5 W

Jul 4.7 W

Aug 4.4 W

Sep 3.7 W

Oct 2.1 W

Nov 1.4 NE

Dec 1.4 NE

Year 3.0 W

* VRB: Variable

Source: Pakistan Meteorological Department




R5A05ENP: 09/29/15 4-9

Exhibit 4.8: Wind Rose of the Study Area for the Year 2011

Source: Climate data for 2011 purchased from Lakes Environmental (www.weblakes.com)

4.2.4 Air Quality

The Project-site is located in the PQA, with no sensitive receptors including settlements,

schools, hospitals and mosques in the vicinity. However, during office hours, industrial

personnel working in the PQA may be exposed to the gaseous emissions from the

proposed Project which may also extend to communities outside the PQA. The intensity

of the impact on air quality due to emissions from the Project is expected to decrease with

increasing distance from the Project-site. Therefore, analyzing the airshed within a

distance of 10 km from the Project-site will be sufficient to accurately assess the impact

on air quality in the PQA and the communities surrounding it.

http://www.weblakes.com/




R5A05ENP: 09/29/15 4-10

Existing Sources of Emissions in the PQA

There are numerous small and large stationary sources of gaseous emissions around the

Project-site as it is located in an industrial area. Some of the major stationary sources in

the PQA are listed in Exhibit 4.9 and are their locations are shown in Exhibit 4.10. The

industries are selected on the basis of their distance (<10 km) from the Project-site.

Emissions from these sources may consist of oxides of nitrogen (NOx), sulfur dioxide

(SO2) and particulate matter.

Exhibit 4.9: Major Sources of Air Emissions in the PQA around the Project-Site

Industries Approximate Distance from Project-site (kilometers, km)

Direction relative to Project-site

Engro Zarkhez 1 West

Engro Polymer 1 West

Lotte Pakistan 1 East

Linde Pakistan 1 East

ASG Metals Ltd. 1 Southeast

Geolinks Incineration Plant 2 Northeast

K-Electric Power Station 3 Southwest

Tuwairqi Steel Mills 3 West

Northwest Mineral 4 Northeast

Pakistan Steel Mills 4 Northwest

Kausar Ghee Mill 5 Northeast

Peki Cakes 5 Northeast

Fauji Fertilizer Bin Qasim Ltd. 5 Northeast

Wali Oil Mills Ltd. 6 Northeast

Rasul Floor Mills 6 Northeast

Exide Sulfuric Acid Plant 6 Northeast




R5A05ENP: 09/29/15 4-11

Exhibit 4.10: Location of Major Sources of Air Emissions around Project-Site




R5A05ENP: 09/29/15 4-12

Baseline Air Quality Data

Data on ambient air quality at the Project-site was collected using the following two

resources:

Primary data-collection by conducting an air quality survey at two sampling

points in the vicinity of the Project-site.

Collection of secondary data on ambient air quality from published EIA reports of

industrial developments in the vicinity of the Project-site. The published EIAs

include:

EIA of Bin Qasim Coal Conversion Project. Undertaken by Hagler Bailly

Pakistan in 2013 for K-Electric Karachi.

EIA of CPP Project for FFBL completed by Hagler Bailly Pakistan in 2013

for Fauji Fertilizer Bin Qasim Limited, Karachi.

EIA of PQEPC’s 2×660 MW CPP completed by Hagler Bailly Pakistan in

2014 for PQEPC, Karachi.

Primary Data Collection


March 4–6, 2015. The following pollutants were measured for 24 hours at two sites near

the Project-site by Pakistan Space and Upper Atmosphere Research Commission

(SUPARCO):

NOX

SO2

PM including Total Suspended Particles(TSP), PM10 and PM2.5

Ozone (O3)

CO

Exhibit 4.11 lists the names of the pollutants, the methodology followed for measuring

these and, the rationale for the selection of these particular pollutants. Exhibit 4.12

provides the details of these sampling locations and Exhibit 4.13 illustrates their location

on a map.




R5A05ENP: 09/29/15 4-13

Exhibit 4.11: Pollutants Sampled during Field Survey March 4–6, 2015

Pollutant Methodology Rationale for Selection

Oxides of Nitrogen (NO and NO2)

Measurement of NOx in the Atmosphere by Gas Phase Chemi-luminescence using NOx Analyzer.

To establish the baseline concentration of this pollutant and to predict the final concentration of these oxides in ambient air once the proposed Project is operational.

Sulfur Dioxide (SO2) Determination of SO2 in the Atmosphere by Fluorescence using SO2 Analyzer.

To establish the baseline concentration of the pollutant only. The proposed plant will have negligible emissions of SO2

once in operation.

Particulates (TSP, PM10 and PM2.5)

PM10 and PM2.5 measurement β Ray Absorption using Particulate Monitor,

To establish the baseline concentration only. The proposed plant will have negligible emissions of PM10 and PM2.5

once in operation.

Ozone (O3) Measurement of O3 by UV Spectroscopy using Ozone Analyzer

To establish the baseline concentration and to assess the impact of this pollutant on environment during operation phase of the proposed Project

Carbon monoxide (CO)

Measurement of CO by GFC Spectroscopy using CO Analyzer

To establish the baseline concentration only. The proposed plant will have negligible emissions of CO once in operation.

Exhibit 4.12: Description of Ambient Air Quality Sampling Locations

Sampling Site ID

Location Coordinates Rationale for Selection

ENPA1 Northeast corner of the Project-site

24°47'54.41" N

67°23'8.30" E

To assess the current air quality downwind of the Project-site where we expect to get maximum concentration as a result of emissions from the proposed Project.

ENPA2 5 km east of the Project-site

24°47'31.26" N

67°26'16.96" E

To assess the concentration of pollutants at a distance from the Project-site where the concentration of pollutants is less likely caused by other emission sources close to the Project-site.

Data from Secondary Sources

Ambient air-quality data at twelve more locations around the Project-site was collected

from published EIA reports prepared during the years from 2012 to 2014. These EIA

reports were prepared for three industrial developments in the PQA close to the Project-

site. Exhibit 4.14 lists these projects with the number and name of locations at which the

baseline data was collected. Exhibit 4.15 provides the locations of the sampling points on

a map.




R5A05ENP: 09/29/15 4-14

Exhibit 4.13: Sampling Locations on Map




R5A05ENP: 09/29/15 4-15

Exhibit 4.14: Baseline Air quality Data from Secondary Sources

Project Year Location ID Parameters measured Data Collected Using Sampling Period

Environmental Impact Assessment of Bin Qasim Coal Conversion Project6

2012 KBRA1 SO2 Passive Diffusion Tubes 4 weeks

KBRA2 SO2, NO, NO2, CO, PM10 and PM2.5

SUPARCO Mobile Lab and Passive Diffusion Tubes

24 hours (NOx, TSP, PM10 and PM2.5), 4 weeks (SO2,)

KBRA3 SO2 Passive Diffusion Tubes 4 weeks

KBRA4 SO2, NO, NO2, CO, PM10 and PM2.5

SUPARCO Mobile Lab and Passive Diffusion Tubes

24 hours (NOx, TSP, PM10 and PM2.5), 4 weeks (SO2,)

KBRA5

EIA of Coal Fired Power Plant, Fauji Fertilizer Bin Qasim Complex7

2013 FBEA1 SO2, NO, NO2, CO, PM10 and PM2.5,TSP

Passive Diffusion Tubes and Minvol Sampler

24 hours (PM10), 2 weeks (SO2, NOx)

FBEA2 SO2, NO, NO2, CO, and PM10

FBEA3 SO2, NO, NO2, CO, PM10 and PM2.5,TSP

EIA of PQEPC’s 2×660 MW Coal Power Plant, PQ Authority, Karachi8

2014 SCTA1, SCTA2, SCTA3, SCTA4

SO2, NO, NO2, CO, PM10 and PM2.5,TSP

SUPARCO Mobile Lab 24 hours

6 Hagler Bailly Pakistan (2013). Environmental Impact Assessment of Bin Qasim Coal Conversion Project. Karachi: K-Electric. 7 Hagler Bailly Pakistan (2013). Environmental Impact Assessment of CPP Project Bin Qasim Fertilizer Complex. Karachi: Fauji Fertilizer Bin Qasim Limited. 8 Hagler Bailly Pakistan (2014). EIA of PQEPC’s 2×660 MW Coal Power Plant, PQ Authority, Karachi, Karachi: Port Qasim Electric Power Company.




R5A05ENP: 09/29/15 4-16

Exhibit 4.15: Sampling Locations for Baseline Air quality Data from Secondary Sources




R5A05ENP: 09/29/15 4-17

Results

Primary Data Collected

A summary of the air quality results from the samples collected at two locations for the

proposed Project is provided in Exhibit 4.16. The detailed set of results can be found in

Appendix B.

Key observations for the two sampling locations are:

At sampling point ENPA1, located in northeast of the Project-site, the average


15.9 μg/m3, 12.1 μg/m3, 19.2 μg/m3, 1.5 mg/m3, 8.5 μg/m3, 310 μg/m3, 125 μg/m3

and 25.6 μg/m3 respectively. All values are within the limits prescribed by the

SEQS and EHS guidelines prescribed by IFC for 24-hour average time ambient

air quality concentrations.

At sampling point ENPA2, located 5 km east of the Project-site, the average


12 μg/m3, 7 μg/m3, 12 μg/m3, 1.1 mg/m3, 4.6 μg/m3, 232 μg/m3, 102 μg/m3 and

22.4 μg/m3 respectively. All values are within the limits prescribed by the SEQS

and EHS guidelines prescribed by IFC for 24-hour average time ambient air

quality concentrations.

Data from Secondary Sources

A summary of the information from the secondary sources is also provided in

Exhibit 4.16. All the values recorded at these sampling sites were within the limits

prescribed by the SEQS IFC EHS for 24-hour average time ambient air quality

concentrations.

Key observations at these sampling sites are as follow:

At sampling point SCTA1, the average ambient air concentrations of SO2, NO2,

NO, TSP, PM10 and PM2.5 are 16.0 μg/m3, 12.9 μg/m3, 8.9 μg/m3, 183 μg/m3,

80.4 μg/m3 and 18.6 μg/m3 respectively.

At sampling point SCTA2, northeast on PQ Road, the average ambient air

concentrations of SO2, NO2, NO, TSP, PM10 and PM2.5 are 11.8 μg/m3,

10.1 μg/m3, 6.1 μg/m3, 216.2 μg/m3, 88.9 μg/m3 and 20.8 μg/m3 respectively.

At sampling point SCTA3, near Arabian Sea Country Club, the average ambient

air concentrations of SO2, NO2, NO, TSP, PM10 and PM2.5 are 13.4 μg/m3,


At sampling point SCTA4, across the Pakistan still mills and the mosques,

northwest of Project site, the average ambient air concentrations of SO2, NO2,

NO, TSP, PM10 and PM2.5 are 11.8 μg/m3, 10.1 μg/m3, 6.1 μg/m3, 216.9 μg/m3,


At sampling point FBEA1 ambient air concentrations of SO2, NO2, NO and PM10

are 22.8 μg/m3, 20.2 μg/m3, 5.4 μg/m3 and 117.4 μg/m3 respectively.




R5A05ENP: 09/29/15 4-18

At sampling point FBEA2, near the Ghaghar Phattak Colony, ambient air

concentrations of SO2, NO2, NO, PM10, PM2.5 and TSP are 22.5 μg/m3,


At sampling point FBEA3, near the Arabian Sea Country Club, due west of the

Complex, ambient air concentrations for SO2, NO2, NO and PM10 are 12.2 μg/m3,

12 μg/m3, 9.7 μg/m3 and 122.6 μg/m3 respectively.

At sampling point KBRA1, the average ambient air concentrations of SO2 is

44.89 μg/m3

At sampling point KBRA2, the average ambient air concentrations of SO2, NO2,

NO, CO, PM10 and PM2.5 are 35.9 μg/m3, 13.8 μg/m3, 13.7 μg/m3, 3.9 mg/m3,


At sampling point KBRA3, the average ambient air concentrations of SO2 is

10.92 μg/m3


NO, CO, PM10 and PM2.5 are 26 μg/m3, 9.7 μg/m3, 9.6 μg/m3, 2.8 mg/m3,



NO, CO, PM10 and PM2.5 are 34.4 μg/m3, 14.1 μg/m3, 14.3 μg/m3, 3.2 mg/m3,


Exhibit 4.16: Summary of Air Quality Sampling Results

Sampling Location

ID

Sampling Year

SO2

(μg/m3) NO2

(μg/m3) NO

(μg/m3) TSP

(μg/m3) PM10

(μg/m3) PM2.5

(μg/m3) CO

(mg/m3) O3

(μg/m3)

ENPA1 2015 15.9 12.1 19.2 310 125 25.6 1.5 8.5

ENPA2 2015 12 7 12 232 102 22.4 1.1 4.6

SCTA1 2014 16 12.9 8.9 183 80.4 18.6 – –

SCTA2 2014 11.8 10.1 6.1 216.2 88.9 20.8 – –

SCTA3 2014 13.4 9.3 6.4 199.6 81.1 18.6 – –

SCTA4 2014 11.8 10.1 6.1 216.9 88.9 20.8 – –

FBEA1 2013 22.8 20.2 5.4 – 117.4 – – –

FBEA2 2013 22.5 18.4 11.1 236.1 142.5 69.4 – –

FBEA3 2013 12.2 12 9.7 – 122.6 – – –

KBRA1 2012 44.89 – – – – – – –

KBRA2 2012 35.9 13.8 13.7 – 120.8 43.3 3.9 –

KBRA3 2012 10.92 – – – – – – –

KBRA4 2012 26 9.7 9.6 – 83.7 32.2 2.8 –

KBRA5 2012 34.4 14.1 14.3 – 98.4 36.9 3.2 –




R5A05ENP: 09/29/15 4-19

Notes: “–“ indicates this parameter was not measured at given sampling location or that it is not applicable

for the given cell.

Conclusion

From the above results it can be concluded that, at all sampling points, the concentration

of pollutants is well below the limit prescribed by the SEQS IFC EHS Guidelines. The

overall average concentration of SO2, NO2, NO, CO, O3, TSP, PM10 and PM2.5 provided

in Exhibit 4.17 indicates that the ambient concentrations of all these pollutants during the

years from 2012 to present have been low.

Exhibit 4.17: Average Concentration of Pollutants around the Project Site

Year SO2

(μg/m3)

NO2

(μg/m3) NO

(μg/m3) TSP

(μg/m3) PM10

(μg/m3) PM2.5

(μg/m3) CO

(mg/m3) O3

(μg/m3)

2015 14.0 9.6 15.6 271.0 113.5 24.0 1.3 6.5

2014 13.3 10.6 6.9 203.9 84.8 19.7 – –

2013 19.2 16.9 8.7 236.1 127.5 69.4 – –

2012 30.4 12.5 12.5 – 101.0 37.5 3.3 –

Overall Average 19.2 12.4 10.9 237.0 106.7 37.6 2.3 –

SEQS (1-hour) – – – – – – 10 130

SEQS (8-hour9) – – – – – – 5 –

SEQS (24-hour10)

120 80 40 500 150 75 – –

SEQS (Annual) 80 40 40 360 120 40 – –

IFC EHS Guidelines (8-hour)

– – – – – – – 160

IFC EHS Guidelines (24-hour)

125 – – – 150 75 – –

IFC EHS Guidelines (Annual)

– 40 – – 70 35 – –

Notes: “–“ indicates no limit or that a guideline has not been prescribed for this parameter for the given

averaging period or the average could not be calculated for this pollutant.

4.3 Ecological Baseline

The Project-site is located in the PQA industrial estate which is on the northwestern edge

of the Indus delta system characterized by long and narrow creeks, mud flats and

mangroves plants (Exhibit 4.1). The Project will be constructed over an area of 33 acres 9 8 hourly values should be met 98 % of the year, 2 % of the time it may exceed but not on two

consecutive days 10 24 hourly values should be met 98 % of the year, 2 % of the time it may exceed but not on two

consecutive days




R5A05ENP: 09/29/15 4-20

(15 hectares) on a barren and empty plot of land. The plot is located in an industrial area

with two existing industries located to its east and west. All construction activities will be

carried out within the battery limits of the empty plot. Therefore, site clearance and

construction activities will not result in any immediate and direct modification of land or

loss of terrestrial habitat.

However, as described in Section 3 the intake channel will extend south from the Project-

site into the Gharo Creek. The site-clearing and construction works related to the

development of the channel may have an adverse impact on any marine species and

marine habitat present on the edge of the coast in the Gharo Creek. In addition, once the

Project becomes operational, effluent streams made up of discharge from the cooling-

water process and the RO treatment plant from the proposed Project will be discharged,

through the Badal Nullah, into the Gharo Creek (Section 3.4.12). This too, may have a

potential adverse impact on the marine ecological resources in the Gharo Creek.

Therefore, the focus of this section is to establish the marine ecological baseline of the

Gharo Creek in the vicinity of the proposed intake and outfall channels of the Project.

The baseline was developed to address the requirements of the Equator Principles11 ,

Safeguards Requirement (SR) 1 of Asian Development Banks’s (ADB) Safeguard Policy

Statement (SPS)12, and IFC PSs13.

Information for this section has been gathered from literature sources, particularly

scholarly articles, journals and recent ESIA reports of other industrial developments in

the vicinity of the Project. Due to the detail and reliability of the available secondary data

on marine ecological resources in the creek, the need to collect primary data did not arise

during the EIA of this Project. The following ESIA reports of recent projects in the PQA

area have been particularly useful.

Hagler Bailly Pakistan (HBP), March 2014, Environmental Impact Assessment of

PQEPC’s 2×660 MW Coal Power Plant, Bin Qasim, Karachi, PQEPC, Karachi.

Hagler Bailly Pakistan (HBP), February 2014, Environmental Impact Assessment

of Coal Power Plant (CPP) Project, Fauji Fertilizer Bin Qasim Complex, Fauji

Fertilizer Bin Qasim Limited (FFBL)

Hagler Bailly Pakistan (HBP) and Environmental Management Consultants,

September 2013, Environmental Impact Assessment of Bin Qasim Coal

Conversion Project, K-Energy (Pvt) Ltd.

4.3.1 Scope

The specific objectives of the ecological baseline study were as follows:

11 The Equator Principle. June 2006. Adopted by The Equator Principles Financial Institutions,

www.equator–principles.com, Accessed 11 October, 2011. 12 ADB’s 2009 Safeguard Policy Statement (SPS) – Safeguards Requirement (SR) 1 on Environment 13 Policy on Social and Environmental Sustainability, January 2012. Performance Standard 6: Biodiversity

Conservation and Sustainable Management of Living Natural Resources, International Finance Corporation. The World Bank Group.




R5A05ENP: 09/29/15 4-21

A review of the available literature on the coastal and marine biodiversity of the

Project site and vicinity including mangroves, mud flat habitats, marine invertebrate

species, coastal fish, marine turtles and marine mammals

A review of the available literature on the terrestrial biodiversity of the Project

site and vicinity including vegetation, mammals, herpeto-fauna and birds

Identification of key species and determination if there is any potential critical

habitat and ecosystem services in the Project site and vicinity.

4.3.2 Basis for Determination of Conservation Status of Species and Performance Standard for Preparation of the Baseline

The conservation status of the species identified were determined using criteria set by the

IUCN Red List of Threatened Species (IUCN Red List, 2014) 14 , Pakistan’s Mammals

National Red List 200615, the Convention on International Trade in Endangered Species

(CITES) appendices (as of March 2015)16. The baseline was developed to address the

requirements of the Equator Principles, SR 1 of ADB’s SPS, and IFC Performance

Standards.

Overview of Creeks in the Port Qasim Authority Area

The Indus River delta covers an area of about 600,000 hectares and is characterized by 16

major creeks and innumerable minor creeks, dominated by mud flats, and fringing

mangroves. The coastal morphology is characterized by a network of tidal creeks and a

number of small islands with sparse mangrove vegetation, mud banks, swamps, and

lagoons formed because of changes in river courses. The Gharo Phitti Creek System

consists of three creeks: Gharo Creek, Kadiro Creek and Phitti Creek. All three are

connected in a series starting from Gharo Creek at the north-eastern end to the Phitti

Creek at the south-western end. This creek system is about 28 km long and its width

ranges from 250 m to 2,500 m. The Korangi Creek, and Kadiro Creeks are connected

with it at the north-eastern end while it acts as the main waterway connected with the

open sea at the south-western end. The main channel of Port Bin Qasim lies in this creek

system, which has been dredged to maintain a navigable depth of -11.3 metres.

The tides at Port Qasim are predominantly semidiurnal with a substantial diurnal

component. At Gharo Creek tides fall down rapidly due to frictional effects and the

gradual weakening of the tidal forces. At Gharo Creek, 56 km from the Phitti Creek

entrance, the tides are almost half of the mean sea tides at the entrance. The Mean Higher

High Water (MHHW) to Mean Lower Low Water (MLLW) range is about 2.4 m at the

port complex while the peak tide over diurnal range is about 3.5 m. The flow pattern

within this large, relatively deep and generally stable creek system around Port Qasim is

strongly influenced by tides and the presence of extensive inter-tidal flats.

14 IUCN 2014. IUCN Red List of Threatened Species. Version 2014.3 <www.iucnredlist.org>.

Downloaded on 02 March 2015. 15 Status and Red List of Pakistan Mammals. 2006. Biodiversity Programme, IUCN Pakistan 16 UNEP–WCMC Species Database: CITES–Listed Species, Downloaded on 5 March 2015





R5A05ENP: 09/29/15 4-22

The currents in Gharo Creek show a well-defined ebb bias. In the channel, Ebb currents

of up to 2 m/s have been measured with corresponding flood currents of up to 1 m/s. The

strong current corresponds to the large volume of tidal flows.

The inner section of the creek is sheltered from the onslaught of high energy waves

during the south west monsoons (June, July and August). Strong tidal currents have been

observed during spring and neap tides. Seawater flows in the creek with velocities as high

as 2-3 m/sec during the flood and ebb tides. The sediments are subjected to coastal

dynamic processes, such as tides, winds, waves, and currents. This leads to accretion and

erosion of the Indus deltaic coast. The daily ebb and flow of water entering and leaving

the creek has an erosional effect on the sediment movement in the creek.

Destabilization of mangroves in the Indus Delta has been attributed to the progressive

reduction in fresh water discharge over a period of many years. Historical records

indicate that the distribution of mangroves in the Indus Delta has significantly changed

during the past several hundred years with the shifting pattern of the river.17 Until

recently the Indus River had a largely river-dominated estuary but increased utilization of

the river for agriculture etc. has resulted in discharge to the Arabian Sea only during the

summer southwest monsoon. During remaining nine to ten months the Indus River has no

estuary due to elimination of the river discharge.18 As a result, the mangrove ecosystem

has been adversely affected. The mangroves are degrading rapidly caused by a number of

factors such as cutting, browsing and by reduced silt laden river water. These forests

which covered 263,000 ha in 1977 have recessed to about 160,000 ha in 1990.19

Physio-Chemical Parameters of Major Creeks in PQA

Seawater parameters at different location in PQA are given in Exhibit 4.18. The surface

water temperature, salinity and density show some variation within the major creeks of

PQA. The annual seawater temperature ranges from 21.0 °C–25.0 °C. Water

temperatures in tidal channels in the Indus Delta creeks have been reported to be 19 °C in

January and 30 °C in June. Seawater salinity ranges from 33.4 – 39.2 parts per thousand

(ppt) (or Practical Salinity Units, PSU). Seawater density in the PQA creek system ranges

from 1.025 – 1.030 kg/m3.

17 Snedaker, S.C. 1984 Mangrove: A summary of Knowledge with emphasis on Pakistan. In Marine

Geology and Oceanography of Arabian Sea and coastal Pakistan Ed. B.U Haq and J.D Milliman Van Nostrand Reinhold Company Inc. NY. pp 255-262

18 Schubel,J.R. 1984 Estuarine circulation and sedimentation: an overview..Marine Geology and Oceanography of Arabian Sea and coastal Pakistan Ed. B.U Haq and J.D Milliman Van Nostrand Reinhold Company Inc. NY. pp113-136

19 Qureshi, T. 2005. Mangroves of Pakistan: status and management. IUCN. Pakistan.




R5A05ENP: 09/29/15 4-23

Exhibit 4.18: Annual Seawater Parameters in PQA Creeks

Seawater analysis was conducted in the subsurface water column in the Gharo Creek in

2014.20 The results of the seawater parameters analyzed are given in Exhibit 4.19.

Exhibit 4.19: Seawater Parameter in the Water Column

Seawater Parameters

LoR US EPA

Sampling Point 1

Sampling Point 2

Sampling Point 3

Sampling Point 4

Sampling Point 5

pH 0.1 7.49 7.52 7.60 7.66 7.69

TDS 10.0 mg/l 43,314 42,286 42,198 42,144 42,934

TSS 4.0 mg/l 24.67 15.67 21.00 16.00 22.00

Total Alkalinity (CO3, HCO3, OH)

4.0 mg/l 159.00 156.88 157.94 162.18 164.30

Chloride 5.0 mg/l 23,042 23,574 22,688 22,776 22,865

Sulfate 10.0 mg/l 2,850.87 3,155.38 2,779.68 3,000.25 2,961.56

Note:

TSS: Total Suspended Solids

TDS: Total Dissolved Solids

LOR: Level of Reporting

mg/l: Milligram Per Liter

The suspended matter in the creek areas has an annual range of 25–170 parts per million

(ppm). The higher values were observed during the southwest monsoon period (usually

May to August). The average suspended load during June-July was between 80–115 ppm.

However, higher values (115–170 ppm) were also recorded at some places in the


Coal Power Plant, Bin Qasim, Karachi, Port Qasim Electric Power Company, Karachi.

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Seawater Temperature, Salinity, Density in PQA Area

Sea water Temp Salinity ppt Density kg/m3

Data Source: NIO archives




R5A05ENP: 09/29/15 4-24

Gharo/Korangi Creek system. Lower suspended matter (25–50 ppm) was recorded during

March and the September-November period. The suspended load in these creeks also

exhibits variations with the degree of turbulence during a tidal cycle. During the flood

season in the Indus River (September) the suspended load rises to about 4,000 ppm in

Khobar Creek and to about 1,500 to 2,000 ppm in the adjacent creeks.

Heavy Metals in Sediment Substrate

Sampling to detect the presence of heavy metals in the sediment of the Gharo Creek was

conducted in 2014.21 Results of the laboratory analysis revealed the presence of a number

of heavy metals in the sediment samples analyzed. These include Copper, Iron, Nickel,

Lead, Zinc, Cadmium, Calcium, Lead, Arsenic, Nickel, and Chromium. Concentrations

of heavy metals observed in the sediments from the Gharo Creek are given in

Exhibit 4.20 and Exhibit 4.21. The levels of Cadmium, Copper, Lead, Nickel are on the

higher side compared to Sediment Quality Criteria in use around the world (Burton G.A

2002)22. Heavy metal concentrations of Zinc and Mercury in the sediment profiles are

relatively lower.

Calcium was the most abundantly seen heavy metal in the samples. Calcium is a naturally

occurring element and the fifth most abundant element in the earth's crust, It occurs as

limestone (CaCO3), gypsum (CaSO4.2H2O), and fluorite (CaF2). The existence of few

grains in sediments can change the percentage concentration of the Calcium in the

sediment samples.

Exhibit 4.20: Heavy Metal Concentrations in Sediments of the Gharo Creek

Sampling stations in the Gharo

Creek

Heavy Metal Concentration (mg/kg)

Cd Zn Cu Ca Pb As Se Sb Hg Ni Ag

St 1 0.327 44.674 48.622 227.238 14.405 2.837 2.613 0.027 0.201 25.689 0.115

St 2 0.542 34.117 43.922 417.852 22.618 8.604 5.822 0.043 0.235 44.615 0.287

St 3 1.405 39.646 16.044 207.28 21.254 9.611 6.401 0.066 0.24 41.668 0.624

St 4 0.241 52.061 43.002 315.43 16.824 4.197 3.475 0.041 0.223 48.575 0.248

St 5 0.661 36.817 41.602 340.87 21.273 7.814 6.287 0.032 0.118 39.244 0.28

Effect Low Range stds

NOAA (ERL) for metals (mg/kg)

1.2 150 34 NA 46.7 8.2 NA NA 0.15 20.9 NA


Coal Power Plant, Bin Qasim, Karachi, Port Qasim Electric Power Company, Karachi. 22 ELR = Effects Range Low NOAA22 Burton G.A 2002. Sediment quality criteria in use around the world.

The Japanese Society of Limnology 3: 65-75




R5A05ENP: 09/29/15 4-25

Exhibit 4.21: Heavy Metal Concentrations in Sediments of the Gharo Creek

Heavy Metal Analysis in Fish, Crab and Shrimp Tissues.

Fish tissue sampling to detect the presence of heavy metals in fish, cabs and shrimps in

the Gharo Creek was conducted in 2014.23 Results of fish tissue sampling are represented

in Exhibit 4.22.

Analysis of the edible tissues of fish, crab, and shrimp showed that Antimony, Cadmium,

Mercury, Nickel and Silver were below the Level of Reporting (<0.05 mg/kg). The

concentration of Arsenic was between 0.80 -3.55 mg/kg, the concentration of Copper was

between 1.21 - 41.0 mg/kg. Lead concentrations ranged between 0.09-0.24 mg/kg while

Zinc concentrations were between 11.3– 57.2 mg/kg. The levels of heavy metals

observed in the fish tissues and the maximum permissible levels prescribed by Food and

Agriculture Organization (FAO, 1983)24 for edible fish are given in Exhibit 4.23. For

almost all the metals, the results are below the limits prescribed.


Coal Power Plant, Bin Qasim, Karachi, Port Qasim Electric Power Company, Karachi. 24 FAO (Food and Agriculture Organization), 1983. Compilation of legal limits for hazardous substances in

fish and fishery products. FAO Fish Circ., 464:5-100.

0

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R5A05ENP: 09/29/15 4-26

Exhibit 4.22: Concentration of Heavy Metals Observed in the Edible Tissues of Fish,

Crab, and Shrimp

Exhibit 4.23: Concentration of Heavy Metals Observed in the Edible Tissues of Fish,

Crab, and Shrimp

Heavy metal Heavy Metals Observed (mg/kg)

Maximum Limit (mg/kg) prescribed by FAO, 1983 for fish and fishery products

Antimony <0.05 -

Cadmium <0.05 0.05 - 5.5

Mercury <0.05 mg/kg 0.5

Nickel <0.05 mg/kg 10

Silver <0.05 mg/kg -

Arsenic 0.80 -3.55 86

Copper 1.21 - 41.0 mg/kg 10 - 100

Lead 0.09-0.24 0.05 - 6

Zinc 11.3– 57.2 30 - 100

Selenium 0.1 – 0.76

Calcium 1860 – 10100

0

10

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60

70

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Heavy Metals in Fish, crab and shrimp tissues

Cynoglossus spp (sole fish) Sillago spp (Lady fish)

Terepon jarbua Portunus spp (crab)

Mugil spp (Mullets) Metapenaeus (shrimp)




R5A05ENP: 09/29/15 4-27

4.3.3 Ecological Resources in Project site and vicinity

According to the definition provided in IFC PSs 625, “modified habitats are areas that

may contain a large proportion of plant and/or animal species of non-native origin, and/or

where human activity has substantially modified an area’s primary ecological functions

and species composition. Modified habitats may include areas managed for agriculture,

forest plantations, reclaimed coastal zones, and reclaimed wetlands.” According to

ADB’s SPS – SR 1 on Environment26, a modified habitat is defined as “an area where the

natural habitat has apparently been altered, often through the introduction of alien species

of plants and animals, such as in agricultural areas.”

The Project site and vicinity lies in the PQA industrial area where there is a high level of

anthropogenic disturbance and the natural habitat has been substantially altered. It can

therefore be concluded that the Project lies in a ‘modified habitat’.

Mangrove habitat

The Project is located near PQ which is part of the Indus Delta. The Indus Delta supports

the seventh largest mangrove forest system in the world.27 In the Indus Delta mangrove

ecosystem, eight (8) species of mangroves have been reported out of 70 species known to

occur in the tropical forests of the world. The Avicennia marina is the dominant species

of the mangroves in the Indus Delta. All other species are rare and have disappeared from

most part of the Delta due to adverse environmental/ecological conditions.28 Out of 70

mangrove species worldwide 11 species (16 percent) have been placed on the IUCN Red

List.29 The Avicennia marina is the dominant species of the mangroves in the Indus

Delta. About 60 percent of the mangroves are over 3 m in height.30

Mangrove plantations enjoy a special legal status under the Forest Act of 1927. An area

of 344,870 ha of mangroves was transferred to the Sindh Forest Department (SFD) in the

year 1958 and declared “Protected Forest” under the Act. In 1973, an area of 64,400 ha

was transferred by SFD to PQA. However, the areas with PQA continue legally to be

“Protected Forests”.31

The most abundant mangrove species located along the southern edge of the Gharo Creek

is the Avicennia marina that grows on the tidal mudflats having high organic matter.

These mangrove trees are at a distance of approximately 2 km from the proposed location

of the intake and outfall channels.

25 Policy on Social and Environmental Sustainability, January 2012. Performance Standard 6: Biodiversity

Conservation and Sustainable Management of Living Natural Resources, International Finance Corporation. The World Bank Group.

26 ADB’s 2009 Safeguard Policy Statement (SPS) – Safeguards Requirement (SR) 1 on Environment 27 World Wide Fund for Nature- Pakistan, official website available at www.panda.org 28 Altaf A. Memon (May 14–19, 2005). "Devastation of the Indus River Delta". World Water &

Environmental Resources Congress 2005. Anchorage, Alaska: World Wide Fund for Nature. 29 The IUCN Red List of Threatened Species. Version 2014.3. <www.iucnredlist.org>. Downloaded on 02

March 2015 30 Amjad. S.,and Moin uddin Ali Khan. 2011. Marine Ecological Assessment for LNG Terminal at Port

Qasim. Pak.J.Eng.Technol.Sci Vol 1 No.2 pp 74-85 31 International Union for Conservation of Nature (IUCN) Pakistan. Mangroves of Pakistan–Status and

Management. IUCN, 2005.





R5A05ENP: 09/29/15 4-28

Conservation Status: The Avicennia marina is listed as Least Concern in the IUCN Red

List.32 However, the mangroves in PQA are included in the “Protected Forests” category.

Mudflats Habitats, Surface and Burrowing Animal Forms

Benthic community: This community includes the microbes: detritus feeders, small and

large herbivores, and small and large carnivores. In the mangrove ecosystem, the benthic

community of the adjacent shallow water is a subject of interest. Here, the microbes

decompose the plant litter into organic detritus - a fundamental commodity for the

transfer of energy from lower to higher trophic level.

Mudflat habitats: Coastal areas and the intertidal region is a complex area where the

division between land and sea is unclear. Coastal intertidal areas have a diverse range of

communities that inhabit muddy/clay shores. Patchy mangrove ecosystem supported the

epifaunal33 communities in the surveyed area.

At low tide, when a large part of muddy substrate is exposed, crabs, mudskippers and

birds are seen in large numbers picking up their food which includes worms and different

animals left behind and exposed by the receding tide.

Marine Invertebrate Species: The marine invertebrates play an important role in mixing

the organically enriched bottom sediments and are the key linkages in transferring the

energy from lower trophic level to the next higher trophic level in the food chain. The

marine invertebrate communities reported from the Project site and vicinity are

characteristic of fine sediments from muddy to clayey. Dominant communities reported

include Fiddler Crab Uca sp., Mud Skippers Boleophthalmus spp and Telescopium spp

assemblages as well as annelid (Polychaete) worms, bivalve mollusks, Pinnotherid crabs

and Cerithium sp (Exhibit 4.24).34 35 36

Conservation Status: None of the marine invertebrates species reported from the Project

site and vicinity are threatened or included in the IUCN Red List of Threatened Species.37

Moreover, their distribution is not limited to any specific site or habitat type, and their

distribution is widespread.

32 Duke, N., Kathiresan, K., Salmo III, S.G., Fernando, E.S., Peras, J.R., Sukardjo, S., Miyagi, T.,

Ellison, J., Koedam, N.E., Wang, Y., Primavera, J., Jin Eong, O., Wan-Hong Yong, J. & Ngoc Nam, V. 2010. Avicennia marina. The IUCN Red List of Threatened Species. Version 2014.3. <www.iucnredlist.org>. Downloaded on 02 March 2015.

33 Epifauna refers to benthic animals that live on the surface of a substrate, such as rocks, pilings, marine vegetation, or the sea or lake floor itself. Epifauna may attach themselves to such surfaces or range freely over them, as by crawling or swimming.

34 Hagler Bailly Pakistan (HBP), March 2014, Environmental Impact Assessment of PQEPC’s 2×660 MW Coal Power Plant, Bin Qasim, Karachi, Port Qasim Electric Power Company, Karachi.

35 Hagler Bailly Pakistan (HBP), February 2014, Environmental Impact Assessment of Coal Power Plant

(CPP) Project, Fauji Fertilizer Bin Qasim Complex, Fauji Fertilizer Bin Qasim Limited (FFBL) 36 Hagler Bailly Pakistan (HBP), September 2013, Environmental Impact Assessment of Bin Qasim Coal

Conversion Project, K Energy (PVT) Limited, Karachi.

37 The IUCN Red List of Threatened Species. Version 2014.3. <www.iucnredlist.org>. Downloaded on 02 March 2015






R5A05ENP: 09/29/15 4-29

Exhibit 4.24: Marine Invertebrate Species reported from the Gharo Creek

Fiddler Crab Uca spp. Fiddler Crab Uca spp

Mud Skippers Boleophthalmus spp Telescopium spp assemblages

Source: Hagler Bailly Pakistan (HBP), March 2014, Environmental Impact Assessment of PQEPC’s 2×660 MW Coal Power Plant, Bin Qasim, Karachi, Port Qasim Electric Power Company, Karachi.

Coastal Marine Fish Fauna

Over 180 species of fish have been reported from the Indus Delta.38 In Korangi Creek and

the adjoining creeks areas there are four types of fish groups: the permanent dwellers,

partial residents, tidal fish, and seasonal visitors in the mangrove habitat. Ahmed (1997)39

reported 98 species of fish from mangrove swamps of Korangi-Phitti creek system and

backwaters of Sandspit. Out of these 98 species, 46 species were fingerling or young

stages while 52 species were either sub-adult or adult. Common larvae of fishes described

for Korangi Creek and adjoining creeks in Indus Delta belong to the families Mugilidae,

Gerreidae, Clupeidae, Nemipteridae, Gobiidae, Sciaenidae, Engraulidae, Sillaginidae and

Lutjanidae.40

Many detritus feeders like clupeids, grey mullets and small carnivorous fish like silver

biddies and pony fish find these coastal habitats suitable for their living. Mudskippers are

adapted to live in the creek environment. Pleuronectiformes which represent bottom

living fish move towards this area for their food.

38 Amad (1988) ESIA of LNG terminal, Jetty and Extraction facility- Pakistan Dasport Limited 39 Ahmed, M., 1997. Natural and human threats to biodiversity in the marine ecosystem of coastal Pakistan.

In: Coastal zone management imperative for maritime developing nations (eds. B.U. Haq, S.M. Haq, G. Kullenberg and J.H. Stel), pp. 319-332. Kluwer Academic Publishers, Netherlands.

40 Ibid




R5A05ENP: 09/29/15 4-30

The abundance of fish fauna varies from season to season. There are a number of

settlements of fishermen along the creeks of Indus Delta which depend on the fisheries

resources of these creeks.

Benthic Fish Community

Benthic fish community includes detritus feeders, small and large herbivores, and small

and large carnivores. In the mangrove ecosystem, the benthic community of the adjacent

shallow water is a subject of interest. Here, the microbes decompose the plant litter into

organic detritus - a fundamental commodity of system energy. This detritus matter is

picked up by the detritus feeders over the bottom, such as fishes, shrimps and shellfish,

and then carried to the littoral zone by wave action, shared by the intertidal fauna such as

crabs, shrimps, mudskippers, and other invertebrates. Grey mullets, gizzard shads, flat

fishes, many skates and rays are some of the fish which prefer to live on soft bottom and

feed on bottom detritus. At low tide, when a large part of muddy bottom is exposed,

crabs, mudskippers and birds are seen in large numbers picking up their food which

includes worms and different animals left behind by the receding tide.

Pelagic Fish Community

This community includes powerful swimmers, which are exclusively carnivore in nature

like predaceous fishes, mullets, croakers, snappers, carangids breams, perches, and sea

snakes. In the mangrove ecosystem the predaceous fish forms are often small in size and

easily wander among the mangroves at high tide41. Subsistence fishing and recreational

fishing takes place in the vicinity of the Port Qasim Area (PQ Area) during ebb and flow

tides but commercial fishing is very limited. The local fishermen are engaged in catching

swimming crabs (Portunus pelagicus) and juvenile shrimps (Metapenaeus spp) from the

area (Exhibit 4.25). 42 Details of fishing activities in the Gharo Creek south of the

proposed Project-site are available in Section 4.4.6.

Artisanal Crab Fishery

Local fishing community members fish for mud crabs Scylla serrata during low tide. The

mud crab, burrows in mudflats in close proximity to the mangrove plantation. The locals

excavate the soft mud with bare hands or a hooked iron rod is used which is inserted into

the mud crab dwelling during the exposed mud flats at low tide. The crabs are caught

from their habitats and kept alive in moist gunny bags. The locals earn their livelihood

through the capture and sale of mud crabs.

Conservation Status: None of the fish or crab species reported off the coast of PQ Area

are threatened or included in the IUCN Red List.43

41 Bianchi, G. 1985. Field guide to the commercial marine and brackish-water species of Pakistan. FAO

species identification sheets for fishery purposes. FAO, Rome, Italy. 42 Hagler Bailly Pakistan (HBP), March 2014, Environmental Impact Assessment PQEPC’s 2×660 MW

Coal Power Plant, Bin Qasim, Karachi, Port Qasim Electric Power Company, Karachi. 43 The IUCN Red List of Threatened Species. Version 2014.3. <www.iucnredlist.org>. Downloaded on 02

March 2015





R5A05ENP: 09/29/15 4-31

Exhibit 4.25: Fishing in Port Qasim Area.

Portunus pelagicus Metapenaeus spp

Source: Hagler Bailly Pakistan (HBP), September 2013, Environmental Impact Assessment of Bin Qasim

Coal Conversion Project, K Energy (PVT) Limited, Karachi.

Marine Mammals and Turtles

Dolphins are marine mammals that have been sighted in the Indus deltaic region and in

the PQ Area. However, there is no published information available with regards to the

number of Cetaceans that visit the PQ Area. Marine mammals prefer the deep waters of

the ocean and are very rarely seen in the shallow waters of coastal areas.

Two turtle species have been reported from the marine waters off the coast of Sindh.

Olive Ridley Turtle Lepidochelys olivalea is listed as Vulnerable in the IUCN Red List44

and included in Appendix I of the CITES Species List45 while the Green Turtle Chelonia

mydas is listed as Endangered in the IUCN Red List 2014, and included in the

Appendix I of the CITES Species List.46 However, neither of these species has been

reported from the PQ Area and are not known to use the coast line south of the Project

site or vicinity for breeding or nesting. During ecological surveys conducted in the

Project vicinity in March 2014,47 48 the survey team did not find any turtles, turtle

remnants or turtle tracks on the muddy shores at the locations sampled. No turtle nest was

observed. This is because turtles prefer sandy beach substrates instead of muddy

substrates found near the Project-site.

Conservation Status: No threatened marine mammal or turtle species has been reported

from the coastal areas in Project-site and vicinity.49


March 2015 45 UNEP-WCMC Species Database: CITES-Listed Species, Downloaded on 05 March 2015 46 Ibid 47 Hagler Bailly Pakistan (HBP), March 2014, Environmental Impact Assessment of PQEPC’s 2×660 MW

Coal Power Plant, Bin Qasim, Karachi, Port Qasim Electric Power Company, Karachi. 48 Hagler Bailly Pakistan (HBP), February 2014, Environmental Impact Assessment of Coal Power Plant

(CPP) Project, Fauji Fertilizer Bin Qasim Complex, Fauji Fertilizer Bin Qasim Limited (FFBL)







R5A05ENP: 09/29/15 4-32

Terrestrial Vegetation

The Project-site is located in a barren and dry plain land. Plant species reported from the

vicinity of the Project-site includes Mesquite Prosopis juliflora, Milk Hedge Euphorbia

caducifolia, Indian Milkweed Calotropis procera and Caper Bush Capparis deciduas

(Exhibit 4.26).50 The most abundant among these, Mesquite Prosopis juliflora is an alien

invasive species and is harvested by the locals and sold in the local timber market for fire

food and construction of local huts. Locals graze their camels on Mesquite Prosopis

juliflora.

Exhibit 4.26: Vegetation Species observed in Port Qasim Area

Xerophytic vegetation Indian milkweed Calotropis procera

Mesquite Prosopis juliflora Harvest of Mesquite Prosopis juliflora by locals

Source: Hagler Bailly Pakistan (HBP), March 2014, Environmental Impact Assessment of PQEPC’s 2×660 MW Coal Power Plant, Bin Qasim, Karachi, Port Qasim Electric Power Company, Karachi

Conservation Status: No threatened or endemic terretsrial plant species has been

reported from the Project-site and vicinity. In addition, their distribution is not limited to

any specific site or habitat type, and their distribution is widespread.






R5A05ENP: 09/29/15 4-33

Terrestrial Mammals

The carnivorous large mammal species reported from the PQ Area are Jackal Canis

aureus and Fox Vulpes vulpes. Jackal Canis aureus is a very adaptable animal. It is

included in Appendix III of the CITES Species List51 and listed as Near Threatened in

Pakistan Mammals National Red List 200652. Fox Vulpes vulpes is placed in Appendix III

of the CITES List and listed as Near Threatened in the Pakistan’s Mammals National Red

List 2006. However both these species are listed as Least Concern in the IUCN Red

List.53

Locals report occasional sightings of wolf, hyena and wild boars. Small mammals such as

rodents, hares, squirrels have also been reported from the area.54

Conservation Status: None of the mammals reported from Project site and vicinity are

threatened or included in IUCN Red List.55 Even though some mammals are included in

the Pakistan’s Mammals National Red List 56 and CITES Species List,57 none of the

mammal species is endemic, their distribution is not limited to any specific site or habitat

type, and their distribution is widespread.

Avifauna

Both water and land birds are reported from the PQ Area. Most of these birds are

omnivores while others scavenge on marine crabs and dead fish.

During a survey carried out in March 201458, approximately 1 km from the Project-site

(GPS co-ordinates: Latitude: 24°47'21.69"N and Longitude: 67°21'57.06"E) common

bird species observed included Little Cormorant Phalacrocorax niger, Grey Heron Ardea

cinerea, Indian Pond Heron Ardeola grayii, Great Egret Casmerodius albus, Little Egret

Egretta garzetta, Common Myna Acridotheres tristis, Indian Robin Saxicoloides

fulicatus, House Sparrow Passer domesticus and House Crow Corvus splendens

Information about the endemic and migratory birds of Indus Delta is given below.

Endemic Birds of Indus Delta

The mangroves of the Indus Delta provide abundant food and shelter to a number of

endemic species of birds. The common birds are Oystercatcher Haematopus ostralegus,

Lesser Sand Plover Charadrius mongolus, Greater Sand Plover Charadrius leschenaultii,

Grey Plover Pluvialis squatarola, Golden Plover Pluvialis apricaria, Little Ringed

Plover Charadrius dubius, Kentish Plover Charadrius alexandrinus, Sanderling Calidris 51 UNEP-WCMC. 02 March 2015. UNEP-WCMC Species Database: CITES-Listed Species 52 Status and Red List of Pakistan Mammals. 2006. Biodiversity Programme IUCN Pakistan


54 Hagler Bailly Pakistan (HBP), March 2014, Environmental Impact Assessment of PQEPC’s 2×660 MW Coal Power Plant, Bin Qasim, Karachi, Port Qasim Electric Power Company, Karachi.


56 Status and Red List of Pakistan Mammals. 2006. Biodiversity Programme IUCN Pakistan 57 UNEP-WCMC. 02 March 2015. UNEP-WCMC Species Database: CITES-Listed Species 58 Hagler Bailly Pakistan (HBP), March 2014, Environmental Impact Assessment of PQEPC’s 2×660 MW


http://en.wikipedia.org/wiki/Charadrius


http://en.wikipedia.org/wiki/Pluvialis

http://en.wikipedia.org/wiki/Pluvialis



http://en.wikipedia.org/wiki/Calidris






R5A05ENP: 09/29/15 4-34

alba, Dunlin Calidris alpina, Curlew Numenius arquata , Whimbrel Numenius phaeopus,

Marsh Sandpiper Tringa stagnatilis and Common Sandpiper Actitis hypoleucos.

Breeding activities of a number of endemic birds have been reported in the coastal

wetlands of the Delta particularly Little Tern Sterna albifrons, Common Tern Sterna

hirundo, Gullbilled Tern Gelochelidon nilotica, Yellow legged Gull Larus michahellis,

Lesser Black backed Gull Larus fuscus and Great Black headed Gull Ichthyaetus

ichthyaetus.

Migratory Birds of Indus Delta

Pakistan is host to a large number of guest birds from Europe, Central Asian States and

India every year. These birds originally reside in the northern states and spend winters in

various wetlands and deserts of Pakistan from the high Himalayas to coastal mangroves

and mud flats in the Indus delta. After the winter season, they go back to their native

habitats.

This famous route from Siberia to various destinations in Pakistan over Karakorum,

Hindu Kush, and Suleiman Ranges along Indus River down to the delta is known as

International Migratory Bird Route Number 4. It is also known as the Green Route or,

more commonly, as the Indus Flyway and is one of the important migratory routes in the

Central Asian - Indian Flyway 59 (Exhibit 4.27). The birds start on this route in

November. February is the peak time and by March they start flying back home. These

periods may vary depending upon weather conditions in Siberia and/or Pakistan. As per

an estimate based on regular counts at different Pakistani wetlands, between 700,000 and

1,200,000 birds arrive in Pakistan through Indus Flyway every year60. Some of these

birds stay in the lakes but majority migrate to coastal areas.

The common migratory waterfowl of the lakes in the Indus Delta include a variety of

ducks including Dunlin Calidris alpina, Redshank Tringa totanus, Coot Fulica atra,

White Pelicans Pelecanus onocrotalus, Flamingoes Phoenicopterus minor and Spoonbills

Platalea leucorodia. The Indus Delta also provides refuge for the rare species of birds

such as Painted Stork Mycteria leucocephala , White Stork Ciconia ciconia, Greater Knot

Calidris tenuirostris , Crane Grus grus, Ruddy Shelduck (Surkhab) Tadorna ferruginea,

Greyleg Geese Anser anser, Common Shelduck Tadorna tadorma and Marbled teal

Marmaronetta angustirostris.

Conservation Status: Among the birds of the Indus River Delta, Flamingoes

Phoenicopterus minor and Painted Stork Mycteria leucocephala are listed as Near

Threatened while Greater Knot Calidris tenuirostris and Marbled Teal Marmaronetta

angustirostris are listed as Vulnerable in IUCN Red List.61 The Flamingoes

Phoenicopterus minor is also included in CITES Appendix II.

59 Convention on the Conservation of Migratory Species. 1 February 2006. Central Asian Flyway Action

Plan for the Conservation of Migratory Waterbirds and their Habitats. New Delhi, 10-12 June 2005: UNEP/CMS Secretariat.

60 Pakistan Wetlands Programme. 2012. Migratory Birds Census Report.


http://en.wikipedia.org/wiki/Calidrid

http://en.wikipedia.org/wiki/Curlew

http://en.wikipedia.org/wiki/Curlew

http://en.wikipedia.org/wiki/Tringa

http://en.wikipedia.org/wiki/Actitis

http://en.wikipedia.org/wiki/Sterna

http://en.wikipedia.org/wiki/Sterna

http://en.wikipedia.org/wiki/Larus

http://en.wikipedia.org/wiki/Larus

http://en.wikipedia.org/wiki/Ichthyaetus


http://en.wikipedia.org/wiki/Tringa

http://en.wikipedia.org/wiki/Fulica

http://en.wikipedia.org/wiki/Pelican

http://en.wikipedia.org/wiki/Phoenicopterus

http://en.wikipedia.org/wiki/Spoonbill

http://en.wikipedia.org/wiki/Mycteria

http://en.wikipedia.org/wiki/Ciconia


http://en.wikipedia.org/wiki/Grus_(bird)

http://en.wikipedia.org/wiki/Shelduck

http://en.wikipedia.org/wiki/Anser_(genus)

http://en.wikipedia.org/wiki/Shelduck


http://en.wikipedia.org/wiki/Mycteria



http://global.wetlands.org/Portals/0/external%20docs/Annex4_CAF_Action_Plan.pdf

http://global.wetlands.org/Portals/0/external%20docs/Annex4_CAF_Action_Plan.pdf

http://en.wikipedia.org/wiki/UNEP

http://en.wikipedia.org/wiki/Convention_on_Migratory_Species





R5A05ENP: 09/29/15 4-35

Exhibit 4.27: Asian Migratory Bird Flyways

Source: U.S. Fish and Wildlife Service 2008. Available at: http://alaska.fws.gov/media/avian

influenza/ak-flyway2.gif U.S. Fish and Wildlife Service/Alaska

Birds of Korangi/Phitti Creek system

The PQA is part of the Korangi Phitti Creek system. A total of 52 bird species have been

reported from these creek systems that belong to 30 genera and 12 families62

(Exhibit 4.28).

Exhibit 4.28: Diversity of Bird Fauna at Korangi Phitti Creek System

No. Family Genera Species Population Status

Abundant Common Less Common

1. Phalacrocoracidae 1 2 2

2. Pelecanidae 1 1 1

3. Ardeidae 4 7 4 3

4. Phoenicopteridae 1 1 1

5. Accipitridae 3 4 3 1

6. Charadriidae 7 18 1 9 8

7. Recurvistridae 2 2 - 2

62 Hasan, A., 1996. Biodiversity of bird fauna in mangrove areas of Sindh. In: Proc.UNESCO Workshop on

Coastal Aquaculture (Q.B.Kazmi, ed.). Marine Reference Collection and Resource Centre, Univ. Karachi:. 21-26.

Hasan, A., S. I. Ahmad, 2006. Some Observations on Birds and Marine Mammals of Karachi Coast Rec. Zool. Surv. Pakistan, 17: 15 – 20




R5A05ENP: 09/29/15 4-36

No. Family Genera Species Population Status

Abundant Common Less Common

8. Laridae 5 11 5 6

9. Alecedinidae 3 3 3

10. Meriopidae 1 1 1

11. Motacillidae 1 1 1

12. Corvidae 1 1 1

30 52 2 26 24

Source: Hasan, A., S. I. Ahmad, 2006. Some Observations on Birds and Marine Mammals of Karachi Coast

Rec. Zool. Surv. Pakistan, 17: 15 – 20

Conservation Status: Of the birds reported from the Korangi Phitti Creek System, three

are included in the IUCN Red List63 and listed as Near Threatened. These are Painted

Stork Mycteria leucocephala, Black Tailed Godwit Limosa limosa, and Eurasian Curlew

Numenius arquata. However, their distribution is not limited to any specific site or

habitat type, and their distribution is widespread. Moreover, due to the high level of

disturbance in the area, the migratory birds avoid the Project-site and vicinity for

breeding or nesting.

Terrestrial Reptiles

A low abundance and diversity of the reptiles species has been reported from the vicinity

of the Project-site.64 Most of the reptiles are usually associated with vegetation.

Commonly observed terrestrial reptiles include the Short-toed Sand Swimmer

Ophiomorus brevipes and Sindh Gecko Crossobamon orientalis.

Conservation Status: None of the reptiles reported from the Project-site and vicinity are

endemic or included in the IUCN Red List.65

4.3.4 Critical Habitat Assessment

The Critical Habitat Assessment of the Project is summarized below as defined by the

IFC’s PS 666 and paragraphs 28-29, SR1, ADB SPS. 67


March 2015 64 Hagler Bailly Pakistan (HBP), March 2014, Environmental Impact Assessment of PQEPC’s 2×660 MW



66 Performance Standard 6, January 2012, Biodiversity Conservation and Sustainable Management of Living Natural Resources, International Finance Corporation. The World Bank Group

67 ADB’s 2009 Safeguard Policy Statement (SPS) – Safeguards Requirement (SR) 1 on Environment,

http://en.wikipedia.org/w/index.php?title=Ophiomorus_brevipes&action=edit&redlink=1

http://en.wikipedia.org/wiki/Crossobamon_orientalis






R5A05ENP: 09/29/15 4-37

Critical habitat is described as having a high biodiversity value, as defined by:

Areas protected by the IUCN (Categories I-VI) 68,

wetlands of international importance (according to the Ramsar convention);69

important bird areas (defined by Birdlife International);70 and

biosphere reserves (under the UNESCO Man and the Biosphere Programme;71

The Project-site and vicinity does not meet the criteria of any of these determinations.

The following additional characteristics are used in Critical Habitat Assessment and are

discussed below with respect to the Project.

Habitat of significant importance to Critically Endangered and/or Endangered

species: The habitats in the PQ Area where the Project is located is not integral to the

survival of any Endangered or Critically Endangered terrestrial or marine species

Habitat of significant importance to endemic and/or restricted-range species: The

habitats found in the Project site and vicinity are homogenous and widespread. They hold

no significance for the survival of endemic or restricted range species; or

Habitat supporting globally significant concentrations of migratory species and/or

congregatory species: Some migratory birds have been reported from the Project-site

and vicinity. However, due to the high level of anthropogenic disturbance in the area,

their population is low. According to investigations, these migratory birds do not use the

Project-site and vicinity as a breeding or nesting area. Moreover, no mammal species

depends on the area for its migration. No significant concentration of congregatory

species is present in the Project-site or vicinity.

Highly threatened and/or unique ecosystems: The ecosystems found in the Project-site

and vicinity are typically those found in coastal areas. There are no threatened or unique

ecosystems.

Areas with unique assemblages of species or which are associated with key

evolutionary processes or provide key ecosystem services. This situation is not present

in the Project-site and vicinity. While all species are functioning components of

ecosystems, there are no unique assemblages of species or association of key

evolutionary processes in the Project-site and vicinity.

Areas having biodiversity of significant social, economic or cultural importance to

local communities. Although the area is of importance to locals in terms of ecosystem

services (including fishing and fuel wood provision), it has no unique biodiversity value

of social, economic or cultural importance to the community.

Determination: There is no Critical Habitat present in the Project-site or vicinity.

68 IUCN. 1994. Guidelines for Protected Areas Management Categories. IUCN, Cambridge, UK. 69 Ramsar Convention, or Convention on the Wetlands of International Importance, Administered by the

Ramsar Secretariat, Geneva, Switzerland 70 Birdlife International, UK 71 Administered by International Co-ordinating Council of the Man and the Biosphere (MAB), UNESCO.




R5A05ENP: 09/29/15 4-38

4.3.5 Ecosystem Services

Humankind benefits from a multitude of resources and processes that are supplied by

natural ecosystems. Collectively, these benefits are known as ecosystem services72. These

include the following:

Provisioning services: the products obtained from ecosystems, including, for

example, genetic resources, food and fiber, and fresh water

Regulating services: the benefits obtained from the regulation of ecosystem

processes, including, for example, the regulation of climate, water, and some

human diseases

Cultural services: the non-material benefits people obtain from ecosystems

through spiritual enrichment, cognitive development, reflection, recreation, and

aesthetic experience, including, e.g., knowledge systems, social relations, and

aesthetic values

Supporting services: ecosystem services that are necessary for the production of

all other ecosystem services. Some examples include biomass production,

production of atmospheric oxygen, soil formation and retention, nutrient cycling,

water cycling, and provisioning of habitat.

The PQA is an industrial area with no settlements inside its battery limits. Therefore,

ecosystem services are limited. However, some ecosystem services of PQA are outlined

below:

Locals from settlements surrounding the PQA graze their livestock on the

vegetation in PQA and vicinity.

The terrestrial vegetation species Mesquite Prosopis juliflora is harvested by the

locals outside the PQA and sold in the local timber market for fire food and

construction of local huts

Local communities use the wood from the mangroves for firewood, building

material and fodder

Only recreational fishing is conducted in the Gharo Creek

4.4 Socioeconomic Environment

A socioeconomic baseline study was conducted to examine the socioeconomic conditions

of communities living in settlements in the proximity of the proposed Project-site. For

this purpose, a survey was undertaken by HBP’s social team from March 13–16, 2015,

which covered 16 settlements within a 10 km radius around the Project-site. The

socioeconomic baseline information collected will be used to predict potential

socioeconomic impacts of the Project on nearby communities. The process followed for

collecting the baseline information and key-findings from the field survey are

documented in this section.

72 Farber, S., Costanza, R., Childers, D.L., Erickson, J., Gross, K., Grove, M., Hopkinson, C.S., et al.

(2006). Linking Ecology and Economics for Ecosystem Management. Bioscience, 56(2), 121




R5A05ENP: 09/29/15 4-39

4.4.1 Scope

Prior to conducting the socioeconomic field survey, a screening exercise was conducted

to:

Identify potential socioeconomic impacts of the Project;

Determine the area of influence for each potential impact identified and;

Identify the socioeconomic baseline information required to evaluate the potential

impact.

The screening exercise was a desk-based study which analyzed preliminary project-

design details and secondary data and information available on the socioeconomic

conditions prevailing in the region. The results of the screening exercise are summarized

in Exhibit 4.29.




R5A05ENP: 09/29/15 4-40

Exhibit 4.29: Results of the Screening Exercise for Potential Socioeconomic Impacts from the Project

Project activity: Development at the site and operations of the RLNG based CCPP

Potential Impact Identified Area of Influence Information Required

Construction Phase

The impact on existing fishing activities in the nearby vicinity of water intake and outfall channel locations in Gharo Creek.

Generation of both skilled and unskilled employment opportunities during Project construction

Industries in the vicinity of the Project-site

The coast line south of the Project-site

Settlements outside the PQA

Existing fishing activities in the area of Gharo Creek located to the south of the Project-site.

Livelihood and employment status of community members living in settlements outside the PQA.

Current status of electricity supply and shortfall in the country Operation Phase

Impact on livelihood of the fishermen and recreational fishing due to change in water quality resulting from cooling water intake and discharge of salt concentrated effluents

Generation of skilled employment during power plant operations

Direct and indirect benefits of power evacuation to the country’s economy due to addition of electricity into the national grid




R5A05ENP: 09/29/15 4-41

4.4.2 Socioeconomic Baseline Survey

A field survey to collect data on the socioeconomic conditions prevailing in the Study

Area was conducted from March 13–16, 2015, covering 16 settlements within a 10 km

radius around the Project-site.

Survey Team

Two teams which collectively comprised of seven members with two HBP Sociologists,

two female field assistants, one local male field assistant and two representatives from

EPL carried out the survey.

Methods of Data Collection

Information on the socioeconomic conditions prevailing within the Study Area was

collected through a combination of settlement-level surveys and focus-group interviews.

To determine the socioeconomic condition for both the genders residing the Study Area,

data was collected from both male and female members of the society. Data collection for

settlement surveys was carried out using two standardized questionnaires designed

separately for men and women. Both questionnaires are provided in Appendix C.

Principal areas of inquiry covered in the questionnaires are listed in Exhibit 4.30. The

questionnaire designed for men included all the areas of inquiry stated in the exhibit

while the questionnaire designed for women covered only the shaded areas of inquiry in

the exhibit.

The information was obtained from both male and female key informants including

literate people, representatives of local government, town management officers and

community leaders with knowledge of the socioeconomic conditions of their

communities.

Exhibit 4.30: Principal Areas Covered in Questionnaires

Area of Inquiry Data Requirement

Demographic and Houses Total population

Housing

Proportion of houses (adobe/masonry) 73, 74

Migration and seasonal movement of population

Ethnology Social groups

Languages

Economic Occupational profile (employment, agricultural and livestock-based work, labor etc.)

Agriculture, Cropping pattern

Livestock

73 Adobe houses are made of mud or unbaked bricks or clay and straw. 74 Masonry houses are constructed with brick walls and concrete or tin roof.




R5A05ENP: 09/29/15 4-42

Area of Inquiry Data Requirement

Physical Infrastructure Roads and transportation

Water supply

Energy sources and consumption

Communication

Social Infrastructure Educational institutions and educational attainment and enrollment

Health facilities and health indicators

Anthropological Leadership systems and conflict resolution methods

Gender roles in the family and society

Land uses and ownership

Survey Locations

The settlements, on the basis of prevailing conditions of infrastructure and development

there, were divided into two categories: urban/semi-urban settlements and rural

settlements. The list and geographical coordinates of the surveyed urban and semi-urban

and rural settlements within the Study Area are provided in Exhibit 4.31 while their

locations are shown in Exhibit 4.32.

Communities residing in the Railway Colony and Pakistan Steel Mills Town (PSM

Town) could not be surveyed as the respondents, mostly employees of the Pakistan

Railways and PSM respectively, informed the survey team that their respective

managements had advised them not to participate in any surveys without authorization

due to security concerns. The socioeconomic survey team was only allowed to consult

with the officials of the PSM Town management during which socioeconomic data for

the town was also collected.

The socioeconomic survey and community consultations were held simultaneously. For

urban and semi-urban settlements, one male and female questionnaire was filled during

the first round of consultation meeting with the male and female residents of the

communities. The information collected, was then verified from the respondents from

other consultation meeting(s) held at the same community.

For rural communities, consultations were held only once, separately with male and

female respondents, during which socioeconomic data was also collected. To verify the

rural socioeconomic data, the HBP team carried along the data collected for the similar

communities visited during the course of previous EIA study conducted in PQA75. The

data was verified through cross questioning and relating the provided information with

the previous data, keeping in mind the possible population and infrastructure growth

which may have occurred in the area.

75 Hagler Bailly Pakistan. “Environmental Impact Assessment of Coal Power Plant (CPP) Project at Fauji

Fertilizer Bin Qasim Complex” Fauji Fertilizer Bin Qasim Limited, February 2014.




R5A05ENP: 09/29/15 4-43

Exhibit 4.31: Types of Settlements and their Geographical Coordinates

Type No Settlement Name Coordinates

Urb

an a

nd

Sem

i-U

rba

n

Sett

lem

ents

1 PSM Town 24° 51' 56.887" N 67° 20' 26.078" E

2 Gulshan-e-Hadeed 24° 52' 3.448" N 67° 21' 13.272" E

3 Railway Colony 24° 50' 58.588" N 67° 24' 58.214" E

4 Pipri 24° 51' 15.293" N 67° 20' 9.614" E

Rura

l S

ett

lem

ents

5 Soomar Jokiho 24° 52' 14.741" N 67° 22' 39.177" E

6 Haji Ibrahim Goth 24° 50' 30.250" N 67° 26' 1.828" E

7 Natho Tando Khoso 24° 50' 48.354" N 67° 25' 40.073" E

8 Haji Jhangi Khan 24° 51' 8.380" N 67° 25' 51.588" E

9 Haji Khan Zohrani 24° 51' 3.982" N 67° 25' 31.838" E

10 Humar Khan 24° 51' 29.369" N 67° 25' 53.611" E

11 Mir Khan Baloch 24° 51' 0.273" N 67° 26' 26.123" E

12 Haji Ghulam Muhammad 24° 50' 48.078" N 67° 26' 3.612" E

13 Ameen Muhammad Baloch 24° 49' 19.015" N 67° 26' 27.116" E

14 Pir Bux Goth 24° 51' 50.11" N 67° 25' 57.132" E

15 Muhammad Qasim Baloch 24° 50' 12.038" N 67° 26' 30.015" E

16 Morand Khan Qaserani Baloch

24° 51' 21.424" N 67° 22' 55.002" E




R5A05ENP: 09/29/15 4-44

Exhibit 4.32: Location of Urban, Semi-Urban and Rural Settlements within the Study Area




R5A05ENP: 09/29/15 4-45

4.4.3 Socioeconomic Survey Results

The results of the socioeconomic survey of the communities in the Study Area are

presented in the sections below. The summary of the results is provided in Exhibit 4.33.

Exhibit 4.33: Summary of the Socioeconomic Conditions in the Study Area

Socioeconomic Aspect Survey Result

Estimated number of households76 26,281


Type of housing Urban and Semi Urban Masonry Adobe

100% –

Rural Masonry Adobe

75% 25%

Estimated number of educational institutions

97 (84 in urban and semi urban and 13 in rural settlements)

Estimated number of health facilities 20 (including private clinics, one health center by Fauji Fertilizer Bin Qasim Limited, one 100 bed hospital in PSM Town, and GoS facilitated dispensaries)

Major transportation route National highway (N-5), connecting the Study Area to Karachi city located to its west

Major source of water Keenjar lake, located in Thatta, to the east of the Study Area, at an approximate geodesic distance of 45 km. Water is supplied to the settlements through Karachi Development Authority (KDA) pipeline and PSM water supply pipelines

4.4.4 Urban and Semi-Urban Settlements

In this report, urban and semi-urban settlements refer to the densely populated

settlements within the Study Area containing relatively well-developed formal

government and administrative offices and residential infrastructure. Two urban

(Gulshan-e-Hadeed and PSM Town) and one semi-urban (Pipri) settlements were

surveyed to determine their existing socioeconomic conditions. The details of the survey

are provided below:

Gulshan-e-Hadeed

Gulshan-e-Hadeed, the largest and most developed settlement in the Study Area, is

located at a geodesic distance of 8 km north-northwest from the proposed Project-site

(Exhibit 4.32). The land on which Gulshan-e-Hadeed is located was originally owned by

PSM but later sold to private individuals. The town now comprises of a population with

mixed social and economic characteristics from various parts of Karachi and smaller 76 A household consists of one or more people living in a same residence and share meals and living

accommodation. A single residence will be considered to contain multiple households if meals or living space is not shared.




R5A05ENP: 09/29/15 4-46

settlements nearby. The reason for the pull to settle in Gulshan-e-Hadeed include poor

law and order situation in other parts of Karachi city and the attraction of potential

employment opportunities in PSM and other industries in the PQA.

Administratively, Gulshan-e-Hadeed is the sixth union council (UC#6) of Bin Qasim

Town, District Malir, Karachi. It is located at an approximate distance of 40 km east from

Karachi city and is approachable via the National Highway (N-5).

It is divided into two phases (Phase I and II) offering three categories of houses to its

residents (A, B and C). The A category include houses with maximum covered area of

120 yards, B with 240 yards size houses, whereas category C offers 500 yards bungalow.

Gulshan-e-Hadeed has a well-developed educational infrastructure with a number of

private coeducational primary, middle and high schools. There is only one government

primary girls’ school situated in the settlement. Due to a fee-wavier provided by the GoS,

girls from scattered villages around Gulshan-e-Hadeed visit this primary school. For

higher education, the residents of Gulshan-e-Hadeed visit colleges and universities

located in Karachi city.

As the settlement is located on the N-5, public transportation facilities are widely

available for the residents to commute to Karachi city and other areas in the Sindh

province. The forms of public transportation include buses, vans, pick-ups and taxis. The

residents commonly use motorcycle driven rickshaws to visit markets, schools, health

facilities and other places located within Gulshan-e-Hadeed.

The socioeconomic baseline established for Gulshan-e-Hadeed, including demography,

ethnicity77, education and health infrastructure and occupational profile is provided in the

series of exhibits from Exhibit 4.34 to Exhibit 4.37 while photographs from the

settlement are provided in Exhibit 4.38.

Exhibit 4.34: Socioeconomic Profile of Gulshan-e-Hadeed

Socioeconomic Aspect Gulshan-e-Hadeed Profile



Estimated number of educational institutes

70 (this includes the sole government primary girls’ school, while the rest are privately owned and operated coeducational primary and middle schools)

Estimated number of health centers/private clinics/dispensaries

10 (mostly private clinics)

Water supply scheme KDA pipeline supplying water from Keenjar lake, Thatta, with pumping station at Gharo

Housing 100% masonry structures

Post office Located in PSM Town at a distance of approximately 1 km

77 An ethnic group or ethnicity is a socially defined category of people who identify with each other based

on common ancestral, social, cultural or national experience. Definition is taken from People, James; Bailey, Garrick “Humanity: An Introduction to Cultural Anthropology (9th ed.)”. Wadsworth Cengage learning. 2010, p. 389.




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Socioeconomic Aspect Gulshan-e-Hadeed Profile

from the settlement

Police station A community police center is located in settlement. The nearest police station is located in PSM Town

Other infrastructure Ample number of shops, banks and mosques are situated in the settlement

Exhibit 4.35: Occupational Profile of Gulshan-e-Hadeed

Exhibit 4.36: Spoken Languages in Gulshan-e-Hadeed

Government services

55%

Private services9%

PQA industry employees

27%

Overseas employment

9%

Urdu30%

Sindhi45%

Balochi10%

Pashtu10%

Punjabi5%




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Exhibit 4.37: Percentage Share of Ethnic Groups in Gulshan-e-Hadeed

Exhibit 4.38: Photographs of the Socioeconomic Features of Gulshan-e-Hadeed

Entrance of Gulshan-e-Hadeed from N-5 Government girls’ primary school Gulshan-e-Hadeed

A view of a market in Gulshan-e-Hadeed A bank in Gulshan-e-Hadeed

Jokhio25%

Memon25%

Awan10%

Butt10%

Afridi2%

Khattak3%

Sheikh25%




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A view of mosque in Gulshan-e-Hadeed Al-Hadeed (private) school, Gulshan-e-Hadeed

Water tower (storage tank), Gulshan-e-Hadeed GoS operated public transport in Gulshan-e-Hadeed

Pakistan Steel Mills Town

PSM Town or Steel Town is stretched over an area of 3,288 hectares (8,126 acres) and

offers subsidized residence to PSM employees. The land for the town development was

leased by PSM from GoS. (See Exhibit 4.32 for the exact location of PSM Town within

the Study Area).

PSM Town is developed by PSM and is well-equipped with all the basic facilities for an

urban settlement and includes proper drainage and sanitation system, police station,

utility stores and developed electricity and natural gas transmission infrastructure. The

PSM Town offers a cricket stadium, football ground and a hockey stadium to promote

sports among the young individuals residing in the town. PSM Town has a post office,

police station and a 100-bed hospital providing communication, security and health

services not only to its residents but also to other settlements located in its vicinity. PSM

also offers houses to the employees of police and rangers serving in the police station

located within the town.

Data on the percentage of different ethnic groups living here and the languages spoken

within the PSM Town could not be collected as the PSM management did not allow the

survey to be conducted due to restricted permission. However, during the stakeholder

consultation regarding the proposed Project with Mr. Tariq Masood, Manager, Estate

Department, PSM, the socioeconomic data for the town was also collected. It was noted

that 98% of the residents of the PSM Town are employed in PSM, while the remaining




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2% includes families of individuals serving in the Police and Rangers.78 Some

socioeconomic features of the PSM Town are provided in Exhibit 4.39, while

photographs of the socioeconomic infrastructure existing in the PSM Town are provided

in Exhibit 4.40.

Exhibit 4.39: Socioeconomic Profile of PSM Town

Socioeconomic Aspect PSM Town Profile



Estimated number of educational institutes 14 (8 secondary coeducatioal schools owned and managed by PSM, 4 private coeducational secondary schools, one Madar-e-Millat girls’college and one PSM cadet college for boys)

Estimated number of health centers/private clinics/dispensaries

3 (2 dispensaries and one 100 bed hospital)

Water supply scheme PSM pipeline supplying water from Keenjar lake, Thatta

Housing 100% masonry structures

Post office one

Police station one

Other infrastructure Two markets large markets (Russian and Pakistani Market), one Mandir (prayer house for Hindus), one Church (prayer house for Christians), four mosques and the largest Imam Bargah of the Study Area

Exhibit 4.40: Photographs of the Socioeconomic Features of PSM Town

A distant view of police station in PSM Town A view of post office located in PSM Town

78 Pakistan Rangers is a paramilitary force of Pakistan, under the direct control of the Ministry of the

Interior. The Rangers is an internal security force with the prime objective to provide and maintain security in war zones and areas of conflict as well as maintaining law and order which includes providing assistance to the police.

http://en.wikipedia.org/wiki/Ministry_of_Interior_(Pakistan)

http://en.wikipedia.org/wiki/Ministry_of_Interior_(Pakistan)




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Mandir in PSM Town Imam Bargah

A view of Russian market in PSM Town 100 bed hospital located in PSM Town

Private school located PSM Town Madar-e-Millat degree college, PSM Town

Pipri

Pipri is located at an approximate geodesic distance of 6.5 km to the northwest of the

proposed Project site. The settlement compromises of numerous small clusters of

communities (Goths)79 named after the elders of the family or the ethnic group residing in

it. The list of these clusters along with estimated numbers of households and population,

as reported by the key informants, is provided in Exhibit 4.41. As compared to Gulshan-

e-Hadeed and PSM Town, Pipri is a less developed area, with poorly developed

infrastructure.

79 Goth is a Sindhi word for village.




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Electricity and gas to Pipri is supplied through K-Electric and SSGCL electricity and gas

transmission networks. Pipri has a water pumping station located in Shanawaz Goth. The

water is extracted from Keenjar Lake, Thatta, and is stored in a water tower from where it

is supplied to the settlement through a gravity-driven water supply system.

Pipri, near Pathan Goth, has the largest graveyard located in the Study Area. The

graveyard is used by the residents of Pipri, Gulshan-e-Hadeed and PSM Town.

Pipri has one each of a boys’ and girls’ government private school, one government boys’

secondary school and approximately 10 coeducational private primary schools providing

education to children in the settlement. For middle and high school, the residents attend

schools located in Gulshan-e-Hadeed, while for higher education; the residents go to

colleges and universities in Karachi city. The key informants also reported that some of

the university-goers also head to universities located in Hyderabad, Tando Jam and

Jamshoro.

The respondents from Pipri reported a substandard health infrastructure in the settlement

with limited number of dispensaries and private clinics. The absence of doctors and lack

of medicines in these health centers is one the major issues cited by the residents.

The percentage share of ethnic groups and spoken languages prevalent in Pipri are

presented in Exhibit 4.42 and Exhibit 4.43 respectively. Photographs from the settlement

are provided in Exhibit 4.44.

Exhibit 4.41: Clusters of communities (Goths) within Pipri with Estimated Number of

Households and Population

Cluster Name Estimated number of households

Estimated population

Shahnawaz Goth 450 3150

New Allah Bakhsh Goth 320 2,240

Mureed Gabol Goth 350 2,450

Khuda Bakhsh Goth 320 2,240

Ali Muhammad Jokhio Goth 300 2,100

Ali Bakhsh Baloch Goth 280 1,960

Suffan Gabol Goth 250 1,750

Dur Muhammad Goth 280 1,960

Muhammadi Colony 250 1,750

Pathan Goth 300 2,100

Total 3,100 21,700




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Exhibit 4.42: Percentage Share of Ethnic Groups in Pipri

Exhibit 4.43: Spoken Languages in Pipri

Gabol35%

Jokhio 25%

Baloch10%

Sario10%

Abro10%

Bhutto10%

Sindhi75%

Pashtu20%

Balochi5%




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Exhibit 4.44: Photographs of the Socioeconomic Features of Pipri

Government Boys Secondary School, Pipri A private school and government dispensary, Pipri

Water pumping station, Pipri A distant view of water tower, Pipri

A view of main market located in Pipri A mosque in Pipri

4.4.5 Rural Settlements

In this report, settlements in the Study Area with a less developed socioeconomic

infrastructure including health, education and communication infrastructure are defined

as rural settlements. The inhabitants of the rural settlements are mostly engaged in daily

wage labors like gardening, laboring, agriculture, livestock and fishing.

The Study Area includes 12 rural settlements. Details of their socioeconomic baseline

conditions are provided below.




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Demography

According to the population estimates obtained by the socioeconomic baseline survey,

the total population of the 12 surveyed rural settlements is, approximately, 20,220 people.

The largest rural settlement is Haji Ghulam Muhammad, with an estimated population of

5,200 individuals, whereas Pir Bux Goth is the smallest settlement with an estimated

population of 90 people. Exhibit 4.45 provides the number of rural households and

population by each settlement. A map indicating the location of the rural settlements is


Household Size

The average size in the surveyed rural settlement was 6.9 persons. The maximum and

minimum household sizes, recorded in the surveyed population were 8.2 and 5.3,

respectively (Exhibit 4.45).

Exhibit 4.45: Demographic Profile of the Surveyed Rural Settlements

Settlement Estimated Population

No. of Households

Average Household Size

Soomar Jokiho 1,200 175 6.8

Haji Ibrahim Goth 2,500 380 6.5

Natho Tando Khoso 2,200 290 7.5

Haji Jhangi Khan 4,500 550 8.2

Haji Khan Zohrani 2,200 270 8.1

Humar Khan 800 100 8.0

Mir Khan Baloch 130 18 7.2

Haji Ghulam Muhammad 5,200 970 5.3

Ameen Muhammad Baloch 150 28 5.3

Pir Bux Goth 90 15 6.0

Muhammad Qasim Baloch 450 75 6.0

Morand Khan Qaserani Baloch 800 110 7.3

Total 20,220 2,981

Ethnicity and Religion

The ethnic makeup of the population within the surveyed rural settlements comprises

mainly of the Kalmati Baloch caste, followed by Khosa Baloch, Hoti Baloch and

Zohrani. The total estimated population of the surveyed rural settlements is Muslim.

The main language spoken in the surveyed rural settlements was Sindhi followed by

Balochi and Siraiki (Exhibit 4.46). Urdu being the national language of Pakistan is also

spoken in the settlements to communicate with outsiders.




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Exhibit 4.46: Percentage of Spoken languages in the Surveyed Rural Settlements

Occupational Profile

Employment has a direct impact on poverty, income distribution and economic

development. There are certain issues inherent to employment such as literacy and skill

level. An unskilled and uneducated workforce is unable to compete in the global market

and contribute to economic development of the country.

Daily wage labor is the major source of income in the surveyed rural settlements. About

66% of the total surveyed population is engaged in daily wage labor, masonry, wood

cutting, shop owner and shop keeping etc. Up to 24% is employed in the private sector,

mainly in the nearby industries, where they work as peons, security guard, drivers etc.,

while eight percent of those employed work as government employees including teachers

and drivers (Exhibit 4.47).

Exhibit 4.47: Percentage of Occupations in the Surveyed Rural Settlements

Sindhi, 80%

Balochi, 10%

Siraiki, 10%

Daily Wage labor, 66%

Private Service, 24%

Government Service, 8%

Overseas, 2%




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Physical Infrastructure

The condition of infrastructure in the surveyed rural settlements is poor. None of the rural

surveyed settlements in the area reported having police stations, police check-posts, and

banks. The inhabitants of the area have to travel to Gulshan-e-Hadeed and Dhabeji to

avail these facilities.

The surveyed rural settlements have access to mobile networks services provided by

Telenor, Zong and Warid.

Housing and Other Structures

About 75% of the residential structures in the surveyed rural settlements were of masonry

construction, while 25% were of adobe construction. Exhibit 4.48 provides photographs

of masonry and adobe houses from the surveyed settlements.

Exhibit 4.48: Housing Structures in the Surveyed Rural Settlements

Masonry Construction House at Ameen Muhammad Baloch Settlement

Adobe Construction House at Pir Bux Settlement

The main market in the area is located in Ghaghar Phattak. The market contains general

stores, grocer shops, food-stores, and, mechanics and other service shops, while some

small shops for basic supplies exist in surveyed rural settlements Exhibit 4.49.

Exhibit 4.49: View of Shops in the Surveyed Rural Settlements

Shops in Haji Ghulam Muhammad Settlement




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Every settlement had at least one mosque. The mosques were of masonry construction,

consisting of a single large prayer room or hall. The male population from the settlement

congregates here for prayers Exhibit 4.50.

Exhibit 4.50: View of Mosques in the Surveyed Rural Settlements

Mosque in Haji Ibrahim Settlement Mosque in Haji Ghulam Muhammad Settlement

Roads and Transport

Five of the surveyed settlements are connected by blacktop roads, whereas the remaining

settlements are connected by unsealed road. Regular transport facilities to the inhabitants

of the rural surveyed settlements are in the form of taxis and buses. The inhabitants can

easily access public transport from the N-5.

Power Supply

Electricity is available in 10 of the 12 surveyed rural settlements, supplied through the K–

Electric grid. Results from the socioeconomic baseline survey indicate that fuel wood is

generally used for heating and cooking purposes. The fuel wood is usually collected from

surrounding areas. Mesquite bushes locally known as keekar, growing in the nearby

lands, are the main source of fuel wood. These are used in combination with larger logs

which are purchased from Ghaghar Phattak market or sellers roaming within the

community. Logs are available at a price of 300 to 400 per mund (mund is a local unit

that equals 40 kg).

Water Supply

Water supply is one of the major problems faced by inhabitants living in the surveyed

rural settlements. Most of the underground water is brackish and saline. Up to 25% of the

surveyed rural settlements have access to potable water supplied and managed by the

KDA through pipelines, while the rest of the settlements purchase water from private

tankers. The inhabitants of Mir Khan Baloch have access to potable water supplied by

PSM through pipelines. FFBL in association with Human Development Foundation




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(HDF)80 has also established a water filtration plant in Haji Khan Zohrani settlement.

Pictures showing the water supply sources in the area are presented in Exhibit 4.51.

Exhibit 4.51: Water Supply and Storage Resources in the Surveyed Rural Settlements

Water Supply from Private Tankers Water Filtration Plant at Haji Khan Zohrani Settlement

Social Infrastructure

Improved socioeconomic conditions tie in with higher education levels and good health

of the people. An educated and skilled labor-force is more productive and contributes to

economic growth. Health is the basic right of every human and improved nutrition and

healthcare also contribute to bolstering the productivity of the human capital.

Education

Education facilities in the surveyed rural settlements are provided by primary, middle and

secondary schools run by the provincial education department, HDF, FFBL and Sindh

Education Foundation (SEF).81 Government educational facilities in the surveyed

settlements comprises of six primary, two middle and two high schools. The private

educational facilities comprise of one primary school, functioning under HDF. A primary

school was also functioning under the SEF, located at Natho Tando Khoso settlement.

FFBL has also established a girl’s elementary school in Haji Jhangi Khan, where

education up to class eight is provided to girls. Most of the schools were co-educational

(Exhibit 4.52). Pictures showing the education institutions in the area are presented in

Exhibit 4.53

80 Human Development Foundation (HDF) Pakistan was registered in 1999 as an independent organization

in an effort to better deliver program services. HDF Pakistan is primarily responsible for program delivery but also forms partnerships with other organizations including international agencies like World Food Program and UNDP. Website link http://www.hdf.com/about/the-hdf-network/hdf-pakistan/.

81 The Sindh Education Foundation (SEF) was established in 1992 as a semi-autonomous organization to undertake educational initiatives in the disadvantaged areas of Sindh. SEF provides communities with direct access to educational facilities by opening schools through its various endeavors.

http://www.hdf.com/about/the-hdf-network/hdf-pakistan/




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Exhibit 4.52: Educational Facilities in the Surveyed Rural Settlements

Settlement Name Primary School Middle School High School

Soomar Jokiho 1 - -

Haji Ibrahim Goth - 1 -

Natho Tando Khoso 1 1 -

Haji Jhangi Khan - 1 1

Haji Khan Zohrani - - -

Humar Khan 1 - -

Mir Khan Baloch 1 - -

Haji Ghulam Muhammad 1 - 1

Ameen Muhammad Baloch 1 - -

Pir Bux Goth - - -

Muhammad Qasim Baloch 1 - -

Morand Khan Qaserani Baloch 1 - -

Exhibit 4.53: Education Institutions in the Surveyed Rural Settlements

Government Primary School at Mir Khan Baloch Settlement

Government Boys Secondary School at Haji Ghulam Muhammad Settlement

Health

Of the surveyed settlements, it was reported that three settlements, Haji Ghulam

Muhammad, Haji Jhangi Khan and Haji Khan Zohrani had access to community health

center located at Haji Khan Zohrani settlement. The facility was established by FFBL and

is operated by the HDF (Exhibit 4.54). The inhabitants of the area have access to the

private clinics and hospital located in Gulshan-e-Hadeed and PSM Town, respectively.

These facilities are, on average, located at a distance of about 7 km from the settlements.

In case of emergencies and serious illness, the inhabitants head to Jinnah Hospital located

at an approximate distance of 40 km in Karachi city.

The most common ailments reported were respiratory issues, cough and flu, followed by

Hepatitis B and C and stomach problems among men and women and children.




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Exhibit 4.54: Community Health Center

Community Health Center at Haji Khan Zohrani

Migration

Primary data collected from the field indicates that potential employment opportunities

and water-availability are the main reasons for households to migrate towards or away

from the rural settlements in the Study Area. Immigration was recorded in six

settlements, while out-migration was not reported in any of the surveyed rural settlements

by the key respondents. Exhibit 4.55 indicates information regarding migration patterns

in the surveyed rural settlements.

Exhibit 4.55: Migration Patterns in the Surveyed Rural Settlements

Settlement Name In Migration in Last 10 Years

In Migration in Last 20 Years

Out Migration in Last 10

Years

Out Migration in Last 20

Years

Soomar Jokiho

Haji Ibrahim Goth

Natho Tando Khoso

Haji Jhangi Khan

Haji Khan Zohrani

Humar Khan

Mir Khan Baloch

Haji Ghulam Muhammad

Ameen Muhammad Baloch

Pir Bux Goth

Muhammad Qasim Baloch

Morand Khan Qaserani Baloch




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Crime and Security Conditions

There were almost no reported cases of conflicts, feuds, thefts, land disputes or other

serious crimes with the exception of some incidents of robbery which occurred in the

recent past in Haji Ghulam Muhammad and Haji Jhangi Khan. The elders of the

community are usually approached to resolve all disputes and conflicts. Formal

mechanisms, such as, police are only approached if the elders are unable to resolve an

issue.

4.4.6 Fishing

A socioeconomic survey with a focus on the PQA coast line south of the Project-site (see

Exhibit 4.56) was conducted on March 15, 2015. The purpose of the survey was to

determine the frequency and nature of existing fishing activities in the Gharo Creek near

the proposed locations for the proposed Project’s intake and outfall channels. The survey

adopted an informal interview style with fishermen focusing questions on the frequency

of their fishing activities in the Gharo Creek, the size of the catch, and whether it was

sold in the market or consumed by the fishermen. The survey location and photographs of

the survey are provided in Exhibit 4.56 and Exhibit 4.57 respectively.

Findings of the Survey

The informal discussions with the fishermen revealed that in the past, the livelihood of a

large number of local fishermen residing in the area of Ghaghar Phattak was dependent

on the Gharo Creek located south of the Project. However, due to the development of PQ,

and operations of its shipping lanes and jetties, in the mid 1980’s, the fishermen were

forced to relocate and shift fishing to the areas near Keti Bandar, located at an

approximate distance of 80 km south east of Gharo Creek (see Exhibit 4.58). According

to the fishermen, this shift was triggered by the continuous deterioration in quality and

quantity of fish due to ecological disturbances caused by the development of PQ. Now,

only recreational fishermen ventured in the Gharo Creek.

Further, it was informed that that due to passage of huge cargo carrying vessels through

PQ shipping lanes, the fish population has alarmingly decreased to a level that

recreational fishing in the area is also being adversely affected. Commonly, the

recreational and small fishermen visiting the Gharo Creek catch Crabs, Shrimps, Poplette

and Surmaii. The recreational fishermen use the catch as subsistence food while some of

them, at times, find a sizable catch enough to sell it to the Karachi Sun Fishery Market.




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Exhibit 4.56: Survey Locations to identify existing Fishing Activities




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Exhibit 4.57: Photographs of the Fishing Survey

A view of survey location with respect to PQA Rented boat by recreational fishers entering the Gharo Creek

Recreational fishermen using net to catch shrimps Recreational fisherman preparing bait to catch fish

Recreational fishermen catching fish Informal discussion with a local fisherman




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Exhibit 4.58: Location of Keti Bandar with respect to Study Area




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4.4.7 Shrine of Shah Hassan

The Shrine of Hazrat Shah Hassan is located at a geodesic distance of 3.2 km southeast of

the Project-site (see Exhibit 4.32). A field visit to the shrine was conducted on March 8,

2015 to determine its cultural and religious status and ascertain if it would be susceptible

to impacts from the Project.

Shah Hassan, one of the descendants of Imam Taqi82, is believed to have arrived in the

sub-continent nearly 1,100 years ago. Shah Hassan is revered by his followers as one of

seven saints who used to protect Karachi city from cyclones. He is supposed to be a

contemporary of Hazrat Abdullah Shah Ghazi.83

Shah Hassan has followers from all over the country, visiting his shrine on his annual Urs

(death anniversary) which is observed on the first weekend after the Islamic month of

Ramadan. The Urs is a three day event (Friday to Sunday) in which his followers from all

over the country visit the place and camp around his shrine. The arrangements of the

annual Urs are managed by the shrine’s management.

The Shrine is currently managed by Shah Hassan’s descendant Syed Mehdi Shah who

has an office at the shrine. During the field visit, an informal interview was conducted

with Syed Mehdi Shah. He reported that the GoP acquired some portion of their land

during Prime Minister Zulfiqar Ali Bhutto’s tenure (1973–1977) for development of PQ

Industrial Area. He further reported that they have been allocated a small area around the

shrine for camping, while the rest of the area is under control of Pakistan Coast Guards

who have prohibited the area for camping or any other kind of civilian activity.

According to Mr Mehdi, one of the major issues faced by the shrine management is the

lack of provision of utilities like natural gas and electricity for the shrine. Previously, they

had an electricity distribution line connecting the shrine with a main transmission line.

However, according to Mr Mehdi, the PQA disconnected that line claiming their rights

on the land the line was passing through.

Currently the shrine’s management use oil lamps in the shrine and its neighboring

vicinity to light the area at night. Mr Mehdi reported that currently they are looking for a

donor to install a solar panel system to solve the electricity availability issue faced by

them.

Informal discussions with the locals present at the time of the survey were also held. The

locals visiting the shrine did not report any issues of access due to the PQA and its

industries. Furthermore, the shrine’s management reported that different industries in the

PQA make generous donations at the time of Urs for making arrangements for the

followers. However, the shrine’s management stated concerns over a lack of co-operation

extended from the PQA authorities regarding provision of utilities and limited access to

the neighboring areas for camping during Urs.

82 Imam Muhammad Al-Jawad (or Imam Taqi) is the ninth apostolic Imam. He was son of Imam Ali Ar-Rida.

Imam Taqi took responsibility of Imamate after the death of his father Imam Ali Ar-Rida in 203 AH. Imam Taqi dies at the age of 25, in 220 AH when he was poisoned. (source: http://www.ziaraat.org/taqi.php)

83 Hazrat Abdullah Shah Ghazi was the great grandson of Prophet Muhammad (P.B.U.H) form the lineage of Hasan Ibne Ali Ibne Abu Talib. (source: www. http://abdullahshahghazi.com/)

http://www.ziaraat.org/taqi.php

http://abdullahshahghazi.com/




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The interview with the shrine management was concluded with a discussion on the

proposed Project. The respondents from the management reported no issues and

reservations with it. The photographs of the shrine taken during the field visit are


Exhibit 4.59: Photographs of the Shrine of Shah Hassan

Stone mark preseting brief history of Shah Hasa A distant view of the shrine

Coastline on the west of the shrine A view of PQA industrial area from the shrine

Grave of Hazrat Shah Hassan

Al-Hadeed (private) school, Gulshan-e-Hadeed

4.5 Anticipated Developments in the vicinity of the Project

This section provides brief information regarding the design and potential impacts of

some of the anticipated developments proposed in the vicinity of the Project-site. The

anticipated developments included in this section are those for which information was

readily available in the form of published EIAs, prepared by HBP.

The objective of this section is to shed light on the magnitude of contribution to potential

cumulative impacts from the development of the Project and other anticipated projects in




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the vicinity of the PQA. Due to the nature of the anticipated developments, the

contributions are focused to those which will have an impact on ambient air quality in the

PQA and water quality in the Gharo Creek. These have the highest likelihood among all

other impacts of resulting in adverse cumulative impacts.

Therefore, this section provides a comparison of the air emissions and the water intake

and outfall rates and characteristics between the proposed Project and the anticipated

developments. Information regarding anticipated developments included in this section

has been collected from the following published EIA reports of industrial developments

in the vicinity of the Project-site:

Environmental Impact Assessment of Bin Qasim Coal Conversion Project.

Undertaken by Hagler Bailly Pakistan and Environmental Management

Consultants in 2013 for K-Electric Karachi.

Environmental Impact Assessment of PQEPC’s 2×660 MW Coal Power Plant

completed by Hagler Bailly Pakistan in 2014 for PQEPC.

The location of these developments is shown in Exhibit 4.1, southwest of the proposed

Project-site.

4.5.1 2 × 660 MW Coal-Fired Power Plant Port Qasim Electric Power Company

Brief Project Description

PQEPC intends to install a 2 × 660 MW coal-fired power plant with a net capacity of

1,200 MW in the eastern industrial zone of PQA. The geographical coordinates of the

plant are 24°47' 2.4°N, 67°22' 2.4 E.

Prior to the construction of the project, land at the project-site will be reclaimed from the

sea. The project will employ two super-critical boilers to generate up to 1,200 MW of

power which will be fed to the national grid. Coal for firing the boilers will be imported

from abroad. The design, as-received, calorific value of the coal used will be

4,340 kcal/kg and it will have an ash content of about 12-15 %. The desired sulfur

content is about 0.75–1 %. Ash generated during project operation will be disposed at an

ash disposal location outside the PQA.

Super-critical boilers typically emit gases containing NOx, SOx, CO and PM which are

harmful for both humans and the environment. The project includes the installation of

emission control systems to reduce the emissions to the levels prescribed by NEQS and

IFC guidelines.

The water requirements of the project will be met by extracting seawater from the Gharo

Creek. Seawater will be treated in four water demineralization plants installed within the

premises of the project site and supplied to the power plant. Potable and other water

requirements will also be met from the demineralized seawater. Effluents from the

demineralization plant will be neutralized and kept in an aeration pond for some time.

After treatment the effluents will eventually be discharged back into the Gharo Creek.

Cooling tower blowdown and discharge from the seawater treatment process are the only

wastewater streams which will be discharged into the sea. Both will be treated to comply

with the NEQS. All other industrial effluents such as boiler make-up water, oily waste




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and sanitary waste will be treated and re-used. Some of the activities utilizing the re-used

water are dust suppression of ash and coal washing. From here, water will once again be

retreated and re-used.

Air and Water Quality Impact Assessment Results

The project will release cooling water blowdown generated from the plant operations and

brine generated from the desalinization plant into the Gharo Creek. The effluent stream

will not have a temperature higher than 3 °C at the point of discharge and the

concentration of pollutants in the effluent will be well below the limits prescribed by the

NEQS. The incremental impact from the project on water in the creeks will be quite small

and is unlikely to have significant impacts on creek ecology downstream. Secondly, no

untreated liquid effluent will be discharged into the creek and the profile of the thermal

plume will remain unchanged.

The results of the air dispersion modeling for the proposed emission from the coal-fired

power plant indicate that SO2, NO2, and PM10 concentrations in the air during operation

will be compliant with the prescribed ambient air quality standards provided in NEQS.

4.5.2 K-Electric Bin Qasim Coal Conversion Project

Brief Project Description

K-Electric, the owner of Bin Qasim Thermal Power Station-1 (BQPS-1), Karachi intends

to partly convert the power plant from natural gas and furnace oil firing to coal firing by

installing two new coal-fired boilers at the existing BQPS-1 plant site.

BQPS-1 comprises six dual-fired (oil and gas) units each with installed power generating

capacity of 210 MW. The proposed Coal Conversion Project involves installation of two

new coal-fired boilers. The steam generated from these boilers will be used to operate the

two existing steam turbines of BQPS-1 thus replacing oil as fuel for these boilers.

The existing dual fuel boilers will remain in place but will not be in operation after

conversion. Coal will be stored in coal yard, which is to be located east of the existing

plant site. An ash disposal ponds will be developed for storage of ash produced in the

boilers. New coal boilers, sea water treatment plant, waste water treatment plant,

chlorination plant, hydrogen plant, continuous emissions monitoring system (CEMS),

condensate polishing unit and compressed air system will be constructed within the plant

boundary.

Coal for the plant will be imported from Indonesia, with expected calorific value of

3,500-4,500 kcal/kg. The ash content is expected to be between 5% and 10% however,

the ash pond is designed assuming ash content to be 15%. The expected sulfur content is

between 0.3 and 1.0%. The planned facility will thus have the provision to use Thar

lignite once it is available in suitable quantities after blending with higher grade coal.

Air and Water Quality Impact Assessment Results

This project will result in the reduction of emission of pollutants from the power plant

and it will also improve the ambient air quality. Retrofitting of the boilers is not expected

to change the pollutant load, no untreated liquid effluent will be discharged into the creek

and the profile of the thermal plume will remain unchanged. Therefore, there will be no

significant impact on the marine biodiversity from these aspects of project activities.




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4.5.3 Comparisons of Design Features of the Anticipated Projects with the Proposed Project

Exhibit 4.60 provides a comparison between some of the design specifications of the

proposed Project and the anticipated K-Electric and PQEPC plants.

Exhibit 4.60: Comparison of some Design Specifications between the

Proposed Project and PQEPC and K-Electric Projects

PQEPC K- Electric EPL

Project Area (acres) 203 (Plant-site only) Inside existing plant 37

Installed Net Power Generation Capacity (MW)

1200 420 (two converted boilers) 225

Primary Fuel Used Coal Coal Natural Gas

Boiler Type Supercritical Subcritical Combined Cycle Gas and Stream Turbines

Cooling-Water System

Recirculating with Cooling Tower

Once-through Recirculating with Cooling Tower

Water Intake Rate (m3/h)

11,482 321,000 (intake channel capacity for all six boilers of BQPS 1)

738

Water Discharge Rate (m3/h)

8,436 100,000 (intake channel capacity for all six boilers of BQPS 1)

397

Emission Rates of the Projects

SO2 (tons per day) 14.9 64.3 Negligible

PM10 (mg/Nm3) 44.8 100.0 Not emitted

PM2.5 (mg/Nm3) 22.4 50. Not emitted

NO2 (nanogram per Joule of heat input)

195.7 178.6 44.3

Increment in Ambient Concentrations (µg/m³) as a result of the Anticipated Projects

Annual 24–hour Annual 24–hour Annual 24–hour

SOx 5.1 18.0 50.0 102.5 Negligible Negligible

NOx 13.4 47.4 23.2 51.5 11.3 32.2

PM10 1.4 4.9 21.5 61.2 Negligible Negligible

4.5.4 Conclusion

A comparison of the design information and the impact assessment findings of the K-

Electric and PQEPC plant, with the design information of the proposed Project reveals

the following:




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Both the air quality and water quality impact assessments of K-Electric and

PQEPC plants indicate they will both be in compliance with SEQS and NEQS

standards.

The water intake and outfall rates of the proposed Project are far lower than

PQEPC and K-Electric plants.

The emission rates of the proposed Project are far less than those of the

anticipated K-Electric and PQEPC plants. In fact, the Project will not emit PM

and SOx.

The predicted increments of pollutants to the ambient air by the Project are less

than those of the anticipated K-Electric and PQEPC plants. There will be no

increments to PM and SOx concentrations as a result of the Project.

Taking the above into account, it can be safely concluded that the quantum of

contribution to cumulative air- and water-quality impacts from the Project will be

considerably low compared to other power projects in the PQA.



Hagler Bailly Pakistan Stakeholder Consultations

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5. Stakeholder Consultations

Stakeholder engagement is an integral part of the EIA process. Stakeholders are groups

and individuals that can be affected by or can affect the outcome of the project.1

Engaging with stakeholders helps ensure their suggestions and concerns regarding a

proposed project are taken into account during the project’s design-phase. Effective

stakeholder consultations involve informing the stakeholders about the project plans,

development activities, its potential consequences on the environment and the proposed

plans to mitigate the impacts. As a result, confidence is established amongst the

stakeholders that the project is being developed in a responsible manner. The consultation

process should last through the life of the project, providing a continuous platform for

stakeholders to voice any concerns.

As part of the scoping phase to identify potential impacts of the Project, stakeholder

consultations with communities were held from March 13–16, 2015, whereas

institutional stakeholder consultations were held on March 18 and 19, 2015. Community

consultations were conducted in settlements located around the PQA within a 10 km

radius from the proposed Project-site. Institutional consultations were held with

industries located in the PQA and with non-governmental organizations (NGOs)

specializing in the field of ecology and nature-conservation.

This section provides a summary of the concerns, expectations and feedback shared by

the stakeholders. The complete record of the consultations is provided in Appendix D.

After the preparation of the draft of the EIA report, a second round of consultations will

be organized and the stakeholders will be informed about the measures that were taken to

address the issues raised by them in the previous consultation session. The consultation

record for the second round of consultations will be incorporated as an addendum to the

EIA report.

During the construction and operation phase of the Project, EPL will continue engaging

with stakeholders as a part of their environmental and social monitoring and management

plan. EPL will maintain a detailed log of these engagements.

5.1 Objectives of Stakeholder Consultations

The objectives of stakeholder consultations during an EIA include the following:

Ensure involvement of the affected and interested public into the project planning

and the EIA decision making processes;

Inform stakeholders of the proposed activities and its consequences;

1 This definition for Stakeholders is consistent with the definition adopted by the World Bank Group. See

Stakeholder Engagement: A Good Practice Handbook for Companies Doing Business in Emerging Markets, International Finance Corporation, 2007.




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Gather data and information from the stakeholders about their human and

biophysical environment, as well as about the relations they have with their

environment; and

Seek input from key stakeholders regarding the planned activities to increase its

positive outcomes and avoid or mitigate any negative impacts.

The views, interests and concerns of stakeholders were taken into account on the

following aspects of the Project:

Planning, design and implementation of the Project;

The assessment of the potential impacts of the Project and the identification of

appropriate mitigation measures;

The decisions by the regulatory authorities on whether to approve the project and

determination of corresponding conditions of approval.

5.2 National Regulations and International Practice for Stakeholder Consultations

The Project will adhere to the applicable national laws and international guidelines for

the EIA process in accordance with the legal framework for stakeholder consultations

explained below.

5.2.1 Pakistan Environmental Law

Public consultation is mandated under the Pakistan environmental law. The Federal

Agency, under Regulation 6 of the IEE-EIA Regulations 2000,2 has issued a set of

guidelines of general applicability and sectoral guidelines indicating specific assessment

requirements. This includes Guidelines for Public Consultation, 1997 (the ‘Guidelines’).

Key extracts that represent the underlying theme of the Guidelines are given below:

Objectives of consultations: “To inform stakeholders about the proposed project,

to provide an opportunity for those otherwise unrepresented to present their views

and values, providing better transparency and accountability in decision making,

creating a sense of ownership with the stakeholders”;

Stakeholders: “people who may be directly or indirectly affected by a proposal

will clearly be the focus of public involvement. Those who are directly affected

may be project beneficiaries, those likely to be adversely affected, or other

stakeholders. The identification of those indirectly affected is more difficult, and

to some extent it will be a subjective judgment. For this reason it is good practice

to have a very wide definition of who should be involved and to include any

person or group who thinks that they have an interest. Sometimes it may be

necessary to consult with a representative from a particular interest group. In such

cases the choice of representative should be left to the group itself. Consultation

should include not only those likely to be affected, positively or negatively, by the

2 Pakistan Environmental Protection Agency Review of Initial Environmental Examination and

Environmental Impact Assessment Regulations, 2000




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outcome of a proposal, but should also include those who can affect the outcome

of a proposal.”

Mechanism for consultations: “provide sufficient relevant information in a form

that is easily understood by non-experts (without being simplistic or insulting),

allow sufficient time for stakeholders to read, discuss, consider the information

and its implications and to present their views, responses should be provided to

issues and problems raised or comments made by stakeholders, selection of

venues and timings of events should encourage maximum attendance”;

Timing and frequency: “Ideally, the public involvement program should

commence at the screening stage of a proposal and continue throughout the EIA

process.”

Consultation tools: some specific consultation tools outlined in the Guidelines

that can be used for conducting consultations include; focus group meetings,

needs assessment, semi-structured interviews; village meetings and workshops.

Other important considerations: “The development of a public involvement

program would typically involve consideration of the following issues; objectives

of the proposal and the study; identification of stakeholders; identification of

appropriate techniques to consult with the stakeholders; identification of

approaches to ensure feedback to involved stakeholders; and mechanisms to

ensure stakeholders’ consideration are taken into account”.

5.2.2 International Practice

International guidelines, such as, the IFC PSs and World Bank (WB) policies for

environmental assessment layout the objectives and approach for stakeholder

consultations. Consultations are required for all development initiatives that lead to

environmental and social impacts. Some of the main principles laid out for consultations

include: 3,4,5,6

Stakeholder identification: Stakeholders include individuals and/or groups that

can be affected by or are interested in the development initiative. Consultations

should engage all types stakeholders, which can include potentially affected

communities, local government authorities, NGOs, academia and other civil

society bodies;

Selection of consultation techniques: Sufficient information should be shared with

the stakeholders in a timely and effective manner, with consideration for

stakeholder interests, linguistic and educational backgrounds, and socio-cultural

setting;

3 Performance Standard 1, January 2012, International Finance Corporation.

4 Meaningful Consultations in Environmental Assessment, September 1998. This note was prepared by Shelton H. Davis and Nightingale Rukuba–Ngaiza based on the World Bank's Operational Directive 4.01 on Environmental Assessments.

5 Stakeholder Engagement: A Good Practice Handbook for Companies Doing Business in Emerging Markets, May 2007, International Finance Corporation.

6 Operational Directive OD 4.20, September 1991, The World Bank Operational Manual, The World Bank.




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Arrangements for consultations: Venue and timing for consultation meetings

should be chosen in a manner that encourages maximum participation on behalf

of stakeholders;

Stages of consultation: Consultations should be conducted during the early cycle

of project development (scoping stage), so that the results and outcomes of the

consultations can contribute to the design process. Following this, stakeholders

should be provided feedback before finalization of the project’s environmental

design (feedback stage) on how their concerns, raised at the scoping stage, were

addressed through suitable mitigation or design changes;

Stakeholder feedback and use of results: The views of stakeholders should be

documented and then analyzed for use in more effective decision-making.

5.2.3 Good Practice Principles

The good practice principles that were adhered to during the consultations are listed

below:

Cultural sensitivity: this requires understanding and appreciation of the social

institutions, values, and culture of the communities in the project area and respect

for the historical, cultural, environmental, political and social backgrounds of the

communities which are affected by a proposal;

Interactive approach: consultation should not be limited to one–way

dissemination of information. Stakeholder comments should feed into the EIA

process and proposed project design;

Open, transparent and informative: People who are affected by the Project and

are interested in participating should have access to relevant information, in a

simple and understandable format;

Inclusive and equitable: Ensure that all stakeholder groups are represented,

including less represented groups such as women, children, elderly and poor

people;

Appropriateness and flexibility: Consultation methodologies must be appropriate

to the specific phase of the EIA process and the stakeholder groups identified.

The consultation should also be adjusted according to the resources available;

Capacity building: Capacity building should be a part of consultation interaction

wherever appropriate and practicable.

5.3 Stakeholder Identification and Analysis

As stated earlier, stakeholders are defined as groups and individuals that can take affect

or can affect the outcome of a project. Stakeholders that can be affected by the

construction and operation activities of the proposed Project were identified during a

desk-based screening phase and include all groups and individuals that can take affect or

can be affected by its outcomes.

The identified communities and institutions were consulted through their representatives

during the consultations.




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Groups and individuals that hold interest in the Project and can influence the outcome of

the Project (latter part of the definition of stakeholders) include:

Government and regulatory authorities directly or indirectly connected to or

responsible for overseeing the activities of the Project;

Industries or NGOs working in areas that can be affected by the Project;

Academia that can be interested in transfer of skill and knowledge aspect of the

Project.

The identified potential impacts that may occur at various stages of the Project and the

potentially affected stakeholders of these impacts are listed in Exhibit 5.2. The

stakeholders were identified on the basis of the most recent information and

understanding of the Project and its surrounding environment. This understanding

changes during the course of the EIA, as more information is gathered. In addition, both

stakeholders and their interests can change over the life of the Project. Therefore,

stakeholder identification and analysis is understood to be a dynamic process which is

continued through the course of the EIA and the life of the Project.

On the basis of the potential impacts, the following groups were identified as those which

may have an interest in the Project or may be impacted by Project activities.

Communities near the coast which are dependent on the ecological resources

(especially fish) present in and around the location of the proposed Project.

Communities present in and around the location of the proposed Project which are

likely to be the source of local labor.

Communities located within 10 km of the proposed Project-site.

Key institutional stakeholders (businesses and industries) located close to the site

of the proposed Project.

NGOs working in areas that can be affected by the Project.

A different consultation approach was adopted for each target group to suit their varying

backgrounds, as described ahead.




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Exhibit 5.1: Identified Potential Impacts and the Affected or Interested Groups

Project Phase Activity Potential Impact Affected or Interested Group

Project Design and Location Land ownership issues may arise from the location of any associated component of the Project built outside land owned by EPL. Such associated structures may be the pipeline from the Custody Transfer Station to the Project, and the intake and outfall channels.


Siddique Sons

Trans Asia Refinery Limited

Construction Phase Issues associated with noise and vibration generated from construction activities disturbing nearby industries.

Increase in job opportunities for nearby communities.

Engro Polymer and Chemicals Ltd

Lotte Chemicals Pakistan Ltd

Engro Zarkhez Ltd

ASG Metals Limited

Siddique Sons

Trans Asia Refinery Limited

Linde Pakistan

Communities living within a 10-km radius from the Project

Shrine of Shah Hassan

Operation Phase Increase in job opportunities for nearby communities.

Deterioration in air quality and thus potential adverse health impacts on nearby communities.

Deterioration of sea water quality due to discharge of cooling water and effluents into the Gharo Creek, adversely affecting the marine flora and fauna. This may also reduce the presence of fish in the area affecting the livelihood of any fisherman dependent on the area.

Deterioration in sea water quality may also adversely impact intake water quality for neighboring industries.

Communities living within a 10-km radius from the Project


IUCN

WWF

K–Electric

Tuwairqi Steel Mills

Pakistan Steel Mills

Port Qasim Electric Power Company




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5.4 Consultation Methodology

The methodology adopted for stakeholder consultations is summarized below:

5.4.1 Consultation Material

The main document for distribution to stakeholders during the consultations was the

Background Information Document (BID). The BID contained information on the

preliminary design of the Project and the EIA process. The BID developed for the Project

is provided in Appendix E. It was also made available to community stakeholders in

Urdu to accommodate their language preferences.

5.4.2 Consultation Mechanism for Institutional Consultations

Letters to inform the institutional and industrial stakeholders about the objectives of the

consultation process and to set up meetings with them were dispatched in the first week

of March, 2015. A copy of the BID was enclosed with the letters which contained

information regarding the Project design. All industrial stakeholders were invited for a

consultation meeting which was held on March 18, 2015, at the Arabian Sea Country

Club located in the PQA. Other institutional stakeholders with offices outside the PQA

were visited at their respective offices.7

The list of institutional stakeholders to whom letters were sent is provided in Exhibit 5.2.

The same table also indicates those among the recipients of the letter that did not

participate in the consultation process. Exhibit 5.3 provides a few photographs from the

consultations. The locations of the industrial stakeholders are shown on a map in

Exhibit 5.5.

The consultation sessions progressed in the following manner:

The main points of the BID and Project design were described to the stakeholders.

Through the BID, an overview of the Project and EIA process was provided.

Stakeholders were given the opportunity to raise queries or concerns regarding the

Project. Queries were responded to and concerns were documented.

7 The stakeholders were consulted during the scoping consultation visits carried out for 225 MW RLNG

CCPP (the initial design of the Project). These stakeholders were consulted again to discuss the change in the Project design from 225 MW to 450 MW. The background information document (BID), shared with the stakeholders for the updated design is attached at Appendix E of this report. The main objective for

consulting the stakeholders again was to record their concerns associated with the updated design.




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Exhibit 5.2: List of Institutions and Industries Consulted with

Consultation Location and Date

Stakeholder Consultation Location Date Consulted

Pakistan Steel Mills (PSM) Arabian Sea Country Club, PQA, Karachi

Mar 18, 2015



Engro Zarkhez

The stakeholder confirmed receipt of invitation letter for consultation at the Arabian Sea Country Club, however, they did not attend the consultation session.

K-Electric

Lotte Chemical Pakistan Ltd


Linde Pakistan Limited

Port Qasim Electric Company


Siddique Sons

ASG Metals Limited

The World Conservation Union (IUCN) IUCN Office, 1 Bath Island, Clifton, Karachi

Mar 19, 2015

World Wildlife Fund (WWF) WWF Office, 46-K, PECHS, Shara-e-Faisal Karachi

Mar 19, 2015

Exhibit 5.3: Photographs of Institutional Stakeholder Consultations

Consultation session at Arabian Sea Country Club Consultation with IUCN

Consultation with WWF




R5A05ENP: 09/29/15 5-9

5.4.3 Consultation Mechanism for Community Consultations

Community consultations were conducted from March 13–16, 2015. Separate

consultation sessions were conducted with community women by female team members.

The community consultations were conducted with the community members within their

settlements to encourage and facilitate their participation.

The list of communities consulted along with the geographical coordinates and dates

when the consultations took place are shown in Exhibit 5.4. The locations of the

community stakeholders are shown on a map in Exhibit 5.5. Photographic records of the

consultations with men and women from the communities are presented in Exhibit 5.6.

The meetings progressed in the following manner:

Stakeholders were introduced to the HBP team and briefed about the consultation

process and its objectives;

The main points of the BID were read out to the stakeholders in Urdu and Sindhi,

depending on their language preference. Through the BID an overview of the

Project and EIA process was provided;

Stakeholders were given the opportunity to raise queries or concerns regarding the

Project. Queries were responded to and concerns were documented.

Exhibit 5.4: List of Communities Consulted in Chronological Order with the

Geographical Coordinates of the Consultation Locations

Location District Province Coordinates Date Consulted

Latitude Longitude

Gulshan-e-Hadeed Malir Sindh 24 52 3.44 67 21 13.27 Mar 13, 2015

Ameen Muhammad Baloch Malir Sindh 24 49 23.4 67 26 25.8 Mar 13, 2015

Muhammad Qasim Malir Sindh 24 50 16.4 67 26 29.9 Mar 13, 2015

Haji Ibrahim Malir Sindh 24 50 30.1 67 25 54.3 Mar 13, 2015

Mir Khan Baloch Malir Sindh 24 51 11.8 67 26 39.6 Mar 13, 2015

Haji Ghulam Muhammad Malir Sindh 24 50 40.7 67 26 05.1 Mar 14, 2015

Haji Jhangi Khan Malir Sindh 24 51 04.7 67 25 44.7 Mar 14, 2015

Haji Khan Zohrani Malir Sindh 24 51 31.9 67 25 31.8 Mar 14, 2015

Humar Khan Malir Sindh 24 51 32.2 67 25 56.5 Mar 14, 2015

Pir Bux Malir Sindh 24 51 50.1 67 25 57.1 Mar 14, 2015

Pipri Malir Sindh 24 51 15.29 67 20 9.61 Mar 14, 2015

PSM town Malir Sindh 24 51 56.88 67 20 26.07 Mar 16, 2015

Soomar Jhokio Malir Sindh 24 52 15.7 67 22 31.0 Mar 16, 2015

Natho Tando Khoso Malir Sindh 24 50 51.8 67 25 40.0 Mar 16, 2015

Morand Khan Qaisrani Malir Sindh 24 51 21.4 67 22 55.0 Mar 16, 2015




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Exhibit 5.5: Locations of Community and Industrial Stakeholders




R5A05ENP: 09/29/15 5-11

Exhibit 5.6: Photographs of Community Consultations

Consultation with members of Ameen Mohammad Baloch community

Consultation with members of Muhammad Qasim community

Consultation with members of Haji Ibrahim community Consultation with members of Mir Khan Baloch community

Consultation with members of Haji Ghulam Muhammad community

Consultation with members of Haji Khan Zohrani community




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Consultation with members of Humar Khan community

Consultation with members of Pir Bux community

Consultation with members of Soomar Jhokio community Consultation with members of Natho Tando Khoso

community

Consultation with members of Morand Khan Qaiserani community

Consultation with the residents of Gulshan-e-Hadeed

Consultation with the residents of Gulshan-e-Hadeed Consultation with the residents of Pipri




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Consultation with Secretary Union Council, Gulshan-e-Hadeed

Consultation with manager, estate department, PSM town

Consultation with the females of Haji Khan Zohrani Consultation with the females of Humar Khan

Consultation with the females of Natho Tando Khoso Consultation with the females of Soomar Jokhio

5.4.4 Documentation and Reporting

The HBP team recorded all the discussions held with both the institutions and

communities which have been documented in the form of a detailed log provided in

Appendix H. Exhibit 5.7 provides a summary of the concerns expressed by the

community stakeholders and states EPL’s response. Similarly, Exhibit 5.8 contains a

summary of the concerns raised by the institutional stakeholders and provides EPL’s

response.




R5A05ENP: 09/29/15 5-14

Exhibit 5.7: Summary of Concerns Raised by Communities

Comments/Issues raised Response by EPL

Air Quality The impact of air emissions from the existing plants in PQA and from the proposed Project should be mitigated and minimized.

All the emissions from the proposed Project will comply with NEQS and IFC standards.

Effluent Discharge

The wastewater stream from fertilizer plants in PQA attracts many insects and diseases. Any effluents from the proposed Project should be treated.

All effluents from the Project will comply with NEQS and IFC standards.

Employment The villagers have no permanent and reliable source of income. The villagers did not obtain employment in the previously constructed industries in PQA. The management of existing factories did not fulfill their promises of providing employment to the local community members. It is therefore reasonable for the villagers to expect that they will be meted out the same treatment with construction of the new power plant Project.

The locals residing in the Socioeconomic Study Area include individuals with technical diplomas and university degrees. Preference should be given to those who suit best to be employed during construction and operation phased of the Project.

There are various contractors of local origin who have the capability to supply raw material and labor required for the Project. These contractors should be hired by EPL during construction phase of the Project for material supply and provision of local labor.

Recruitment from local settlements will be given a priority. Locally available labor will be used where demanded skills match the skills in the local area.

Social Educational facilities and quality education should be provided to the villagers.

There is a scarcity of potable water which is a major problem in the villages. The inhabitants are bound to buy water tankers which are expensive and beyond the means of the inhabitants. Potable water should be provided by the project proponent to the villagers.

EPL will plan and implement a Corporate Social Responsibility Plan (CSR) for the welfare of local communities in the vicinity of the Project.

Healthcare infrastructure in the area is lacking. Hepatitis B, C and respiratory diseases are common in the area. Health facilities or such as medical camps should be set up for the locals and ambulances should be arranged for the villagers.

Preference should be given to locals for the provision of electricity produced and then to the rest of Pakistan.

Provision of electricity to specific areas is not under the jurisdiction of EPL.




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Exhibit 5.8: Summary of Concerns Raised by Institutions

Issues raised Response by EPL

Biodiversity Green patches in the PQA should be preserved. EPL should, on its own, or in conjunction with the PQA, preserve this green patch north of its boundary wall.

The proposed Project will be located on a barren piece of land with no vegetation on it. The construction of the proposed Project will be carried out within the boundary wall of the plot and the construction management plan will ensure that there is no construction or material-handling activity that spills outside the boundary wall of the plot. In this way, both the construction and operation phase of the Project will have no adverse impact on the green patch north of the boundary wall.

Other than this, as part of its CSR, EPL will look into what it can do to preserve the green patches with cooperation from the PQA and other industries in the PQA.

EPL should keep at least 5% of the built area in its plant reserved for greenery. EPL should also set aside some of its revenue to invest back into the ecosystem it will be using such as the airshed to release emissions and Gharo Creek for intake and outfall.

EPL will consider these aspects in the design.

Cooling Water System

What will be the design of the cooling water system? Is it a once-through system? Will there be cooling towers installed? How will the Project be able to achieve the NEQS standards for temperature of the outfall?

EPL is in the process of finalizing the design of the proposed Project. Once, finalized, the design will be described in detail in the Project Description section of the EIA report. Regardless of what mechanism is finally chosen, the plant will meet the NEQS, SEQS and IFC standards for effluent discharge.

(Please see Section 3.4)

Water Intake If groundwater exists in PQA it will be in small interconnected pockets due to the rocky geology of the Port Qasim area. At the intake rate proposed for the Project, it will quickly dry out the entire network of underground aquifers in the PQA. Finishing the groundwater may damage the natural process which it may be supporting. We would like to suggest that EPL should use water from the Gharo Creek instead.

The final option for sourcing intake water will be finalized after in-depth feasibility and environmental studies. The EIA report will include an impact assessment study of the final option to be utilized.





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Issues raised Response by EPL

Effluent Discharge

EPL should recycle all of its effluent rather than discharging it into the Gharo Creek. The recycled effluent can be used for watering green areas in the plant or for sprinkling over dust and other purposes. At the moment all of the industries in the vicinity of the proposed Project are discharging their effluent into the Gharo Creek. Anticipated projects in the region will also do the same. The Gharo Creek may be able to absorb the existing effluent pressure; however, with all the industries being planned here in the future, the Gharo Creek may become a dead creek in terms of biodiversity. In time, adjoining creeks may also suffer badly.

The proposed Project is a natural gas-based power plant which has little to no chemicals present in its effluent discharge. The effluent will primarily consist of concentrated salt water from the cooling-water discharge. In addition, the effluent generated will comply with both the NEQS/SEQS and IFC standards for industrial effluents. EPL will also look into maximizing reuse of effluents generated.

Cumulative Impacts

We would like to recommend that EPL also considers conducting a cumulative impact assessment study keeping in mind the anticipated developments in the area.

Cumulative impact studies are usually conducted by government bodies or together by a group of developers. It is individually conducted by a single developer if the scale of their impacts contributing to the cumulative impacts is very high. In this case, the proposed Project is a natural gas-based power plant which is considered to be a very clean fuel. The EIA report will provide a comparison between the water consumption, emissions and effluents rate between natural gas based plants and other such as coal-fired plants.




Hagler Bailly Pakistan Scoping of Environmental and Social Impacts

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6. Scoping of Environmental and Social Impacts

A development project can have adverse as well as beneficial environmental and social

impacts. The extent of the impacts depends on the nature and magnitude of the proposed

activities and the type and sensitivity of the host environment.

Prior to carrying out in-depth impact assessment of identified potential impacts, a scoping

exercise is carried out in this section to determine the significance of the identified

impacts. The significance of the impact can be rated as low, medium or high according to

the anticipated probability of the impact occurring and a preliminary understanding of the

nature of its consequence in terms of its magnitude, duration, and spatial scale

By using professional judgment, and, analyzing the information on project design in

Section 3, the existing environmental conditions at the Project-site in Section 4, and

taking into account feedback from stakeholder consultations in Section 5, the scoping

exercise in this section evaluates the likely significance of the identified environmental

and social impacts arising from the Project. Project activities identified as having

negligible impact, if any, or no impact whatsoever are also identified at this stage.

6.1 Scoping Methodology

Potential environmental and social impacts are identified on the basis of the professional

opinions of the specialists involved in carrying out the EIA, technical guidelines and

concerns raised by stakeholders. The environmental scoping process in this section is

conducted using a systematic approach to assess all possible impacts arising from various

phases of the proposed Project. The approach comprises of the following steps:

1. Criteria are defined for determining probability, magnitude, duration and spatial

scale for identified potential impacts. The criteria are a mix of the following:

a. Institutional recognition—laws, standards, government policies, or plans

b. Technical recognition—guidelines, scientific or technical knowledge, or

judgment of recognized resource persons

c. Public recognition—social or cultural values or opinion of a segment of the

public, especially the community directly affected by the Project

d. Professional interpretation of the evaluator.

2. For each identified impact, a justification is provided for the selection of ratings

of probability, magnitude, duration and spatial scale against the defined criteria.

The consequence rating is determined based on the magnitude, duration and

spatial extent of the identified impacts.

3. Together with the consequence and probability of the identified impact, an impact

significance rating is determined as either ‘no impact or not significant’, ‘low’,

‘medium’ or ‘high’.

Impacts with significance rated ‘no impact or not significant’ or ‘low’, as an outcome of

the scoping exercise, will not be included for further impact assessment beyond the




R5A05ENP: 09/29/15 6-2

scoping exercise. On the other hand, impacts with significance rated ‘medium’ or ‘high’

will have the potential impacts assessed in-depth in Section 7. This may be achieved

through the use of models or comparison with other similar activities.

The impact assessment process in Section 7 will comprise of the following steps:

1. Prediction of the magnitude of potential impacts: This step refers to the

description, quantitatively (where possible) or qualitatively, of the anticipated

impacts with of the proposed Project. This may be achieved through the use of

models or comparison with other similar activities.

2. Identification of mitigation measures: There is a range of mitigation measures

that can be applied to reduce impacts.

3. Evaluation of the residual impact: Incorporation of the suggested mitigation

measures reduces the adverse impact of a project and brings it within acceptable

limits. This step refers to the identification of the anticipated remaining impacts

after mitigation measures have been applied, i.e., the residual impacts.

4. Identification of monitoring requirements: The last step in the assessment process

is the identification of minimum monitoring requirements. The scope and

frequency of the monitoring required depends on the residual impacts identified.

The purpose of monitoring is to confirm that the impact is within the predicted

limits and to provide timely information if unacceptable impact is taking place.

The criteria used for determining the magnitude, duration and spatial scale of the

identified potential impacts are provided in Exhibit 6.1. The criteria used for determining

consequence and probability, and thus the significance rating of identified impacts, are





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Exhibit 6.1: Defining Criteria for determining Magnitude, Duration and

Spatial Scale of Identified Impact

Impact characteristics

Definition Criteria

MAGNITUDE Major Substantial deterioration or harm to receptors; receiving environment has an inherent value to stakeholders; receptors of impact are of conservation importance; or identified threshold often exceeded

Moderate Moderate/measurable deterioration or harm to receptors; receiving environment moderately sensitive; or identified threshold occasionally exceeded

Minor Minor deterioration (nuisance or minor deterioration) or harm to receptors; change to receiving environment not measurable; or identified threshold never exceeded

Minor+ Minor improvement; change not measurable; or threshold never exceeded

Moderate+ Moderate improvement; within or better than the threshold; or no observed reaction

Major+ Substantial improvement; within or better than the threshold; or favorable publicity

DURATION/ FREQUENCY

Continuous aspects Intermittent aspects

Short term/ low frequency

Less than 4 years Occurs less than once a year

Medium More than 4 years up to end of life of project (approximately 30 years)

Occurs less than 10 times a year but more than once a year

Long term/ high frequency

Beyond the life of the project (greater than 30 years)

Occurs more than 10 times a year

SPATIAL SCALE

Biophysical Socioeconomic

Small Within 200 meters (m) of the Project footprint. Or, if in a marine environment, impact is within 50 m from the shore.

Within the PQA industrial area

Intermediate Within 3 kilometer (km) of the Project footprint. Or, if in a marine environment, impact extends to more than 50 m but is less than 200 m from the shore.

Outside the PQA but within the Study Area i.e 10 km from the Project-site

Extensive Beyond 3 km of the Project footprint Or, if in a marine environment, impact extends beyond 200 m from the shore.

Beyond 15 km from the Project facilities




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Exhibit 6.2: Determining Consequence, Probability and Significance Rating of

Identified Impacts

DETERMINING CONSEQUENCE RATING

Rate consequence based on definition of magnitude, spatial extent and duration

SPATIAL SCALE

Small Intermediate Extensive

MAGNITUDE

Minor DURATION/ FREQUENCY

Long / high Medium Medium Medium

Medium Low Low Medium

Short / low Low Low Medium

Moderate DURATION/ FREQUENCY

Long / high Medium High High

Medium Medium Medium High

Short / low Low Medium Medium

Major DURATION/ FREQUENCY

Long / high High High High

Medium Medium Medium High

Short / low Medium Medium High

DETERMINING SIGNIFICANCE RATING

Rate significance based on consequence and probability

CONSEQUENCE

Low Medium High

PROBABILITY

(of exposure to impacts)

Definite Low Medium High

Possible Low Medium High

Unlikely Low Low Medium

+ denotes a positive impact.

6.2 Scoping of Identified Potential Environmental and Social Impacts

Exhibit 6.3 provides a table which lists the different activities that will be carried out

during the construction and operation of the Project. The identified potential impacts

associated with the activities are also listed. Ratings for the probability, magnitude,

duration and spatial scale of the impacts are also provided along with a supporting

rationale. Using the ratings, the table also lists the significance of each impact which is

determined using its probability and consequence.

The summary of the results from the scoping exercise is as follows:

No Impact or Not Significant — The following impacts were determined to not

occur at all or to have no significance. These will not be assessed further beyond

this scoping exercise.

Impact 1 – Potential socioeconomic impacts related to resettlement or

equitable sale of privately-owned land required for the development of the

Project.




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Impact 2 – Potential impacts related to occupational health and safety of

neighboring industries from the fundamental design quality, configuration and

layout of the plant.

Impact 3 – Potential adverse land-use changes from the intake and outfall

channels altering the fundamental structure of the land through which they

will traverse. This may result in damaging or adversely affecting existing or

intended land-use at the route of the proposed channels.

Impact 6 – Potential loss of livelihood and/or nutrition for local fishermen

from dwindling fish species in the Gharo Creek due to habitat degradation as a

result of construction activities in the creek for the intake and outfall channels.

Impact 8 – Any adverse environmental or social impacts arising out of the

location of the storage area and/or the transportation and handling of stored

material/equipment.

Impact 10 – Contamination of water resources, spread of foul-smelling and

noxious odor due to sanitary, solid, oily and liquid waste generated during the

construction of the Project.

Impact 13 – Contamination of water resources or spread of foul-smelling or

noxious odor due to solid waste generated during the operation of the Project.

Impact 17 – Occupational health and safety risks to existing industries in the

vicinity of the Project during operation.

Low Impact Significance — The following potential impacts were rated as being low in

significance. These impacts do not require additional mitigation measures beyond those

already inherent in the Project design. These impacts will not be considered for further

assessment beyond this scoping exercise.

Impact 4 – Increase in ambient noise levels and decrease in air quality levels

from fugitive dust emissions in the vicinity of the Project-site due to

construction activities.

Impact 9 – Adverse impact on the level of service of the roads used for

transportation during the construction phase, from congestion due to

additional Project-related traffic.

Impact 14 – Direct physical damage to marine species from entrainment into

the intake channel.




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Medium Impact Significance — The following potential impacts were rated as

having medium significance. These will be considered for impact assessment1 in

Section 7 and mitigation measures will also be provided which will be a part of

the EMP in Section 8.

Impact 5 – Habitat degradation, and thus damage to aquatic species, in the

Gharo Creek as a result of direct physical damage or decrease in water quality

from turbidity from the construction of the intake and outfall channels.



Impact 11 – Gaseous emissions from the Project during the operation phase

may result in the deterioration of ambient air quality beyond the limits

prescribed by SEQS and IFC EHS guidelines.

Impact 15 – Habitat degradation and thus damage to aquatic species in the

Gharo Creek from increased concentration of brine discharged in the Project

effluent during operation.

Impact 16 – Potential cumulative impacts from the effluent discharge of

existing and anticipated industries on water quality in the Gharo Creek

resulting in marine habitat degradation

High Impact Significance — Only one impact was rated as having high

significance: Impact 12.

Impact 12 – Potential cumulative impact of gaseous emissions from the

Project and anticipated industries on air quality in the PQA airshed may

increase pollutant concentrations beyond the prescribed SEQS and IFC EHS

limits.

However, it is an identified potential impact which will require an assessment of

the cumulative impacts of the Project and anticipated developments in the PQA

on the air quality of the PQA airshed. A cumulative impact assessment exercise is

considered beyond the scope of this EIA study due to the following reasons: (a)

There is limited publically available information regarding anticipated

developments in the PQA; (b) Using information on two anticipated

developments in the vicinity of the Project-site in Section 4.5, it has been

demonstrated that the relative contribution of the Project to the potential

cumulative impacts will be relatively small; and, (c)The existing baseline

conditions in the PQA (Section 4.2.4) do not indicate a degraded airshed in the

PQA.

1 There is one exception: Impact 16 is an identified potential impact with medium significance which will

require an impact assessment of the cumulative impacts of the Project and anticipated developments in the PQA on the water quality and, thus, the ecological resources of the Gharo Creek. A cumulative impact assessment exercise is considered beyond the scope of this EIA study due to the following reasons: (a) There is limited publically available information regarding anticipated developments in the PQA; (b) Using information on two anticipated developments in the vicinity of the Project-site in Section 4.5, it has been demonstrated that the relative contribution of the Project to the potential

cumulative impacts will be relatively small; and, (c)The existing baseline conditions in the PQA (Section 4.2.3) do not indicate a degraded environment particularly with respect to water quality and the

status of the ecological resources in the Gharo Creek.




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Exhibit 6.3: Scoping of Environmental and Social Impacts of the Proposed Project

Impact No. Phase Activities Identified Potential Impact Probability Magnitude Duration Spatial Scale

Consequence Significance

Project Design and Location

1 Land Acquisition Potential socioeconomic impacts related to resettlement or equitable sale of privately-owned land required for the development of the Project.

None: The Project and its associated components such as the CTS, gas pipelines, intake/outfall channel will be built on empty barren land owned by EPL or acquired by the PQA or other industries. There are no settlements in the PQA and all land in the PQA is owned by the PQA and leased to other industries.

No Impact No Impact No Impact No Impact No Impact

2 Design of the Power Plant

Potential impacts related to occupational health and safety of neighboring industries from the fundamental design quality, configuration and layout of the plant.

None: EPL will design, construct, operate, and decommission the structural elements or components of the Project in accordance with good industrial and international practice. Structural elements will be designed and constructed by competent professionals, and certified or approved by competent authorities or professionals.


3 Design of Intake and Outfall Channels

Potential adverse land-use changes from the intake and outfall channels altering the fundamental structure of the land through which they will traverse. This may result in damaging or adversely affecting existing or intended land-use at the route of the proposed channels.

None: Water intake channel will be built through empty plots of land extending approximately 600 m from the southern end of the Project-site and ending at the Gharo Creek (Section 3.4.3). Wastewater will be discharged through an effluent channel into the Badal Nullah. EPL will acquire the land area required for these components from the PQA or existing industries that are leasing it. The channels will be designed to ensure there are no impacts that may alter the fundamental structure of the land through which it will traverse and damage or adversely affect existing or intended use by its owners or by land owners in adjacent plots.


Construction Phase

4 Site Preparation, Civil/Installation Works and General Construction Activity for Power Plant and CTS

Increase in ambient noise levels and decrease in air quality levels from fugitive dust emissions in the vicinity of the Project-site due to construction activities.

Definite: Site-preparation, civil/installation works and general construction activities will result in the generation of noise, fugitive dust and traffic. These perturbations will extend beyond the boundaries of the Project-site.

Minor: There are no sensitive receptors in the vicinity of the construction site, only existing industries. These receptors will not be susceptible to the quantum of dust and noise generated during the construction activities. Similarly, traffic generated due to construction works will be intermittent and limited mostly to the PQA

Short term: These impacts are likely to be generated only during the construction phase of the Project which is expected to be 2 years.

Small: Impacts related to noise and air quality are not expected to extend beyond 200 m of the Project-site. The concentration of additional traffic due to Project construction will be within PQA roads only.

Low Low




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roads which have been designed to cater for industrial activity in the estate.

5 Site Preparation and Civil Works for Intake and Outfall Channels

Habitat degradation, and thus damage to aquatic species, in the Gharo Creek as a result of direct physical damage or decrease in water quality from turbidity from the construction of the intake and outfall channels.

Definite: The construction activities related to the intake and outfall will extend into the Gharo Creek.

Moderate: According to the ecological baseline in Section 4.3, Gharo Creek is host to marine benthic invertebrates, fish species, crabs and crustaceans. These ecological resources at the location of the construction activities in the creek will be harmed. The same section also states that none of these species in the creek are critically endangered nor are any livelihoods of local fishermen attached to these resources.

Short term: The construction phase is expected to last 2 years.

Intermediate: The length of the outfall channel extending into the Gharo Creek will be 190 m away from the PQA shoreline. The intake channel will not extend more than a few meters beyond the shoreline.

Medium Medium

6 Site Preparation and Civil Works for Intake and Outfall Channels

Potential loss of livelihood and/or nutrition for local fishermen from dwindling fish species in the Gharo Creek due to habitat degradation as a result of construction activities in the creek for the intake and outfall channels.

None: Only recreational fishing activities are carried out in the Gharo Creek (Section 4.4.6). Therefore, any loss of marine species in the creek will not have any impact on the socioeconomic conditions of fishermen in the area. Nor will any recreational fishing activities be hindered by the construction activities as the fishermen will be able to avoid the area of disturbance.


7 Establishment of a Construction Camp

Employment and livelihood generated for skilled and semi-skilled personnel hired during the construction of the Project.

Definite: A construction camp will be set up within the boundary limits of the plot owned by EPL.

Major+: There are no settlements close to the Project-site and workers in the camp will be isolated from communities. The supply of workers will be made available through third-party contractors who will screen the workers’ health condition and age and comply with national labor laws.

All solid waste and sanitary waste generated as a result of the construction camp will be disposed at designated areas by licensed contractors.


Intermediate: Personnel will be hired from communities living in settlements surrounding the PQA.

Medium Medium




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8 Storage of material and equipment for construction

Any adverse environmental or social impacts arising out of the location of the storage area and/or the transportation and handling of stored material/equipment.

None: All materials and equipment required during the construction phase will be stored within the boundary of the plot owned by EPL. It will be safely managed to ensure health and safety of workers and the preservation of machinery and equipment.


9 Transportation of material, equipment and staff

Adverse impact on the level of service of the roads used for transportation during the construction phase, from congestion due to additional Project-related traffic.

Definite: During the construction phase, vehicles carrying workers, staff and equipment will be added to the PQA roads.

Minor: Being an industrial area, the roads in the PQA have been designed to cater for the construction and operation of industries in the entire estate without having an adverse impact on the level of service of the roads and without adversely impacting transport operations of any of the industries there.

In addition, almost all of the traffic in the PQA is related to industrial processes and the movement of employees. All Project-related transportation activities will be carried out according to high health and safety standards to ensure there are no accidents.


Small: During construction, there may be some travel required on roads outside the PQA due to delivery of machinery or labor; however, such traffic will only be a very small percentage of the overall transport related activities.

Low Low

10 Waste disposal Contamination of water resources, spread of foul-smelling and noxious odor due to sanitary, solid, oily and liquid waste generated during the construction of the Project.

None: All solid, liquid and sanitary waste generated during the construction phase will be collected and disposed by licensed contractors at designated waste disposal sites. No hazardous waste will be generated during the construction works. Third-party contractors will ensure all waste is disposed according to NEQS requirements. No waste will be dumped into the Gharo Creek.


Operational Phase

11 Gaseous emissions Gaseous emissions from the Project during the operation phase may result in the deterioration of ambient air quality beyond the limits prescribed by SEQS and IFC EHS guidelines.

Definite: During the operation phase, the main and bypass stacks of the power plant will emit NOx and CO2 (Section 3.3). Quantities of PM and SOx produced, if any, will be negligible.

Minor: All emission rates will comply with air emissions standards as prescribed by the SEQS and IFC EHS guidelines.

NOx emissions, although within the prescribed limits of SEQS and IFC EHS guidelines, may raise ambient air quality levels for NOx above the

Medium: The impact is expected to last till the end of life of project (approximately 30 years)

Extensive: The emissions are expected to spread in the airshed beyond 3 km from the Project-site.

Medium Medium




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prescribed SEQS and IFC limits for ambient air quality.

However, this is unlikely given the fact that the results from the ambient air quality survey (Section 4.2.4) indicate the existing concentration of NOx in the ambient air is well below the two limits.

12 Gaseous emissions Potential cumulative impact of gaseous emissions from the Project and anticipated industries on air quality in the PQA airshed may increase pollutant concentrations beyond the prescribed SEQS and IFC EHS limits.

Possible: There are other power plants anticipated in the vicinity on the Project. These include PQEPC's 2 X 660 MW coal-fired power plant and K-Electric's conversion to coal-fired boilers. Along with these, Pakistan Steel Mills is already operational in the area.

The cumulative impact on air quality from the existing industries in the PQA and the proposed Project is unlikely to deteriorate air quality beyond the prescribed SEQS and IFC EHS limits. This is due to the fact that the results from the ambient air quality survey (Section 4.2.4) indicate the existing concentration of pollutants in the ambient air, as a result of existing industries in the PQA, is well below the SEQS and IFC EHS limits.

However, this combined with future developments in the PQA may result cumulative air quality impacts which increase the concentration of pollutants above the prescribed legal limits.

Even in such a scenario, Section 4.5 compares the incremental emissions from Project and compares them to the increments as a result of some anticipated developments in the PQA to indicate that the Project’s overall contribution will be relatively small.

Major: The cumulative impacts on air quality may increase the concentration of pollutants above the prescribed legal limits.

Long term: The cumulative impacts are expected to last as long as the combined operational ages of all existing and anticipated developments in the PQA.

Extensive: The cumulative emissions are expected to spread in the airshed beyond 3 km from the Project-site.

High High




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13 Solid Waste disposal Contamination of water resources or spread of foul-smelling or noxious odor due to solid waste generated during the operation of the Project.

None: All solid, liquid and sanitary waste generated during the operation phase will be collected and disposed by licensed contractors at designated waste disposal sites. No hazardous waste will be generated during operation. Third-party contractors will ensure all waste is disposed according to NEQS requirements. No waste will be dumped into the Gharo Creek.


14 Water Intake Direct physical damage to marine species from entrainment into the intake channel.

Unlikely: For cooling water purposes the Project will pump water from Gharo Creek through an intake channel (Section 3.4.3). The intake channel will be designed to prevent entrainment of marine species into the channel.

Minor: Despite designing the intake channel to ensure minimum entrainment, there is still a small possibility that some marine species may still be entrained and suffer from direct physical damage.

Medium: Cases of entrainment are expected to occur more than once a year.

Small: Entrainment is most likely closest to the entrance of the intake channel.

Low Low

15 Effluent Discharge Habitat degradation and thus damage to aquatic species in the Gharo Creek from increased concentration of brine discharged in the Project effluent during operation.

Definite: Effluent from the Project (Section 3.4) will be discharged into Badal Nullah from where it flow into the Gharo Creek.

Moderate: According to the ecological baseline in Section 4.3, Gharo Creek is host to marine benthic invertebrates, fish species, crabs and crustaceans.

Other than the increased concentration of brine in the effluent, the effluent will meet SEQS and IFC EHS standards for industrial discharge of effluents into the sea.

The increase in the concentration of brine as a result of the effluent may disturb marine habitat at the point of discharge into the Gharo Creek. There may be a reduction in the number of marine species in the area due to habitat degradation.

There are no critical aquatic species in the area and only recreational fishing activities are carried out in the Gharo Creek (Section 4.4.6). Therefore, any loss of marine species in the creek will not have any impact on the socioeconomic conditions of fishermen in the area.

Medium: The impact is expected to last till the end of life of project (approximately 30 years)

Small: The effects of the effluent discharge are not expected to extend beyond 100 m from the point of discharge into the Gharo Creek.

Medium Medium




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16 Effluent Discharge Potential cumulative impacts from the effluent discharges of existing and anticipated industries on water quality in the Gharo Creek resulting in marine habitat degradation.

Although, individually, the quality of the effluent will be within SEQS and IFC EHS limits, together with the effluent discharges of existing and anticipated industries into the Gharo Creek, the water quality of the creek may degrade further.

However, this is unlikely given the fact that the existing water quality of the Gharo Creek (Section 4.3.2) does not indicate any signs of being contamination as a result of effluents from existing industries. In addition, a comparison of the quantum of effluent discharge between the Project and other anticipated developments in the PQA (Section 4.5) indicates that that the effluent contribution from the Project will be relatively small.

Possible: There are other power plants anticipated in the vicinity on the Project. These include PQEPC's 2 X 660 MW coal-fired power plant and K-Electric's conversion to coal-fired boilers. Along with these, Pakistan Steel Mills is already operational in the area. All of these industries either intend to or are currently discharging their effluents into the Gharo Creek.

The cumulative impact on water quality in the Gharo Creek from the existing industries in the PQA, the proposed Project and future developments in the PQA may result cumulative water quality.

Minor: As long as the effluents being discharged into the Gharo Creek by different industries comply with NEQS limits, the magnitude of the cumulative impacts is expected to be small. This is due to the hydrological characteristics of the receiving body which is part of a creek system with an outlet into the Arabian Sea.

Long term: The cumulative impacts are expected to last as long as the combined operational ages of all existing and anticipated developments in the PQA.

Intermediate: The cumulative impacts are expected to affect a broader region across the Gharo Creek depending on the locations of the discharge locations of existing and anticipated industries in the PQA.

Medium Medium

17 Electrical and gas installations, operation and maintenance

Occupational health and safety risks to existing industries in the vicinity of the Project during operation.

None: Under normal operational circumstances, there are no impacts expected on neighboring industries and personnel in the PQA from the operation and maintenance of electrical and gas installations related to the Project. Structural elements will be designed and constructed by competent professionals, and certified or approved by competent authorities or professionals.

As natural gas is an explosive material EPL, as a part of the occupational health and safety management systems of the plant, will conduct and maintain hazard analysis and risk assessment studies such as Hazard Identification (HAZID) studies, Hazard and Operability (HAZOP) studies, and quantitative risk assessments (QRAs).


+ denotes a positive impact



Hagler Bailly Pakistan Environmental Impact Assessment and Mitigation Measures for the Proposed Project

R5A05ENP: 09/29/15 7-1

7. Environmental Impact Assessment and Mitigation Measures for the Proposed Project

This section provides an in-depth assessment of the potential impacts identified as in

Section 6.

These impacts are as follows:

Impact 5 – Habitat degradation, and thus damage to aquatic species, in the Gharo

Creek as a result of direct physical damage or decrease in water quality from

turbidity from the construction of the intake and outfall channels.



Impact 11 – Gaseous emissions from the Project during the operation phase may

result in the deterioration of ambient air quality beyond the limits prescribed by

SEQS and IFC EHS guidelines.

Impact 15 – Habitat degradation and thus damage to aquatic species in the Gharo

Creek from increased concentration of brine discharged in the Project effluent

during operation.

7.1 Impact Assessment Methodology

The methodology used for impact assessment in this section will comprise of the

following steps:

1. Prediction of the magnitude of potential impacts — This step refers to the

description, quantitatively (where possible) or qualitatively, of the anticipated

impacts of the proposed Project. This may be achieved through the use of models

or comparison with other similar activities.

2. Identification of mitigation measures — There is a range of mitigation measures

that can be applied to reduce impacts.

3. Evaluation of the residual impact — Incorporation of the suggested mitigation

measures reduces the adverse impact of a project and brings it within acceptable

limits. This step refers to the identification of the anticipated remaining impacts

after mitigation measures have been applied, i.e., the residual impacts.

4. Identification of monitoring requirements — The last step in the assessment

process is the identification of minimum monitoring requirements. The scope and

frequency of the monitoring required depends on the residual impacts identified.

The purpose of monitoring is to confirm that the impact is within the predicted

limits and to provide timely information if unacceptable impact is taking place.




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7.2 Impacts on Ambient Air Quality from Stack Emissions during Operational Phase

The major source of air pollution during the operation phase of the Project will be

emissions from the HRSG and bypass stacks from the combustion of natural gas in the

combustion system of turbines. The main pollutants generated will be nitrogen oxides as

nitrogen dioxide (NO2) and carbon monoxide (CO) with negligible emissions of sulfur

dioxide (SO2) and mercury compounds. Maximum acceptable concentration of CO and

NO2 in the ambient air has been prescribed by SEQS as well as by IFC EHS guidelines

(Section 2.1.3).

In this section, the United States Environmental Protection Agency (USEPA) approved

regulatory air quality model AERMOD1, is used to simulate emissions from the proposed

Project during the operation phase. The objective of the modeling exercise is to predict if

the emissions from the proposed Project will comply with the SEQS and IFC limits. A

description of AERMOD is provided in Appendix F. The results of AERMOD provide

the incremental increase in the concentration of CO and NO2 generated during the

operation of the Project. This concentration is then added to the baseline concentration of

CO and NO2 provided in Section 4.2.4 to determine the ambient concentration of CO and

NO2 during the operation of the Project.

7.2.1 Objectives

The objectives of the air quality impact assessment are to:

predict the impact of the proposed Project on the air quality of the surrounding

area;

determine whether predicted air quality exceeds applicable standards and

guidelines; and

identify mitigations measures that may be required to ensure compliance with the

applicable standards and guidelines.

7.2.2 Sources of Emission

The Project has 2 stacks, which include the following:

Bypass Stack:

The plant will have one bypass stack with a height of 26 m. The bypass stack will be used

to directly discharge the exhaust generated from the combustion of gas in the gas turbine

instead of sending it to the HRSG and the steam turbine.

HRSG Stack:

The plant will have one HRSG stack with a height of 40 m The HRSG stack will be used

to discharge the exhaust generated from the combustion of gas in the gas turbine which,

during normal plant operation, will flow into the HRSG to generate electricity from the

steam turbine in a combined-cycle arrangement.

1 US Environmental Protection Agency, “Support Center for Regulatory Atmospheric Modeling,

Recommended Models,” last modified on April 8, 2015, http://www.epa.gov/scram001/dispersion_prefrec.htm.




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7.2.3 Modeling Data and Parameters

Detailed AERMOD input parameters used for the modeling exercise are provided in

Exhibit 7.1. In addition, modeled weather and climate data of the years 2011 for the

Project-site was obtained and used for the modeling. This was modeled using nearby

stations and the MM5 model.2 A wind rose diagram for the Project-site based on this data

is provided in Exhibit 4.8, in Section 4.

Scenarios and Assumptions

When plant is operating at 100 % load factor with the original temperatures for Bypass

and HRSG, is considered as the base case. To assess the impacts of the power plant due

to emissions from the stacks mentioned above, two scenarios were developed for base

case. These scenarios are discussed below:

Scenario 1:

In this scenario it is assumed that the exhaust gases generated from the combustion

system of gas turbine will be carried forward into the HRSG that will finally discharged

into the environment through the HRSG stack. In this scenario, the plant will be

generating electricity in a combined cycle arrangement using both the gas and steam

turbines.

Scenario 2:

In this scenario it is assumed that all the exhaust gases generated from the combustion

system of gas turbines will be emitted through the bypass stack. None of the exhaust will

be carried forward into the HRSG. In this scenario, the plant will be generating electricity

using only the gas turbine.

The detailed AERMOD input parameters representing these scenarios are provided in

Exhibit 7.1.

Exhibit 7.1: AERMOD Modeling Data and Parameters for Scenario 1 and Scenario 2

(base case)

Parameter/Data Category

Parameter/Data Scenario 1 Scenario 2 Unit Source/Notes

Stacks Number of stacks

1 1 – EPL

Emission from selected stacks

HRSG Stack only

Bypass Stack only

– EPL

Stack Height 40 26 m EPL

Stack Diameter 6.75 10.30 m Calculated from flow rate and exit velocity

Exhaust Gas Flow Rate 688.17 688.17 kg/s EPL

Exit Velocity 20 20 m/s Taken constant to calculate stack diameters.

2 The MM5 (short for Fifth-Generation Penn State/NCAR Mesoscale Model) is a regional meso-scale

model used for creating weather forecasts and climate projections.




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Parameter/Data Category

Parameter/Data Scenario 1 Scenario 2 Unit Source/Notes

Temperature 379.20 882.25 Kelvin EPL

Emissions from stacks

NO2 21.16 21.16 g/s EPL

CO 51.52 51.52 g/s EPL

Building Heights used to account for Building Downwash Effect

Administrative Building

10 10 m EPL

7.2.4 Background Concentration of NO2 in Ambient Air

The ground-level concentration of CO and NO2 is presented in Section 4.2.4 was used to

calculate the background concentration for determining ambient air quality in the Study

Area. Exhibit 7.2 lists the values for average concentration for each pollutant from the

surveys carried out in the years; 2012, 2013, 2014 and 2015. These values were used for

determining the background concentration of each pollutant. The details are discussed

below:

Oxides of Nitrogen (NOx) as NO2

For NOx the average value of the concentrations of NO2 and NO from the years 2012,

2013, 2014 and 2015, mentioned in Exhibit 7.2, were used. The concentration of NO was

calculated in terms of NO2 using the stoichiometric ratio between NO and NO2.

According to the balanced equation, for the conversion of NO into NO2, 1 g of NO reacts

with approximately 0.5 g of oxygen to form approximately 1.5 g of NO2. This ratio was

used to convert the average concentration of NO measured in the area to NO2. The

background concentration for NOx as NO2 was then calculated by adding the average

concentration of NO calculated in terms of NO2 and average concentration of NO2

mentioned in Exhibit 7.2.

Background concentration of NOx as NO2

= Average concentration of NO2 + (1.5 × Average concentration of NO)

The final background concentration for NOx as NO2 was calculated to be 28.8 μg/m3.

Carbon monoxide (CO)

For CO the overall average values from the years 2012, 2013, 2014 and 2015, mentioned

in Exhibit 7.2, were used as the background concentration. As a result, the background

concentration for CO is 2.30 mg/m3.




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Exhibit 7.2: Background Concentrations of Pollutants in Ambient Air3

Year NO2

(μg/m3) NO (μg/m3) NO in terms

of NO2 (μg/m3)

NOx4 (NO2 + NO in

terms of NO2) (μg/m3) 5

CO (mg/m3)

2015 9.6 15.6 23.9 33.0 1.3

2014 10.6 6.9 10.5 20.9 –

2013 16.9 8.7 13.4 30.0 –

2012 12.5 12.5 19.2 31.3 3.3

Overall Average 12.4 10.9 16.8 28.8 2.3

SEQS (1-hour) – – – – 10

SEQS (8-hour6) – – – – 5

SEQS (24-hour7) 80 40 60 140 –

SEQS (Annual) 40 40 60 100

IFC EHS Guidelines (Annual)

40 – – –

Note: “–“indicates that no limit has been prescribed for the given pollutant or the concentration for the given

year for the particular pollutant is not available.

7.2.5 Modeled Incremental Pollutant Concentrations using AERMOD

Modeling Area

The modeling area was defined as 14 km by 14 km, within the Study Area (Exhibit 4.1,

centered at the stacks of the proposed plant. The size of the area was defined considering:

distance from the center of the stacks , at which, the pollutants’ concentrations are

expected to become negligible;

location and distance of other sources of emissions; and

location and distance of receptors

Model Grid

In order to predict dispersion modeling results over the entire modeling area, the model

area was divided into a circular polar grid network centered at the Project site. The nodes

of the grid were placed along 36 direction radials; beginning with 10 degrees from true

North and increasing with increments of 10 degrees in a clockwise fashion up to a radius

of 7 km, with an interval of 500 meters between the circular radials. This polar grid

3 This table is a summary of Exhibit 4.17 provided in Air Quality Baseline Section (Section 4.2.4)

4 NOx as NO2 = (Concentration of NO2 + Concentration of NO in terms of NO2) 5 All the values in this column are based on the assumptions and calculation for background concentration

of NOx mentioned above 6 8 hourly values should be met 98 % of the year, 2 % of the time it may exceed but not on two

consecutive days 7 24 hourly values should be met 98 % of the year, 2 % of the time it may exceed but not on two

consecutive days




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consisted of 540 grid nodes. The polar grid was incorporated into the model to obtain the

predicted concentrations of incremental pollutants on these grid nodes. Exhibit 7.3

illustrates the grid network within the Study Area.

Sensitive Receptors in the Grid Network

The Project-site is located within the PQA, a designated industrial area. There are no

parks, schools, hospitals or settlements in the Study Area. However, all the industries in

the Study Area are considered as sensitive receptors for this modeling exercise. It

includes all the industries (Exhibit 4.9 and Exhibit 4.10) within the area with 7 km

radius centered at the Project-site. It also includes the Arabian Sea County Club located

3.5 km north of the Project-site. These industries and the club were considered as

sensitive receptors due to the workers and visitors at the PQA which may potentially be

exposed to the pollutants released from the Project.




R5A05ENP: 09/29/15 7-7

Exhibit 7.3: Model Grid within the Study Area




R5A05ENP: 09/29/15 7-8

Modeling Results

The maximum incremental concentration levels in ambient air for CO and NO2 was

determined through modeling. NO2 was modeled for 24-hour and annual averaging

period whereas CO was modeled for 1-hour and 8-hour averaging period.

As shown in Exhibit 7.4, in terms of the increment in pollutant concentrations at the

ground-level near the Project-site, Scenario 1 is representative of the worst- scenario. In

this scenario, the plant will operate on the combined cycle mode with the exhaust

emissions being emitted from the HRSG stack only. The emissions from the HRSG stack

will have a lower temperature compared to emissions from the bypass stack. Due to the

lower temperature, exhaust from the HRSG stack will encounter less dispersion in the air

resulting in greater incremental concentrations at the ground-level close to the Project-

site. However, these incremental concentrations of CO and NO2 in Scenario 1 are still in

compliance with the SEQS and IFC EHS guidelines. These concentration values leave a

wide window for the emissions of future projects in the area.

The contours for incremental concentrations of pollutants from the proposed Project for

Scenario 1 and Scenario 2 are presented in Exhibit 7.5 to Exhibit 7.10.

Exhibit 7.4: Modeling Results for Incremental Concentrations of CO and NO2 from the

Project in Scenario 1 and Scenario 2

Pollutant Averaging Time Incremental Concentration Level (Scenario 1)

Incremental Concentration Level (Scenario 2)

NO2(µg/m³) 24–hr (Max) 11.37 1.49

24–hr (98th Percentile) 8.24 1.40

Annual (Max) 2.99 0.30

CO (mg/m3) 8–hr (Max) 0.04 0.01

8–hr (98th Percentile) 0.03 0.01

1–hr (Max) 0.08 0.03




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Exhibit 7.5: Predicted Annual Incremental Concentration of NO2 (Scenario 1)




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Exhibit 7.6: Predicted 24-hour Incremental Concentration of NO2 (Scenario 1)




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Exhibit 7.7: Predicted 1-hour Incremental Concentration of CO (Scenario 1)




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Exhibit 7.9: Predicted Annual Incremental Concentration of NO2 (Scenario 2)




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Exhibit 7.10: Predicted 24-hour Incremental Concentration of NO2 (Scenario 2)




R5A05ENP: 09/29/15 7-15





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7.2.6 AQ1: Impact on air quality in the PQA airshed from gaseous emissions from the Project during the operation phase.

Resultant Ambient Air Quality in the Study Area with the Project in Operation

The incremental concentration of CO and NO2 obtained from Scenario 1 (worst scenario)

of the modeling exercise was added to the background concentration to determine the

resultant CO and NO2 concentration in the Study Area. The results after addition of

background concentration are presented in Exhibit 7.13. The results are then compared

with the applicable standards.

Compliance with Guidelines and Standards

The results of the air dispersion modeling indicate that concentration of NO2 in the air

when the Plant is in operation will be compliant with the SEQS and IFC EHS guidelines.

It will also comply with the IFC EHS guideline which states that “emissions from a

single project should not contribute more than 25 % of the applicable ambient air quality

standards to allow additional, future sustainable development in the same airshed.”

Moreover, the contour maps illustrating the incremental pollution values indicate that the

NO2 concentrations as a result of the Project decrease to insignificant levels at a distance

of 1–2 km from the Project-site. Therefore, the impact on air quality in the Study Area as

a result of the Project during operation in any scenario will be of a low magnitude and

will be limited to a small spatial scale.

Exhibit 7.13: Compliance with Ambient Air Quality Guidelines and Standards

Pollutant Averaging Time Background Concentrati

on (µg/m³)

Predicted Incremental

Concentration for worst scenario

(µg/m³)

Predicted Ambient

Concentration (µg/m³)

IFC EHS Guidelines

SEQS

NO2 (µg/m³)

24–hr (Max) 28.80 11.37 40.17 – –

24–hr (98th Percentile)

8.24 37.04 – 80

Annual (Max) 2.99 31.79 40 40

CO (mg/m3

)

8–hr (Max) 2.30 0.04 2.34 – –


0.03 2.33

– 5

1–hr (Max) 0.08 2.38 – 10

Note: “–“indicates that no limit has been prescribed for the given pollutant or the concentration for the

given averaging period for the particular pollutant is not available

Sensitivity Analysis

The incremental concentration of CO and NO2 for both Scenarios not only comply with

the SEQS and IFC EHS guidelines but also leaves an open room for the emissions from

the future industrial projects. Between Scenario 1 and Scenario 2, the worst scenario

comes out to be Scenario 1 when the exhaust is supposed to emit from HRSG stack. To




R5A05ENP: 09/29/15 7-18

determine the available room for future emissions sensitivity analysis was carried out

with NO2 only as the CO emissions are well below the standards..

Sensitivity analysis was done by developing eight different cases from base case8, in

which the variables are load factor and temperature. Modeling was carried out at each

configuration formed from three different load factors; 100 %, 90 % and 80 % at three

varying temperatures; original temperature given by EPL, 10 % increase in original

temperature and 10 % decrease in original temperature. The modeling for these cases was

done for worst scenario, when the exhaust will be flow out of only HRSG stack. The

different cases developed from above mentioned configuration along with the graphical

representation of their results are shown in Appendix G. The worst case is then

developed while keeping into account the results from eight different cases used for

sensitivity analysis. The worst case is defined when the plant will be operating at 50 %

load factor with 10 % decrease in original temperature and 20 % increase in NO2

emission. This condition will result in low flow rate that will ultimately result in low

stack exit velocity provided the stack diameter is constant; because once the plant is

designed its diameter will not change. Due to low temperature and exit velocity, the

plume height will decrease and the dispersion of pollutant will be low that will result in

high ground level concentration of the pollutant. The results for worst case are provided

in Exhibit 7.14.

Modeling results for worst case for worst scenario (Scenario 1) show that the NO2

concentrations are still in compliance with the SEQS and IFC EHS guidelines.

Exhibit 7.14: Modeling results for worst case scenario

Pollutant Averaging Time Background Concentrati

on (µg/m³)


Concentration for worst case for

scenario 1 (µg/m³)

Predicted Ambient


IFC EHS Guidlines

SEQS

NO2 (µg/m³)

24–hr (Max) 28.8 15.08 43.88 – –


10.48 39.29 – 80

Annual (Max) 4.53 33.33 40 40

8 Base case: load factor as 100 %, original temperature given by EPL (both for HRSG and bypass) and

NO2 emission from Siemens SGT5 – 4000F is 20 ppmv




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Impact AQ1: Impacts on Ambient Air Quality from Stack Emissions

Applicable Project Phase

Operation

Impact Rating

Magnitude Duration Scale Consequence Probability Significance + /- Confidence

Initial Impact Minor Long-term

Small Low Definite Low - High

Mitigation Measures:

Since, even in a very conservative scenario, the increment in concentration of pollutants in ambient air is very low as compared to the limits prescribed in SEQS and IFC EHS guidelines; therefore, no specific mitigation measures are required.

Monitoring

Refer to environmental monitoring plan outlined in the Environmental Management Plan (Section 8, Exhibit 8.6).

7.3 Ecological Impacts

Based on the scoping of identified potential impacts in Section 6, potential ecological

impacts of significance are discussed below.

Construction works in the Gharo Creek for constructing the intake and outfall

channels of the Project may result in direct physical damage to aquatic habitat

present in the creek. Construction works may also result in turbidity which may

also impact aquatic habitats adversely. These may lead to changes in abundance

and diversity number of aquatic species in the area.

The brine released by the Project is likely to disturb the aquatic ecosystem in the

Gharo Creek at the point of discharge.

These are discussed in more detail below.

7.3.1 EC1: Impact on Marine Ecological Resources from the Construction of Intake and Outfall Channels extending into the Gharo Creek

Marine life consisting of marine benthic invertebrates, phytoplankton, zooplankton, crabs

and fish will suffer direct physical damage from construction works in the Gharo Creek.

However, such damage will be limited only to the site of the construction works. On the

other hand, turbidity generated from the construction works may spread a few meters

away from the construction site and result in ill health effects and changes in abundance

and diversity of marine ecological resources in the Gharo Creek. This alteration in the

sediment levels in the water is likely to change the nature and diversity of benthic and

pelagic marine communities, such as decline of density, species abundances or biomass.9

The marine benthic invertebrates and fish fauna in the vicinity of the construction

activities are likely to suffer negative impacts caused primarily by smothering of benthic

invertebrate and clogging of gills of the fish species. A decrease of primary production

due to reduced transparency of the water column is expected. In addition, release of

nutrients caused by disturbance of the sediment will increase eutrophication leading to

decreased amount of dissolved oxygen in the water column.

9 Amjad,S and Moinuddin Khan 2011 Marine Ecological Assessment for LNG Terminal at Port Qasim.

Pak.J. Eng. Technol.Sci Vol 1. No.2 74-85.




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Marine benthic invertebrates are essential for the energy transfer within the coastal

ecosystem. However, they have a short reproductive life cycle, especially the marine

benthic meiofauna (0.5 mm) which can quickly re-colonize a new site within a short span

of about 2 – 3 weeks. None of the MBI species reported in the Gharo Creek are included

in the IUCN Red List 2014.10 In addition, these species are abundantly located in other

parts of the creek. Therefore, even though individuals are liable to suffer short-term harm,

construction of the intake and outfall channels is not likely to have a significant long-

term impact on the overall MBI species populations.

Similarly, construction works will lead to the short-term decline in the abundance and

diversity of fish, crabs and crustaceans. None of the fish, crab or crustacean species is

included in the IUCN Red List 201411 and are abundantly found in other parts of the

coast. In addition, the fish and to some extent the other species are likely to avoid

disturbance and move to a less disturbed area. However, it is recommended that the

construction activities not be carried out during the spawning period of coastal fish

(July/August) to avoid any long-term harm to the species. In addition, it is recommended

that all measures outlined in the Environmental Management Plan for Project

construction and operation be implemented to ensure minimal pollution of marine waters.

Impact EC1: Impact on Marine Ecological Resources from the Construction of Intake and Outfall Channels

extending into the Gharo Creek


Construction

Impact Rating


Initial Impact Moderate Medium Small Medium Possible Medium - High

Mitigation Measures:

To the extent possible, avoid construction during the spawning period of coastal fish (July – August)

Debris netting to be applied around the sides of the construction site of intake/outfall channels to prevent any materials or debris falling into the creek.

To contain any other debris generated, a layer of terram (or any geosynthetic material) will be laid across the platform at the beginning of each shift and removed at the end of the shift ensuring all debris resulting from the works is restricted from entering the marine environment.

Waste materials generated during the construction of the intake and outfall channel shall be trapped and collected on the temporary works platform for appropriate disposal off site.

The proposed paint system for underwater structures will have a low VOC content and fast curing times. An example of such a paint is Baltoflake Ecolife paint protection system, considered as one of the most environmentally friendly products on the paint protection market.


Residual Impact

Minor Medium Small Low Possible Low - High

Monitoring:



August 2014. 11 The IUCN Red List of Threatened Species. Version 2014.2. <www.iucnredlist.org>. Downloaded on 06

August 2014.






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7.3.2 EC2: Changes in Abundance and Diversity of Marine Flora and Fauna caused by Discharge of Effluent into the Creek

Once the Project becomes operational, effluent streams made up of discharge from the

cooling-water process and the RO treatment plant will be discharged into the Gharo

Creek (Section 3.4.8). Higher concentrations of brine from the RO process will have a

negative impact on the marine life in Gharo Creek. This is because the marine flora and

fauna consisting of the marine epifaunal invertebrate species, phytoplankton,

zooplankton, fish, crabs and crustaceans are adapted to ambient saline concentrations.

Any change in salt concentration in the sea water has the potential to cause changes in

abundance and diversity of these ecological resources.12

In the following sections, modeling of the effluent profile is conducted to predict the

extent to which the concentrated brine in the effluent will travel before reaching ambient

salinity levels.

7.3.3 Assessment of Brine Concentration Profile in the Gharo Creek

According to the Project design (Section 3.4.1), the saline concentration of the effluent

discharged into the Gharo Creek will be double than that of the ambient water salinity in

the creek. The NEQS provides a limit with respect to the concentration of salt in the

effluent being discharged which should be the same concentration as that of the receiving

body, which, in the present case is the Gharo Creek. In order to predict the distance at

which the effluent from the Project will be able to achieve this requirement, a plume

modeling exercise was carried out. The modeling approach, parameters and results are

described below.

Objective

The objective of the plume modeling exercise was to determine the distance at which the

brine concentration in the effluent will reach ambient salinity levels.

Scope

As described in Section 3.4 effluent from the Project will be discharged into the Badal

Nullah which flows into the Gharo Creek. Plume modeling will be carried out to

determine the brine plume profile generated from the point where the effluent will enter

the Gharo Creek.

Methodology

Plume modeling was carried out using a modeling software developed by the United

States Environmental Protection Agency (USEPA) known as Visual Plumes (VP). VP is

a Windows-based computer application which simulates single and merging submerged

plumes in arbitrarily stratified ambient flow and buoyant surface discharges. Among its

features are graphics, time-series input files, user specified units, a conservative tidal

background-pollutant build-up capability, a sensitivity analysis capability, and a multi-

12 Hobday, AJ & Matear R (eds) 2005, ‘Review of climate impacts on Australian fisheries and aquaculture:

implications for the effects of climate change’, Report to the Australian Greenhouse Office, Canberra




R5A05ENP: 09/29/15 7-22

stressor pathogen decay model that predicts coliform mortality based on temperature,

salinity, solar insolation, and water column light absorption.

Input data used for modeling included the design characteristics of the outfall channel at

the point of discharge, the flow characteristics of the effluents, and, the tidal current

velocities and directions in the Gharo Creek.

Modeling Parameters

The design parameters of the Badal Nullah at the point of discharge into the Gharo Creek

and effluent characteristics used for modeling are provided in Exhibit 7.15. The

parameters used for simulating the hydrological conditions of the Gharo Creek and

modeling approach used is described further in the section below.

Design Parameters of Effluent Channel at Outfall Location and Effluent Flow Characteristics

Exhibit 7.15: Plume Modeling Input Parameters for Design of Effluent Channel

and Flow Characteristics

Parameter Unit Value Notes

Effluent temperature at discharge,

°C 30.0 Project design (during summer)

Effluent Salinity PSU 80.0 Project design – due to the RO process

Effluent Total Dissolved Solids

ppm 60,000.0 Project design - due to the RO process

Flow rate of effluent discharge,

m3/h 726.6 Project design

Conversion: Flow rate of effluent discharge

m3/s 0.2 Project design

Diameter of discharge pipe m 1.6 Project design – as the Badal Nullah will be redesigned to cater for Project’s effluent flow, this parameter may change. However, modeling results indicate that change in this parameter has insignificant bearing on the modeling outcomes.

Port elevation, vertical distance between the port and the bottom of the water body

m 5.0 Project design – as the Badal Nullah will be redesigned to cater for Project’s effluent flow, this parameter may change. However, modeling results indicate that change in this parameter has insignificant bearing on the modeling outcomes.

Port depth, distance from the surface to the port centerline

m 5.7 Modeling was carried out using the average daily water depth in the Gharo Creek of 10.7m at the point of effluent discharge. The port depth of 5.7 m corresponds to this average depth. As the Badal Nullah will be redesigned to cater for Project’s effluent flow, this parameter may change.




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Modeling Assumptions, Results and Discussion

Plume modelling for discharges associated with the RLNG CCPP project are based on a

1-D model i.e. along a single channel. Typically in discharges in estuarine situations

along a single channel, tidal pollutant build-up may occur. This is since a single volume

of water travels up and down a channel during ebb and flow currents and pollutants begin

to build up in this volume. This is characteristic particularly of long channels such as that

along which this discharge is occurring (i.e. the Phitti-Kadiro-Gharo Creek system).

Nonetheless, a 1-D approximation with tidal pollutant build up would be an unjustifiably

conservative assumption leading to erroneous results based on the following discussion.

Based on preliminary analysis of water quality being carried out by Hagler Bailly

Pakistan for the Cumulative Impact Assessment of Industrial and Port Developments at

Port Qasim, key observations, particularly related to estuarine dynamics, for the creeks

within the Port Qasim Notified Area are as follows:

The estuary is vertically well mixed (i.e. no salinity or temperature gradients)

possibly due to high turbulence associated with penetration of wind waves, tidal

currents and since there are little freshwater flows in multiple investigated

channels and creeks across the Notified Port Qasim Area (~ 69,000 ha).

The estuary is laterally well mixed (i.e. no major differences in water quality)

along the entire PQ Notified Area (~ 69,000 ha)

Water quality along Port Qasim’s Industrial and Port Zones is of good quality

indicating that there is no pollutant build up.

Little to no contamination of marine sediments, indicating no long term pollutant

build up.

Other than indicating good mixing in the estuary associated with turbulence associated

with wind waves and currents, the observations above indicate that pollutants are flushed

out of the system i.e. the same volume does not remain within the channel, and tidal

pollution build up is not occurring. It is assumed that there is interaction of the volume

with multiple other smaller creeks of the inactive northwestern extent of the Indus Delta

such as the Chan Wado and Issaro Creek. A 1-D approximation with tidal pollutant build

up would be unjustifiably conservative. Nonetheless, a 1-D approximation for a dynamic

3-D situation is still considered conservative compared to actual field conditions.

Therefore, based on the current modelling the NEQs will be met well within 100 m of the

point of discharge under conservative modelling conditions.

An additional characteristic of the modelling, is that the model utilized average flow rates

for flood and ebb currents separately to take into account plume extents in different

principal directions during flood and ebb currents.

Recommendations

Considering that there are additional effluents discharged by other industries in the area,

it is recommended that a combined approach to modelling is utilized in collaboration

with other industries, particularly to consider the impact of two separate plume

discharges (or mixing of two streams of wastewater within a single channel before

discharge into the estuary). The modeling results are provided in Exhibit 7.16 and

Exhibit 7.17. .




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Exhibit 7.16: Pollutant Load Dilution with ebb Current

0

10000

20000

30000

40000

50000

60000

70000

0 10 20 30 40 50 60 70 80 90 100

Po

lluta

nt

Load

(P

PM

)

Distance from Source (m)

Pollutant Load (ebb current)

Pollutant Load

Diluting to the Ambient Level

Ambient 30,000 ppm

Current Direction




R5A05ENP: 09/29/15 7-25

Exhibit 7.17: Pollutant Load Dilution with Flood Current

0

10000

20000

30000

40000

50000

60000

70000

0 10 20 30 40 50 60 70 80 90 100

Po

lluta

nt

Load

(P

PM

)

Distance from Source (m)

Pollutant Load (flood current)

Pollutant Load

Diluting to the Ambient Level

Ambient 30,000 ppm

Current Direction




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Impact EC2: Changes in Abundance and Diversity of Marine Flora and Fauna caused by Discharge of

Effluent into the Creek


Operation

Impact Rating

Magnitude Duration Scale Consequence Probability

Significance

+/- Confidence

Initial Impact

Minor Medium Small Low Definite Low - High

Mitigation and Monitoring Measures:

No mitigation measures are required.


7.4 Socioeconomic Impacts

This section assesses the potential socioeconomic impacts of the proposed Project. Based

on the scoping of identified potential impacts in Section 6.2, potential socioeconomic

impacts of significance are as follows:

7.4.1 SE1: Generation of skilled and unskilled employment from the construction and operation of the Project

The construction and operation phases of the Project will include various civil, mechanic,

electrical and masonry works which will require a considerable number of workforce to

accomplish the desired job. This will result in opening of various job opportunities for

both skilled and unskilled individuals residing in the Socioeconomic Study Area.

Transparent and fair distribution of these jobs among locals, matching their education and

skill level is expected to enhance the socioeconomic condition existing in the area.




R5A05ENP: 09/29/15 7-27

Impact SE1: Generation of skilled and unskilled employment from the construction and operation of the

Project


Construction and Operation

Impact Group

Economy related impact

Impact Rating


Initial Impact

Major+ Long Extensive High Definite High + High

Enhancement Measures:

Prioritize hiring of local people. The plant owners and operators should ensure that the recruitment process is fully transparent and is based on merit.

Maintain regular communication with local communities through community liaison officer to identify community perspective about the proposed development

Development, implementation and monitoring of grievance redress mechanism to record and keep a track of employment related complaints take actions to resolve them.


Enhanced Impact

Major+ Long Extensive High Definite High + High

Monitoring:

No monitoring required.



Hagler Bailly Pakistan Environmental Management Plan R5A05ENP: 09/29/15 8-1

8. Environmental Management Plan

8.1 Purpose and Objectives of the EMP

The primary objectives of the EMP are to:

Facilitate the implementation of the identified mitigation measures in the

environmental assessment

Define the responsibilities of the project proponent and contractor, and provide a

means of effective communication of environmental issues between them.

Identify monitoring parameters in order to ensure the effectiveness of the

mitigation measures.

Provide a mechanism for taking timely action in the face of unanticipated

environmental situations.

Identify training requirements at various levels.

The EMP is prepared on the basis of details currently available on the construction and

operation phases of the project. As a construction contractor is appointed and further

information is available, the EMP will be amended to reflect the changes. However, no

mitigation measures committed in the EMP can be changed.

8.1.1 Management Approach

The organizational roles and responsibilities of the key players are summarized below:

The Owners: The project proponent will undertake overall responsibility for compliance

with the EMP. The Owners will carry out verification checks to ensure that the

contractors are effectively implementing their environmental and social requirements.

Assuming that owners will operate the plant, the implementation of the EMP applicable

to the operation phase of the Project will be the responsibility of the owners.

Contractors: The construction contractors will implement the majority of environmental

and social mitigations as required by their contract with the Owners. The contractors will

carry out field activities as part of the proposed project. The contractors are subject to

certain liabilities under the environmental laws of the country, and under their contracts

with the Owners.

8.1.2 Management Responsibilities

The responsibilities of the client and contractor are briefly described below:

Primary responsibilities:

As regards environmental performance during the project construction and

operation, the respective highest-ranking officers in the country will assume

the primary responsibilities on behalf of both the project proponent and their

contractors.




The Owner’s Project Manager will be responsible for environmental

assessment and EMP compliance throughout the project on behalf of the

company itself.

The Owners will coordinate with the concerned government departments.

Project management and quality control:

Carrying out construction activities in an environmentally sound manner

during the project will be the responsibility of the contractor’s site manager.

Owner’s representative will be responsible for the overall environmental

soundness of all field operations.

Specific roles and responsibilities for environmental monitoring are provided in

Exhibit 8.1.

Exhibit 8.1: Roles and Responsibilities for Environmental Monitoring

Aspect The Owners’ Responsibilities

Contractor’s Responsibilities

Relevant Documentation

Contracting Ensuring that monitoring and mitigation requirements are included in the contract between the Owners and the construction contractor(s).

Understanding the requirements and estimating the required resources

Contract between the Owners and the construction contractor(s)

Monitoring plan Ensuring finalization of monitoring plan before commencement of principal part of project construction

Prepare a construction management plan

Finalized monitoring plan and Construction Management Plan

Resources Ensuring availability of resources required for environmental monitoring

Ensuring availability of resources required for environmental monitoring

Project budgets

Environmental staff

Designating an Environmental Manager for the project

Designating an Environmental Manager for the project (may be combined with health and safety)

Job descriptions

Monitoring surveys and inspections

Undertaking regular inspections and carrying out further measurements when necessary

Undertaking regular inspections and collecting data on environmental performance, and carry out surveys

Inspection and survey reports

Environmental audit

Conducting periodic environmental audits during construction and operation phases of the Project

Conducting periodic internal audits

Audit reports

Reporting Ensuring that periodic environmental monitoring reports are received from

Producing environmental monitoring reports periodically and distributing

Environmental monitoring reports




Aspect The Owners’ Responsibilities

Contractor’s Responsibilities

Relevant Documentation

the construction contractor(s) during construction and from responsible personnel during operation and reviewing those reports

those among the Owners management and appropriate staff members

Corrective actions

Verifying that activities carried out comply with the EIA/EMP and identifying corrective actions if needed

Carrying out corrective actions as required

Corrective action record

Maintenance of record

Maintaining monitoring data and recording all incidents of environmental significance and related corrective measures

Maintaining monitoring data and recording all incidents of environmental significance and related corrective measures

Environmental databases

8.2 Mitigation Plan

The mitigation plan is a key component of the EMP. It lists all of the mitigation measures

identified in the environmental assessment and the associated environmental and social

aspects of those measures. The mitigation measures for the proposed project are

presented in Exhibit 8.2 for construction phase and in Exhibit 8.3 for operation phase.

Major mitigation measures are proposed for following environmental aspects:

8.2.1 Waste Management

The waste management plan is summarized in Exhibit 8.4.




Exhibit 8.2: Mitigation Plan during Construction Phase

Environmental or Social Aspects

ID Measure Responsibility

Air Quality 1.1 Water will be sprinkled when there is an obvious dust problem on all exposed surfaces (in the construction area) susceptible to producing dust emissions.

Construction contractor

1.2 Soil and aggregate storage piles stored for extended periods will be kept moist, and will either be covered with a tarpaulin or thick plastic sheets or have windshield walls 0.5 m higher than the pile.


1.3 All roads within the plant site and construction campsite that are to be paved or sealed will be paved as soon as possible after the commencement of construction work. Tracks will be sprinkled regularly until they are paved. Temporary roads will be compacted and sprinkled with water during construction.


1.4 Project traffic will observe a maximum speed limit of 20 km/h during construction on all unsealed roads within the construction site.


1.5 Construction materials that are susceptible to dust emission will be transported only in securely covered trucks. Aggregate material will be delivered in a damp condition, and water sprays will be applied if needed.


Soil and Water Contamination

2.1 Measures will be taken to avoid oil and grease spills, and immediate remedial measures will be taken in the event of a spill.

Construction contractor, the Owners

2.2 Tarpaulins or other impermeable materials will be spread on the ground to prevent contamination during on-site maintenance of construction vehicles.


2.3 Regular inspections will be carried out to detect leakages from construction vehicles and equipment, and vehicles/equipment with leakages will not be used until repaired.


2.4 Fuels, lubricants and chemicals will be stored in covered areas, underlain with impervious liners. Construction contractor

2.5 Spill control arrangements including shovels, plastic bags, and absorbent materials will be available near hazardous material storage areas.







2.6 Measures will be taken to deal with soil contamination. Contaminated soil will be immediately collected and disposed of appropriately.


2.7 Storm water runoff will be redirected away from the construction site through the use of contouring and embankments.


2.8 Soil banks from ditching operations will not be placed where they might impair drainage. Construction contractor

2.9 Areas containing potentially hazardous materials will be hydrologically isolated from the rest of the site.


2.10 To the extent possible, construction activities related to the intake and outfall channels in the Gharo Creek during the spawning period of coastal fish (July – August) will be avoided.


2.11 Debris netting to be applied around the sides of the construction site of intake and outfall channels to prevent any materials or debris falling into the creek.


2.12 To contain any other debris generated, a layer of terram (or any geosynthetic material) will be laid across the platform at the beginning of each shift and removed at the end of the shift ensuring all debris resulting from the works is restricted from entering the marine environment.


2.13 Waste materials generated during the construction of the intake and outfall channel shall be trapped and collected on the temporary works platform for appropriate disposal off site.


2.14 The proposed paint system for underwater structures will have a low VOC content and fast curing times. An example of such a paint is Baltoflake Ecolife paint protection system, considered as one of the most environmentally friendly products on the paint protection market.







Traffic 3.1 All vehicles will be NEQS compliant for noise and air emissions. Construction contractor

3.2 Construction materials that are susceptible to dust emission will be transported only in securely covered trucks. Aggregate material will be delivered in a damp condition, and water sprays will be applied if needed.


3.3 Over-loading of equipment and material transportation vehicles will be avoided. The recommended axle load of each truck will be logged and it will be ensured that the load limit is not exceeded.


3.4 Non-conformance and incident reporting system will be used to record and evaluate the cause of traffic accidents and to update traffic safety procedures accordingly.


Occupational health and safety

4.1 Personnel will be provided with appropriate personal protection equipment (PPE). Staff will be trained in PPE use.


4.2 Vehicles and equipment maintenance will be scheduled in accordance with manufacturer’s instructions.


4.3 Visitors to the construction site will be required to wear PPE (helmets, hard boots, ear protection, and safety goggles) if visiting areas where occupational health and safety hazards exist.


4.4 Health and safety management plan will be developed for construction phase to cover identified health and safety risks that are likely to occur during construction.


4.5 Health and safety risks in the construction phase will be systematically and continuously identified, assessed and responded to.


4.6 Prevent access to areas with high hazard potential and clearly mark such areas with suitable warning signs showing written and visual representation of the hazard.


4.7 Encourage personnel to report near misses where construction activities or infrastructure could have potentially resulted in harm to staff, visitors, local communities or ecological systems.


Local Economy 5.1 Locally award contracts that are within the capability of local contractors. Owners

5.2 Hire workers from nearby communities as far as practically possible. Construction contractor




Exhibit 8.3: Mitigation Plan for the Operation Phase

Aspect ID Mitigation Measure Achievement Indicators

Air Quality 1.1 Maintain vehicles and equipment (including abatement equipment) in accordance with manufacturer’s instructions.

Maintenance log

1.2 Soil and aggregate storage piles will be kept moist, and will either be covered with a tarp or thick plastic sheets or have windshield walls 0.5 m higher than the pile,

Visual inspection

Hazardous Materials

2.1 Develop and implement a Hazardous Material Management Plan including procedures for transport, handling and storage of hazardous substances to minimize risk of accidental exposure. Include clear instructions on what to do should exposure occur. Hazardous materials include explosives, fuel, lubricants, laboratory chemicals, hazardous waste etc.

Procedures for transport, handling and storage of hazardous substances with evidence of implementation

2.2 Require vehicle maintenance be performed in designated workshops where appropriate pollution control measures are provided.

Visual inspection

2.3 Record and report information on spills including:

location of spill;

material type (hazard potential) and quantity released;

quantity of material recovered;

media affected (soils, water, air);

actions taken to contain, recover and remove material released;

methods and location of disposal of recovered material or affected media;

cause of the spill; and

how future spills could be avoided.

Records of spills showing lessons learnt

2.4 Provide spill prevention and response training to staff , contractors and visitors, including:

an explanation of good house-keeping practices;

identification and use of equipment and engineering controls designed to prevent spills;

description of proper spill response procedures; and

indication of possible health, safety and environmental risks potentially occurring as a result of a spill.

Training/induction logs





2.5 Develop and implement Spill Prevention and Mitigation Plan for the plant site and road transportation

Plan document, training provided as documented in training logs

Health 3.1 Undertake health screening of employees. Health screening reports

Local Economy 4.1 Locally award contracts that are within the capability of local contractors. Records of procurement contracts awarded to local companies

4.2 Develop and maintain a supplier and contractor database, along with a process to review, monitor and strengthen capabilities of local suppliers and contractors on an ongoing basis.

Database established and being used

Noise impacts 5.1 Provide hearing protection for operators. Protective equipment available and staff know how to use

5.2 Maintain vehicles and equipment in accordance with manufacturer’s instructions. Maintenance log

5.3 Require visitors to the site to wear ear protectors if working or visiting areas where appropriate occupational health and safety sound levels are exceeded.

Protective equipment available for use

Occupational health and safety

6.1 Develop health and safety management plan to cover identified health and safety risks likely to occur during start up, operation, phases of the project.

Plan in place with evidence of review

6.2 Systematically and continuously identify, assess and respond to health and safety risks throughout the Project life cycle.

Record of risk identification and management

6.3 Restrict the noise levels emitted from equipment or provide suitable personal protection devices if this limit cannot be achieved.

Noise levels known and equipment provided where necessary

6.4 Provide fire protection systems to comply with United States of America’s National Fire Protection Association regulations.

Systems in place and tested

6.5 Provide personnel with appropriate personal protection equipment (PPE). Provide staff with training on how and when to use the PPE.

PPE available and staff know how to use it





6.6 Prevent access to areas with high hazard potential and clearly mark such areas with suitable warning signs showing written and visual representation of the hazard.

High hazard areas identified on a plan and barriers in place with suitable warning signs

6.7 Encourage personnel to report near misses where Project activities or infrastructure could have potentially resulted in harm to staff, visitors, local communities or ecological systems.

Near miss register established and used

Road traffic 7.1 Provide driver training, assessment and monitoring including what to do in the event of an emergency.

Training reports

7.2 Maintain vehicles in accordance with manufacturer’s instructions. Maintenance logs

7.3 Use the non-conformance and incident report system to record and evaluate the cause of traffic accidents and update traffic procedures accordingly.

Accidents are recorded and investigated

7.4 Prohibit unnecessary off road driving. No visual evidence of Project related off road driving.

7.5 Loading on each truck will be noted and should not exceed the allowable limit. Vehicle log

7.6 All vehicles will be covered to avoid dust emissions during transportation. Visual inspections

Stakeholder engagement

8.1 Develop and implement Stakeholder Engagement Plan that includes:

maintaining regular communication with stakeholders to address any potential issues in timely manner;

maintaining a grievance procedure, and encourage and facilitate stakeholders to use the mechanism to express concerns; and

providing sufficient resources to the community relations team to enable them to monitor negative perceptions and associated tensions, and to address them in a timely fashion.

Plan in place with records of implementation including records of communication/ information sharing





Waste Management

9.1 Prepare operation waste management plans and implement these consistent with Pakistan regulations and international standards to the extent practicable.

Plan in place with evidence of review

9.2 Include in the waste management plans the following:

a commitment to a waste hierarchy comprising a) waste avoidance, source reduction, prevention or minimization; b) waste recovery for materials that can be re-used; c) waste treatment to avoid potential impacts to human health and the environment or to reduce the waste to a manageable volume; and d) safe and responsible waste disposal specifically for hazardous material and waste oil disposal;

inventory of wastes identifying the source/s, characteristics and expected volumes;

waste segregation requirements;

location and type of waste collection points, which are conveniently located, have adequate capacity, are frequently serviced and clearly labeled;

storage requirements;

opportunities for source reduction, re-use or recycling;

targets for waste re-use, recycling and incineration;

opportunities to minimize bulk or render waste non-hazardous;

procedures for operating waste storage, treatment and disposal facilities;

labeling requirements for waste disposed of offsite;

method of tracking waste recovered, incinerated or disposed of to the site’s landfill;

method of tracking quantity, date, transporter and fate of waste disposed of offsite;

a contingency plan should waste disposal facilities be unavailable for a time; and

training requirements for waste management staff and other employees and contractors.

Waste management plan in place with evidence of implementation

9.3 Recycle and reuse non-hazardous waste to the extent practicable. Records of waste recycled, composed or incinerated

9.4 Preferably return hazardous waste to the associated supplier or transport to other appropriately licensed facilities off-site to the extent practicable and permitted.

Records of waste returned to supplier





9.5 Provisionally store hazardous waste not transported off site in appropriate storage facilities on-site until their final disposal is determined. Include a roofed enclosure over a concrete pad with a low concrete wall to provide containment to hold 110% of the volume of stored hazardous liquids. Also include a fenced open area of storage of empty containers (if any). Restrict access to this area to qualified personnel only.

Visual inspection

9.6 Develop and implement supporting procedures to the waste management plans as needed, for the transport, storage, handling and disposal of waste materials (including hazardous waste)

Procedures in place with evidence of implementation

9.7 Maintain sewage treatment facilities according to manufacturers’ specifications and Pakistan requirements.

Maintenance logs

Wastewater 10.1 Minimize release of potentially contaminated storm water from the plant site by segregating water from potentially contaminated areas from rest of the plant.

Construction signed off by appropriately qualified engineer

10.2 Treat sewage effluent. Sewage treatment facilities in place and operating according to instructions

10.3 Deploy erosion control and sediment management measures around areas disturbed during construction.


Water conservation

10.1 Recycle wastewater after treatment for horticulture and road sprinkle Maintenance of water balance to track water usage

10.2 Use water efficiency technologies, as far as practicable, to minimize raw water consumption. Maintenance of water balance to track water usage

10.3 Train staff and keep them aware of good water conservation practices. Training material and records

10.4 Develop a water management plan for the Project that includes monitoring of water use, development of water balance, and periodic review of use predictions, impacts and mitigation.

Plan in place with evidence of implementation and review





Intake Channel 11.1 There will be a sufficient depth of water at the intake heads to protect against low water conditions below mean sea level at low low water mark (LLWM -0.4m). The sill of the intake will be high enough above seabed level to prevent sediment and debris being drawn from the seabed into the intake. This also reduces the risk of drawing in benthic fish.


11.2 The intake heads should not be close to the inter-tidal zone where juvenile fish and shellfish are concentrated and abundant.


11.3 The orientation of the intake screens on the intake heads will be such so that the inflow direction is perpendicular to the main tidal currents to prevent entrainment.


11.4 The intake heads should be sufficiently distant from the discharge heads, and in deep enough water, to ensure that discharged heat is not recirculated in the intake system.


11.5 If there are more than one intake heads, there should be significant separation between the intake heads on one tunnel and the intake heads on the other tunnel in order to provide segregation to protect against localized external hazards.


11.6 The intake velocities should be designed to be minimal to prevent pinning a swimmer or diver to the bars of the intake channel. This will also protect aquatic mammals.


11.7 The dimensions of bar spacing in the intake screen will be between 50 and 250 mm to protect marine mammals from being entrained as well as for the exclusion of fish, diving birds and other biota. This is also important for public safety (divers, swimmers and anyone falling into the water).


11.8 Intake screen/s shall be installed at (a) strategic location/s to prevent the entrainment of aquatic life. The gaps in the screens, in conjuction with the intake flow velocities should allow any impinged fish to escape.


11.9 The material of the screen will be mild steel protected by a suitable corrosion protection system. Alternatively the bars could be constructed in stainless steel or a non-ferrous metal that inhibits marine growth. Consideration will be given to making the screen in removable sections to facilitate maintenance and cleaning. The intake channel can be injected with dosages of (1-2 ppm) chlorine to discourage larvae of biofouling organism entering the channel.






11.10 The intake channel will be fitted with a combination of acoustic fish deterrent (AFD) system and fish recovery and return (FRR) provision. The combination of both processes caters for hearing-sensitive, delicate species as well as more insensitive demersal and epibenthic species, including crustaceans.


11.11 Monitoring of intake and outfall channels will take place during operation using underwater cameras and occasionally through divers. The latter will be carried out during one of the scheduled plant outages.

Systems in place and tested




Exhibit 8.4: Waste Management Plan Summary

No. Material Waste Final Disposal Method Associated Risks Recommended Procedure

1 Iron Material returned to Store as unserviceable

Scrap Store

Recycling

Equipment and parts may be contaminated with oil or other liquids. This may pose hazards during recycling and/or melting.

Separate contaminated parts and ensure disposal contractor cleans and removes contaminations before recycling equipment.

2 Copper Recycling

Scrap Store

Copper wires and tubes may be covered with insulation and may pose hazard if melted.

Separate insulated copper from rest and ensure disposal contractor removes it before recycling.

3 Other Materials Material returned to Store as unserviceable

Scrape Store

Recycling

Landfill

Some waste materials may contain hazardous materials (such as mercury and lead) which may pose health risks if not handled or disposed of properly.

All hazardous substances such as lead and mercury will be identified and separated.

Ensure waste contractor disposes hazardous materials in accordance with accepted methods.

4 Wood, Cotton, Plastic, Waste and Packing Materials

Recycling

Landfill

Burning of wood, paper, plastic and other materials may cause air pollution

Littering due to improper disposal

Ensure waste contractor disposes all non–recyclable plastic wastes and other non–recyclable materials at land disposal.

5 Electronics Material returned to Store as unserviceable

Some electronic equipment may contain toxic materials and pose a health risk if opened or dismantled.

Ensure contractor disposes equipment properly and equipment is opened only under guidance of qualified professional.

6 Insulation Material Re–used

Landfill

Burning may cause air pollution.

Littering due to improper disposal

Ensure contractor disposes insulation properly at landfill site.

7 Oil Recycling Contractors May cause contamination of soil or waterways Ensure properly certified recycling contractors are used.

8 Concrete Landfill or reuse as for filling None Ensure safe storage till disposal




8.3 Monitoring Plan

Environmental monitoring is a vital component of an EMP. It is the mechanism through

which the effectiveness of the EMP is gauged. The feedback provided by environmental

monitoring is instrumental in identifying any problems and planning corrective actions.

8.3.1 Objective of Monitoring

The main objectives of environmental monitoring during the construction phase of the

Project will be:

To provide a mechanism to determine whether the project construction

contractors and the Owners plant management are carrying out the project in

conformity with the EMP.

To identify areas where the impacts of the projects are exceeding the criteria of

significance and, therefore, require corrective actions.

To document the actual project impacts on physical, biological, and

socioeconomic receptors, quantitatively where possible, in order to design better

and more effective mitigation measures.

To provide data for preparing the monitoring report to be submitted to the Sindh

EPA in accordance with the national law requirement.

8.3.2 Performance Indicators

The environmental parameters that may be qualitatively and quantitatively measured and

compared are selected as ‘performance indicators’ and recommended for monitoring

during project stages. These monitoring indicators will be monitored to ensure

compliance with the national or other applicable standards and comparison with the

baseline conditions established during design stage. The list of indicators and their

applicable standards to ensure compliance are given below.

Construction Phase

1. Ambient air quality for emissions and dust generation from construction

equipment and vehicles including diesel engines and generators and civil works

(NOx, COX, HCs, VOCs, PM2.5 and PM10), – Sindh Environmental Quality

Standards,(SEQS) 2014, Pakistan NEQS 2010 and those prescribed in IFC EHS

guidelines for ambient air quality.

2. Noise levels – Pakistan National Standards, NEQS 2100 and IFC EHS guidelines

for noise management.

Operation Phase

1. Stack emissions (NOX) – NEQS. Continuous emission monitoring on new boilers.

Monthly testing on other boilers.

2. Ambient air quality (NOX) –SEQS and NEQS 2010 and IFC EHS guidelines for

thermal power plants

3. Noise levels –NEQS 2010 and IFC EHS guidelines for noise management.




4. Wastewater quality –NEQS 2000 and IFC EHS guidelines for effluents.

5. Cooling water inlet and outlet temperature – Continuous measurement

6. Gas consumption per unit of power generated (m3unit) – Comparison with design

data

8.3.3 Environmental Monitoring Plan

The detailed environmental monitoring plan will be finalized prior to commencement of

construction and operation. The requirements identified in the environmental assessment

are presented in Exhibit 8.5 for construction phase and in Exhibit 8.6 for operation

phase.




Exhibit 8.5: Monitoring Plan during Construction Phase

Project Activity and Potential Impact

Objective of Monitoring

Parameters to be Monitored

Measurements Location Frequency Responsibility

Air Quality

Dust emissions during construction

To determine the effectiveness of dust control programs at receptor level

PM10 (particulate matter <10 microns) and PM2.5 concentration

1 hour and 24 hour concentration levels

At three representative locations

Once every three months on a typical working day

Contractor’s environmental officer, the Owners

Visible dust Visual observation of size of dust clouds, their dispersion and direction of dispersion

Construction site Daily during construction period


Exhaust emissions from generators and other construction equipment

To determine the effectiveness of gaseous emission control measures

Gaseous emission rates from generators and other equipment

COx, NOx. SOx, HCs, VOCs and PM measurements should be taken at full, typical, and idling conditions

Exhaust Baseline when equipment is first put into use, and once a week after that


Shoreline Erosion

Creek bank erosion due to wind and construction of water intake and outfall channels

To determine the effectiveness of erosion control measures

Visual inspections Creek banks Weekly Contractor’s environmental officer, the Owners

Water/Soil Contamination

Contamination due to oil/chemical leakages

To determine the effectiveness of control measures taken to minimize the risk of oil and chemical spills

Procedures in place to handle liquids and availability of procedures and equipment for emergency response incidents

Visual inspections and availability checks

Construction site Weekly Contractor’s environmental officer, the Owners




Project Activity and Potential Impact

Objective of Monitoring

Parameters to be Monitored

Measurements Location Frequency Responsibility

Traffic

Exhaust and PM emissions from trucks transporting construction materials

To determine the effectiveness of control measures taken to minimize exhaust and dust emissions from trucks

Vehicle exhaust emissions and visual inspection to ensure vehicle load is secured

Vehicle exhaust emissions, Smoke, NOX, SOX and COX

Construction material transport trucks

Weekly Contractor’s environmental officer, the Owners

Exhibit 8.6: Monitoring Requirements during Operational Phase

Aspect Type of monitoring Frequency Location/s

Land disturbance Soil quality (major metals, nutrients, organic contents, and TPH)

Every two years 4 monitoring points around the plant

Visual inspection of road condition Annually or on receipt of grievance

Effluent Water Water quality (as indicated in NEQS) Annually All the effluent channels exit point from the plant into the sea

Water resources Water quality of the Gharo creek around the water intake and outfall channels openings in the creek

Quarterly 3 monitoring points around the intake and outfall opening in the creek

Air Ambient 24 hr NO2 and SO2 concentrations (using active sampler)

Once every year 4 monitoring points around the plant

Stack testing As per the regulations All stacks

CEM Boilers and Generators

Times and duration of upset conditions When upset conditions occur All plant stacks




Aspect Type of monitoring Frequency Location/s

Vehicles and equipment Random speed checks At different locations and different time

Access road and plant road

Records of vehicle and equipment maintenance As per manufacturer’s instructions

Transport office and workshop

Baseline noise emissions of new equipment On commissioning of new equipment

Within 100m of equipment

Ecological Records of animal and fish kills On occurrence

Surrounding areas around plant site

Records of major wildlife sightings

Community Community grievances or complaints, categorized by type.

Monthly Grievance register maintained at plant site

Hazardous material Records of hazardous materials used On arrival at site Warehouse or storage facility

Inspections of hazardous substances containment facilities, instrumentation and detection systems.

Evert three months Hazardous material containment facilities

Waste Volume of different wastes types disposed of to landfill or incineration

Continuous Waste disposal sites

Volume of different waste types recycled or reused Continuous Waste disposal sites

Volume of soil bio-remediated Continuous Waste management site at mine




8.3.4 Environmental Records

The following environmental records will be maintained:

Periodic inspection reports of Contractor’s Environmental Officer or his designate

Incident record of all moderate and major spills. The record will include:

Location of spill

Estimated quantity

Spilled material

Restoration measures

Photographs

Description of any damage to vegetation, water resource

Corrective measures taken, if any

Corrective measures taken, if any

Waste Tracking Register that will records of all waste generated during the

construction and operational period. This will include quantities of waste

disposed, recycled, or reused

Survey reports, in particular, the following:

Soil erosion: Baseline survey, including photographs (or video), will be

conducted to document pre-construction condition of the construction corridor

Vehicle and equipment noise

Ambient noise survey reports

8.4 Communication and Documentation

An effective mechanism to store and communicate environmental information during the

project is an essential requirement of an EMP.

8.4.1 Meetings

Two kinds of environmental meetings will take place during the project:

Kick-off meetings

Monthly meetings

The purpose of the kick-off meeting will be to present the EMP to project staff and

discuss its implementation.

A monthly meeting will be held during construction phase at site. The purpose of this

meeting will be to discuss the environmental issues and their management. The

proceedings of the meeting, the required action, and responsibilities will be recorded in

the form of a brief report.




8.4.2 Reports

Environmental reports will be prepared on a quarterly basis during the construction and

biannually during the operation. The report will be provided to the Owners.

8.4.3 Change-Record Register

A change-record register will be maintained at the site, in order to document any changes

in EMP and procedures related to changes in the project design, construction plan or

external environmental changes affecting the EMP. These changes will be handled

through the change management mechanism discussed later in this chapter.

8.5 Change Management

An environmental assessment of the proposed project has been made on the basis of the

project description available at the time the environmental assessment report was

prepared. However, it is possible that changes in project design may be required at the

time of project implementation. This section describes the mechanism that will be put

into place to manage changes that might affect the project’s environmental impacts.

Potential changes in project design have been categorized as first-order, second-order,

and third-order changes. These are defined below.

8.5.1 First-Order Change

A first-order change is one that leads to a significant departure from the project described

in the environmental assessment report and consequently requires a reassessment of the

environmental impacts associated with the change.

In such an instance, the environmental impacts of the proposed change will be reassessed,

and the results sent to the SEPA for approval.

8.5.2 Second-Order Change

A second-order change is one that entails project activities not significantly different

from those described in the environmental assessment report, and which may result in

project impacts whose overall magnitude would be similar to the assessment made in this

report.

In case of such changes, the environmental impact of the activity will be reassessed,

additional mitigation measures specified if necessary, and the changes reported to the

SEPA.

8.5.3 Third-Order Change

A third-order change is one that is of little consequence to the environmental assessment

reports’ findings. This type of change does not result in impact levels exceeding those

already discussed in the environmental assessment; rather these may be made onsite to

minimize the impact of an activity. The only action required in this case will be to record

the change in the change record register.




8.5.4 Changes to the EMP

Changes in project design may necessitate changes in the EMP. In this case, the

following actions will be taken:

A meeting will be held between the Owners and the contractor representatives, to

discuss and agree upon the proposed addition to the EMP

Based on the discussion during the meeting, a change report will be produced

collectively, which will include the additional EMP clause and the reasons for its

addition

A copy of the report will be sent to the head offices of the Owners and the

contractor

All relevant project personnel will be informed of the addition

8.6 Environmental Training

Environmental training will help to ensure that the requirements of the environmental

assessment and EMP are clearly understood and followed by all project personnel in the

course of the project. The contractor will be primarily responsible for providing training

to all project personnel. An indicative environmental and social training program is

provided in Exhibit 8.7, which will be finalized before the commencement of the project.




Exhibit 8.7: Training Program

Type of Training Training By

Personnel to be Trained

Training Description Period Duration

Occupational Health and Safety External

Sources

EHS Manager Training should be provided to aware staff to

conform to safety codes.

Before starting of

project activities

Full day

(8 hour

session)

Occupational Health and Safety EHS

Manager

Workers

Staff

Health, safety and hygiene

Proper usage of personnel protective gear

Precautions to be taken for working in confined

areas.

Before starting of

project activities

During Project

Activities

Full day

(8 hour

session)

Health, Safety and Environmental

Auditing

External

Sources

Staff responsible

for

inspection/audits

Procedures to carry out Health, Safety and

Environmental Audits

Reporting requirements

Before starting of

project activities

Full day

(8 hour

session)

Waste Disposal and Handling External

Sources

Relevant Workers

Relevant Staff

Segregation, identification of hazardous waste, use

of PPEs, waste handling

Before starting of

project activities

Full day

(8 hour

session)

Social & Environmental laws &

regulations, norms, procedures

and guidelines of Government

External

sources

EHS staff

Plant managers

and supervisors

Environmental standards and their compliance

Govt. regulations

Before starting

the project

activities

Full day

(8 hour

session)

Implementation of environmental

management and monitoring plant

External

Sources

EHS staff

Responsible

supervisory staff

Management

Concepts of environmental management and

monitoring plan

Once in 3 months

during the entire

construction

period

Full day

(8 hour

session)




8.7 Construction Management Plan

The construction contractor will develop a specific construction management plan (CMP)

based on the CMP included in the Exhibit 8.8. The CMP will be submitted to the EPL

for approval.

The CMP will clearly identify all areas that will be utilized during construction for

various purposes. For example, on a plot plan of the construction site the following will

be shown:

Areas used for camp

Storage areas for raw material and equipment

Waste yard

Location of any potentially hazardous material such as oil

Parking area

Loading and unloading of material

Septic tanks




Exhibit 8.8: Construction Management Plan

Aspect Objective Mitigation and Management Measure

Vegetation

clearance

Minimize vegetation clearance

and felling of trees

Removal of trees should be restricted to the development footprint.

Construction activities shall minimize the loss or disturbance of vegetation

Use clear areas to avoid felling of trees

A procedure shall be prepared to manage vegetation removal, clearance and reuse

Inform the plant management before clearing trees

Poaching Avoid illegal poaching Contractual obligation to avoid illegal poaching

Provide adequate knowledge to the workers relevant government regulations and punishments for illegal poaching

Discharge from

construction sites

Minimize surface and ground water contamination

Reduce contaminant and sediment load discharged into water bodies affecting humans and aquatic life

Install temporary drainage works (channels and bunds) in areas required for sediment and erosion control and around storage areas for construction materials

Prevent all solid and liquid wastes entering waterways by collecting waste where possible and transport to approved waste disposal site or recycling depot

Ensure that tires of construction vehicles are cleaned in the washing bay (constructed at the entrance of the construction site) to remove the mud from the wheels. This should be done in every exit of each construction vehicle to ensure the local roads are kept clean.

Soil Erosion and

siltation

Avoid sediment and

contaminant loading of surface

water bodies and agricultural

lands.

Minimize the length of time an area is left disturbed or exposed.

Reduce length of slope of runoff

Construct temporary cutoff drains across excavated area

Setup check dams along catch drains in order to slow flow and capture sediment

Water the material stockpiles, access roads and bare soils on an as required basis to minimize dust.

Increase the watering frequency during periods of high risk (e.g. high winds)

All the work sites (except permanently occupied by the plant and supporting facilities) should be reinstated to its initial conditions (relief, topsoil, vegetation cover).





Excavation, earth

works, and

construction yards

Proper drainage of rainwater

and wastewater to avoid water

and soil contamination.

Prepare a program for prevent/avoid standing waters, which Construction Supervision Contractor (CSC) will verify in advance and confirm during implementation

Establish local drainage line with appropriate silt collector and silt screen for rainwater or wastewater connecting to the existing established drainage lines already there

Ponding of water Prevent mosquito breeding Do not allow ponding of water especially near the waste storage areas and construction camps

Discard all the storage containers that are capable of storing of water, after use or store them in inverted position

Reinstate relief and landscape.

Storage of

hazardous and

toxic chemicals

Prevent spillage of hazardous

and toxic chemicals

Implement waste management plans

Construct appropriate spill containment facilities for all fuel storage areas

Remediate the contaminated land using the most appropriate available method to achieve required commercial/industrial guideline validation results

Land clearing Preserve fertile top soils

enriched with nutrients

required for plant growth or

agricultural development.

Strip the top soil to a depth of 15 cm and store in stock piles of height not exceeding 2m and with a slope of 1:2

Spread the topsoil to maintain the physio–chemical and biological activity of the soil.

The stored top soil will be utilized for covering all disturbed area and along the proposed plantation sites

Topsoil stockpiles will be monitored and should any adverse conditions be identified corrective actions will include:

Anaerobic conditions – turning the stockpile or creating ventilation holes through the stockpile;

Erosion – temporary protective silt fencing will be erected;

Avoid change in local

topography and disturb the

natural rainwater/ flood water

drainage

Ensure the topography of the final surface of all raised lands are conducive to enhance natural draining of rainwater/flood water;

Reinstate the natural landscape of the ancillary construction sites after completion of works





Construction

vehicular traffic

Control vehicle exhaust

emissions and combustion of

fuels.

Use vehicles with appropriate exhaust systems.

Establish and enforce vehicle speed limits to minimize dust generation

Cover haul vehicles carrying dusty materials (cement, borrow and quarry) moving outside the construction site

Level loads of haul trucks travelling to and from the site to avoid spillage

Use of defined haulage routes and reduce vehicle speed where required.

Regular maintenance of all vehicles

All vehicle exit points from the construction site shall have a wash-down area where mud and earth can be removed from a vehicle before it enters the public road system.

Minimize nuisance due to

noise

Maintain all vehicles in good working order

Make sure all drivers comply with the traffic codes concerning maximum speed limit.

Avoid impact on existing traffic

conditions

Prepare and submit a traffic management plan

Restrict the transport of oversize loads.

Operate transport vehicles, if possible, in non–peak periods to minimize traffic disruptions.

Prevent accidents and spillage

of fuels and chemicals

Restrict the transport of oversize loads.

Operate transport vehicles, if possible, in non–peak periods to minimize traffic disruptions.

Design and implement safety measures and an emergency response plan to contain damages from accidental spills.

Designate special routes for hazardous materials transport.

Construction

machinery

Prevent impact on air quality

from emissions

Use machinery with appropriate exhaust systems.

Regular maintenance of all construction machinery

Provide filtering systems, duct collectors or humidification or other techniques (as applicable) to the concrete batching and mixing plant to control the particle emissions in all stages

Reduce impact of noise and

vibration on the surrounding

Appropriately site all noise generating activities to avoid noise pollution to local residents.

Ensure all equipment is in good repair and operated in correct manner.

Install high efficiency mufflers to construction equipment.

Operators of noisy equipment or any other workers in the vicinity of excessively noisy equipment are to be provided with ear protection equipment





Construction

activities

Minimize dust generation Water the material stockpiles, access roads and bare soils on an as required basis to minimize dust.

Increase the watering frequency during periods of high risk (e.g. high winds).

Stored materials such as gravel and sand should be covered and confined

Locate stockpiles away from sensitive receptors

Reduce impact of noise and vibration on the surrounding

Avoid driving hazard where construction interferes with pre– existing roads.

Notify adjacent landholders or residents prior to noise events during night hours

Install temporary noise control barriers where appropriate

Avoid working during 22:00 to 06:00 within 500m from residences.

Minimizing impact on water quality

Stockpiles of potential water pollutants (i.e. bitumen, oils, construction materials, fuel, etc.) shall be locate so as to minimize the potential of contaminants to enter local watercourses or storm-water drainage.

Storm-water runoff from all fuel and oil storage areas, workshop, and vehicle parking areas is to be directed into an oil and water separator before being discharged to any watercourse.

An Emergency Spills Contingency Plan shall be prepared.

Siting and location

of construction

camps

Minimize impact from

construction footprint

Locate the construction camps at areas which are acceptable from environmental, cultural or social point of view.

Construction Camp

Facilities

Minimize pressure on local

services

Adequate housing for all workers

Safe and reliable water supply.

Hygienic sanitary facilities and sewerage system.

Treatment facilities for sewerage of toilet and domestic wastes

Storm water drainage facilities.

In–house community entertainment facilities.

Disposal of waste Minimize impacts on the

environment

Ensure proper collection and disposal of solid wastes in the approved disposal sites

Store inorganic wastes in a safe place within the household and clear organic wastes on daily basis





to waste collector.

Establish waste collection, transportation and disposal systems

Ensure that materials with the potential to cause land and water contamination or odor problems are not disposed of on the site.

Ensure that all on-site wastes are suitably contained and prevented from escaping into neighboring fields, properties, and waterways, and the waste contained does not contaminate soil, surface or groundwater or create unpleasant odors for neighbors and workers.

Fuel supplies for

cooking purposes

Discourage illegal fuel wood

consumption

Provide fuel to the construction camps for domestic purpose

Conduct awareness campaigns to educate workers on preserving the biodiversity and wildlife of the project area, and relevant government regulations and punishments on wildlife protection.

Site Restoration Restoration of the construction

camps to original condition

To the extent possible, restore the camp site and all other areas temporarily used for construction to their conditions that existed prior to commencement of construction work.

Construction

activities near

religious and

cultural sites

Avoid disturbance to cultural

and religious sites

Stop work immediately and notify the site manager if, during construction, an archaeological or burial site is discovered.

It is an offence to recommence work in the vicinity of the site until approval to continue is given by the plant management.

Maintain appropriate behavior with all construction workers especially women and elderly people

Resolve cultural issues in consultation with local leaders and supervision consultants

Best practices Minimize health and safety

risks

Implement suitable safety standards,

Provide the workers with a safe and healthy work environment, taking into account inherent risks in its particular construction activity and specific classes of hazards in the work areas,

Provide personal protection equipment (PPE) for workers, such as safety boots, helmets, masks, gloves, protective clothing, goggles, full–face eye shields, and ear protection.

Maintain the PPE under a regular checking and replacement program

Water and

sanitation facilities

at the construction

sites

Improve workers’ personal

hygiene

Provide portable toilets at the construction sites and drinking water facilities.

Portable toilets should be cleaned once a day.

All the sewerage should be pumped from the collection tank once a day into the common septic tank for further treatment.




8.8 Spill Management

Liquid waste spills that are not appropriately managed have the potential to harm the

environment. By taking certain actions EPL can ensure that the likelihood of spills

occurring is reduced and that the effect of spills is minimized.

To enable spills to be avoided and to help the cleanup process of any spills, the EPL

contractors and its management staff should be aware of spill procedures. By formalizing

these procedures in writing, staff members can refer to them when required thus avoiding

undertaking incorrect spill procedures.

A detailed spill management plan will be prepared for the construction phase. Similar,

plan will also be developed for specific areas during plant operation. The plan will

contain the following:

Identification of potential sources of spill and the characterization of spill material

and associated hazards.

Risk assessment (likely magnitude and consequences)

Steps to be undertaken taken when a spill occurs (stop, contain, report, clean up

and record).

A map showing the locations of spill kits or other cleaning equipment.

8.8.1 Avoiding spills

By actively working to prevent spills, money and time can be saved by not letting

resources go to waste. In addition, the environment is protected from contaminants that

can potentially cause harm.

All liquids will be stored in sealed containers that are free of leakage. All containers will

be on sealed ground and in an undercover area. Sharp parts will be kept away from liquid

containers to avoid damage and leaks.

Bunding: To prevent spills from having an effect on the plant site operations or the

environment, bunding will be placed around contaminant storage areas. A bund can be a

low wall, tray, speed bump, iron angle, sloping floor, drain or similar and is used to

capture spilt liquid for safe and proper disposal.

8.8.2 Spill Kits

Spill kits are purpose designed units that contain several items useful for cleaning up

spills that could occur. Typical items are:

Safety gloves and appropriate protective clothing (depending on the type of

chemicals held onsite)

Absorbent pads, granules and/or pillows

Booms for larger spills

Mops, brooms and dustpans.




Spill kits are used to contain and clean up spills in an efficient manner. Sufficient number

of spill kits will be provided. Spill kits will be kept in designated areas that are easily

accessible to all staff. Staff members will be trained in using the spill kit correctly.

After cleaning up a spill, the materials used to clean up will be disposed of correctly.

Depending on the spill material, the used material may be disposed in the hazardous

waste facility or the landfill site.

8.8.3 Responding to spills

Stop the source: If it is safe to do so, the source of the spill should be stopped

immediately. This may be a simple action like upturning a fallen container.

Contain and control the flow: To stop the spill from expanding, absorbent materials and

liquid barriers should be placed around the spill. Work from the outside to soak up the

spill. It is vital that spilt liquid is not allowed to reach storm water drains, sewer drains,

natural waterways or soil.

For large scale spills that involve hazardous materials, authorities may have to be alerted.

Clean up: Using information from Material Safety Data Sheets (MSDS) about the

properties of the liquid spilled and the spill equipment available, spills should be cleaned

up promptly.

Record the incident: By keeping a simple log of all spills, precautionary measures can be

put in place to avoid similar accidents from occurring in the future.

8.9 Grievance Redress Mechanism

Timely and effective redress of stakeholder grievances contribute to bringing

sustainability in the operations of a project. In particular, it will help advocate the process

of forming and strengthening relationships between project management and the

stakeholder community groups and bridge any gaps to create a common understanding,

providing the project management the ‘social license’ to operate in the area. The

grievance redress mechanism proposed for the Project will help achieve the objectives of

sustainability and cooperation by dealing with the environmental and social issues of the

Project.

The proposed grievance redress mechanism will be designed to cater for the issues of the

people that can be affected by the Project. The population that can be affected by the

Project is identified in Section 4.4.3 – Description of Environment, and comprises of the

people residing within ten km of the plant site. The potential impacts of the Project are

described in Section 7 – Anticipated Environmental Impacts and Mitigation Measures.

8.9.1 Framework for Grievance Redress Mechanism

The Owners will develop a stakeholder grievance redress mechanism.

Sindh Environmental Protection Act 2014

The Federal Agency, under Regulation 6 of the IEE-EIA Regulations 2000, has issued a

set of guidelines of general applicability and sectoral guidelines indicating specific

assessment requirements. Under the regulations and guidelines, no specific requirements




are laid out for developing a grievance redress mechanism for projects. However, under

its Guidelines for Environmental Examinations and Assessments provided in Section 17

of the Act, in its third clause, SEPA 2014 directs the project proponents to involve public

during the review procedure of the environmental assessment to record their concern at

the very initial phase of the project.

IFC Performance Standards

IFC Performance Standard 1 (IFC PS 1) in its paragraph 30 states “When Affected

Communities are subject to identified risks and adverse impacts from a project, the client

will undertake a process of consultation in a manner that provides the Affected

Communities with opportunities to express their views on project risks, impacts and

mitigation measures, and allows the client to consider and respond to them”.1

In addition to holding consultation with the affected communities, IFC PS 1 require the

project proponents to compel with its requirements to establish and maintain procedures

for external communications and grievance mechanism to receive, register, screen, assess

and response to the complaints recorded by the affected communities and develop an

mechanism to periodically report the affected communities about the progress and

implementation of the project action plans on the issues raised.2

8.9.2 Outline of Mechanism for Grievance Redress

The Owners will have an effective mechanism to ensure timely and effective handling of

grievances related to the Project, including those related to transportation of construction

material, ecological services and employment. It may include:

A Public Complaints Unit (PCU), which will be responsible to receive, log, and

resolve complaints; and,

A Grievance Redress Committee (GRC), responsible to oversee the functioning of

the PCU as well as the final non-judicial authority on resolving grievances that

cannot be resolved by PCU;

Grievance Focal Points (GFPs), which will be educated people from the fishing

community that can be approached by the community members for their

grievances against the EPL. The GFPs will be provided training by the Owners in

facilitating grievance redress.

1 International Finance Corporation. “IFC Performance Standards on Environmental and Social Suitability”,

World Bank Group, Washington D.C, January, 2012. 2 Ibid



Hagler Bailly Pakistan Conclusion

R5A05ENP: 09/29/15 9-1

9. Conclusion

The proposed RLNG CCPP project includes the construction and operation of a new

thermal power plant with gas and steam turbine generators to generate 450 MW of

electric power.

The Project will incorporate state-of-the-art equipment and effluent treatment

technologies to minimize associated wastes and mitigate their adverse impacts on the

physical and socioeconomic environment of the Project area to the maximum possible

levels.

The EIA study has documented all major environmental concerns associated with the

development of the proposed Project. The EIA also documents an EMP which provides

mitigation and monitoring measures for significant environmental impacts on the existing

biophysical environmental of the Study Area.

In view of the findings of the EIA study and assuming effective implementation of the

mitigation measures and monitoring requirements as outlined in the EMP, it can be

concluded that all environmental impacts of the construction and operation of the Project

will be manageable and the Project will comply with national, provincial and

international standards and guidelines including NEQS, SEQS, IFC EHS guidelines and

IFC PSs.



Hagler Bailly Pakistan Appendix A R5A05ENP: 09/29/15 A-1

Appendix A: Sindh Environmental Quality Standards and IFC EHS Guidelines for Thermal Power Plants

See following pages.




A.1 Sindh Environmental Quality Standards

The environmental standards applicable in Sindh are National Environmental Quality

Standards (NEQS) as developed by Pakistan Environmental Protection Agency prior to

18th Amendment. The only exception is the ambient air quality standards which Sindh

Environmental Protection Agency has notified separately.

Exhibit A.1: National Environmental Quality Standards for Municipal and Liquid

Industrial Effluents (mg/l, unless otherwise defined)

No. Parameter Standards

Into Inland Waters

Into Sewage Treatment1

Into Sea2)

1. Temperature increase3 =<3°C =<3°C =<3°C

2. pH value 6 to 9 6 to 9 6 to 9

3. Five-day bio-chemical oxygen demand (BOD)5 at 20°C4

80 250 805

4. Chemical oxygen demand (COD)1 150 400 400

5. Total suspended solids (TSS) 200 400 200

6. Total dissolved solids (TDS) 3,500 3,500 3,500

7. Grease and oil 10 10 10

8. Phenolic compounds (as phenol) 0.1 0.3 0.3

9. Chlorides (as Cl') 1,000 1,000 SC6

10. Fluorides (as F') 10 10 10

11. Cyanide total (as CN') 1.0 1.0 1.0

12. Anionic detergents (as MBAS)7 20 20 20

13. Sulfates (SO4) 600 1,000 SC6

14. Sulfides (s') 1.0 1.0 1.0

15. Ammonia (NH3) 40 40 40

16. Pesticides8 0.15 0.15 0.15

17. Cadmium9 0.1 0.1 0.1

18. Chromium (trivalent and hexavalent)9 1.0 1.0 1.0

19. Copper9 1.0 1.0 1.0

20. Lead9 0.5 0.5 0.5

21. Mercury9 0.01 0.01 0.01

22. Selenium9 0.5 0.5 0.5

23. Nickel9 1.0 1.0 1.0

24. Silver9 1.0 1.0 1.0




No. Parameter Standards

Into Inland Waters

Into Sewage Treatment1

Into Sea2)

25. Total toxic metals 2.0 2.0 2.0

26. Zinc 5.0 5.0 5.0

27. Arsenic9 1.0 1.0 1.0

28. Barium9 1.5 1.5 1.5

29. Iron 8.0 8.0 8.0

30. Manganese 1.5 1.5 1.5

31. Boron9 6.0 6.0 6.0

32. Chlorine 1.0 1.0 1.0

Explanations:

1. Applicable only when and where sewage treatment is operational and BOD = 80 mg/l is achieved by the sewage treatment system.

2. Provided discharge is not at shore and not within 10 miles of mangrove or other important estuaries.

3. The effluent should not result in temperature increase of more than 3oC at the edge of the zone where initial mixing and dilution take place in the receiving body. In case zone is not define, use 100 m from the point of discharge

4. Assuming minimum dilution 1:10 discharge, lower ratio would attract progressively stringent standards to be determined by the Federal Environmental Protection Agency. By 1:10 dilution means, for example that for each one cubic meter of treated effluent, the recipient water body should have 10 cubic meter of water for dilution of this effluent.

5. The value for industry is 200 mg/l

6. Discharge concentration at or below sea concentration (SC)

7. Methylene Blue Active substances assuming surfactant as biodegradable

8. Pesticides include herbicides, fungicides, and insecticides

9. Subject to total toxic metals discharge should not exceed level given at S. No. 25

Notes:

1. Dilution of liquid effluents to bring them to the NEQS limiting values is not permissible through fresh water mixing with the effluent before discharging into the environment.

2. The concentration of pollutants in water being used will be subtracted from the effluent for calculating the NEQS limits.




Exhibit A.2: National Environmental Quality Standards for Gaseous Emissions

(mg/Nm3 unless otherwise stated)

No. Parameter Source of Emission Standards

1. Smoke Smoke opacity not to exceed 40% or 2 on Ringlemann Scale or equivalent smoke number

2. Particulate matter1 (a) Boilers and furnaces:

i) Oil-fired 300

ii) Coal-fired 500

iii) Cement kilns 300

(b) Grinding, crushing, clinker coolers and related processes, metallurgical processes, converters, blast furnaces and cupolas

500

3. Hydrogen chloride Any 400

4. Chlorine Any 150

5. Hydrogen fluoride Any 150

6. Hydrogen sulfide Any 10

7. Sulfur oxides2, 3 Sulfuric acid/sulfonic acid plants 5,000

Other plants except power plants operating on oil and coal

1,700

8. Carbon monoxide Any 800

9. Lead Any 50

10. Mercury Any 10

11. Cadmium Any 20

12. Arsenic Any 20

13. Copper Any 50

14. Antimony Any 20

15. Zinc Any 200

16. Oxides of nitrogen3 Nitric acid manufacturing unit 3,000

Gas-fired 400

Oil-fired 600

Coal-fired 1,200

1. Based on the assumption that the size of the particulate is 10 micron or more.

2. Based on 1 per cent sulfur content in fuel oil. Higher content of sulfur will cause standards to be pro-rated.

3. In respect of emissions of sulfur dioxide and nitrogen oxides, the power plants operating on oil and coal as fuel shall in addition to National Environmental Quality Standards (NEQS) above, comply with the standards stated in Exhibit A.3 and Exhibit A.4.




Exhibit A.3: Sulfur Dioxide Standards for Power Plants Operating on Oil and Coal

Sulfur Dioxide Background Levels (µg/m3) Standards

Criterion I Criterion II

Background Air Quality (SO2 basis)

Annual Average

Maximum 24-Hour Interval

Max. SO2 Emissions (TPD)

Max. Allowable 1-Year Average Ground Level Increment to Ambient (µg/m3)

Unpolluted < 50 < 200 500 50

Moderately polluted1

Low 50 200 500 50

High 100 400 100 10

Very polluted2 > 100 > 400 100 10

1. For intermediate values between 50 and 100 g/m3 linear interpretation should be used.

2. No project with sulfur dioxide emissions will be recommended.

Exhibit A.4: Nitrogen Oxides Standards for Power Plants Operating on Oil and Coal

Annual arithmetic mean of ambient air concentrations of nitrogen oxides (expressed as NO2) should not exceed

100 g/m3 (0.05 ppm)

Maximum emission levels for stationary source discharges, before mixing with the atmosphere: For fuel fired steam generators

Liquid fossil fuel 130 ng/J of heat input

Solid fossil fuel 300 ng/J of heat input

Lignite fossil fuel 260 ng/J of heat input

Exhibit A.5: National Environmental Quality Standards for Motor Vehicle

Exhaust and Noise

No. Parameter Standards (Maximum Permissible Limit)

Measuring Method

1. Smoke 40% or 2 on the Ringelmann Scale during engine acceleration mode.

To compared with Ringlemann chart at a distance of 6 meters or more.

2. Carbon Monoxide

Emission Standards:

New Vehicles Used Vehicles

4.5% 6% Under idling conditions: Nondispersive infrared detection through gas analyzer.

3. Noise 85 db (A) Sound-meter at 7.5 meters from the source.




Exhibit A.6: Sindh Environmental Quality Standards for Ambient Air

Pollutants Time-weighted Average

Concentration in Ambient Air

Method of Measurement

Sulfur Dioxide (SO2)

Annual Average* 80 μg/m3 -Ultra Violet Fluorescence method

24 hours** 120 μg/m3

Oxide of Nitrogen as (NO) Annual Average* 40 μg/m3 -Gas Phase Chemiluminescence


Oxide of Nitrogen as (NO2)

Annual Average* 40 μg/m3 -Gas Phase Chemiluminescence


O3 1 hour 130 μg/m3 -Non dispersive UV absorption method

Suspended Particulate Matter (SPM)

Annual Average* 360 μg/m3 -High Volume Sampling, (Average flow rate not less than 1.1 m3/min)


Respirable particulate Matter. PM 10

Annual Average* 120 μg/m3 -β Ray Absorption method


Respirable Particulate Matter. PM 2.5

Annual Average* 40 μg/m3 *** -β Ray Absorption method


Lead (Pb) Annual Average* 1 μg/m3 ASS Method after sampling using EPM 2000 or equivalent Filter paper

24 hours** 1.5 μg/m3

Carbon Monoxide (CO)

8 hours** 5 mg/m3 Non Dispersive Infra Red (NDIR) method

1 hour 10 mg/m3

* Annual arithmetic mean of minimum 104 instruments in a year taken twice a week 24 hourly at uniform interval

** 24 hourly /8 hourly values should be met 98% of the in a year. 2% of the time, it may exceed but not on two consecutive days.

*** or 9 μg/m3 plus baseline, whichever is low.




Exhibit A.7: National Environmental Quality Standards for Noise

No. Category of Area/Zone Effective from Ist July, 2010 Effective from Ist July, 2012

Limit in dB(A) Leq*

Day time Night time Day time Night time

1. Residential are (A) 65 50 55 45

2. Commercial are (B) 70 60 65 55

3. Industrial area (C) 80 75 75 65

4. Silence zone (D) 55 45 50 45

Note:

1. Day time hours: 6 .00 am to 10.00 pm

2. Night Time hours: 10.00 pm to 6.00 am

3. Silence zone: Zones which are declared as such by the competent authority. An area comprising not less than 100 meters around hospitals, educational institutions and courts and courts.

4. Mixed categories of areas may be declared as one of the four above-mentioned categories by the competent authority.

5. dB(A) Leq: time weighted average of the level of sound in decibels on scale A which is relatable to human hearing.

Exhibit A.8: National Environmental Quality Standards for Drinking Water

Properties/ Parameters Standard Values For Pakistan

Who Guidelines Remarks

Bacterial

All water intended for drinking (e.Coli or Thermo tolerant Coliform bacteria)

Must not be detectable in any 100 ml sample


Most Asian countries also follow WHO standards

Treated water entering the distribution system (E.Coli or thermo tolerant coliform and total coliform bacteria)




Treated water in the distribution system (E.coli or thermo tolerant coliform and total coliform bacteria)

Must not be detectable in any 100 ml sample In case of large supplies, where sufficient samples are examined, must not be present in 95% of the samples taken throughout any 12-month period.

Must not be detectable in any 100 ml sample In case of large supplies, where sufficient samples are examined, must not be present in 95% of the samples taken throughout any 12-month period.


Physical

Colour ≤15 TCU ≤15 TCU

Taste Non objectionable/Accept Non objectionable/Accept






able able

Odour Non objectionable/Accept able

Non objectionable/Accept able

Turbidity < 5 NTU < 5 NTU

Total hardness as CaCO3

< 500 mg/l –

TDS < 1000 < 1000

pH 6.5 – 8.5 6.5 – 8.5

Chemical

Essential Inorganic mg/Litre mg/Litre

Aluminium (Al) mg/1 <0.2 0.2

Antimony (Sb) <0.005 (P) 0.02

Arsenic (As) < 0.05 (P) 0.01 Standard for Pakistan similar to most Asian developing countries

Barium (Ba) 0.7 0.7

Boron (B) 0.3 0.3

Cadmium (Cd) 0.01 0.003 Standard for Pakistan similar to most Asian developing countries

Chloride (Cl) <250 250

Chromium (Cr) <0.05 0.05

Copper (Cu) 2 2

Toxic Inorganic mg/Litre mg/Litre

Cyanide (CN) <0.05 0.07 Standard for Pakistan similar to Asian developing countries

Fluoride (F)* <1.5 1.5

Lead (Pb) <0.05 0.01 Standard for Pakistan similar to most Asian developing countries

Manganese (Mn) < 0.5 0.5






Mercury (Hg) <0.001 0.001

Nickel (Ni) <0.02 0.02

Nitrate (NO3)* <50 50

Nitrite (NO2)* <3 (P) 3

Selenium (Se) 0.01(P) 0.01

Residual chlorine 0.2-0.5 at consumer end 0.5-

1.5 at source

–

Zinc (Zn) 5.0 3 Standard for Pakistan similar to most Asian developing countries

* indicates priority health related inorganic constituents which need regular monitoring.

Organic

Pesticides mg/L PSQCA No. 4639-2004, Page No. 4 Table No. 3 Serial No. 20- 58 may be consulted.***

Annex II

Phenolic compounds (as Phenols) mg/L

< 0.002

Polynuclear aromatic hydrocarbons (as PAH) g/L

0.01 ( By GC/MS method)

Radioactive

Alpha Emitters bq/L or pCi

0.1 0.1

Beta emitters 1 1

*** PSQCA: Pakistan Standards Quality Control Authority.

Proviso:

The existing drinking water treatment infrastructure is not adequate to comply with WHO guidelines. The arsenic concentrations in South Punjab and in some parts of Sindh have been found high then Revised WHO guidelines. It will take some time to control arsenic through treatment process. Lead concentration in the proposed standards is higher than WHO Guidelines. As the piping system for supply of drinking water in urban centres are generally old and will take significant resources and time to get them replaced. In the recent past, lead was completely phased out from petroleum products to cut down lead entering into environment. These steps will enable to achieve WHO Guidelines for Arsenic, Lead, Cadmium and Zinc. However, for the bottled water, WHO limits for Arsenic, Lead, Cadmium and Zinc will be applicable and PSQCA Standards for all the remaining parameters.




A.2 IFC Environmental, Health, and Safety Guidelines


Environmental, Health, and Safety Guidelines THERMAL POWER PLANTS

DECEMBER 19, 2008 1

WORLD BANK GROUP

Environmental, Health, and Safety Guidelines for Thermal Power Plants

Introduction

The Environmental, Health, and Safety (EHS) Guidelines are technical reference documents with general and industry-specific examples of Good International Industry Practice (GIIP)1. When one or more members of the World Bank Group are involved in a project, these EHS Guidelines are applied as required by their respective policies and standards. These industry sector EHS guidelines are designed to be used together with the General EHS Guidelines document, which provides guidance to users on common EHS issues potentially applicable to all industry sectors. For complex projects, use of multiple industry-sector guidelines may be necessary. A complete list of industry-sector guidelines can be found at: www.ifc.org/ifcext/sustainability.nsf/Content/EnvironmentalGuidelines

The EHS Guidelines contain the performance levels and measures that are generally considered to be achievable in new facilities by existing technology at reasonable costs. Application of the EHS Guidelines to existing facilities may involve the establishment of site-specific targets, based on environmental assessments and/or environmental audits as appropriate, with an appropriate timetable for achieving them. The applicability of the EHS Guidelines should be tailored to the hazards and risks established for each project on the basis of the results of an environmental assessment in which site-specific variables, such as host country context, assimilative capacity of the environment, and other project factors, are taken into account. The applicability

1 Defined as the exercise of professional skill, diligence, prudence and foresight that would be reasonably expected from skilled and experienced professionals engaged in the same type of undertaking under the same or similar circumstances globally. The circumstances that skilled and experienced professionals may find when evaluating the range of pollution prevention and control techniques available to a project may include, but are not limited to, varying levels of environmental degradation and environmental assimilative capacity as well as varying levels of financial and technical feasibility.

of specific technical recommendations should be based on the professional opinion of qualified and experienced persons. When host country regulations differ from the levels and measures presented in the EHS Guidelines, projects are expected to achieve whichever is more stringent. If less stringent levels or measures than those provided in these EHS Guidelines are appropriate, in view of specific project circumstances, a full and detailed justification for any proposed alternatives is needed as part of the site-specific environmental assessment. This justification should demonstrate that the choice for any alternate performance levels is protective of human health and the environment.

Applicability

This document includes information relevant to combustion processes fueled by gaseous, liquid and solid fossil fuels and biomass and designed to deliver electrical or mechanical power, steam, heat, or any combination of these, regardless of the fuel type (except for solid waste which is covered under a separate Guideline for Waste Management Facilities), with a total rated heat input capacity above 50 Megawatt thermal input (MWth) on Higher Heating Value (HHV) basis.2 It applies to boilers, reciprocating engines, and combustion turbines in new and existing facilities. Annex A contains a detailed description of industry activities for this sector, and Annex B contains guidance for Environmental Assessment (EA) of thermal power projects. Emissions guidelines applicable to facilities with a total heat input capacity of less than 50 MWth are presented in Section 1.1 of the General EHS Guidelines. Depending on the characteristics of the project and its associated activities (i.e., fuel sourcing and evacuation of generated electricity), readers should also consult

2 Total capacity applicable to a facility with multiple units.

http://www.ifc.org/ifcext/sustainability.nsf/Content/EnvironmentalGuidelines

http://www.ifc.org/ifcext/sustainability.nsf/Content/EnvironmentalGuidelines


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the EHS Guidelines for Mining and the EHS Guidelines for Electric Power Transmission and Distribution.

Decisions to invest in this sector by one or more members of the World Bank Group are made within the context of the World Bank Group strategy on climate change.

This document is organized according to the following sections:

Section 1.0 – Industry Specific Impacts and Management Section 2.0 – Performance Indicators and Monitoring Section 3.0 – References and Additional Sources Annex A – General Description of Industry Activities Annex B – Environmental Assessment Guidance for Thermal Power Projects.

1.0 Industry-Specific Impacts and Management

The following section provides a summary of the most significant EHS issues associated with thermal power plants, which occur during the operational phase, along with recommendations for their management.

As described in the introduction to the General EHS Guidelines, the general approach to the management of EHS issues in industrial development activities, including power plants, should consider potential impacts as early as possible in the project cycle, including the incorporation of EHS considerations into the site selection and plant design processes in order to maximize the range of options available to prevent and control potential negative impacts.

Recommendations for the management of EHS issues common to most large industrial and infrastructure facilities during the construction and decommissioning phases are provided in the General EHS Guidelines.

1.1 Environment

Environmental issues in thermal power plant projects primarily include the following:

• Air emissions

• Energy efficiency and Greenhouse Gas emissions

• Water consumption and aquatic habitat alteration

• Effluents

• Solid wastes

• Hazardous materials and oil

• Noise

Air Emissions The primary emissions to air from the combustion of fossil fuels or biomass are sulfur dioxide (SO2), nitrogen oxides (NOX), particulate matter (PM), carbon monoxide (CO), and greenhouse gases, such as carbon dioxide (CO2). Depending on the fuel type and quality, mainly waste fuels or solid fuels, other substances such as heavy metals (i.e., mercury, arsenic, cadmium, vanadium, nickel, etc), halide compounds (including hydrogen fluoride), unburned hydrocarbons and other volatile organic compounds (VOCs) may be emitted in smaller quantities, but may have a significant influence on the environment due to their toxicity and/or persistence. Sulfur dioxide and nitrogen oxide are also implicated in long-range and trans-boundary acid deposition.

The amount and nature of air emissions depends on factors such as the fuel (e.g., coal, fuel oil, natural gas, or biomass), the type and design of the combustion unit (e.g., reciprocating engines, combustion turbines, or boilers), operating practices, emission control measures (e.g., primary combustion control, secondary flue gas treatment), and the overall system efficiency. For example, gas-fired plants generally produce negligible quantities of particulate matter and sulfur oxides, and levels of nitrogen oxides are about 60% of those from plants using coal (without


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emission reduction measures). Natural gas-fired plants also release lower quantities of carbon dioxide, a greenhouse gas.

Some measures, such as choice of fuel and use of measures to increase energy conversion efficiency, will reduce emissions of multiple air pollutants, including CO2, per unit of energy generation. Optimizing energy utilization efficiency of the generation process depends on a variety of factors, including the nature and quality of fuel, the type of combustion system, the operating temperature of the combustion turbines, the operating pressure and temperature of steam turbines, the local climate conditions, the type of cooling system used, etc. Recommended measures to prevent, minimize, and control air emissions include:

• Use of the cleanest fuel economically available (natural gas is preferable to oil, which is preferable to coal) if that is consistent with the overall energy and environmental policy of the country or the region where the plant is proposed. For most large power plants, fuel choice is often part of the national energy policy, and fuels, combustion technology and pollution control technology, which are all interrelated, should be evaluated very carefully upstream of the project to optimize the project’s environmental performance;

• When burning coal, giving preference to high-heat-content, low-ash, and low-sulfur coal;

• Considering beneficiation to reduce ash content, especially for high ash coal;3

• Selection of the best power generation technology for the fuel chosen to balance the environmental and economic benefits. The choice of technology and pollution control systems will be based on the site-specific environmental assessment (some examples include the use of higher energy-efficient systems, such as combined cycle gas turbine system for natural gas and oil-fired units, and supercritical, ultra-supercritical or integrated coal gasification combined cycle (IGCC) technology for coal-fired units);

• Designing stack heights according to Good International Industry Practice (GIIP) to avoid excessive ground level concentrations and minimize impacts, including acid deposition;4

• Considering use of combined heat and power (CHP, or co-generation) facilities. By making use of otherwise wasted heat, CHP facilities can achieve thermal efficiencies of 70 – 90 percent, compared with 32 – 45 percent for conventional thermal power plants.

• As stated in the General EHS Guidelines, emissions from a single project should not contribute more than 25% of the applicable ambient air quality standards to allow additional, future sustainable development in the same airshed.5

Pollutant-specific control recommendations are provided below.

Sulfur Dioxide The range of options for the control of sulfur oxides varies substantially because of large differences in the sulfur content of different fuels and in control costs as described in Table 1. The choice of technology depends on a benefit-cost analysis of the environmental performance of different fuels, the cost of controls, and the existence of a market for sulfur control by-products6. Recommended measures to prevent, minimize, and control SO2 emissions include:

3 If sulfur is inorganically bound to the ash, this will also reduce sulfur content. 4 For specific guidance on calculating stack height see Annex 1.1.3 of the General EHS Guidelines. Raising stack height should not be used to allow more emissions. However, if the proposed emission rates result in significant incremental ambient air quality impacts to the attainment of the relevant ambient air quality standards, options to raise stack height and/or to further reduce emissions should be considered in the EA. Typical examples of GIIP stack heights are up to around 200m for large coal-fired power plants, up to around 80m for HFO-fueled diesel engine power plants, and up to 100m for gas-fired combined cycle gas turbine power plants. Final selection of the stack height will depend on the terrain of the surrounding areas, nearby buildings, meteorological conditions, predicted incremental impacts and the location of existing and future receptors. 5 For example, the US EPA Prevention of Significant Deterioration Increments Limits applicable to non-degraded airsheds provide the following: SO2 (91 μg/m3 for 2nd highest 24-hour, 20 μg/m3 for annual average), NO2 (20 μg/m3 for annual average), and PM10 (30 μg/m3 for 2nd highest 24-hour, and 17 μg/m3 for annual average).


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• Use of fuels with a lower content of sulfur where economically feasible;

• Use of lime (CaO) or limestone (CaCO3) in coal-fired fluidized bed combustion boilers to have integrated desulfurization which can achieve a removal efficiency of up to 80-90 % through use of Fluidized Bed Combustion7, 8;

• Depending on the plant size, fuel quality, and potential for significant emissions of SO2 , use of flue gas desulfurization (FGD) for large boilers using coal or oil and for large reciprocating engines . The optimal type of FGD system (e.g., wet FGD using limestone with 85 to 98% removal efficiency, dry FGD using lime with 70 to 94% removal efficiency, seawater FGD with up to 90% removal efficiency) depends on the capacity of the plant, fuel properties, site conditions, and the cost and availability of reagent as well as by-product disposal and utilization.9

Table 1 - Performance / Characteristics of FGDs Type of FGD

Characteristics Plant Capital Cost Increase

Wet FGD • Flue gas is saturated with water • Limestone (CaCO3) as reagent • Removal efficiency up to 98% • Use 1-1.5% of electricity generated • Most widely used • Distance to limestone source and

the limestone reactivity to be considered

• High water consumption • Need to treat wastewater • Gypsum as a saleable by-product

or waste

11-14%

Semi-Dry FGD

• Also called “Dry Scrubbing” – under controlled humidification.

• Lime (CaO) as reagent • Removal efficiency up to 94%

9-12%

6 Regenerative Flue Gas Desulfurization (FGD) options (either wet or semi-dray) may be considered under these conditions. 7 EC (2006). 8 The SO2 removal efficiency of FBC technologies depends on the sulfur and lime content of fuel, sorbent quantity, ratio, and quality. 9 The use of wet scrubbers, in addition to dust control equipment (e.g. ESP or Fabric Filter), has the advantage of also reducing emissions of HCl, HF, heavy metals, and further dust remaining after ESP or Fabric Filter. Because of higher costs, the wet scrubbing process is generally not used at plants with a capacity of less than 100 MWth (EC 2006).

• Can remove SO3 as well at higher removal rate than Wet FGD

• Use 0.5-1.0% of electricity generated, less than Wet FGD

• Lime is more expensive than limestone

• No wastewater • Waste – mixture of fly ash,

unreacted additive and CaSO3 Seawater FGD

• Removal efficiency up to 90% • Not practical for high S coal

(>1%S) • Impacts on marine environment

need to be carefully examined (e.g., reduction of pH, inputs of remaining heavy metals, fly ash, temperature, sulfate, dissolved oxygen, and chemical oxygen demand)

• Use 0.8-1.6% of electricity generated

• Simple process, no wastewater or solid waste,

7-10%

Sources: EC (2006) and World Bank Group.

Nitrogen Oxides Formation of nitrogen oxides can be controlled by modifying operational and design parameters of the combustion process (primary measures). Additional treatment of NOX from the flue gas (secondary measures; see Table 2) may be required in some cases depending on the ambient air quality objectives. Recommended measures to prevent, minimize, and control NOX emissions include:

• Use of low NOX burners with other combustion modifications, such as low excess air (LEA) firing, for boiler plants. Installation of additional NOX controls for boilers may be necessary to meet emissions limits; a selective catalytic reduction (SCR) system can be used for pulverized coal-fired, oil-fired, and gas-fired boilers or a selective non-catalytic reduction (SNCR) system for a fluidized-bed boiler;

• Use of dry low-NOX combustors for combustion turbines burning natural gas;

• Use of water injection or SCR for combustion turbines and


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reciprocating engines burning liquid fuels;10

• Optimization of operational parameters for existing reciprocating engines burning natural gas to reduce NOx emissions;

• Use of lean-burn concept or SCR for new gas engines.

Table 2 - Performance / Characteristics of Secondary NOx Reduction Systems

Type Characteristics Plant Capital Cost Increase

SCR • NOx emission reduction rate of 80 – 95%

• Use 0.5% of electricity generated • Use ammonia or urea as reagent. • Ammonia slip increases with increasing

NH3/NOx ratio may cause a problem (e.g., too high ammonia in the fly ash). Larger catalyst volume / improving the mixing of NH3 and NOx in the flue gas may be needed to avoid this problem.

• Catalysts may contain heavy metals. Proper handling and disposal / recycle of spent catalysts is needed.

• Life of catalysts has been 6-10 years (coal-fired), 8-12 years (oil-fired) and more than 10 years (gas-fired).

4-9% (coal-fired boiler) 1-2% (gas-fired combined cycle gas turbine) 20-30% (reciprocating engines)

SNCR • NOx emission reduction rate of 30 – 50%

• Use 0.1-0.3% of electricity generated • Use ammonia or urea as reagent. • Cannot be used on gas turbines or gas

engines. • Operates without using catalysts.

1-2%

Source: EC (2006), World Bank Group

Particulate Matter Particulate matter11 is emitted from the combustion process, especially from the use of heavy fuel oil, coal, and solid biomass. The proven technologies for particulate removal in power plants are fabric filters and electrostatic precipitators (ESPs), shown in Table 3. The choice between a fabric filter and an ESP depends on the fuel properties, type of FGD system if used for SO2 control, 10 Water injection may not be practical for industrial combustion turbines in all cases. Even if water is available, the facilities for water treatment and the operating and maintenance costs of water injection may be costly and may complicate the operation of a small combustion turbine.

and ambient air quality objectives. Particulate matter can also be released during transfer and storage of coal and additives, such as lime. Recommendations to prevent, minimize, and control particulate matter emissions include:

• Installation of dust controls capable of over 99% removal efficiency, such as ESPs or Fabric Filters (baghouses), for coal-fired power plants. The advanced control for particulates is a wet ESP, which further increases the removal efficiency and also collects condensables (e.g., sulfuric acid mist) that are not effectively captured by an ESP or a fabric filter;12

• Use of loading and unloading equipment that minimizes the height of fuel drop to the stockpile to reduce the generation of fugitive dust and installing of cyclone dust collectors;

• Use of water spray systems to reduce the formation of fugitive dust from solid fuel storage in arid environments;

• Use of enclosed conveyors with well designed, extraction and filtration equipment on conveyor transfer points to prevent the emission of dust;

• For solid fuels of which fine fugitive dust could contain vanadium, nickel and Polycyclic Aromatic Hydrocarbons (PAHs) (e.g., in coal and petroleum coke), use of full enclosure during transportation and covering stockpiles where necessary;

• Design and operate transport systems to minimize the generation and transport of dust on site;

• Storage of lime or limestone in silos with well designed, extraction and filtration equipment;

• Use of wind fences in open storage of coal or use of enclosed storage structures to minimize fugitive dust

11 Including all particle sizes (e.g. TSP, PM10, and PM2.5) 12 Flue gas conditioning (FGC) is a recommended approach to address the issue of low gas conductivity and lower ESP collection performance which occurs when ESPs are used to collect dust from very low sulfur fuels. One particular FGC design involves introduction of sulfur trioxide (SO3) gas into the flue gas upstream of the ESP, to increase the conductivity of the flue gas dramatically improve the ESP collection efficiency. There is typically no risk of increased SOx emissions as the SO3 is highly reactive and adheres to the dust.


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emissions where necessary, applying special ventilation systems in enclosed storage to avoid dust explosions (e.g., use of cyclone separators at coal transfer points).

See Annex 1.1.2 of the General EHS Guidelines for an additional illustrative presentation of point source emissions prevention and control technologies.

Table 3 – Performance / Characteristics of Dust Removal Systems

Type Performance / Characteristics ESP • Removal efficiency of >96.5% (<1 μm), >99.95%

(>10 μm) • 0.1-1.8% of electricity generated is used • It might not work on particulates with very high

electrical resistivity. In these cases, flue gas conditioning (FGC) may improve ESP performance.

• Can handle very large gas volume with low pressure drops

Fabric Filter • Removal efficiency of >99.6% (<1 μm), >99.95% (>10 μm). Removes smaller particles than ESPs.

• 0.2-3% of electricity generated is used • Filter life decreases as coal S content increases • Operating costs go up considerably as the fabric

filter becomes dense to remove more particles • If ash is particularly reactive, it can weaken the

fabric and eventually it disintegrates. Wet Scrubber • Removal efficiency of >98.5% (<1 μm), >99.9%

(>10 μm) • Up to 3% of electricity generated is used. • As a secondary effect, can remove and absorb

gaseous heavy metals • Wastewater needs to be treated

Sources: EC (2006) and World Bank Group.

Other Pollutants Depending on the fuel type and quality, other air pollutants may be present in environmentally significant quantities requiring proper consideration in the evaluation of potential impacts to ambient air quality and in the design and implementation of management actions and environmental controls. Examples of additional pollutants include mercury in coal, vanadium in heavy fuel oil, and other heavy metals present in waste fuels such as petroleum coke (petcoke) and used lubricating oils13. Recommendations to

13 In these cases, the EA should address potential impacts to ambient air quality

prevent, minimize, and control emissions of other air pollutants such as mercury in particular from thermal power plants include the use of conventional secondary controls such as fabric filters or ESPs operated in combination with FGD techniques, such as limestone FGD, Dry Lime FGD, or sorbent injection.14 Additional removal of metals such as mercury can be achieved in a high dust SCR system along with powered activated carbon, bromine-enhanced Powdered Activated Carbon (PAC) or other sorbents. Since mercury emissions from thermal power plants pose potentially significant local and transboundary impacts to ecosystems and public health and safety through bioaccumulation, particular consideration should be given to their minimization in the environmental assessment and accordingly in plant design.15

Emissions Offsets Facilities in degraded airsheds should minimize incremental impacts by achieving emissions values outlined in Table 6. Where these emissions values result nonetheless in excessive ambient impacts relative to local regulatory standards (or in their absence, other international recognized standards or guidelines, including World Health Organization guidelines), the project should explore and implement site-specific offsets that result in no net increase in the total emissions of those pollutants (e.g., particulate matter, sulfur dioxide, or nitrogen dioxide) that are responsible for the degradation of the airshed. Offset provisions should be implemented before the power plant comes fully on stream. Suitable offset measures could include reductions in emissions of particulate matter, sulfur dioxide, or nitrogen dioxide, as necessary through (a) the installation of new or more effective controls at other units within the same power plant or at other power plants in for such heavy metals as mercury, nickel, vanadium, cadmium, lead, etc. 14 For Fabric Filters or Electrostatic Precipitators operated in combination with FGD techniques, an average removal rate of 75% or 90 % in the additional presence of SCR can be obtained (EC, 2006). 15 Although no major industrial country has formally adopted regulatory limits for mercury emissions from thermal power plants, such limitations where under consideration in the United States and European Union as of 2008. Future updates of these EHS Guidelines will reflect changes in the international state of


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the same airshed, (b) the installation of new or more effective controls at other large sources, such as district heating plants or industrial plants, in the same airshed, or (c) investments in gas distribution or district heating systems designed to substitute for the use of coal for residential heating and other small boilers. Wherever possible, the offset provisions should be implemented within the framework of an overall air quality management strategy designed to ensure that air quality in the airshed is brought into compliance with ambient standards. The monitoring and enforcement of ambient air quality in the airshed to ensure that offset provisions are complied with would be the responsibility of the local or national agency responsible for granting and supervising environmental permits. Project sponsors who cannot engage in the negotiations necessary to put together an offset agreement (for example, due to the lack of the local or national air quality management framework) should consider the option of relying on an appropriate combination of using cleaner fuels, more effective pollution controls, or reconsidering the selection of the proposed project site. The overall objective is that the new thermal power plants should not contribute to deterioration of the already degraded airshed.

Energy Efficiency and GHG Emissions Carbon dioxide, one of the major greenhouse gases (GHGs) under the UN Framework Convention on Climate Change, is emitted from the combustion of fossil fuels. Recommendations to avoid, minimize, and offset emissions of carbon dioxide from new and existing thermal power plants include, among others:

• Use of less carbon intensive fossil fuels (i.e., less carbon containing fuel per unit of calorific value -- gas is less than oil and oil is less than coal) or co-firing with carbon neutral fuels (i.e., biomass);

• Use of combined heat and power plants (CHP) where feasible;

• Use of higher energy conversion efficiency technology of the

practice regarding mercury emissions prevention and control.

same fuel type / power plant size than that of the country/region average. New facilities should be aimed to be in top quartile of the country/region average of the same fuel type and power plant size. Rehabilitation of existing facilities must achieve significant improvements in efficiency. Typical CO2 emissions performance of different fuels / technologies are presented below in Table 4;

• Consider efficiency-relevant trade-offs between capital and operating costs involved in the use of different technologies. For example, supercritical plants may have a higher capital cost than subcritical plants for the same capacity, but lower operating costs. On the other hand, characteristics of existing and future size of the grid may impose limitations in plant size and hence technological choice. These tradeoffs need to be fully examined in the EA;

• Use of high performance monitoring and process control techniques, good design and maintenance of the combustion system so that initially designed efficiency performance can be maintained;

• Where feasible, arrangement of emissions offsets (including the Kyoto Protocol’s flexible mechanisms and the voluntary carbon market), including reforestation, afforestation, or capture and storage of CO2 or other currently experimental options16;

• Where feasible, include transmission and distribution loss reduction and demand side measures. For example, an investment in peak load management could reduce cycling requirements of the generation facility thereby improving its operating efficiency. The feasibility of these types of off-set options may vary depending on whether the facility is part of a vertically integrated utility or an independent power producer;

• Consider fuel cycle emissions and off-site factors (e.g., fuel

16 The application of carbon capture and storage (CCS) from thermal power projects is still in experimental stages worldwide although consideration has started to be given to CCS-ready design. Several options are currently under evaluation including CO2 storage in coal seams or deep aquifers and oil reservoir injection for enhanced oil recovery.


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supply, proximity to load centers, potential for off-site use of waste heat, or use of nearby waste gases (blast furnace gases or coal bed methane) as fuel. etc).

Table 4 - Typical CO2 Emissions Performance of New Thermal Power Plants

Fuel Efficiency CO2 (gCO2 / kWh – Gross)

Efficiency (% Net, HHV) Coal (*1, *2)

Ultra-Supercritical (*1): 37.6 – 42.7 Supercritical: 35.9-38.3 (*1) 39.1 (w/o CCS) (*2) 24.9 (with CCS) (*2) Subcritical: 33.1-35.9 (*1) 36.8 (w/o CCS) (*2) 24.9 (with CCS) (*2) IGCC: 39.2-41.8 (*1) 38.2–41.1 (w/o CCS) (*2) 31.7–32.5 (with CCS) (*2)

676-795

756-836

763 95

807-907

808 102

654-719

640 – 662 68 – 86

Gas (*2) Advanced CCGT (*2): 50.8 (w/o CCS) 43.7 (with CCS)

355 39

Efficiency (% Net, LHV) Coal (*3) 42 (Ultra-Supercritical)

40 (Supercritical) 30 – 38 (Subcritical) 46 (IGCC) 38 (IGCC+CCS)

811 851

896-1,050 760 134

Coal and Lignite (*4, *7)

(*4) 43-47 (Coal-PC) >41(Coal-FBC) 42-45 (Lignite-PC) >40 (Lignite-FBC)

(*6) 725-792 (Net) <831 (Net)

808-866 (Net) <909 (Net)

Gas (*4, *7)

(*4) 36–40 (Simple Cycle GT) 38-45 (Gas Engine) 40-42 (Boiler) 54-58 (CCGT)

(*6) 505-561 (Net) 531-449 (Net) 481-505 (Net) 348-374 (Net)

Oil (*4, *7)

(*4) 40 – 45 (HFO/LFO Reciprocating Engine)

(*6) 449-505 (Net)

Efficiency (% Gross, LHV) Coal (*5, *7)

(*5) 47 (Ultra-supercritical) 44 (Supercritical) 41-42 (Subcritical) 47-48 (IGCC)

(*6) 725 774

811-831 710-725

Oil (*5, *7)

(*5) 43 (Reciprocating Engine) 41 (Boiler)

(*6) 648 680

Gas (*5) (*5) 34 (Simple Cycle GT) 51 (CCGT)

(*6) 594 396

Source: (*1) US EPA 2006, (*2) US DOE/NETL 2007, (*3) World Bank, April 2006, (*4) European Commission 2006, (*5) World Bank Group, Sep 2006, (*6) World Bank Group estimates

Water Consumption and Aquatic Habitat Alteration Steam turbines used with boilers and heat recovery steam generators(HRSG) used in combined cycle gas turbine units require a cooling system to condense steam used to generate electricity. Typical cooling systems used in thermal power plants include: (i) once-through cooling system where sufficient cooling water and receiving surface water are available; (ii) closed circuit wet cooling system; and (iii) closed circuit dry cooling system (e.g., air cooled condensers).

Combustion facilities using once-through cooling systems require large quantities of water which are discharged back to receiving surface water with elevated temperature. Water is also required for boiler makeup, auxiliary station equipment, ash handling, and FGD systems.17 The withdrawal of such large quantities of water has the potential to compete with other important water uses such as agricultural irrigation or drinking water sources. Withdrawal and discharge with elevated temperature and chemical contaminants such as biocides or other additives, if used, may affect aquatic organisms, including phytoplankton, zooplankton, fish, crustaceans, shellfish, and many other forms of aquatic life. Aquatic organisms drawn into cooling water intake structures are either impinged on components of the cooling water intake structure or entrained in the cooling water system itself. In the case of either impingement or entrainment, aquatic organisms may be killed or subjected to significant harm. In some cases (e.g., sea turtles), organisms are entrapped in the intake canals. There may be special concerns about the potential impacts of cooling water intake structures located in or near habitat areas that support threatened, endangered, or other protected species or where local fishery is active.

Conventional intake structures include traveling screens with relative high through-screen velocities and no fish handling or 17 The availability of water and impact of water use may affect the choice of FGD


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return system.18 Measures to prevent, minimize, and control environmental impacts associated with water withdrawal should be established based on the results of a project EA, considering the availability and use of water resources locally and the ecological characteristics of the project affected area. Recommended management measures to prevent or control impacts to water resources and aquatic habitats include19:

• Conserving water resources, particularly in areas with limited water resources, by: o Use of a closed-cycle, recirculating cooling water

system (e.g., natural or forced draft cooling tower), or closed circuit dry cooling system (e.g., air cooled condensers) if necessary to prevent unacceptable adverse impacts. Cooling ponds or cooling towers are the primary technologies for a recirculating cooling water system. Once-through cooling water systems may be acceptable if compatible with the hydrology and ecology of the water source and the receiving water and may be the preferred or feasible alternative for certain pollution control technologies such as seawater scrubbers

o Use of dry scrubbers in situations where these controls are also required or recycling of wastewater in coal-fired plants for use as FGD makeup

o Use of air-cooled systems

• Reduction of maximum through-screen design intake velocity to 0.5 ft/s;

• Reduction of intake flow to the following levels: o For freshwater rivers or streams to a flow sufficient to

maintain resource use (i.e., irrigation and fisheries) as well as biodiversity during annual mean low flow conditions20

system used (i.e., wet vs. semi-dry). 18 The velocity generally considered suitable for the management of debris is 1 fps [0.30 m/s] with wide mesh screens; a standard mesh for power plants of 3/8 in (9.5 mm). 19 For additional information refer to Schimmoller (2004) and USEPA (2001). 20 Stream flow requirements may be based on mean annual flow or mean low flow. Regulatory requirements may be 5% or higher for mean annual flows and 10% to

o For lakes or reservoirs, intake flow must not disrupt the thermal stratification or turnover pattern of the source water

o For estuaries or tidal rivers, reduction of intake flow to 1% of the tidal excursion volume

• If there are threatened, endangered, or other protected species or if there are fisheries within the hydraulic zone of influence of the intake, reduction of impingement and entrainment of fish and shellfish by the installation of technologies such as barrier nets (seasonal or year-round), fish handling and return systems, fine mesh screens, wedgewire screens, and aquatic filter barrier systems. Examples of operational measures to reduce impingement and entrainment include seasonal shutdowns, if necessary, or reductions in flow or continuous use of screens. Designing the location of the intake structure in a different direction or further out into the water body may also reduce impingement and entrainment.

Effluents Effluents from thermal power plants include thermal discharges, wastewater effluents, and sanitary wastewater.

Thermal Discharges As noted above, thermal power plants with steam-powered generators and once-through cooling systems use significant volume of water to cool and condense the steam for return to the boiler. The heated water is normally discharged back to the source water (i.e., river, lake, estuary, or the ocean) or the nearest surface water body. In general, thermal discharge should be designed to ensure that discharge water temperature does not result in exceeding relevant ambient water quality temperature standards outside a scientifically established mixing zone. The mixing zone is typically defined as the zone where initial dilution of a discharge takes place within which relevant water quality 25% for mean low flows. Their applicability should be verified on a site-specific


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temperature standards are allowed to exceed and takes into account cumulative impact of seasonal variations, ambient water quality, receiving water use, potential receptors and assimilative capacity among other considerations. Establishment of such a mixing zone is project specific and may be established by local regulatory agencies and confirmed or updated through the project's environmental assessment process. Where no regulatory standard exists, the acceptable ambient water temperature change will be established through the environmental assessment process. Thermal discharges should be designed to prevent negative impacts to the receiving water taking into account the following criteria:

• The elevated temperature areas because of thermal discharge from the project should not impair the integrity of the water body as a whole or endanger sensitive areas (such as recreational areas, breeding grounds, or areas with sensitive biota);

• There should be no lethality or significant impact to breeding and feeding habits of organisms passing through the elevated temperature areas;

• There should be no significant risk to human health or the environment due to the elevated temperature or residual levels of water treatment chemicals.

If a once-through cooling system is used for large projects (i.e., a plant with > 1,200MWth steam generating capacity), impacts of thermal discharges should be evaluated in the EA with a mathematical or physical hydrodynamic plume model, which can be a relatively effective method for evaluating a thermal discharge to find the maximum discharge temperatures and flow rates that would meet the environmental objectives of the receiving water.21

basis taking into consideration resource use and biodiversity requirements. 21 An example model is CORMIX (Cornell Mixing Zone Expert System) hydrodynamic mixing zone computer simulation, which has been developed by the U.S. Environmental Protection Agency. This model emphasizes predicting the site- and discharge-specific geometry and dilution characteristics to assess the environmental effects of a proposed discharge.

Recommendations to prevent, minimize, and control thermal discharges include:

• Use of multi-port diffusers;

• Adjustment of the discharge temperature, flow, outfall location, and outfall design to minimize impacts to acceptable level (i.e., extend length of discharge channel before reaching the surface water body for pre-cooling or change location of discharge point to minimize the elevated temperature areas);

• Use of a closed-cycle, recirculating cooling water system as described above (e.g., natural or forced draft cooling tower), or closed circuit dry cooling system (e.g., air cooled condensers) if necessary to prevent unacceptable adverse impacts. Cooling ponds or cooling towers are the primary technologies for a recirculating cooling water system.

Liquid Waste The wastewater streams in a thermal power plant include cooling tower blowdown; ash handling wastewater; wet FGD system discharges; material storage runoff; metal cleaning wastewater; and low-volume wastewater, such as air heater and precipitator wash water, boiler blowdown, boiler chemical cleaning waste, floor and yard drains and sumps, laboratory wastes, and backflush from ion exchange boiler water purification units. All of these wastewaters are usually present in plants burning coal or biomass; some of these streams (e.g., ash handling wastewater) may be present in reduced quantities or may not be present at all in oil-fired or gas-fired power plants. The characteristics of the wastewaters generated depend on the ways in which the water has been used. Contamination arises from demineralizers; lubricating and auxiliary fuel oils; trace contaminants in the fuel (introduced through the ash-handling wastewater and wet FGD system discharges); and chlorine, biocides, and other chemicals used to manage the quality of water in cooling systems. Cooling tower blowdown tends to be very high in total dissolved solids but is generally classified as non-contact cooling water and, as such,



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is typically subject to limits for pH, residual chlorine, and toxic chemicals that may be present in cooling tower additives (including corrosion inhibiting chemicals containing chromium and zinc whose use should be eliminated).

Recommended water treatment and wastewater conservation methods are discussed in Sections 1.3 and 1.4, respectively, of the General EHS Guidelines. In addition, recommended measures to prevent, minimize, and control wastewater effluents from thermal power plants include:

• Recycling of wastewater in coal-fired plants for use as FGD makeup. This practice conserves water and reduces the number of wastewater streams requiring treatment and discharge22;

• In coal-fired power plants without FGD systems, treatment of process wastewater in conventional physical-chemical treatment systems for pH adjustment and removal of total suspended solids (TSS), and oil / grease, at a minimum. Depending on local regulations, these treatment systems can also be used to remove most heavy metals to part-per-billion (ppb) levels by chemical precipitation as either metal hydroxide or metal organosulfide compounds;

• Collection of fly ash in dry form and bottom ash in drag chain conveyor systems in new coal-fired power plants;

• Consider use of soot blowers or other dry methods to remove fireside wastes from heat transfer surfaces so as to minimize the frequency and amount of water used in fireside washes;

• Use of infiltration and runoff control measures such as compacted soils, protective liners, and sedimentation controls for runoff from coal piles;

• Spraying of coal piles with anionic detergents to inhibit bacterial growth and minimize acidity of leachate;23

22 Suitable wastewater streams for reuse include gypsum wash water, which is a different wastewater stream than the FGD wastewater. In plants that produce marketable gypsum, the gypsum is rinsed to remove chloride and other undesirable trace elements. 23 If coal pile runoff will be used as makeup to the FGD system, anionic detergents

• Use of SOX removal systems that generate less wastewater, if feasible; however, the environmental and cost characteristics of both inputs and wastes should be assessed on a case-by-case basis;

• Treatment of low-volume wastewater streams that are typically collected in the boiler and turbine room sumps in conventional oil-water separators before discharge;

• Treatment of acidic low-volume wastewater streams, such as those associated with the regeneration of makeup demineralizer and deep-bed condensate polishing systems, by chemical neutralization in-situ before discharge;

• Pretreatment of cooling tower makeup water, installation of automated bleed/feed controllers, and use of inert construction materials to reduce chemical treatment requirements for cooling towers;

• Elimination of metals such as chromium and zinc from chemical additives used to control scaling and corrosion in cooling towers;

• Use the minimum required quantities of chlorinated biocides in place of brominated biocides or alternatively apply intermittent shock dosing of chlorine as opposed to continuous low level feed.

Sanitary Wastewater Sewage and other wastewater generated from washrooms, etc. are similar to domestic wastewater. Impacts and management of sanitary wastewater is addressed in Section 1.3 of the General EHS Guidelines.

Solid Wastes Coal-fired and biomass-fired thermal power plants generate the greatest amount of solid wastes due to the relatively high percentage of ash in the fuel.24 The large-volume coal

may increase or create foaming within the scrubber system. Therefore, use of anionic surfactants on coal piles should be evaluated on a case-by-case basis. 24 For example, a 500 MWe plant using coal with 2.5% sulfur (S), 16% ash, and 30,000 kilojoules per kilogram (kJ/kg) heat content will generate about 500 tons of



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combustion wastes (CCW) are fly ash, bottom ash, boiler slag, and FGD sludge. Biomass contains less sulfur; therefore FGD may not be necessary. Fluidized-bed combustion (FBC) boilers generate fly ash and bottom ash, which is called bed ash. Fly ash removed from exhaust gases makes up 60–85% of the coal ash residue in pulverized-coal boilers and 20% in stoker boilers. Bottom ash includes slag and particles that are coarser and heavier than fly ash. Due to the presence of sorbent material, FBC wastes have a higher content of calcium and sulfate and a lower content of silica and alumina than conventional coal combustion wastes. Low-volume solid wastes from coal-fired thermal power plants and other plants include coal mill rejects/pyrites, cooling tower sludge, wastewater treatment sludge, and water treatment sludge.

Oil combustion wastes include fly ash and bottom ash and are normally only generated in significant quantities when residual fuel oil is burned in oil-fired steam electric boilers. Other technologies (e.g., combustion turbines and diesel engines) and fuels (e.g., distillate oil) generate little or no solid wastes. Overall, oil combustion wastes are generated in much smaller quantities than the large-volume CCW discussed above. Gas-fired thermal power plants generate essentially no solid waste because of the negligible ash content, regardless of the combustion technology.

Metals are constituents of concern in both CCW and low-volume solid wastes. For example, ash residues and the dust removed from exhaust gases may contain significant levels of heavy metals and some organic compounds, in addition to inert materials.

Ash residues are not typically classified as a hazardous waste due to their inert nature.25 However, where ash residues are expected to contain potentially significant levels of heavy metals, radioactivity, or other potentially hazardous materials, they should be tested at the start of plant operations to verify their

solid waste per day. 25 Some countries may categorize fly ash as hazardous due to the presence of arsenic or radioactivity, precluding its use as a construction material.

classification as hazardous or non-hazardous according to local regulations or internationally recognized standards. Additional information about the classification and management of hazardous and non-hazardous wastes is presented in Section 1.6 of the General EHS Guidelines.

The high-volume CCWs wastes are typically managed in landfills or surface impoundments or, increasingly, may be applied to a variety of beneficial uses. Low-volume wastes are also managed in landfills or surface impoundments, but are more frequently managed in surface impoundments. Many coal-fired plants co-manage large-volume and low-volume wastes.

Recommended measures to prevent, minimize, and control the volume of solid wastes from thermal power plants include:

• Dry handling of the coal combustion wastes, in particular fly ash. Dry handling methods do not involve surface impoundments and, therefore, do not present the ecological risks identified for impoundments (e.g., metal uptake by wildlife);

• Recycling of CCWs in uses such as cement and other concrete products, construction fills (including structural fill, flowable fill, and road base), agricultural uses such as calcium fertilizers (provided trace metals or other potentially hazardous materials levels are within accepted thresholds), waste management applications, mining applications, construction materials (e.g., synthetic gypsum for plasterboard), and incorporation into other products provided the residues (such as trace metals and radioactivity) are not considered hazardous. Ensuring consistent quality of fuels and additives helps to ensure the CCWs can be recycled. If beneficial reuse is not feasible, disposal of CCW in permitted landfills with environmental controls such as run-on/run-off controls, liners, leachate collection systems, ground-water monitoring, closure controls, daily (or other operational) cover, and fugitive dust controls is recommended;



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• Dry collection of bottom ash and fly ash from power plants combusting heavy fuel oil if containing high levels of economically valuable metals such as vanadium and recycle for vanadium recovery (where economically viable) or disposal in a permitted landfill with environmental controls;

• Management of ash disposal and reclamation so as to minimize environmental impacts – especially the migration of toxic metals, if present, to nearby surface and groundwater bodies, in addition to the transport of suspended solids in surface runoff due to seasonal precipitation and flooding. In particular, construction, operation, and maintenance of surface impoundments should be conducted in accordance with internationally recognized standards.26, 27

• Reuse of sludge from treatment of waste waters from FGD plants. This sludge may be re-used in the FGD plant due to the calcium components. It can also be used as an additive in coal-fired plant combustion to improve the ash melting behavior

Hazardous Materials and Oil Hazardous materials stored and used at combustion facilities include solid, liquid, and gaseous waste-based fuels; air, water, and wastewater treatment chemicals; and equipment and facility maintenance chemicals (e.g., paint certain types of lubricants, and cleaners). Spill prevention and response guidance is addressed in Sections 1.5 and 3.7 of the General EHS Guidelines.

In addition, recommended measures to prevent, minimize, and control hazards associated with hazardous materials storage and handling at thermal power plants include the use of double-walled, underground pressurized tanks for storage of pure liquefied ammonia (e.g., for use as reagent for SCR) in quantities over 100

26 See, for example, U.S. Department of Labor, Mine Safety and Health Administration regulations at 30 CFR §§ 77.214 - 77.216. 27 Additional detailed guidance applicable to the prevention and control of impacts to soil and water resources from non-hazardous and hazardous solid waste disposal is presented in the World Bank Group EHS Guidelines for Waste Management Facilities.

m3; tanks of lesser capacity should be manufactured using annealing processes (EC 2006).

Noise Principal sources of noise in thermal power plants include the turbine generators and auxiliaries; boilers and auxiliaries, such as coal pulverizers; reciprocating engines; fans and ductwork; pumps; compressors; condensers; precipitators, including rappers and plate vibrators; piping and valves; motors; transformers; circuit breakers; and cooling towers. Thermal power plants used for base load operation may operate continually while smaller plants may operate less frequently but still pose a significant source of noise if located in urban areas.

Noise impacts, control measures, and recommended ambient noise levels are presented in Section 1.7 of the General EHS Guidelines. Additional recommended measures to prevent, minimize, and control noise from thermal power plants include:

• Siting new facilities with consideration of distances from the noise sources to the receptors (e.g., residential receptors, schools, hospitals, religious places) to the extent possible. If the local land use is not controlled through zoning or is not effectively enforced, examine whether residential receptors could come outside the acquired plant boundary. In some cases, it could be more cost effective to acquire additional land as buffer zone than relying on technical noise control measures, where possible;

• Use of noise control techniques such as: using acoustic machine enclosures; selecting structures according to their noise isolation effect to envelop the building; using mufflers or silencers in intake and exhaust channels; using sound-absorptive materials in walls and ceilings; using vibration isolators and flexible connections (e.g., helical steel springs and rubber elements); applying a carefully detailed design to prevent possible noise leakage through openings or to minimize pressure variations in piping;



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• Modification of the plant configuration or use of noise barriers such as berms and vegetation to limit ambient noise at plant property lines, especially where sensitive noise receptors may be present.

Noise propagation models may be effective tools to help evaluate noise management options such as alternative plant locations, general arrangement of the plant and auxiliary equipment, building enclosure design, and, together with the results of a baseline noise assessment, expected compliance with the applicable community noise requirements.

1.2 Occupational Health and Safety

Occupational health and safety risks and mitigation measures during construction, operation, and decommissioning of thermal power plants are similar to those at other large industrial facilities, and are addressed in Section 2.0 of the General EHS Guidelines. In addition, the following health and safety impacts are of particular concern during operation of thermal power plants:

• Non-ionizing radiation

• Heat

• Noise

• Confined spaces

• Electrical hazards

• Fire and explosion hazards

• Chemical hazards

• Dust

Non-ionizing radiation Combustion facility workers may have a higher exposure to electric and magnetic fields (EMF) than the general public due to working in proximity to electric power generators, equipment, and connecting high-voltage transmission lines. Occupational EMF exposure should be prevented or minimized through the preparation and implementation of an EMF safety program including the following components:

• Identification of potential exposure levels in the workplace, including surveys of exposure levels in new projects and the use of personal monitors during working activities;

• Training of workers in the identification of occupational EMF levels and hazards;

• Establishment and identification of safety zones to differentiate between work areas with expected elevated EMF levels compared to those acceptable for public exposure, limiting access to properly trained workers;

• Implementation of action plans to address potential or confirmed exposure levels that exceed reference occupational exposure levels developed by international organizations such as the International Commission on Non-Ionizing Radiation Protection (ICNIRP), the Institute of Electrical and Electronics Engineers (IEEE).28 Personal exposure monitoring equipment should be set to warn of exposure levels that are below occupational exposure reference levels (e.g., 50 percent). Action plans to address occupational exposure may include limiting exposure time through work rotation, increasing the distance between the source and the worker, when feasible, or the use of shielding materials.

Heat Occupational exposure to heat occurs during operation and maintenance of combustion units, pipes, and related hot equipment. Recommended prevention and control measures to address heat exposure at thermal power plants include:

• Regular inspection and maintenance of pressure vessels and piping;

• Provision of adequate ventilation in work areas to reduce heat and humidity;

28 The ICNIRP exposure guidelines for Occupational Exposure are listed in Section 2.2 of this Guideline.



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• Reducing the time required for work in elevated temperature environments and ensuring access to drinking water;

• Shielding surfaces where workers come in close contact with hot equipment, including generating equipment, pipes etc;

• Use of warning signs near high temperature surfaces and personal protective equipment (PPE) as appropriate, including insulated gloves and shoes.

Noise Noise sources in combustion facilities include the turbine generators and auxiliaries; boilers and auxiliaries, such as pulverizers; diesel engines; fans and ductwork; pumps; compressors; condensers; precipitators, including rappers and plate vibrators; piping and valves; motors; transformers; circuit breakers; and cooling towers. Recommendations for reducing noise and vibration are discussed in Section 1.1, above. In addition, recommendations to prevent, minimize, and control occupational noise exposures in thermal power plants include:

• Provision of sound-insulated control rooms with noise levels below 60 dBA29;

• Design of generators to meet applicable occupational noise levels;

• Identify and mark high noise areas and require that personal noise protecting gear is used all the time when working in such high noise areas (typically areas with noise levels >85 dBA).

Confined Spaces Specific areas for confined space entry may include coal ash containers, turbines, condensers, and cooling water towers

29 Depending on the type and size of the thermal power plants, distance between control room and the noise emitting sources differs. CSA Z107.58 provides design guidelines for control rooms as 60 dBA. Large thermal power plants using steam boilers or combustion turbines tend to be quieter than 60 dBA. Reciprocating engine manufacturers recommend 65 to 70 dBA instead of 60 dBA (Euromot Position as of 9 May 2008). This guideline recommends 60 dBA as GIIP, with an understanding that up to 65 dBA can be accepted for reciprocating engine power plants if 60 dBA is economically difficult to achieve.

(during maintenance activities). Recommend confined space entry procedures are discussed in Section 2.8 of the General EHS Guidelines.

Electrical Hazards Energized equipment and power lines can pose electrical hazards for workers at thermal power plants. Recommended measures to prevent, minimize, and control electrical hazards at thermal power plants include:

• Consider installation of hazard warning lights inside electrical equipment enclosures to warn of inadvertent energization;

• Use of voltage sensors prior to and during workers' entrance into enclosures containing electrical components;

• Deactivation and proper grounding of live power equipment and distribution lines according to applicable legislation and guidelines whenever possible before work is performed on or proximal to them;

• Provision of specialized electrical safety training to those workers working with or around exposed components of electric circuits. This training should include, but not be limited to, training in basic electrical theory, proper safe work procedures, hazard awareness and identification, proper use of PPE, proper lockout/tagout procedures, first aid including CPR, and proper rescue procedures. Provisions should be made for periodic retraining as necessary.

Fire and Explosion Hazards Thermal power plants store, transfer, and use large quantities of fuels; therefore, careful handling is necessary to mitigate fire and explosion risks. In particular, fire and explosion hazards increase as the particle size of coal is reduced. Particle sizes of coal that can fuel a propagating explosion occur within thermal dryers, cyclones, baghouses, pulverized-fuel systems, grinding mills, and other process or conveyance equipment. Fire and explosion prevention management guidance is provided in Section 2.1 and



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2.4 of the General EHS Guidelines. Recommended measures to prevent, minimize, and control physical hazards at thermal power plants include:

• Use of automated combustion and safety controls;

• Proper maintenance of boiler safety controls;

• Implementation of startup and shutdown procedures to minimize the risk of suspending hot coal particles (e.g., in the pulverizer, mill, and cyclone) during startup;

• Regular cleaning of the facility to prevent accumulation of coal dust (e.g., on floors, ledges, beams, and equipment);

• Removal of hot spots from the coal stockpile (caused by spontaneous combustion) and spread until cooled, never loading hot coal into the pulverized fuel system;

• Use of automated systems such as temperature gauges or carbon monoxide sensors to survey solid fuel storage areas to detect fires caused by self-ignition and to identify risk points.

Chemical Hazards Thermal power plants utilize hazardous materials, including ammonia for NOX control systems, and chlorine gas for treatment of cooling tower and boiler water. Guidance on chemical hazards management is provided in Section 2.4 of the General EHS Guidelines. Additional, recommended measures to prevent, minimize, and control physical hazards at thermal power plants include:

• Consider generation of ammonia on site from urea or use of aqueous ammonia in place of pure liquefied ammonia;

• Consider use of sodium hypochlorite in place of gaseous chlorine.

Dust Dust is generated in handing solid fuels, additives, and solid wastes (e.g., ash). Dust may contain silica (associated with

silicosis), arsenic (skin and lung cancer), coal dust (black lung), and other potentially harmful substances. Dust management guidance is provided in the Section 2.1 and 2.4 of the General EHS Guidelines. Recommended measures to prevent, minimize, and control occupational exposure to dust in thermal power plants include:

• Use of dust controls (e.g., exhaust ventilation) to keep dust below applicable guidelines (see Section 2) or wherever free silica levels in airborne dust exceed 1 percent;

• Regular inspection and maintenance of asbestos containing materials (e.g., insulation in older plants may contain asbestos) to prevent airborne asbestos particles.

1.3 Community Health and Safety

Many community health and safety impacts during the construction, operation, and decommissioning of thermal power plant projects are common to those of most infrastructure and industrial facilities and are discussed in Section 3.0 the General EHS Guidelines. In addition to these and other aspects covered in Section 1.1, the following community health and safety impacts may be of particular concern for thermal power plant projects:

• Water Consumption;

• Traffic Safety.

Water Consumption Boiler units require large amounts of cooling water for steam condensation and efficient thermal operation. The cooling water flow rate through the condenser is by far the largest process water flow, normally equating to about 98 percent of the total process water flow for the entire unit. In a once-through cooling water system, water is usually taken into the plant from surface waters, but sometimes ground waters or municipal supplies are used. The potential effects of water use should be assessed, as discussed in Section 3.1 of the General EHS Guidelines, to



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ensure that the project does not compromise the availability of water for personal hygiene, agriculture, recreation, and other community needs.

Traffic Safety Operation of a thermal power plant will increase traffic volume, in particular for facilities with fuels transported via land and sea, including heavy trucks carrying fuel, additives, etc. The increased traffic can be especially significant in sparsely populate areas where some thermal power plants are located. Prevention and control of traffic-related injuries are discussed in Section 3.4 of the General EHS Guidelines. Water transport safety is covered in the EHS Guidelines for Shipping.

Environmental, Health, and Safety Guidelines GENERAL EHS GUIDELINES: ENVIRONMENTAL

AIR EMISSIONS AND AMBIENT AIR QUALITY

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1.0 Environmental 1.1 Air Emissions and Ambient Air Quality

Applicability and Approach ...............................................3 Ambient Air Quality ..........................................................4

General Approach....................................................4 Projects Located in Degraded Airsheds or Ecologically Sensitive Areas........................................................5

Point Sources ..................................................................5 Stack Height.............................................................5 Small Combustion Facilities Emissions Guidelines ....6

Fugitive Sources ..............................................................8 Volatile Organic Compounds (VOCs) ........................8 Particulate Matter (PM).............................................8 Ozone Depleting Substances (ODS) .........................9

Mobile Sources – Land-based ..........................................9 Greenhouse Gases (GHGs) .............................................9 Monitoring......................................................................10

Monitoring of Small Combustion Plants Emissions...11

Applicability and Approach This guideline applies to facilities or projects that generate

emissions to air at any stage of the project life-cycle. It

complements the industry-specific emissions guidance presented

in the Industry Sector Environmental, Health, and Safety (EHS)

Guidelines by providing information about common techniques for

emissions management that may be applied to a range of industry

sectors. This guideline provides an approach to the management

of significant sources of emissions, including specific guidance for

assessment and monitoring of impacts. It is also intended to

provide additional information on approaches to emissions

management in projects located in areas of poor air quality, where

it may be necessary to establish project-specific emissions

standards.

Emissions of air pollutants can occur from a wide variety of

activities during the construction, operation, and decommissioning

phases of a project. These activities can be categorized based on

the spatial characteristic of the source including point sources,

fugitive sources, and mobile sources and, further, by process,

such as combustion, materials storage, or other industry sector-

specific processes.

Where possible, facilities and projects should avoid, minimize, and

control adverse impacts to human health, safety, and the

environment from emissions to air. Where this is not possible, the

generation and release of emissions of any type should be

managed through a combination of:

• Energy use efficiency

• Process modification

• Selection of fuels or other materials, the processing of which

may result in less polluting emissions

• Application of emissions control techniques

The selected prevention and control techniques may include one

or more methods of treatment depending on:

• Regulatory requirements

• Significance of the source

• Location of the emitting facility relative to other sources

• Location of sensitive receptors

• Existing ambient air quality, and potential for degradation of

the airshed from a proposed project

• Technical feasibility and cost effectiveness of the available

options for prevention, control, and release of emissions

General EHS Guidelines [Complete version] at: www.ifc.org/ifcext/enviro.nsf/Content/EnvironmentalGuidelines



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Ambient Air Quality

General Approach Projects with significant5,6 sources of air emissions, and potential

for significant impacts to ambient air quality, should prevent or

minimize impacts by ensuring that:

• Emissions do not result in pollutant concentrations that reach

or exceed relevant ambient quality guidelines and standards9

by applying national legislated standards, or in their absence,

the current WHO Air Quality Guidelines10 (see Table 1.1.1),

or other internationally recognized sources11;

• Emissions do not contribute a significant portion to the

attainment of relevant ambient air quality guidelines or

standards. As a general rule, this Guideline suggests 25

percent of the applicable air quality standards to allow

5 Significant sources of point and fugitive emissions are considered to be general sources which, for example, can contribute a net emissions increase of one or more of the following pollutants within a given airshed: PM10: 50 tons per year (tpy); NOx: 500 tpy; SO2: 500 tpy; or as established through national legislation; and combustion sources with an equivalent heat input of 50 MWth or greater. The significance of emissions of inorganic and organic pollutants should be established on a project-specific basis taking into account toxic and other properties of the pollutant. 6 United States Environmental Protection Agency, Prevention of Significant Deterioration of Air Quality, 40 CFR Ch. 1 Part 52.21. Other references for establishing significant emissions include the European Commission. 2000. “Guidance Document for EPER implementation.” http://ec.europa.eu/environment/ippc/eper/index.htm ; and Australian Government. 2004. “National Pollutant Inventory Guide.” http://www.npi.gov.au/handbooks/pubs/npiguide.pdf 7 World Health Organization (WHO). Air Quality Guidelines Global Update, 2005. PM 24-hour value is the 99th percentile. 8 Interim targets are provided in recognition of the need for a staged approach to achieving the recommended guidelines. 9 Ambient air quality standards are ambient air quality levels established and published through national legislative and regulatory processes, and ambient quality guidelines refer to ambient quality levels primarily developed through clinical, toxicological, and epidemiological evidence (such as those published by the World Health Organization). 10 Available at World Health Organization (WHO). http://www.who.int/en 11 For example the United States National Ambient Air Quality Standards (NAAQS) (http://www.epa.gov/air/criteria.html) and the relevant European Council Directives (Council Directive 1999/30/EC of 22 April 1999 / Council Directive 2002/3/EC of February 12 2002).

additional, future sustainable development in the same

airshed. 12

At facility level, impacts should be estimated through qualitative or

quantitative assessments by the use of baseline air quality

assessments and atmospheric dispersion models to assess

potential ground level concentrations. Local atmospheric, climatic,

and air quality data should be applied when modeling dispersion,

protection against atmospheric downwash, wakes, or eddy effects

of the source, nearby13 structures, and terrain features. The

dispersion model applied should be internationally recognized, or

comparable. Examples of acceptable emission estimation and

dispersion modeling approaches for point and fugitive sources are

12 US EPA Prevention of Significant Deterioration Increments Limits applicable to non-degraded airsheds.

Table 1.1.1: WHO Ambient Air Quality Guidelines7,8

Averaging Period

Guideline value in µg/m3

Sulfur dioxide (SO2) 24-hour

10 minute

125 (Interim target-1) 50 (Interim target-2)

20 (guideline) 500 (guideline)

Nitrogen dioxide (NO2) 1-year 1-hour

40 (guideline) 200 (guideline)

Particulate Matter PM10

1-year

24-hour

70 (Interim target-1) 50 (Interim target-2) 30 (Interim target-3)

20 (guideline)


50 (guideline) Particulate Matter PM2.5

1-year

24-hour


10 (guideline)

75 (Interim target-1) 50 (Interim target-2)

37.5 (Interim target-3) 25 (guideline)

Ozone 8-hour daily maximum

160 (Interim target-1) 100 (guideline)



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included in Annex 1.1.1. These approaches include screening

models for single source evaluations (SCREEN3 or AIRSCREEN),

as well as more complex and refined models (AERMOD OR

ADMS). Model selection is dependent on the complexity and geo-

morphology of the project site (e.g. mountainous terrain, urban or

rural area).

Projects Located in Degraded Airsheds or Ecologically Sensitive Areas Facilities or projects located within poor quality airsheds14, and

within or next to areas established as ecologically sensitive (e.g.

national parks), should ensure that any increase in pollution levels

is as small as feasible, and amounts to a fraction of the applicable

short-term and annual average air quality guidelines or standards

as established in the project-specific environmental assessment.

Suitable mitigation measures may also include the relocation of

significant sources of emissions outside the airshed in question,

use of cleaner fuels or technologies, application of comprehensive

pollution control measures, offset activities at installations

controlled by the project sponsor or other facilities within the same

airshed, and buy-down of emissions within the same airshed.

Specific provisions for minimizing emissions and their impacts in

poor air quality or ecologically sensitive airsheds should be

established on a project-by-project or industry-specific basis.

Offset provisions outside the immediate control of the project

sponsor or buy-downs should be monitored and enforced by the

local agency responsible for granting and monitoring emission

permits. Such provisions should be in place prior to final

commissioning of the facility / project.

13 “Nearby” generally considers an area within a radius of up to 20 times the stack height. 14 An airshed should be considered as having poor air quality if nationally legislated air quality standards or WHO Air Quality Guidelines are exceeded significantly.

Point Sources Point sources are discrete, stationary, identifiable sources of

emissions that release pollutants to the atmosphere. They are

typically located in manufacturing or production plants. Within a

given point source, there may be several individual ‘emission

points’ that comprise the point source.15

Point sources are characterized by the release of air pollutants

typically associated with the combustion of fossil fuels, such as

nitrogen oxides (NOx), sulfur dioxide (SO2), carbon monoxide

(CO), and particulate matter (PM), as well as other air pollutants

including certain volatile organic compounds (VOCs) and metals

that may also be associated with a wide range of industrial

activities.

Emissions from point sources should be avoided and controlled

according to good international industry practice (GIIP) applicable

to the relevant industry sector, depending on ambient conditions,

through the combined application of process modifications and

emissions controls, examples of which are provided in Annex

1.1.2. Additional recommendations regarding stack height and

emissions from small combustion facilities are provided below.

Stack Height The stack height for all point sources of emissions, whether

‘significant’ or not, should be designed according to GIIP (see

Annex 1.1.3) to avoid excessive ground level concentrations due

to downwash, wakes, and eddy effects, and to ensure reasonable

diffusion to minimize impacts. For projects where there are

multiple sources of emissions, stack heights should be established

with due consideration to emissions from all other project sources,

both point and fugitive. Non-significant sources of emissions,

15 Emission points refer to a specific stack, vent, or other discrete point of pollution release. This term should not be confused with point source, which is a regulatory distinction from area and mobile sources. The characterization of point sources into multiple emissions points is useful for allowing more detailed reporting of emissions information.



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including small combustion sources,16 should also use GIIP in

stack design.

Small Combustion Facilities Emissions Guidelines Small combustion processes are systems designed to deliver

electrical or mechanical power, steam, heat, or any combination of

these, regardless of the fuel type, with a total, rated heat input

capacity of between three Megawatt thermal (MWth) and 50

MWth.

The emissions guidelines in Table 1.1.2 are applicable to small

combustion process installations operating more than 500 hours

per year, and those with an annual capacity utilization of more

than 30 percent. Plants firing a mixture of fuels should compare

emissions performance with these guidelines based on the sum of

the relative contribution of each applied fuel17. Lower emission

values may apply if the proposed facility is located in an

ecologically sensitive airshed, or airshed with poor air quality, in

order to address potential cumulative impacts from the installation

of more than one small combustion plant as part of a distributed

generation project.

16 Small combustion sources are those with a total rated heat input capacity of 50MWth or less. 17 The contribution of a fuel is the percentage of heat input (LHV) provided by this fuel multiplied by its limit value.



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Table 1.1.2 - Small Combustion Facilities Emissions Guidelines (3MWth – 50MWth) – (in mg/Nm3 or as indicated) Combustion Technology /

Fuel Particulate Matter (PM) Sulfur Dioxide (SO2) Nitrogen Oxides (NOx) Dry Gas, Excess O2 Content (%)

Engine

Gas N/A N/A 200 (Spark Ignition)

400 (Dual Fuel) 1,600 (Compression Ignition)

15

Liquid

50 or up to 100 if justified by project specific considerations (e.g. Economic feasibility of using lower ash content fuel, or adding secondary treatment to meet 50, and available environmental capacity of the site)

1.5 percent Sulfur or up to 3.0 percent Sulfur if justified by project specific considerations (e.g. Economic feasibility of using lower S content fuel, or adding secondary treatment to meet levels of using 1.5 percent Sulfur, and available environmental capacity of the site)

If bore size diameter [mm] < 400: 1460 (or up to 1,600 if justified to maintain high energy efficiency.) If bore size diameter [mm] > or = 400: 1,850

15

Turbine Natural Gas =3MWth to < 15MWth N/A N/A 42 ppm (Electric generation)

100 ppm (Mechanical drive) 15

Natural Gas =15MWth to < 50MWth N/A N/A 25 ppm 15

Fuels other than Natural Gas =3MWth to < 15MWth N/A

0.5 percent Sulfur or lower percent Sulfur (e.g. 0.2 percent Sulfur) if commercially available without significant excess fuel cost

96 ppm (Electric generation) 150 ppm (Mechanical drive) 15

Fuels other than Natural Gas =15MWth to < 50MWth N/A 0.5% S or lower % S (0.2%S) if commercially

available without significant excess fuel cost 74 ppm 15

Boiler

Gas N/A N/A 320 3

Liquid 50 or up to 150 if justified by environmental assessment

2000 460 3

Solid 50 or up to 150 if justified by environmental assessment

2000 650 6

Notes: -N/A/ - no emissions guideline; Higher performance levels than these in the Table should be applicable to facilities located in urban / industrial areas with degraded airsheds or close to ecologically sensitive areas where more stringent emissions controls may be needed.; MWth is heat input on HHV basis; Solid fuels include biomass; Nm3 is at one atmosphere pressure, 0°C.; MWth category is to apply to the entire facility consisting of multiple units that are reasonably considered to be emitted from a common stack except for NOx and PM limits for turbines and boilers. Guidelines values apply to facilities operating more than 500 hours per year with an annual capacity utilization factor of more than 30 percent.



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Fugitive Sources Fugitive source air emissions refer to emissions that are

distributed spatially over a wide area and not confined to a specific

discharge point. They originate in operations where exhausts are

not captured and passed through a stack. Fugitive emissions have

the potential for much greater ground-level impacts per unit than

stationary source emissions, since they are discharged and

dispersed close to the ground. The two main types of fugitive

emissions are Volatile Organic Compounds (VOCs) and

particulate matter (PM). Other contaminants (NOx, SO2 and CO)

are mainly associated with combustion processes, as described

above. Projects with potentially significant fugitive sources of

emissions should establish the need for ambient quality

assessment and monitoring practices.

Open burning of solid wastes, whether hazardous or non-

hazardous, is not considered good practice and should be

avoided, as the generation of polluting emissions from this type of

source cannot be controlled effectively.

Volatile Organic Compounds (VOCs) The most common sources of fugitive VOC emissions are

associated with industrial activities that produce, store, and use

VOC-containing liquids or gases where the material is under

pressure, exposed to a lower vapor pressure, or displaced from an

enclosed space. Typical sources include equipment leaks, open

vats and mixing tanks, storage tanks, unit operations in

wastewater treatment systems, and accidental releases.

Equipment leaks include valves, fittings, and elbows which are

subject to leaks under pressure. The recommended prevention

and control techniques for VOC emissions associated with

equipment leaks include:

• Equipment modifications, examples of which are presented in

Annex 1.1.4;

• Implementing a leak detection and repair (LDAR) program

that controls fugitive emissions by regularly monitoring to

detect leaks, and implementing repairs within a predefined

time period.18

For VOC emissions associated with handling of chemicals in open

vats and mixing processes, the recommended prevention and

control techniques include:

• Substitution of less volatile substances, such as aqueous

solvents;

• Collection of vapors through air extractors and subsequent

treatment of gas stream by removing VOCs with control

devices such as condensers or activated carbon absorption;

• Collection of vapors through air extractors and subsequent

treatment with destructive control devices such as:

o Catalytic Incinerators: Used to reduce VOCs from

process exhaust gases exiting paint spray booths,

ovens, and other process operations

o Thermal Incinerators: Used to control VOC levels in a

gas stream by passing the stream through a combustion

chamber where the VOCs are burned in air at

temperatures between 700º C to 1,300º C

o Enclosed Oxidizing Flares: Used to convert VOCs into

CO2 and H2O by way of direct combustion

• Use of floating roofs on storage tanks to reduce the

opportunity for volatilization by eliminating the headspace

present in conventional storage tanks.

Particulate Matter (PM) The most common pollutant involved in fugitive emissions is dust

or particulate matter (PM). This is released during certain

operations, such as transport and open storage of solid materials,

and from exposed soil surfaces, including unpaved roads.

18 For more information, see Leak Detection and Repair Program (LDAR), at: http://www.ldar.net



APRIL 30, 2007 9

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Recommended prevention and control of these emissions sources

include:

• Use of dust control methods, such as covers, water

suppression, or increased moisture content for open

materials storage piles, or controls, including air extraction

and treatment through a baghouse or cyclone for material

handling sources, such as conveyors and bins;

• Use of water suppression for control of loose materials on

paved or unpaved road surfaces. Oil and oil by-products is

not a recommended method to control road dust. Examples

of additional control options for unpaved roads include those

summarized in Annex 1.1.5.

Ozone Depleting Substances (ODS) Several chemicals are classified as ozone depleting substances

(ODSs) and are scheduled for phase-out under the Montreal

Protocol on Substances that Deplete the Ozone Layer.19 No new

systems or processes should be installed using CFCs, halons,

1,1,1-trichloroethane, carbon tetrachloride, methyl bromide or

HBFCs. HCFCs should only be considered as interim / bridging

alternatives as determined by the host country commitments and

regulations.20

Mobile Sources – Land-based Similar to other combustion processes, emissions from vehicles

include CO, NOx, SO2, PM and VOCs. Emissions from on-road

and off-road vehicles should comply with national or regional

19 Examples include: chlorofluorocarbons (CFCs); halons; 1,1,1-trichloroethane (methyl chloroform); carbon tetrachloride; hydrochlorofluorocarbons (HCFCs); hydrobromofluorocarbons (HBFCs); and methyl bromide. They are currently used in a variety of applications including: domestic, commercial, and process refrigeration (CFCs and HCFCs); domestic, commercial, and motor vehicle air conditioning (CFCs and HCFCs); for manufacturing foam products (CFCs); for solvent cleaning applications (CFCs, HCFCs, methyl chloroform, and carbon tetrachloride); as aerosol propellants (CFCs); in fire protection systems (halons and HBFCs); and as crop fumigants (methyl bromide). 20 Additional information is available through the Montreal Protocol Secretariat web site available at: http://ozone.unep.org/

programs. In the absence of these, the following approach should

be considered:

• Regardless of the size or type of vehicle, fleet owners /

operators should implement the manufacturer recommended

engine maintenance programs;

• Drivers should 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;

• Operators with fleets of 120 or more units of heavy duty

vehicles (buses and trucks), or 540 or more light duty

vehicles21 (cars and light trucks) within an airshed should

consider additional ways to reduce potential impacts

including:

o Replacing older vehicles with newer, more fuel efficient

alternatives

o Converting high-use vehicles to cleaner fuels, where

feasible

o Installing and maintaining emissions control devices,

such as catalytic converters

o Implementing a regular vehicle maintenance and repair

program

Greenhouse Gases (GHGs) Sectors that may have potentially significant emissions of

greenhouse gases (GHGs)22 include energy, transport, heavy

industry (e.g. cement production, iron / steel manufacturing,

aluminum smelting, petrochemical industries, petroleum refining,

fertilizer manufacturing), agriculture, forestry and waste

management. GHGs may be generated from direct emissions

21 The selected fleet size thresholds are assumed to represent potentially significant sources of emissions based on individual vehicles traveling 100,000 km / yr using average emission factors. 22 The six greenhouse gases that form part of the Kyoto Protocol to the United Nations Framework Convention on Climate Change include carbon dioxide (C02); methane (CH4); nitrous oxide (N2O); hydrofluorocarbons (HFCs); perfluorocarbons (PFCs); and sulfur hexafluoride (SF 6).



APRIL 30, 2007 10

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from facilities within the physical project boundary and indirect

emissions associated with the off-site production of power used by

the project.

Recommendations for reduction and control of greenhouse gases

include:

• Carbon financing;23

• Enhancement of energy efficiency (see section on

‘Energy Conservation’);

• Protection and enhancement of sinks and reservoirs of

greenhouse gases;

• Promotion of sustainable forms of agriculture and

forestry;

• Promotion, development and increased use of

renewable forms of energy;

• Carbon capture and storage technologies;24

• Limitation and / or reduction of methane emissions

through recovery and use in waste management, as well

as in the production, transport and distribution of energy

(coal, oil, and gas).

Monitoring Emissions and air quality monitoring programs provide information

that can be used to assess the effectiveness of emissions

management strategies. A systematic planning process is

recommended to ensure that the data collected are adequate for

their intended purposes (and to avoid collecting unnecessary

data). This process, sometimes referred to as a data quality

objectives process, defines the purpose of collecting the data, the

23 Carbon financing as a carbon emissions reduction strategy may include the host government-endorsed Clean Development Mechanism or Joint Implementation of the United Nations Framework Convention on Climate Change. 24 Carbon dioxide capture and storage (CCS) is a process consisting of the separation of CO2 from industrial and energy-related sources; transport to a storage location; and long-term isolation from the atmosphere, for example in geological formations, in the ocean, or in mineral carbonates (reaction of CO2 with metal oxides in silicate minerals to produce stable carbonates). It is the object of intensive research worldwide (Intergovernmental Panel on Climate Change (IPCC), Special Report, Carbon Dioxide Capture and Storage (2006).

decisions to be made based on the data and the consequences of

making an incorrect decision, the time and geographic

boundaries, and the quality of data needed to make a correct

decision.25 The air quality monitoring program should consider

the following elements:

• Monitoring parameters: The monitoring parameters selected

should reflect the pollutants of concern associated with

project processes. For combustion processes, indicator

parameters typically include the quality of inputs, such as the

sulfur content of fuel.

• Baseline calculations: Before a project is developed, baseline

air quality monitoring at and in the vicinity of the site should

be undertaken to assess background levels of key pollutants,

in order to differentiate between existing ambient conditions

and project-related impacts.

• Monitoring type and frequency: Data on emissions and

ambient air quality generated through the monitoring program

should be representative of the emissions discharged by the

project over time. Examples of time-dependent variations in

the manufacturing process include batch process

manufacturing and seasonal process variations. Emissions

from highly variable processes may need to be sampled

more frequently or through composite methods. Emissions

monitoring frequency and duration may also range from

continuous for some combustion process operating

parameters or inputs (e.g. the quality of fuel) to less frequent,

monthly, quarterly or yearly stack tests.

• Monitoring locations: Ambient air quality monitoring may

consists of off-site or fence line monitoring either by the

project sponsor, the competent government agency, or by

collaboration between both. The location of ambient air

25 See, for example, United States Environmental Protection Agency, Guidance on Systematic Planning Using the Data Quality Objectives Process EPA QA/G-4, EPA/240/B-06/001 February 2006.



APRIL 30, 2007 11

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quality monitoring stations should be established based on

the results of scientific methods and mathematical models to

estimate potential impact to the receiving airshed from an

emissions source taking into consideration such aspects as

the location of potentially affected communities and

prevailing wind directions.

• Sampling and analysis methods: Monitoring programs should

apply national or international methods for sample collection

and analysis, such as those published by the International

Organization for Standardization,26 the European Committee

for Standardization,27 or the U.S. Environmental Protection

Agency.28 Sampling should be conducted by, or under, the

supervision of trained individuals. Analysis should be

conducted by entities permitted or certified for this purpose.

Sampling and analysis Quality Assurance / Quality Control

(QA/QC) plans should be applied and documented to ensure

that data quality is adequate for the intended data use (e.g.,

method detection limits are below levels of concern).

Monitoring reports should include QA/QC documentation.

Monitoring of Small Combustion Plants Emissions • Additional recommended monitoring approaches for boilers:

Boilers with capacities between =3 MWth and < 20 MWth:

o Annual Stack Emission Testing: SO2, NOx and PM. For

gaseous fuel-fired boilers, only NOx. SO2 can be

calculated based on fuel quality certification if no SO2

control equipment is used.

26 An on-line catalogue of ISO standards relating to the environment, health protection, and safety is available at: http://www.iso.org/iso/en/CatalogueListPage.CatalogueList?ICS1=13&ICS2=&ICS3=&scopelist=

27 An on-line catalogue of European Standards is available at: http://www.cen.eu/catweb/cwen.htm .

28 The National Environmental Methods Index provides a searchable clearinghouse of U.S. methods and procedures for both regulatory and non-regulatory monitoring purposes for water, sediment, air and tissues, and is available at http://www.nemi.gov/.

o If Annual Stack Emission Testing demonstrates results

consistently and significantly better than the required

levels, frequency of Annual Stack Emission Testing can

be reduced from annual to every two or three years.

o Emission Monitoring: None

Boilers with capacities between =20 MWth and < 50 MWth

o Annual Stack Emission Testing: SO2, NOx and PM. For

gaseous fuel-fired boilers, only NOx. SO2 can be

calculated based on fuel quality certification (if no SO2

control equipment is used)

o Emission Monitoring: SO2. Plants with SO2 control

equipment: Continuous. NOx: Continuous monitoring of

either NOx emissions or indicative NOx emissions using

combustion parameters. PM: Continuous monitoring of

either PM emissions, opacity, or indicative PM

emissions using combustion parameters / visual

monitoring.

• Additional recommended monitoring approaches for

turbines:

o Annual Stack Emission Testing: NOx and SO2 (NOx

only for gaseous fuel-fired turbines).

o If Annual Stack Emission Testing results show

constantly (3 consecutive years) and significantly (e.g.

less than 75 percent) better than the required levels,

frequency of Annual Stack Emission Testing can be

reduced from annual to every two or three years.

o Emission Monitoring: NOx: Continuous monitoring of


combustion parameters.SO2: Continuous monitoring if

SO2 control equipment is used.

• Additional recommended monitoring approaches for

engines:

o Annual Stack Emission Testing: NOx ,SO2 and PM (NOx

only for gaseous fuel-fired diesel engines).



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o If Annual Stack Emission Testing results show

constantly (3 consecutive years) and significantly (e.g.

less than 75 percent) better than the required levels,

frequency of Annual Stack Emission Testing can be

reduced from annual to every two or three years.

o Emission Monitoring: NOx: Continuous monitoring of


combustion parameters. SO2: Continuous monitoring if

SO2 control equipment is used. PM: Continuous

monitoring of either PM emissions or indicative PM

emissions using operating parameters.



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Annex 1.1.1 – Air Emissions Estimation and Dispersion

Modeling Methods

The following is a partial list of documents to aid in the estimation

of air emissions from various processes and air dispersion

models:

Australian Emission Estimation Technique Manuals

http://www.npi.gov.au/handbooks/

Atmospheric Emission Inventory Guidebook, UN / ECE / EMEP

and the European Environment Agency

http://www.aeat.co.uk/netcen/airqual/TFEI/unece.htm

Emission factors and emission estimation methods, US EPA

Office of Air Quality Planning & Standards

http://www.epa.gov/ttn/chief

Guidelines on Air Quality Models (Revised), US Environmental

Protection Agency (EPA), 2005

http://www.epa.gov/scram001/guidance/guide/appw_05.pdf

Frequently Asked Questions, Air Quality Modeling and

Assessment Unit (AQMAU), UK Environment Agency

http://www.environment-

agency.gov.uk/subjects/airquality/236092/?version=1&lang=_e

OECD Database on Use and Release of Industrial Chemicals

http://www.olis.oecd.org/ehs/urchem.nsf/



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Annex 1.1.2 – Illustrative Point Source Air Emissions Prevention and Control Technologies

Principal Sources and Issues General Prevention / Process Modification Approach

Control Options Reduction Efficiency (%)

Gas Condition

Comments

Particulate Matter (PM)

Fabric Filters 99 - 99.7% Dry gas, temp <400F

Applicability depends on flue gas properties including temperature, chemical properties, abrasion and load. Typical air to cloth ratio range of 2.0 to 3.5 cfm/ft2

Achievable outlet concentrations of 23 mg/Nm3

Electrostatic Precipitator (ESP)

97 – 99% Varies depending of particle type

Precondition gas to remove large particles. Efficiency dependent on resistivity of particle. Achievable outlet concentration of 23 mg/Nm3

Cyclone 74 – 95% None Most efficient for large particles. Achievable outlet concentrations of 30 - 40 mg/Nm3

Main sources are the combustion of fossil fuels and numerous manufacturing processes that collect PM through air extraction and ventilation systems. Volcanoes, ocean spray, forest fires and blowing dust (most prevalent in dry and semiarid climates) contribute to background levels.

Fuel switching (e.g. selection of lower sulfur fuels) or reducing the amount of fine particulates added to a process.

Wet Scrubber 93 – 95% None Wet sludge may be a disposal problem depending on local infrastructure. Achievable outlet concentrations of 30 - 40 mg/Nm3

Sulfur Dioxide (SO2)

Fuel Switching >90% Alternate fuels may include low sulfur coal, light diesel or natural gas with consequent reduction in particulate emissions related to sulfur in the fuel. Fuel cleaning or beneficiation of fuels prior to combustion is another viable option but may have economic consequences.

Sorbent Injection 30% - 70% Calcium or lime is injected into the flue gas and the SO2 is adsorbed onto the sorbent

Dry Flue Gas Desulfurization

70%-90% Can be regenerable or throwaway.

Mainly produced by the combustion of fuels such as oil and coal and as a by-product from some chemical production or wastewater treatment processes.

Control system selection is heavily dependent on the inlet concentration. For SO2 concentrations in excess of 10%, the stream is passed through an acid plant not only to lower the SO2 emissions but also to generate high grade sulfur for sale. Levels below 10% are not rich enough for this process and should therefore utilize absorption or ‘scrubbing,’ where SO2 molecules are captured into a liquid phase or adsorption, where SO2 molecules are captured on the surface of a solid adsorbent.

Wet Flue Gas Desulfurization

>90% Produces gypsum as a by-product



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Annex 1.1.2: Illustrative Point Source Air Emissions Prevention and Control Technologies (continued)

Oxides of Nitrogen (NOx) Percent Reduction by Fuel Type Comments

Combustion modification (Illustrative of boilers)

Coal Oil Gas

Low-excess-air firing 10–30 10–30 10–30

Staged Combustion 20–50 20–50 20–50

Flue Gas Recirculation N/A 20–50 20–50

Water/Steam Injection N/A 10–50 N/A.

Low-NOx Burners 30–40 30–40 30–40

These modifications are capable of reducing NOx emissions by 50 to 95%. The method of combustion control used depends on the

type of boiler and the method of firing fuel.

Flue Gas Treatment Coal Oil Gas

Selective Catalytic Reduction (SCR) 60–90 60–90 60–90

Associated with combustion of fuel. May occur in several forms of nitrogen oxide; namely nitric oxide (NO), nitrogen dioxide (NO2) and nitrous oxide (N2O), which is also a

greenhouse gas. The term NOx serves as a composite between NO and NO2 and emissions are usually

reported as NOx. Here the NO is multiplied by the ratio of molecular weights of NO2 to NO and added to the NO2 emissions.

Means of reducing NOx emissions are based on the modification of operating conditions such as minimizing the resident time at peak temperatures, reducing the peak temperatures by increasing heat transfer rates or minimizing the availability of oxygen.

Selective Non-Catalytic Reduction (SNCR)

N/A 30–70 30–70

Flue gas treatment is more effective in reducing NOx emissions than are combustion controls. Techniques can be classified as

SCR, SNCR, and adsorption. SCR involves the injection of ammonia as a reducing agent to convert NOx to nitrogen in the presence of a catalyst in a converter upstream of the air heater.

Generally, some ammonia slips through and is part of the emissions. SNCR also involves the injection of ammonia or urea

based products without the presence of a catalyst.

Note: Compiled by IFC based on inputs from technical experts.



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Annex 1.1.3 - Good International Industry Practice (GIIP)

Stack Height

(Based on United States 40 CFR, part 51.100 (ii)).

HG = H + 1.5L; where

HG = GEP stack height measured from the ground level

elevation at the base of the stack

H = Height of nearby structure(s) above the base of the

stack.

L = Lesser dimension, height (h) or width (w), of nearby

structures

“Nearby structures” = Structures within/touching a radius

of 5L but less than 800 m.

Annex 1.1.4 - Examples of VOC Emissions Controls

29 Seal-less equipment can be a large source of emissions in the event of equipment failure. 30 Actual efficiency of a closed-vent system depends on percentage of vapors collected and efficiency of control device to which the vapors are routed. 31 Control efficiency of closed vent-systems installed on a pressure relief device may be lower than other closed-vent systems.

Equipment Type Modification

Approximate Control

Efficiency (%)

Seal-less design 10029

Closed-vent system 9030 Pumps

Dual mechanical seal with barrier fluid maintained at a higher pressure than the pumped fluid

100

Closed-vent system 90

Compressors Dual mechanical seal with barrier fluid maintained at a higher pressure than the compressed gas

100

Closed-vent system Variable31 Pressure Relief Devices

Rupture disk assembly 100

Valves Seal-less design 100

Connectors Weld together 100

Open-ended Lines Blind, cap, plug, or second valve 100

Sampling Connections Closed-loop sampling 100

Note: Examples of technologies are provided for illustrative purposes. The availability and applicability of any particular technology will vary depending on manufacturer specifications.

Stack

1.5*LHG

hH

Pro

ject

ed w

idth

(w)

Maximum 5*L



APRIL 30, 2007 17

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Annex 1.1.5 - Fugitive PM Emissions Controls

Control Type Control Efficiency

Chemical Stabilization 0% - 98%

Hygroscopic salts Bitumens/adhesives

60% - 96%

Surfactants 0% - 68%

Wet Suppression – Watering 12% - 98%

Speed Reduction 0% - 80%

Traffic Reduction Not quantified

Paving (Asphalt / Concrete) 85% - 99%

Covering with Gravel, Slag, or "Road Carpet"

30% - 50%

Vacuum Sweeping 0% - 58%

Water Flushing/Broom Sweeping 0% - 96%



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2.0 Performance Indicators and Monitoring

2.1 Environment

Emissions and Effluent Guidelines Effluent guidelines are described in Table 5. Emissions guidelines are described in Table 6. Effluent guidelines are applicable for direct discharges of treated effluents to surface waters for general use. Site-specific discharge levels may be established based on the availability and conditions in the use of publicly operated sewage collection and treatment systems or, if discharged directly to surface waters, on the receiving water use classification as described in the General EHS Guideline. Guideline values for process emissions and effluents in this sector are indicative of good international industry practice as reflected in standards of countries with recognized regulatory frameworks. These levels should be achieved, without dilution, at least 95 percent of the time that the plant or unit is operating, to be calculated as a proportion of annual operating hours. Deviation from these levels due to specific local project conditions should be justified in the environmental assessment.

Table 5 - Effluent Guidelines (To be applicable at relevant wastewater stream: e.g., from FGD

system, wet ash transport, washing boiler / air preheater and precipitator, boiler acid washing, regeneration of demineralizers

and condensate polishers, oil-separated water, site drainage, coal pile runoff, and cooling water)

Parameter mg/L, except pH and temp pH 6 – 9 TSS 50 Oil and grease 10 Total residual chlorine

0.2

Chromium - Total (Cr)

0.5

Copper (Cu) 0.5 Iron (Fe) 1.0 Zinc (Zn) 1.0 Lead (Pb) 0.5 Cadmium (Cd) 0.1 Mercury (Hg) 0.005 Arsenic (As) 0.5 Temperature increase by thermal discharge from cooling system

• Site specific requirement to be established by the EA.

• Elevated temperature areas due to discharge of once-through cooling water (e.g., 1 Celsius above, 2 Celsius above, 3 Celsius above ambient water temperature) should be minimized by adjusting intake and outfall design through the project specific EA depending on the sensitive aquatic ecosystems around the discharge point.

Note: Applicability of heavy metals should be determined in the EA. Guideline limits in the Table are from various references of effluent performance by thermal power plants.

Emissions levels for the design and operation of each project should be established through the EA process on the basis of country legislation and the recommendations provided in this guidance document, as applied to local conditions. The emissions levels selected should be justified in the EA.30 The maximum emissions levels given here can be consistently achieved by well-designed, well-operated, and well-maintained pollution control systems. In contrast, poor operating or maintenance procedures affect actual pollutant removal efficiency and may reduce it to well

30 For example, in cases where potential for acid deposition has been identified as a significant issue in the EA, plant design and operation should ensure that emissions mass loadings are effectively reduced to prevent or minimize such impacts.



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below the design specification. Dilution of air emissions to achieve these guidelines is unacceptable. Compliance with ambient air quality guidelines should be assessed on the basis of good international industry practice (GIIP) recommendations.

As described in the General EHS Guidelines, emissions should not result in pollutant concentrations that reach or exceed relevant ambient quality guidelines and standards31 by applying national legislated standards, or in their absence, the current WHO Air Quality Guidelines32, or other internationally recognized sources33. Also, emissions from a single project should not contribute more than 25% of the applicable ambient air quality standards to allow additional, future sustainable development in the same airshed. 34

As described in the General EHS Guidelines, facilities or projects located within poor quality airsheds35, and within or next to areas established as ecologically sensitive (e.g., national parks), should ensure that any increase in pollution levels is as small as feasible, and amounts to a fraction of the applicable short-term and annual average air quality guidelines or standards as established in the project-specific environmental assessment.

Environmental Monitoring Environmental monitoring programs for this sector are presented in Table 7. Monitoring data should be analyzed and reviewed at regular intervals and compared with the operating standards so

31 Ambient air quality standards are ambient air quality levels established and published through national legislative and regulatory processes, and ambient quality guidelines refer to ambient quality levels primarily developed through clinical, toxicological, and epidemiological evidence (such as those published by the World Health Organization). 32 Available at World Health Organization (WHO). http://www.who.int/en 33 For example the United States National Ambient Air Quality Standards (NAAQS) (http://www.epa.gov/air/criteria.html) and the relevant European Council Directives (Council Directive 1999/30/EC of 22 April 1999 / Council Directive 2002/3/EC of February 12 2002). 34 US EPA Prevention of Significant Deterioration Increments Limits applicable to non-degraded airsheds. 35 An airshed should be considered as having poor air quality if nationally legislated air quality standards or WHO Air Quality Guidelines are exceeded significantly.

that any necessary corrective actions can be taken. Examples of emissions, stack testing, ambient air quality, and noise monitoring recommendations applicable to power plants are provided in Table 7. Additional guidance on applicable sampling and analytical methods for emissions and effluents is provided in the General EHS Guidelines.



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Table 6 (A) - Emissions Guidelines (in mg/Nm3 or as indicated) for Reciprocating Engine Note:

- Guidelines are applicable for new facilities. - EA may justify more stringent or less stringent limits due to ambient environment, technical and economic considerations provided there is compliance with applicable ambient air

quality standards and incremental impacts are minimized. - For projects to rehabilitate existing facilities, case-by-case emission requirements should be established by the EA considering (i) the existing emission levels and impacts on the

environment and community health, and (ii) cost and technical feasibility of bringing the existing emission levels to meet these new facilities limits. - EA should demonstrate that emissions do not contribute a significant portion to the attainment of relevant ambient air quality guidelines or standards, and more stringent limits may be

required. Combustion Technology / Fuel Particulate

Matter (PM) Sulfur Dioxide (SO2) Nitrogen Oxides (NOx) Dry Gas, Excess O2 Content (%)

Reciprocating Engine NDA DA NDA DA NDA DA Natural Gas N/A N/A N/A N/A 200 (Spark Ignition)

400 (Dual Fuel) (a)

200(SI) 400 (Dual Fuel / CI)

15%

Liquid Fuels (Plant >50 MWth to <300 MWth) 50 30 1,170 or use of 2% or less S fuel

0.5% S 1,460 (Compression Ignition, bore size diameter [mm] < 400) 1,850 (Compression Ignition, bore size diameter [mm] ≥ 400) 2,000 (Dual Fuel)

400 15%

Liquid Fuels (Plant >/=300 MWth) 50 30 585 or use of 1% or less S fuel

0.2% S 740 (contingent upon water availability for injection) 400 15%

Biofuels / Gaseous Fuels other than Natural Gas 50 30 N/A N/A 30% higher limits than those provided above for Natural Gas and Liquid Fuels.

200 (SI, Natural Gas), 400 (other)

15%

General notes: - MWth = Megawatt thermal input on HHV basis; N/A = not applicable; NDA = Non-degraded airshed; DA = Degraded airshed (poor air quality); Airshed should be considered as being degraded if

nationally legislated air quality standards are exceeded or, in their absence, if WHO Air Quality Guidelines are exceeded significantly; S = sulfur content (expressed as a percent by mass); Nm3 is at one atmospheric pressure, 0 degree Celsius; MWth category is to apply to the entire facility consisting of multiple units that are reasonably considered to be emitted from a common stack. Guideline limits apply to facilities operating more than 500 hours per year. Emission levels should be evaluated on a one hour average basis and be achieved 95% of annual operating hours.

- (a) Compression Ignition (CI) engines may require different emissions values which should be evaluated on a case-by-case basis through the EA process. Comparison of the Guideline limits with standards of selected countries / region (as of August 2008):

- Natural Gas-fired Reciprocating Engine – NOx o Guideline limits: 200 (SI), 400 (DF) o UK: 100 (CI) , US: Reduce by 90% or more, or alternatively 1.6 g/kWh

- Liquid Fuels-fired Reciprocating Engine – NOx (Plant >50 MWth to <300 MWth) o Guideline limits: 1,460 (CI, bore size diameter < 400 mm), 1,850 (CI, bore size diameter ≥ 400 mm), 2,000 (DF) o UK: 300 (> 25 MWth), India: 1,460 (Urban area & ≤ 75 MWe (≈ 190 MWth), Rural area & ≤ 150 MWe (≈ 380 MWth))

- Liquid Fuels-fired Reciprocating Engine – NOx (Plant ≥300 MWth) o Guideline limits: 740 (contingent upon water availability for injection) o UK: 300 (> 25 MWth), India: 740 (Urban area & > 75MWe (≈ 190 MWth), Rural area & > 150 MWe (≈ 380 MWth))

- Liquid Fuels-fired Reciprocating Engine – SO2 o Guideline limits: 1,170 or use of ≤ 2% S (Plant >50 MWth to <300 MWth), 585 or use of ≤ 1% S (Plant ≥300 MWth) o EU: Use of low S fuel oil or the secondary FGD (IPCC LCP BREF), HFO S content ≤ 1% (Liquid Fuel Quality Directive), US: Use of diesel fuel with max S of 500 ppm (0.05%); EU: Marine

HFO S content ≤ 1.5% (Liquid Fuel Quality Directive) used in SOx Emission Control Areas; India: Urban (< 2% S), Rural (< 4%S), Only diesel fuels (HSD, LDO) should be used in Urban Source: UK (S2 1.03 Combustion Processes: Compression Ignition Engines, 50 MWth and over), India (SOx/NOx Emission Standards for Diesel Engines ≥ 0.8 MW), EU (IPCC LCP BREF July 2006), EU (Liquid Fuel Quality Directive 1999/32/EC amended by 2005/33/EC), US (NSPS for Stationary Compression Ignition Internal Combustion Engine – Final Rule – July 11, 2006)



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Table 6 (B) - Emissions Guidelines (in mg/Nm3 or as indicated) for Combustion Turbine Note:

- Guidelines are applicable for new facilities. - EA may justify more stringent or less stringent limits due to ambient environment, technical and economic considerations provided there is compliance with

applicable ambient air quality standards and incremental impacts are minimized. - For projects to rehabilitate existing facilities, case-by-case emission requirements should be established by the EA considering (i) the existing emission levels and

impacts on the environment and community health, and (ii) cost and technical feasibility of bringing the existing emission levels to meet these new facilities limits. - EA should demonstrate that emissions do not contribute a significant portion to the attainment of relevant ambient air quality guidelines or standards, and more

stringent limits may be required. Combustion Technology / Fuel Particulate


Combustion Turbine NDA/DA NDA/DA Natural Gas (all turbine types of Unit > 50MWth) N/A N/A N/A N/A 51 (25 ppm) 15%

Fuels other than Natural Gas (Unit > > 50MWth) 50 30 Use of 1% or

less S fuel Use of 0.5% or less S fuel

152 (74 ppm)a 15%


nationally legislated air quality standards are exceeded or, in their absence, if WHO Air Quality Guidelines are exceeded significantly; S = sulfur content (expressed as a percent by mass); Nm3 is at one atmospheric pressure, 0 degree Celsius; MWth category is to apply to single units; Guideline limits apply to facilities operating more than 500 hours per year. Emission levels should be evaluated on a one hour average basis and be achieved 95% of annual operating hours.

- If supplemental firing is used in a combined cycle gas turbine mode, the relevant guideline limits for combustion turbines should be achieved including emissions from those supplemental firing units (e.g., duct burners).

- (a) Technological differences (for example the use of Aeroderivatives) may require different emissions values which should be evaluated on a cases-by-case basis through the EA process but which should not exceed 200 mg/Nm3.

Comparison of the Guideline limits with standards of selected countries / region (as of August 2008): - Natural Gas-fired Combustion Turbine – NOx

o Guideline limits: 51 (25 ppm) o EU: 50 (24 ppm), 75 (37 ppm) (if combined cycle efficiency > 55%), 50*η / 35 (where η = simple cycle efficiency) o US: 25 ppm (> 50 MMBtu/h (≈ 14.6 MWth) and ≤ 850 MMBtu/h (≈ 249MWth)), 15 ppm (> 850 MMBtu/h (≈ 249 MWth)) o (Note: further reduced NOx ppm in the range of 2 to 9 ppm is typically required through air permit)

- Liquid Fuel-fired Combustion Turbine – NOx o Guideline limits: 152 (74 ppm) – Heavy Duty Frame Turbines & LFO/HFO, 300 (146 ppm) – Aeroderivatives & HFO, 200 (97 ppm) – Aeroderivatives & LFO o EU: 120 (58 ppm), US: 74 ppm (> 50 MMBtu/h (≈ 14.6 MWth) and ≤ 850 MMBtu/h (≈ 249MWth)), 42 ppm (> 850 MMBtu/h (≈ 249 MWth))

- Liquid Fuel-fired Combustion Turbine – SOx o Guideline limits: Use of 1% or less S fuel o EU: S content of light fuel oil used in gas turbines below 0.1% / US: S content of about 0.05% (continental area) and 0.4% (non-continental area)

Source: EU (LCP Directive 2001/80/EC October 23 2001), EU (Liquid Fuel Quality Directive 1999/32/EC, 2005/33/EC), US (NSPS for Stationary Combustion Turbines, Final Rule – July 6, 2006)



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Table 6 (C) - Emissions Guidelines (in mg/Nm3 or as indicated) for Boiler Note:

- Guidelines are applicable for new facilities. - EA may justify more stringent or less stringent limits due to ambient environment, technical and economic considerations provided there is compliance with

applicable ambient air quality standards and incremental impacts are minimized. - For projects to rehabilitate existing facilities, case-by-case emission requirements should be established by the EA considering (i) the existing emission levels and

impacts on the environment and community health, and (ii) cost and technical feasibility of bringing the existing emission levels to meet these new facilities limits. - EA should demonstrate that emissions do not contribute a significant portion to the attainment of relevant ambient air quality guidelines or standards, and more

stringent limits may be required. Combustion Technology / Fuel Particulate


Boiler NDA DA NDA DA NDA DA Natural Gas N/A N/A N/A N/A 240 240 3% Other Gaseous Fuels 50 30 400 400 240 240 3%

Liquid Fuels (Plant >50 MWth to <600 MWth) 50 30 900 – 1,500a 400 400 200 3%

Liquid Fuels (Plant >/=600 MWth) 50 30 200 – 850b 200 400 200 3%

Solid Fuels (Plant >50 MWth to <600 MWth) 50 30 900 – 1,500a 400 6%

Solid Fuels (Plant >/=600 MWth) 50 30 200 – 850b 200

510c

Or up to 1,100 if volatile matter of fuel < 10% 200 6%


nationally legislated air quality standards are exceeded or, in their absence, if WHO Air Quality Guidelines are exceeded significantly; CFB = circulating fluidized bed coal-fired; PC = pulverized coal-fired; Nm3 is at one atmospheric pressure, 0 degree Celsius; MWth category is to apply to the entire facility consisting of multiple units that are reasonably considered to be emitted from a common stack. Guideline limits apply to facilities operating more than 500 hours per year. Emission levels should be evaluated on a one hour average basis and be achieved 95% of annual operating hours.

- a. Targeting the lower guidelines values and recognizing issues related to quality of available fuel, cost effectiveness of controls on smaller units, and the potential for higher energy conversion efficiencies (FGD may consume between 0.5% and 1.6% of electricity generated by the plant). b. Targeting the lower guidelines values and recognizing variability in approaches to the management of SO2 emissions (fuel quality vs. use of secondary controls) and the potential for higher energy conversion efficiencies (FGD may consume between 0.5% and 1.6% of electricity generated by the plant). Larger plants are expected to have additional emission control measures. Selection of the emission level in the range is to be determined by EA considering the project’s sustainability, development impact, and cost-benefit of the pollution control performance. c. Stoker boilers may require different emissions values which should be evaluated on a case-by-case basis through the EA process.

Comparison of the Guideline limits with standards of selected countries / region (as of August 2008): - Natural Gas-fired Boiler – NOx

o Guideline limits: 240 o EU: 150 (50 to 300 MWth), 200 (> 300 MWth)

- Solid Fuels-fired Boiler - PM o Guideline limits: 50 o EU: 50 (50 to 100 MWth), 30 (> 100 MWth), China: 50, India: 100 - 150

- Solid Fuels-fired Boiler – SO2 o Guideline limits: 900 – 1,500 (Plant > 50 MWth to < 600 MWth), 200 – 850 (Plant ≥ 600 MWth) o EU: 850 (50 – 100 MWth), 200 (> 100 MWth) o US: 180 ng/J gross energy output OR 95% reduction (≈ 200 mg/Nm3 at 6%O2 assuming 38% HHV efficiency) o China: 400 (general), 800 (if using coal < 12,550 kJ/kg), 1,200 (if mine-mouth plant located in non-double control area of western region and burning low S coal (<0.5%))

Source: EU (LCP Directive 2001/80/EC October 23 2001), US (NSPS for Electric Utility Steam Generating Units (Subpart Da), Final Rule – June 13, 2007), China (GB 13223-2003)



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Table 7 – Typical Air Emission Monitoring Parameters / Frequency for Thermal Power Plants (Note: Detailed monitoring programs should be determined based on EA)

Emission Monitoring Stack Emission Testing Combustion Technology / Fuel Particulate

Matter (PM) Sulfur Dioxide

(SO2) Nitrogen Oxides

(NOx) PM SO2 NOx Heavy Metals Ambient Air Quality Noise

Reciprocating Engine Natural Gas (Plant >50 MWth to <300 MWth)

N/A N/A Continuous or indicative

N/A N/A Annual N/A

Natural Gas (Plant >/= 300 MWth)

N/A N/A Continuous N/A N/A Annual N/A

Liquid (Plant >50 MWth to <300 MWth)

Continuous or indicative


Liquid (Plant >/=300 MWth) Continuous or indicative

Continuous if FGD is used or monitor by S content.

Continuous Annual

Biomass Continuous or indicative

N/A Continuous or indicative

Annual N/A Annual N/A

Combustion Turbine Natural Gas (all turbine types of Unit > 50MWth)

N/A N/A Continuous or indicative

N/A N/A Annual N/A

Fuels other than Natural Gas (Unit > 50MWth)



Continuous or indicative Annual

Boiler

N/A N/A Annual N/A Natural Gas N/A N/A Continuous or

indicative Annual Annual Annual N/A

Other Gaseous fuels Indicative Indicative Continuous or indicative

Liquid (Plant >50 MWth to <600 MWth)



Liquid (Plant >=600 MWth) Continuous

Solid (Plant >50 MWth to <600 MWth)

Continuous if FGD is used or monitor by S Content.


Solid (Plant >/=600 MWth)


Continuous

Annual

If incremental impacts predicted by EA >/= 25 % of relevant short-term ambient air quality standards or if the plant >/= 1,200 MWth: - Monitor parameters (e.g., PM10/PM2.5/SO2/NOx to be consistent with the relevant ambient air quality standards) by continuous ambient air quality monitoring system (typically a minimum of 2 systems to cover predicted maximum ground level concentration point / sensitive receptor / background point).

If incremental impacts predicted by EA < 25% of relevant short term ambient air quality standards and if the facility < 1,200 MWth but >/= 100 MWth - Monitor parameters either by passive samplers (monthly average) or by seasonal manual sampling (e.g., 1 weeks/season) for parameters consistent with the relevant air quality standards.

Effectiveness of the ambient air quality monitoring program should be reviewed regularly. It could be simplified or reduced if alternative program is developed (e.g., local government’s monitoring network). Continuation of the program is recommended during the life of the project if there are sensitive receptors or if monitored levels are not far below the relevant ambient air quality standards.

If EA predicts noise levels at residential receptors or other sensitive receptors are close to the relevant ambient noise standards / guidelines, or if there are such receptors close to the plant boundary (e.g., within 100m) then, conduct ambient noise monitoring every year to three years depending on the project circumstances.

Elimination of noise monitoring can be considered acceptable if a comprehensive survey showed that there are no receptors affected by the project or affected noise levels are far below the relevant ambient noise standards / guidelines.

Note: Continuous or indicative means “Continuously monitor emissions or continuously monitor indicative parameters”. Stack emission testing is to have direct measurement of emission levels to counter check the emission monitoring system.



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2.2 Occupational Health and Safety

Occupational Health and Safety Guidelines Occupational health and safety performance should be evaluated against internationally published exposure guidelines, of which examples include the Threshold Limit Value (TLV®) occupational exposure guidelines and Biological Exposure Indices (BEIs®) published by American Conference of Governmental Industrial Hygienists (ACGIH),36 the Pocket Guide to Chemical Hazards published by the United States National Institute for Occupational Health and Safety (NIOSH),37 Permissible Exposure Limits (PELs) published by the Occupational Safety and Health Administration of the United States (OSHA),38 Indicative Occupational Exposure Limit Values published by European Union member states,39 or other similar sources.

Additional indicators specifically applicable to electric power sector activities include the ICNIRP exposure limits for occupational exposure to electric and magnetic fields listed in Table 8. Additional applicable indicators such as noise, electrical hazards, air quality, etc. are presented in Section 2.0 of the General EHS Guidelines.

Source: ICNIRP (1998) : “Guidelines for limiting exposure to time-varying electric, magnetic, and electromagnetic fields (up to 300 GHz)

36 http://www.acgih.org/TLV/36 Available at: http://www.acgih.org/TLV/ and http://www.acgih.org/store/ 37 Available at: http://www.cdc.gov/niosh/npg/ 38 Available at: http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9992 39 Available at: http://europe.osha.eu.int/good_practice/risks/ds/oel/

Accident and Fatality Rates Projects should try to reduce the number of accidents among project workers (whether directly employed or subcontracted) to a rate of zero, especially accidents that could result in lost work time, different levels of disability, or even fatalities. The accident and fatality rates of the specific facility may be benchmarked against the performance of facilities in this sector in developed countries through consultation with published sources (e.g., US Bureau of Labor Statistics and UK Health and Safety Executive)40.

Occupational Health and Safety Monitoring The working environment should be monitored for occupational hazards relevant to the specific project. Monitoring should be designed and implemented by accredited professionals41 as part of an occupational health and safety monitoring program. Facilities should also maintain a record of occupational accidents and diseases and dangerous occurrences and accidents. Additional guidance on occupational health and safety monitoring programs is provided in the General EHS Guidelines.

40 Available at: http://www.bls.gov/iif/ and http://www.hse.gov.uk/statistics/index.htm 41 Accredited professionals may include Certified Industrial Hygienists, Registered Occupational Hygienists, or Certified Safety Professionals or their equivalent.

Table 8 - ICNIRP exposure limits for occupational exposure to electric and magnetic fields.

Frequency Electric Field (V/m) Magnetic Field (µT)

50 Hz 10,000 500

60 Hz 8300 415



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3.0 References and Additional Sources

American Society for Testing and Materials (ASTM) E 1686-02, Standard Guide for Selection of Environmental Noise Measurements and Criteria, January 2003.

ANZECC (Australian and New Zealand Environment and Conservation Council). 1992. National water quality management strategy: Australian water quality guidelines for fresh and marine waters. ISBN 0-642-18297-3. Australian and New Zealand Environment and Conservation Council. Canberra Act 2600. New Zealand.

Commission of European Communities (CEC). 1988. European community environmental legislation: 1967-1987. Document Number XI/989/87. Directorate-General for Environment, Consumer Protection and Nuclear Safety. Brussels, Belgium. 229 pp.

Euromot. 2006. World Bank – International Finance Corporation General Environmental, Health and Safety Guidelines. Position Paper. November 2006.

European Commission (EC), 2001. Integrated Pollution Prevention and Control (IPCC) Reference Document on the Application of Best Available Techniques to Industrial Cooling Systems, December 2001

European Commission (EC). 2006. Integrated Pollution Prevention and Control Reference Document on Best Available Techniques (BREF) for Large Combustion Plants. July 2006.

G. G. Oliver and L. E. Fidler, Aspen Applied Sciences Ltd., Towards a Water Quality Guideline for Temperature in the Province of British Columbia, March 2001.

International Energy Agency. 2007. Fossil Fuel-Fired power Generation. Case Studies of Recently Constructed Coal- and Gas-Fired Power Plants.

International Organization for Standardization, ISO/DIS 1996-2.2, Acoustics – Description, assessment and measurement of environmental noise – Part 2: Determination of environmental noise levels.

Jamaica. 2006. The Natural Resources Conservation Authority Act. The Natural Resources Conservation Authority (Air Quality) Regulations, 2006.

NRC. 2002. Coal Waste Impoundments: Risks, Responses, and Alternatives. Committee on Coal Waste Impoundments, Committee on Earth Resources, Board on Earth Sciences and Resources, National Research Council. ISBN: 0-309-08251-X.

Official Journal of the European Communities. 2001. Directive 2001/80/EC of the European Parliament and of the Council of 23 October 2001 on limitation of emissions of certain pollutants into the air from large combustion plants.

People’s Republic of China. 2003. National Standards of the People’s Republic of China. GB 13223-2003. Emission Standard of Air Pollutants for Thermal Power Plants. December 23, 2003.

Republic of the Philippines. 1999. DENR Administrative Order No. 2000-81. RA 8749: The Philippine Clean Air Act of f 1999 and its Implementing Rules and Regulations. December 2001.

Schimmoller, Brian K. 2004. "Section 316(b) Regulations: The Yin and Yang of Fish Survival and Power Plant Operation" Power Engineering/July 2004 p. 28.

Tavoulareas, E. Stratos, and Jean-Pierre Charpentier. 1995. Clean Coal Technologies for Developing Countries. World Bank Technical Paper 286, Energy Series. Washington, D.C.

The Gazette of India. 2002. Ministry of Environment and Forest Notification, New Delhi, the 9th of July, 2002. Emission Standards for Diesel Engines (Engine Rating More Than 0.8 MW (800kW) for Power Plant, Generator Set Applications and Other Requirements.

The Institute of Electrical and Electronics Engineers, Inc. (IEEE), IEEE Guide for Power-Station Noise Control, IEEE Std. 640-1985, 1985

UNIPEDE / EURELECTRIC. 1997. Wastewater effluents Technology, Thermal Generation Study Committee. 20.04 THERCHIM 20.05 THERRES. April 1997.

UNIPEDE. 1998. Wastewater and water residue management – Regulations. Thermal Generation Study Committee. 20.05 THERRES. February 1998

U.S. Department of Energy (DOE) / National Energy Technology Laboratory (NETL), 2007. Cost and Performance Baseline for Fossil Energy Plants

U.S. Environmental Protection Agency (EPA). 1994. Water Quality Standards Handbook: Second Edition (EPA-823-B94-005a) August 1994.

U.S. Environmental Protection Agency (EPA). 1988d. State water quality standards summary: District of Columbia. EPA 440/5-88-041. Criteria and Standards Division (WH-585). Office of Water Regulations and Standards. Washington, District of Columbia. 7 pp.

U.S. Environmental Protection Agency (EPA). 1997. EPA Office of Compliance Sector Notebook Project Profile of the Fossil Fuel Electric Power Generation Industry. EPA/310-R-97-007. September 1997.

U.S. Environmental Protection Agency (EPA). 2001. Federal Register / Vol. 66, No. 243, National Pollutant Discharge Elimination System: Regulations Addressing Cooling Water Intake Structures for New Facilities, December 18, 2001 pp. 65256 – 65345.

U.S. Environmental Protection Agency (EPA), 2005. Control of Mercury Emissions from Coal Fired Electric Utility Boilers: An Update. Air Pollution Prevention and Control Division National Risk Management Research Laboratory Office of Research and Development.

U.S. Environmental Protection Agency (EPA), 2006. Federal Register / Vol. 71, No. 129, Standards of Performance for Stationary Combustion Turbines; Final Rule, July 6, 2006 pp. 38482-38506.

U.S. Environmental Protection Agency (EPA), 2006. Federal Register / Vol. 71, No. 132, Standards of Performance for Stationary Compression Ignition Internal Combustion Engines; Final Rule, July 11, 2006 pp. 39154-39184.

U.S. Environmental Protection Agency (EPA). 2006. Final Report. Environmental Footprints and Costs of Coal-Based Integrated Gasification Combined Cycle and Pulverized Coal technologies. July 2006.

U.S. Environmental Protection Agency (EPA). 2007. Federal Register / Vol. 72, No. 113, Amendments to New Source Performance Standards (NSPS) for Electric Utility Steam Generating Units and Industrial-commercial-Institutional Steam Generating Units; Final Rule, June 13, 2007 pp. 32710-32768

U.S. Environmental Protection Agency (EPA), 2008. Federal Register / Vol. 73, No. 13, Standards of Performance for Stationary Spark Ignition Internal Combustion Engines and National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines; Final Rule. pp3568-3614

West Virginia Water Research Institute. 2005. Guidance Document for Coal Waste Impoundment Facilities & Coal Waste Impoundment Inspection Form. Morgantown, WV. December 2005.

WHO (World Health Organization). 2006. Air Quality Guidelines Global Update 2005, Particulate matter, ozone, nitrogen dioxide and sulphur dioxide.

World Health Organization Regional Office for Europe Copenhagen. 2000. Air quality guidelines for Europe, 2nd edition, 2000.

World Bank Group. Pollution Prevention and Abatement Handbook 1998.

World Bank April 2006. Clean Energy and Development: Towards an Investment Framework.

World Bank Group. Sep 2006. Technical and Economic Assessment of Off-Grid, Mini-Grid and Grid Electrification Technologies Summary Report.



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Annex A: General Description of Industry Activities

Thermal power plants burn fossil fuels or biomass to generate electrical energy and heat. Mechanical power is produced by a heat engine, which transforms thermal energy from combustion of a fossil fuel into rotational energy. A generator converts that mechanical energy into electrical energy by creating relative motion between a magnetic field and a conductor. Figure A-1 is a generalized flow diagram of a boiler-based thermal power plant and its associated operations.

Not all thermal energy can be transformed to mechanical power, according to the second law of thermodynamics. Therefore, thermal power plants also produce low-temperature heat. If no use is found for the heat, it is lost to the environment. If reject heat is employed as useful heat (e.g., for industrial processes or district heating), the power plant is referred to as a cogeneration power plant or CHP (combined heat-and-power) plant.

Types of Thermal power plants Thermal power plants can be divided based on the type of combustion or gasification: boilers, internal reciprocating engines, and combustion turbines. In addition, combined-cycle and cogeneration systems increase efficiency by utilizing heat lost by conventional combustion systems. The type of system is chosen based on the loads, the availability of fuels, and the energy requirements of the electric power generation facility. Other ancillary processes, such as coal processing and pollution control, must also be performed to support the generation of electricity. The following subsections describe each system and then discuss ancillary processes at the facility (USEPA 1997).

Boilers (Steam Turbines) Conventional steam-producing thermal power plants generate electricity through a series of energy conversion stages: fuel is burned in boilers to convert water to high-pressure steam, which is then used to drive a steam turbine to generate electricity. Heat for the

system is usually provided by the combustion of coal, natural gas, oil, or biomass as well as other types of waste or recovered fuel. High-temperature, high-pressure steam is generated in the boiler and then enters the steam turbine. At the other end of the steam turbine is the condenser, which is maintained at a low temperature and pressure. Steam rushing from the high-pressure boiler to the low-pressure condenser drives the turbine blades, which powers the electric generator.

Low-pressure steam exiting the turbine enters the condenser shell and is condensed on the condenser tubes, which are maintained at a low temperature by the flow of cooling water. As the steam is cooled to condensate, the condensate is transported by the boiler feedwater system back to the boiler, where it is used again. A constant flow of low-temperature cooling water in the condenser tubes is required to keep the condenser shell (steam side) at proper pressure and to ensure efficient electricity generation. Through the condensing process, the cooling water is warmed. If the cooling system is an open or a once-through system, this warm water is released back to the source water body.42 In a closed system, the warm water is cooled by recirculation through cooling towers, lakes, or ponds, where the heat is released into the air through evaporation and/or sensible heat transfer. If a recirculating cooling system is used, only a relatively small amount of make-up water is required to offset the evaporative losses and cooling tower blowdown that must be discharged periodically to control the build-up of solids. A recirculating system uses about one-twentieth the water of a once-through system.

Steam turbines typically have a thermal efficiency of about 35 percent, meaning that 35 percent of the heat of combustion is transformed into electricity. The remaining 65 percent of the heat either goes up the stack (typically 10 percent) or is 42 If groundwater is used for cooling, the cooling water is usually discharged to a



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discharged with the condenser cooling water (typically 55 percent).

Coal and lignite are the most common fuels in thermal power plants although heavy fuel oil is also used. Coal-fired steam generation systems are designed to use pulverized coal or crushed coal. Several types of coal-fired steam generators are in use, and are generally classified based on the characteristics of the coal fed to the burners and the mode of burning the coal. In fluidized-bed combustors, fuel materials are forced by gas into a state of buoyancy. The gas cushion between the solids allows the particles to move freely, thus flowing like a liquid. By using this technology, SO2 and NOX emissions are reduced because an SO2 sorbent, such as limestone, can be used efficiently. Also, because the operating temperature is low, the amount of NOX gases formed is lower than those produced using conventional technology.

Natural gas and liquid fuels are usually transported to thermal power plants via pipelines. Coal and biomass fuels can be transported by rail, barge, or truck. In some cases, coal is mixed with water to form slurry that can be pumped to the thermal power plant in a pipeline. Once coal arrives at the plant, it is unloaded to storage or directly to the stoker or hopper. In transporting coal during warmer months and in dry climates, dust suppression may be necessary.

Coal may be cleaned and prepared before being either crushed or pulverized. Impurities in coal such as ash, metals, silica, and sulfur can cause boiler fouling and slagging. Coal cleaning can be used to reduce sulfur in the coal to meet sulfur dioxide (SO2) emissions regulations and also reduce ash content and the amount of heavy metals. Cleaning the coal is costly, but the cost can be at least partially offset by an increase in fuel efficiency, reduced emission control requirements, and lower waste management costs. Coal cleaning is typically performed

surface water body.

at the mine by using gravity concentration, flotation, or dewatering methods.

Coal is transported from the coal bunker or silo to be crushed, ground, and dried further before it is fired in the burner or combustion system. Many mechanisms can be used to grind the coal and prepare it for firing. Pulverizers, cyclones, and stokers are all used to grind and dry the coal. Increasing the coal’s particle surface area and decreasing its moisture content greatly boosting its heating capacity. Once prepared, the coal is transported within the plant to the combustion system. Devices at the bottom of the boilers catch ash and/or slag.

Reciprocating Engines Internal combustion engines convert the chemical energy of fuels (typically diesel fuel or heavy fuel oil) into mechanical energy in a design similar to a truck engine, and the mechanical energy is used to turn a generator. Two types of engines normally used: the medium-speed, four-stroke trunk piston engine and the low-speed, two-stroke crosshead engine. Both types of engine operate on the air-standard diesel thermodynamic cycle. Air is drawn or forced into a cylinder and is compressed by a piston. Fuel is injected into the cylinder and is ignited by the heat of the compression of the air. The burning mixture of fuel and air expands, pushing the piston. The products of combustion are then removed from the cylinder, completing the cycle.

The exhaust gases from an engine are affected by the load profile of the prime mover; ambient conditions such as air humidity and temperature; fuel oil quality, such as sulfur content, nitrogen content, viscosity, ignition ability, density, and ash content; and site conditions and the auxiliary equipment associated with the prime mover, such as cooling properties and exhaust gas back pressure. The engine parameters that affect NOX emissions are fuel injection in terms of timing, duration, and atomization; combustion air conditions, which are affected by



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valve timing, the charge air system, and charge air cooling before cylinders; and the combustion process, which is affected by air and fuel mixing, combustion chamber design, and the compression ratio.43 The particulate matter emissions are dependent on the general conditions of the engine, especially the fuel injection system and its maintenance, in addition to the ash content of the fuel, which is in the range 0.05–0.2%. SOx emissions are directly dependent on the sulfur content of the fuel. Fuel oil may contain as little as 0.3% sulfur and, in some cases, up to 5% sulfur.

Diesel engines are fuel flexible and can use fuels such as diesel oil, heavy fuel oil, natural gas, crude oil, bio-fuels (such as palm oil, etc.) and emulsified fuels (such as Orimulsion, etc.).

Typical electrical efficiencies in single mode are typically ranging from 40 % for the medium speed engines up to about 50 % for large engines and even higher efficiencies in combined cycle mode. Total efficiency in CHP (Combined Heat and Power) is typically in liquid operation up to 60 – 80 % and in gas mode even higher dependent on the application. The heat to power ratio is typically 0.5 to 1.3 in CHP applications, dependent on the application.

Lean Burn Gas Engines

Typical electrical efficiencies for bigger stationary medium speed engines in single mode are typically 40 – 47 % and up to close to 50 % in combined cycle mode. Total efficiency in CHP facilities is typically up to 90 % dependent on the application. The heat to power ratios are typically 0.5 to 1.3 in CHP-applications, dependent on the application.

43 If the fuel timing is too early, the cylinder pressure will increase, resulting in higher nitrogen oxide formation. If injection is timed too late, fuel consumption and turbocharger speed will increase. NOX emissions can be reduced by later injection timing, but then particulate matter and the amount of unburned species will increase.

Spark Ignition (SG)

Often a spark ignited gas-otto engine works according to the lean burn concept meaning that a lean mixture of combustion air and fuel is used in the cylinder (e.g., much more air than needed for the combustion). In order to stabilize the ignition and combustion of the lean mixture, in bigger engine types a prechamber with a richer air/fuel mixture is used. The ignition is initiated with a spark plug or some other device located in the prechamber, resulting in a high-energy ignition source for the main fuel charge in the cylinder. The most important parameter governing the rate of NOx formation in internal combustion engines is the combustion temperature; the higher the temperature the higher the NOx content of the exhaust gases. One method is to lower the fuel/air ratio, the same specific heat quantity released by the combustion of the fuel is then used to heat up a larger mass of exhaust gases, resulting in a lower maximum combustion temperature. This method low fuel/air ratio is called lean burn and it reduces NOx effectively. The spark-ignited lean-burn engine has therefore low NOx emissions. This is a pure gas engine; it operates only on gaseous fuels.

Dual fuel engines (DF)

Some DF engine types are fuel versatile, these can be run on low pressure natural gas or liquid fuels such as diesel oil (as back-up fuel, etc.), heavy fuel oil, etc. This engine type can operate at full load in both fuel modes. Dual Fuel (DF) engines can also be designed to work in gas mode only with a pilot liquid fuel used for ignition of the gas.

Combustion Turbines Gas turbine systems operate in a manner similar to steam turbine systems except that combustion gases are used to turn the turbine blades instead of steam. In addition to the electric generator, the turbine also drives a rotating compressor to pressurize the air, which is then mixed with either gas or liquid



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fuel in a combustion chamber. The greater the compression, the higher the temperature and the efficiency that can be achieved in a gas turbine. Higher temperatures, however, typically lead to increases in NOX emissions. Exhaust gases are emitted to the atmosphere from the turbine. Unlike a steam turbine system, gas turbine systems do not have boilers or a steam supply, condensers, or a waste heat disposal system. Therefore, capital costs are much lower for a gas turbine system than for a steam system.

In electrical power applications, gas turbines are often used for peaking duty, where rapid startup and short runs are needed. Most installed simple gas turbines with no controls have only a 20- to 30-percent efficiency.

Combined Cycle Combined-cycle generation is a configuration using both gas turbines and steam generators. In a combined-cycle gas turbine (CCGT), the hot exhaust gases of a gas turbine are used to provide all, or a portion of, the heat source for the boiler, which produces steam for the steam generator turbine. This combination increases the thermal efficiency to approximately 50 - 60 percent. Combined-cycle systems may have multiple gas turbines driving one steam turbine. Combined-cycle systems with diesel engines and steam generators are also sometimes used.

In addition, integrated coal gasification combined-cycle (IGCC) units are emerging technologies. In an IGCC system, coal gas is manufactured and cleaned in a "gasifier" under pressure, thereby reducing emissions and particulates.44 The coal gas then is combusted in a CCGT generation system.

44 Gasification is a process in which coal is introduced to a reducing atmosphere with oxygen or air and steam.

Cogeneration Cogeneration is the merging of a system designed to produce electric power and a system used for producing industrial heat and steam and/or municipal heating. This system is a more efficient way of using energy inputs and allows the recovery of otherwise wasted thermal energy for use in an industrial process. Cogeneration technologies are classified as "topping cycle" and "bottoming cycle" systems, depending on whether electrical (topping cycle) or thermal (bottoming cycle) energy is derived first. Most cogeneration systems use a topping cycle.



WORLD BANK GROUP

Figure A-1 Generalized Flow Diagram of a Thermal power plant45 and Associated Operations

Source: EC 2006

45 Applicable to boiler plant with cooling tower only. Diagram does not apply to engines and turbines which have completely different configurations.



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Annex B: Environmental Assessment Guidance for Thermal Power Projects

The development of an environmental assessment (EA) for a thermal power project should take into account any government energy and/or environmental policy or strategy including strategic aspects such as energy efficiency improvements in existing power generation, transmission, and distribution systems, demand side management, project siting, fuel choice, technology choice, and environmental performance.

New Facilities and Expansion of Existing Facilities An (EA) for new facilities and a combined EA and environmental audit for existing facilities should be carried out early in the project cycle in order to establish site-specific emissions requirements and other measures for a new or expanded thermal power plant. Table B-1 provides suggested key elements of the EA, the scope of which will depend on project-specific circumstances.

Table B-1 Suggested Key EHS Elements for EA of New Thermal Power Project

Analysis of Alternatives

• Fuel selection including non-fossil fuel options (coal, oil, gas, biomass, other renewable options – wind, solar, geothermal, hydro), fuel supply sources

• Power generation technology o Thermal generating efficiency

(HHV-gross, LHV-gross, HHV-net, LHV-net)

o Cost o CO2 emissions performance

(gCO2/kWh) • GHG emissions reduction / offset

options o Energy conversion efficiency o Offset arrangement o Use of renewable energy

sources, etc. • Baseline water quality of receiving water

bodies • Water supply

o Surface water, underground water, desalination

• Cooling system o Once-through, wet closed

circuit, dry closed circuit • Ash disposal system - wet disposal vs.

dry disposal • Pollution control

o Air emission – primary vs. secondary flue gas treatment (cost, performance)

o Effluent (cost, performance) • Effluent discharge

o Surface water o Evaporation o Recycling – zero discharge

• Siting o Land acquisition

consideration o Access to fuel / electricity

grid o Existing and future land use

zoning o Existing and predicted

environmental baseline (air, water, noise)

Impact Assessment

• Estimation of GHG emissions (tCO2/year, gCO2/kWh)

• Air quality impact o SO2, NO2, PM10, PM2.5,

Heavy metals as appropriate, Acid deposition if relevant

o Incremental impacts to the attainment of relevant air quality standards

o Isopleth concentration lines (short-term, annual average, as appropriate) overlaid with land use and topographic map

o Cumulative impacts of existing sources / future projects if known

o Stack height determination o Health impact consideration

• Water quality / intake impact o thermal discharge if once-

through cooling system is used

o other key contaminants as appropriate

o water intake impact • Noise impact

o Noise contour lines overlaid with land use and locations of receptors

• Determination of pollution prevention and abatement measures

Mitigation Measures /

• Air (Stack height, pollution control measures, cost)



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Management Program

• Effluent (wastewater treatment measures, cost)

• Noise (noise control measures, cost) • Waste utilization / disposal (e.g., ash,

FGD by-product, used oil) o Ash management plan

(quantitative balance of ash generation, disposal, utilization, size of ash disposal site, ash transportation arrangement)

• Fuel supply arrangement • Emergency preparedness and response

plan • Industrial risk assessment if relevant

Monitoring Program

• Parameters • Sampling Frequency • Evaluation Criteria • Sampling points overlaid with relevant

site layout / surrounding maps • Cost

Tasks related to carrying out the quality impact analysis for the EA should include:

• Collection of baseline data ranging from relatively simple qualitative information (for smaller projects) to more comprehensive quantitative data (for larger projects) on ambient concentrations of parameters and averaging time consistent with relevant host country air quality standards (e.g., parameters such as PM10, PM2.5, SO2 (for oil and coal-fired plants), NOX, and ground-level ozone; and averaging time such as 1-hour maximum, 24-hour maximum, annual average), within a defined airshed encompassing the proposed project;46

• Evaluation of the baseline airshed quality (e.g., degraded or non-degraded);

• Evaluation of baseline water quality, where relevant;

• Use of appropriate mathematical or physical air quality

46 The term “airshed” refers to the local area around the plant whose ambient air quality is directly affected by emissions from the plant. The size of the relevant local airshed will depend on plant characteristics, such as stack height, as well as on local meteorological conditions and topography. In some cases, airsheds are defined in legislation or by the relevant environmental authorities. If not, the EA should clearly define the airshed on the basis of consultations with those responsible for local environmental management.

dispersion models to estimate the impact of the project on the ambient concentrations of these pollutants;

• If acid deposition is considered a potentially significant impact, use of appropriate air quality models to evaluate long-range and trans-boundary acid deposition;

• The scope of baseline data collection and air quality impact assessment will depend on the project circumstances (e.g., project size, amount of air emissions and the potential impacts on the airshed). Examples of suggested practices are presented in Table B-2.

Table B-2 - Suggested Air Quality Impact Assessment Approach

Baseline air quality collection

• Qualitative information (for small projects e.g., < 100MWth)

• Seasonal manual sampling (for mid-sized projects e.g., < 1,200MWth)

• Continuous automatic sampling (for large projects e.g., >= 1,200MWth)

• Modeling existing sources

Baseline meteorological data collection

• Continuous one-year data for dispersion modeling from nearby existing meteorological station (e.g., airport, meteorological station) or site-specific station, if installed, for mid-sized and large projects

Evaluation of airshed quality

• Determining if the airshed is degraded (i.e., ambient air quality standards are not attained) or non-degraded (i.e., ambient air quality standards are attained)

Air quality impact assessment

• Assess incremental and resultant levels by screening models (for small projects)

• Assess incremental and resultant levels by refined models (for mid-sized and large projects, or for small projects if determined necessary after using screening models)47

• Modify emission levels, if needed, to ensure that incremental impacts are small (e.g., 25% of relevant ambient air quality standard levels) and that the airshed will not become degraded.

47 For further guidance on refined / screening models, see Appendix W to Part 51 – Guidelines on Air Quality Models by US EPA (Final Rule, November 9, 2005)



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When there is a reasonable likelihood that in the medium or long term the power plant will be expanded or other pollution sources will increase significantly, the analysis should take account of the impact of the proposed plant design both immediately and after any formally planned expansion in capacity or in other sources of pollution. Plant design should allow for future installation of additional pollution control equipment, should this prove desirable or necessary based upon predicted air quality impacts and/or anticipated changes in emission standards (i.e., impending membership into the EU). The EA should also address other project-specific environmental concerns, such as fuel and emissions from fuel impurities. In cases where fuel impurities lead to known hazardous emissions, the EA should estimate the emission amount, assess impacts and propose mitigations to reduce emissions.48 Examples of compounds which may be present in certain types of coal, heavy fuel oil, petroleum coke, etc. include cadmium, mercury, and other heavy metals.

Rehabilitation of Existing Facilities An environmental assessment of the proposed rehabilitation should be carried out early in the process of preparing the project in order to allow an opportunity to evaluate alternative rehabilitation options before key design decisions are finalized. The assessment should include an environmental audit that examines the impacts of the existing plant’s operations on nearby populations and ecosystems, supplemented by an EA that examines the changes in these impacts that would result under alternative specifications for the rehabilitation, and the estimated capital and operating costs associated with each option. Depending on the scale and nature of the rehabilitation, the audit/environmental assessment may be relatively narrow in

48 Several U.S. states have adopted regulations that give coal-fired power plants the option to meet either a mercury emissions standard based on electricity output or a control-based standard. For instance, Illinois requires all coal-fired power plants of 25 MW electrical capacity or greater to meet either an emissions standard of 0.0080 lbs mercury per gigawatt hour (GWh) gross electrical output or an emissions control requirement of 90 percent relative to mercury input.

scope, focusing on only a small number of specific concerns that would be affected by the project, or it may be as extensive as would be appropriate for the construction of a new unit at the same site. Normally, it should cover the following points:

• Ambient environmental quality in the airshed or water basin affected by the plant, together with approximate estimates of the contribution of the plant to total emissions loads of the main pollutants of concern

• The impact of the plant, under existing operating conditions and under alternative scenarios for rehabilitation, on ambient air and water quality affecting neighboring populations and sensitive ecosystems

• The likely costs of achieving alternative emissions standards or other environmental targets for the plant as a whole or for specific aspects of its operations

• Recommendations concerning a range of cost effective measures for improving the environmental performance of the plant within the framework of the rehabilitation project and any associated emissions standards or other requirements implied by the adoption of specific measures.

These issues should be covered at a level of detail appropriate to the nature and scale of the proposed project. If the plant is located in an airshed or water basin that is polluted as a result of emissions from a range of sources, including the plant itself, comparisons should be made of the relative costs of improving ambient air or water quality by reducing emissions from the plant or by reducing emissions from other sources.



Hagler Bailly Pakistan Appendix B R5A05ENP: 09/29/15 B-1

Appendix B: Air Quality Sampling Results


1

(SUPARCO ENVIRONMENTAL LABORATORY)

PPaakkiissttaann SSppaaccee && UUppppeerr AAttmmoosspphheerree RReesseeaarrcchh CCoommmmiissssiioonn ((SSUUPPAARRCCOO))

P.O. Box 8402, SUPARCO Road, Gulzar-e-Hijri, Sector 28, Karachi

Ph: 021-34650765-79, FAX: 021-34644928, 34644941 Website: www.suparco.gov.pk

S. No

Date Time SO2

(µg/m3) NO

(µg/m3) NO2

(µg/m3) CO

(mg/m3) O3

(µg/m3) PM 2.5

(µg/m3) PM 10

(µg/m3) SPM

(µg/m3) Lead

(µg/m3)

Air Temperature

(°C)

Humidity (%)

Wind Speed (m/s)

Wind Direction (Deg)

1 04-03-2015 1600 17.6 18.9 11.6 1.4 6.1 28

125 310

0.03

26.7 40.7 4.8 116

2 04-03-2015 1630 17.8 18.5 12.2 1.4 5.7 28 26.5 40.5 2.7 121

3 04-03-2015 1700 16.9 18.3 11.9 1.2 6.2 26 25.7 40.5 3.7 105

4 04-03-2015 1730 16.6 18.7 12.0 1.3 6.3 27 25.2 40.8 3.5 114

5 04-03-2015 1800 16.2 18.2 12.1 1.3 5.7 27 24.9 41.2 5.0 117

6 04-03-2015 1830 15.8 18.4 12.3 1.4 5.6 29 24.2 41.2 4.0 122

7 04-03-2015 1900 14.2 18.3 11.4 1.3 6.2 28 24.0 41.1 3.0 121

8 04-03-2015 1930 14.2 18.7 11.5 1.2 5.4 27 23.5 41.0 2.7 120

9 04-03-2015 2000 14.6 19.1 11.2 1.2 5.3 24 23.0 41.0 2.0 122

10 04-03-2015 2030 14.9 18.7 11.3 1.2 5.4 25 22.7 41.1 1.8 120

11 04-03-2015 2100 13.6 18.1 11.7 1.2 5.2 25 22.9 41.2 2.5 120

12 04-03-2015 2130 13.8 18.2 12.4 1.2 5.3 22 22.8 41.0 3.5 120

13 04-03-2015 2200 13.5 17.9 11.4 1.2 5.1 23 22.9 41.5 1.4 122

14 04-03-2015 2230 13.3 17.6 11.6 1.2 5.3 24 22.4 41.2 1.7 120

15 04-03-2015 2300 13.4 17.8 11.8 1.3 5.4 22 22.3 41.2 1.6 120

16 04-03-2015 2330 13.6 18.2 11.9 1.2 5.7 21 22.6 41.5 1.8 123

17 05-03-2015 0000 13.2 18.6 11.4 1.2 5.8 20 22.6 40.8 0.0 19

18 05-03-2015 0030 13.9 18.7 11.8 1.3 5.9 20 22.7 41.7 2.0 120

PROJECT Air Pollution Survey , March 2015 CLIENT Hagler Bailly, Pakistan

SITE # Site 2: Port Qasim, (24°47'54.41" N,

67°23'8.30" E) Contact Number: 0345-5757876

1





19 05-03-2015 0100 13.7 18.4 11.4 1.4 5.9 19 22.7 41.5 2.5 124

20 05-03-2015 0130 13.6 18.6 11.6 1.2 5.3 18 22.4 41.3 1.9 123

21 05-03-2015 0200 13.7 18.4 11.8 1.2 5.7 19 22.6 41.3 1.7 123

22 05-03-2015 0230 13.3 18.6 11.7 1.2 5.4 20 21.8 41.2 0.7 124

23 05-03-2015 0300 13.2 18.6 11.6 1.3 5.2 21 21.3 41.3 2.1 124

24 05-03-2015 0330 13.2 18.4 11.2 1.4 5.3 22 20.8 40.9 0.8 13

25 05-03-2015 0400 13.3 17.3 11.4 1.2 5.9 20 20.1 40.9 0.0 112

26 05-03-2015 0430 14.8 15.8 11.5 1.2 5.7 21 20.1 41.1 0.0 117

27 05-03-2015 0500 13.5 16.7 11.6 1.2 5.9 24 19.3 40.7 1.6 108

28 05-03-2015 0530 14.6 16.5 11.7 1.3 5.2 22 19.1 40.8 1.3 108

29 05-03-2015 0600 14.7 16.7 11.6 1.4 6.1 23 19.1 40.6 0.2 75

30 05-03-2015 0630 15.6 16.4 11.8 1.4 7.3 24 18.8 40.8 0.7 104

31 05-03-2015 0700 15.2 16.2 11.8 1.5 8.9 25 18.8 40.8 0.0 118

32 05-03-2015 0730 15.4 15.8 11.6 1.5 9.7 28 20.0 41.0 0.8 110

33 05-03-2015 0800 15.6 18.8 11.4 1.5 10.3 28 21.5 40.8 0.6 76

34 05-03-2015 0830 16.7 19.7 11.7 1.8 11.6 29 23.3 40.3 0.9 119

35 05-03-2015 0900 16.8 20.4 11.6 1.7 14.7 30 23.9 39.4 1.7 117

36 05-03-2015 0930 16.7 22.3 11.9 1.8 15.2 29 26.0 39.2 3.5 113.7

37 05-03-2015 1000 16.9 22.4 13.4 1.9 16.4 28 26.8 38.7 3.4 101.7

38 05-03-2015 1030 17.1 22.1 11.7 1.9 16.9 30 26.5 38.2 4.8 119.1

39 05-03-2015 1100 18.8 22.0 13.5 1.9 14.2 31 27.4 38.3 6.2 115.6

40 05-03-2015 1130 19.3 22.4 13.3 2.0 14.5 31 27.4 38.1 0.6 108.9

41 05-03-2015 1200 19.2 22.7 13.8 2.0 12.2 28 27.5 38.4 5.6 97.2

42 05-03-2015 1230 19.4 22.6 13.4 2.1 13.4 29 28.1 38.4 4.0 113.7

43 05-03-2015 1300 17.9 22.8 11.9 1.9 13.2 29 27.5 38.1 3.7 83.3

44 05-03-2015 1330 20.3 22.4 12.4 2.1 12.8 30 28.0 38.3 3.8 120.7

45 05-03-2015 1400 20.4 22.7 13.9 2.0 11.9 30 27.8 38.0 5.0 99.1

1





46 05-03-2015 1430 20.6 22.6 14.2 1.8 14.4 31 27.2 37.7 4.4 110

47 05-03-2015 1500 20.1 22.5 14.2 1.9 12.6 31 26.8 37.4 4.5 92

48 05-03-2015 1530 20.3 21.7 14.0 2.0 12.5 31 26.3 37.1 3.8 117

Average 15.9 19.2 12.1 1.5 8.5 25.6

125 310

0.03

- - - -

Min 13.2 15.8 11.2 1.2 5.1 18.0 - - - -

Max 20.6 22.8 14.2 2.1 16.9 31.0 - - - -

NEQS* 120 40 80 5 130 35 150 500 1.5 - - - - *NEQS: National Environmental Quality Standard

Report Prepared By: Mina Akbar Khan (Sub Engineer -II)

Report Reviewed By: Mr. Muhammad Sarfraz Khan (Manager)

Report Approved By: Dr. Muhammad Mansha DH (Env. Monitoring & Modeling Div)

1





S. No

Date Time SO2

(µg/m3) NO

(µg/m3) NO2

(µg/m3) CO

(mg/m3) O3

(µg/m3) PM 2.5

(µg/m3) PM 10

(µg/m3) SPM

(µg/m3) Lead

(µg/m3)

Air Temperature

(°C)

Humidity (%)

Wind Speed (m/s)

Wind Direction (Deg)

1 05-03-2015 1700 13.5 11.4 6.8 1.1 5.2 22

102 232

0.01

29.7 40.1 2.3 113

2 05-03-2015 1730 13.9 12.3 6.4 1.1 4.7 23 28.3 39.2 2.1 117

3 05-03-2015 1800 13.5 12.4 6.9 1.1 4.5 22 26.4 39.6 1.7 120

4 05-03-2015 1830 13.6 11.9 6.8 1.2 4.6 23 26.5 39.8 3.2 118

5 05-03-2015 1900 13.2 11.9 6.2 1.1 4.8 24 26.9 40.1 2.9 115

6 05-03-2015 1930 13.0 12.0 6.3 1.2 5.1 25 26.7 40.6 1.6 110

7 05-03-2015 2000 13.6 11.4 6.7 1.1 5.2 24 26.8 40.2 1.5 111

8 05-03-2015 2030 13.3 11.4 6.3 1.1 4.9 22 26.9 41.4 2.3 114

9 05-03-2015 2100 12.5 12.3 6.2 1.1 4.6 22 25.7 41.1 2.8 115

10 05-03-2015 2130 11.6 11.4 6.4 1.0 4.4 21 25.3 40.9 3.1 114

11 05-03-2015 2200 11.4 11.8 6.3 1.0 4.3 22 24.8 40.8 3.0 112

12 05-03-2015 2230 11.7 11.6 6.4 1.0 4.2 20 24.4 39.7 3.6 112

13 05-03-2015 2300 10.6 12.3 6.3 1.1 4.1 22 23.6 40.3 3.4 119

14 05-03-2015 2330 10.9 11.4 6.8 1.0 3.9 23 24.8 39.9 0.8 119

15 06-03-2015 0000 11.0 11.2 6.7 0.9 3.8 23 22.3 40.0 0.6 114

16 06-03-2015 0030 11.4 11.3 6.3 0.9 3.7 24 21.2 40.2 1.4 119

17 06-03-2015 0100 10.2 10.8 6.2 0.9 3.5 23 21.0 40.7 1.2 119

18 06-03-2015 0130 10.2 10.9 6.4 1.0 3.6 24 21.5 41.0 0.0 118

PROJECT Air Pollution Survey , March 2015 CLIENT Hagler Bailly, Pakistan

SITE # Site 2: Port Qasim, (24°47'31.26" N,

67°26'16.96" E ) Contact Number: 0345-5757876

1





19 06-03-2015 0200 10.3 10.6 7.1 0.9 3.4 20 21.6 41.1 0.8 115

20 06-03-2015 0230 10.0 10.4 7.0 1.1 3.5 18 21.5 41.2 1.7 112

21 06-03-2015 0300 10.4 10.7 6.9 1.1 3.2 19 21.2 41.1 1.2 112

22 06-03-2015 0330 10.6 10.9 6.8 1.0 3.1 20 21.5 41.4 1.7 109

23 06-03-2015 0400 10.2 10.7 6.9 1.0 3.6 20 20.7 41.1 1.6 117

24 06-03-2015 0430 10.7 10.6 6.8 1.1 3.6 21 21.2 41.4 1.7 114

25 06-03-2015 0500 10.7 10.5 6.4 1.1 3.8 21 20.7 41.3 1.3 114

26 06-03-2015 0530 10.6 11.5 7.2 1.0 3.4 18 20.2 40.8 0.8 116

27 06-03-2015 0600 11.8 11.9 7.2 1.0 3.8 17 20.3 41.2 0.9 115

28 06-03-2015 0630 11.9 14.2 7.6 0.9 3.5 20 19.7 41.1 2.0 123

29 06-03-2015 0700 12.2 13.3 7.5 0.9 3.9 22 18.9 40.8 1.8 121

30 06-03-2015 0730 12.0 12.8 7.4 0.9 4.2 23 19.7 41.3 1.6 124

31 06-03-2015 0800 12.1 12.8 7.6 1.1 4.1 22 19.7 41.1 1.5 123

32 06-03-2015 0830 12.9 13.3 7.2 1.1 5.2 22 20.4 41.1 1.6 125

33 06-03-2015 0900 12.5 13.7 7.3 1.2 6.6 23 21.2 41.2 3.7 122

34 06-03-2015 0930 13.0 13.8 7.6 1.2 6.9 23 22.4 40.9 4.4 120

35 06-03-2015 1000 12.2 13.9 7.4 1.2 5.7 24 24.1 40.0 4.4 115

36 06-03-2015 1030 12.7 12.7 7.3 1.2 6.7 23 25.2 39.7 4.2 113

37 06-03-2015 1100 12.4 12.4 7.9 1.1 5.4 24 25.6 39.6 3.8 106

38 06-03-2015 1130 12.3 12.3 7.4 1.2 5.2 25 26.2 38.9 4.9 107

39 06-03-2015 1200 12.7 12.4 7.6 1.2 5.3 25 27.2 39.0 2.7 66

40 06-03-2015 1230 12.8 12.7 7.9 1.2 5.4 24 27.7 38.3 2.2 94

41 06-03-2015 1300 12.6 12.3 7.4 1.1 5.3 23 28.4 37.9 3.3 105

42 06-03-2015 1330 12.4 12.8 7.6 1.0 5.6 25 28.6 37.7 1.6 66

43 06-03-2015 1400 12.6 12.7 7.8 1.2 5.4 24 29.0 37.1 4.0 16

44 06-03-2015 1430 12.7 12.9 7.9 1.2 5.9 25 29.4 37.5 3.7 11

45 06-03-2015 1500 12.2 12.3 7.4 1.1 5.2 23 29.5 36.8 1.5 77

1





46 06-03-2015 1530 12.7 12.4 7.6 1.2 4.6 24 29.1 37.3 3.2 49

47 06-03-2015 1600 12.3 12.5 7.5 1.3 4.2 25 28.6 37.5 2.9 67

48 06-03-2015 1630 12.4 12.6 7.4 1.2 4.1 23 28.2 37.2 2.8 67

Average 12.0 12.0 7.0 1.1 4.6 22.4

102 232

0.01

- - - -

Min 10.0 10.4 6.2 0.9 3.1 17.0 - - - -

Max 13.9 14.2 7.9 1.3 6.9 25.0 - - - -

NEQS* 120 40 80 5 130 35 150 500 1.5 - - - - *NEQS: National Environmental Quality Standard

Report Prepared By: Mina Akbar Khan (Sub Engineer -II)

Report Reviewed By: Mr. Muhammad Sarfraz Khan (Manager)

Report Approved By: Dr. Muhammad Mansha DH (Env. Monitoring & Modeling Div)



Hagler Bailly Pakistan Appendix C R5A05ENP: 09/29/15 C-1

Appendix C: Settlement Questionnaire for Men and Women


Questionnaire for EIA of 225 MW RLNG CCPP

Port Qasim, Karachi

Date of Interview Questionnaire Number

Hagler Bailly Pakistan Settlement Questionnaire For Men

O5SE1ENP: 03/05/15 1

Settlement Questionnaire For Men

A. Background Information

Name of Investigator(s) _________________________________________________________

Settlement / Name _________________________________ District ____________________

Union Council ____________________________________ Tehsil ____________________

Coordinates: N ____________________ E ____________________

B. Respondent Information

Name(s) Role in Community/Occupation Contact Details

C. Demography

Total Households Estimated Population

D. Houses

Proportion of Houses Adobe

%

Proportion of Houses Masonry

%

E. Ethnicity

Group name Share (%)




Port Qasim, Karachi


O5SE1ENP: 03/05/15 2

F. Occupational Profile

Occupation Share in employed population (%)

Description (type of occupation)

Government Service

Private Service

PQA Industry Employee

Fishing (Self Employed/Labor)

Overseas Employment

Other Wage Labor

Trade/Business

Art

Others ___________

G. List of languages spoken in the communities

Language Share in population (%)

Language Share in population (%)

Urdu

Sindhi

Others

H. Marginalized Groups

Group Number Explanation/Remarks

Mentally/physically challenged people

Widow

Religious minorities


Port Qasim, Karachi


O5SE1ENP: 03/05/15 3

I. Education

a. Facilities in the Settlement

Is there any educational facility available? Yes No

Facility Functional (Y/N)

Type Enrollment Remarks

Male Female Total

b. Education in the Settlement

Male Female

No Explanation No Explanation

Completed college (BA/BSc/ …)

Completed Matric

How many children going to primary school?

Where Where

How many children going to secondary school?

Where Where

How many children going to high school and beyond?

Where Where

Literacy Rate

J. Health

a. Health Facilities in Settlement


Location if outside village

Distance (km)

When established

Remarks

Dispensary

BHU

Private Local Clinic

Private Hospital

Government Hospital

Lady Health Visitor (LHV)


Port Qasim, Karachi


O5SE1ENP: 03/05/15 4



Distance (km)

When established

Remarks

Immunization (e.g. polio drops)

Trained Midwife

Untrained Midwife

b. Health

State the number of members who are suffering or have suffered from the following during the last one year

Common Diseases

( ) Men

( ) Women

( ) Adult-Children

(6 to 14)

( )

Children (0 to 5)

( )

Tuberculosis

Diarrhea

Breathing problems

Jaundice

Skin diseases

Cold and flu

Stomach diseases

Joint aches

Tetanus

Paralysis

Diabetes

Cancer

Heart problems

Other (specify)


Port Qasim, Karachi


O5SE1ENP: 03/05/15 5

K. Water Supply and Sanitation

Water Supply

Source (Yes/No) Transportation Mechanism (Tankers/Pipeline/Donkeys

etc.)

Distance (km)

Distribution Mechanism (Central Storage Tanks etc.)

Tube Well

Dug Well

Water Tanker

Government Water Supply System

Water Storage Facility

Typical Sanitation

Pit Latrine Septic Tanks Sewerage Plant Open air

L. Energy Sources and Consumption (Non-mobile)

Type Price (Rs/unit)

Source (e.g. grid, power plant,

forest, market)

Uses

Lighting Space heating

Water heating

Cooking

Electricity

Fuel wood

LPG

Kerosene

Diesel

Gas

M. Infrastructure

Facility Access (Y/N)

Mobile Network (Ufone, Mobilink, Zong, Telenor

Warid etc.)

Nearest Location if out

of Village

Distance (km)

Description

Telephone/PCO

Mobile Phone Service

Post Office

Village Police Station

Transportation Mode to other Locations (Bus, Pick-up, Jeep, Car)


Port Qasim, Karachi


O5SE1ENP: 03/05/15 6

Facility Access (Y/N)

Mobile Network (Ufone, Mobilink, Zong, Telenor

Warid etc.)

Nearest Location if out

of Village

Distance (km)

Description

Village Connected to Black Top Road

Bank

Market

N. Migration Patterns

Out-Migration (No. of HHs) In-Migration (No. of HHs)

Last 10 Years

Last 20 Years

Reasons Last 10 Years

Last 20 Years

Reasons

O. Non-governmental Organization (NGOs) and Community Organizations (COs)

Are NGOs active in the village? Yes No

If yes:

Name Facilities Provided

Year Provided

Number of Beneficiaries

Performance (Good, Average,

Poor)

Location Office

Are COs active in the village? Yes No

If yes:

Name Purpose Performance (Good, Average, Poor)

Location Office

P. Government’s Ongoing Programs and Schemes

Name of the program/ scheme

Facilities Provided

Duration Number of Beneficiaries

Contact Person

Performance

(Good, Average, Poor)


Port Qasim, Karachi


O5SE1ENP: 03/05/15 7

Q. Crime and Security Conditions (Nature of crime and frequency over the last three years)

Nature of Crime Incidence in Last 5 Years

Robbery

Theft

Mobile Snatiching

Murder

Forgery/Fraud

Other

R. Socio-cultural Characteristics

1.1 Who are the tribal and spiritual leaders and how do they exert influence on the communities?

____________________________________________________________________________

____________________________________________________________________________

1.2 What are the main areas of conflicts? (water, agriculture, women, and livestock, etc.) ?

____________________________________________________________________________

____________________________________________________________________________

1.3 What are the traditional and judicial means of conflict resolution?

____________________________________________________________________________

____________________________________________________________________________

1.4 What is the status of mobility of women and children in the village and outside area?

1.5 Describe the roles and responsibilities of each gender (wood collection, jobs, water etc.)?

a. In society:

Men:

Women:

b. Within household:

Men:

Women:

1.6 Types of land and property rights regime?


Port Qasim, Karachi


O5SE1ENP: 03/05/15 8

Govt Land Pvt Land Non-surveyed land Communal Land

Other (Specify)

1.7 Ultimate authority to settle land disputes?

1.8 Describe the family structure (nuclear, joint, extended)?

1.9 Describe fishing in the study area, especially associated with the project intake and outfall locations?


Port Qasim, Karachi

Hagler Bailly Pakistan Settlement Questionnaire For Women

O5SE2ENP: 03/05/15 1

Settlement Questionnaire For Women

A. Background Information

Name of Investigator(s) ________________________ Village Name ____________________

B. Respondent Information

Name(s) Role in Community/Occupation Contact Details

C. Women Occupational Profile

Occupation Share in employed population (%)

Description (type of occupation)

Government Service

Private Service

PQA Industry Employee

Fishing (Self Employed/Labor)

Overseas Employment

Other Wage Labor

Trade/Business

Art

Others ___________

D. Marginalized Groups

Group Number of Explanation/Remarks

Mentally/physically challenged people

Widow

Religious minorities


Port Qasim, Karachi


O5SE2ENP: 03/05/15 2

E. Health

a. Health Facilities in village



Distance (km)

When established

Remarks

Lady Health Visitor (LHV)

Immunization (e.g. polio drops)

Trained Midwife

Untrained Midwife

b. Health

State the number of members who are suffering or have suffered from the following during the last one year

Common Diseases

( ) Men

( )

Women

( )

Adult-Children (6 to 14)

( )

Children (0 to 5)

( )

Tuberculosis

Diarrhea

Breathing problems

Jaundice

Skin diseases

Cold and flu

Stomach diseases

Joint aches

Tetanus

Paralysis

Diabetes

Cancer

Heart problems

Other (specify)


Port Qasim, Karachi


O5SE2ENP: 03/05/15 3

F. Socio-cultural Characteristics

1.1 What are the main areas of conflicts? (water, agriculture, women, and livestock, etc.)?

____________________________________________________________________________

____________________________________________________________________________

1.2 What are the traditional and judicial means of conflict resolution?

____________________________________________________________________________

____________________________________________________________________________

1.3 What is the status of mobility of women and children in the village and outside area?

1.4 Describe the roles and responsibilities of each gender (wood collection, jobs, water etc.)?

a. In society:

Men:

Women:

b. Within household:

Men:

Women:

1.5 Describe the family structure (nuclear, joint, extended)?



Hagler Bailly Pakistan Appendix D R5A05ENP: 09/29/15 D-1

Appendix D: Record of Stakeholder Consultations

D.1 Community Consultations





Environmental Impact Assessment of 225 MW RLNG CCPP Port Qasim Authority, Karachi

Engro Powergen Limited

Record of the Consultation Meeting

Stakeholder: Gulshan-e-Hadeed (Men)

Date: Mar 13, 2015

Time: 11:00 am

Meeting Venue: Office of Mr Dhani Bakhsh

Attended by: Esa Bhutto (EB) Haji Amir Muhammad (HM) Dhani Baksh (DB) Hussain Baksh (HB) Khadim Mirani (KM) Muhammad Musa Korai (MK) Muhammad Ibrahim (MI) Muhammad Shaukat (MS) Muhammad Adil (MA)

Conducted by: Muhammad Salman Ahmed, Public Consultation Consultant, HBP Salman Mukhdoom, Engro Powergen

Recorded by: Muhammad Salman Ahmed, Public Consultation Consultant, HBP

Language: Urdu

Preamble: The discussion started with the introduction of public consultation team members. Mr Ahmed briefed about the purpose of the meeting by using the Background Information Document (BID) for the Project and gave a comprehensive description of the proposed project and its related activities. Copies of the BID translated in Urdu were circulated among the participants. At the end of the informative session, Mr Ahmed invited the participants to share their comments and concerns, which have been documented below. The community was assured that their concerns would be communicated to the Project proponent for their consideration and action. Where possible, the response was given from the Project BID.




No. Issues Raised By Response Provided

1. What would be the impacts on the air quality? What are the precautionary measures you plan to take to mitigate or minimize these impacts?

DB The thermal power plant will use Re-Gasified Liquefied Natural Gas (RLNG) as fuel for power generation. The RLNG is considered to be a much cleaner fuel for power generation as compared to furnace oil and coal based power generation technologies. In addition to this, General Electric LM6000 PF Sprint gas turbines will be employed at the power with emissions falling well within SEQS for ambient air.

2. Would there be any employment opportunities for Gulshan-e-Hadeed inhabitants?

DB Concern noted.

3. Due to the Pakland cement operation, air quality has been ruined. Measures should be taken to mitigate or minimize the negative impacts of the Project activities.

KM Concern noted.

4. In the existing Port Qasim industries, employment opportunities are given to the outsiders. The company should provide employment opportunities to the local unemployed people.

MI Concern noted.

5. Unemployment is very common in the area. Engro neither hired people from the area nor provided any benefit to the Gulshan-e-Hadeed inhabitants.

MI Concern noted.

6. Industries give authority to contractors to hire laborers. Contractors mismanage the hiring and often hire non-locals for employment. This practice should be discouraged and the contractors should be made accountable for their actions.

DB Concern noted.







Stakeholder: Gulshan-e-Hadeed (Women)

Date: Mar 13, 2015

Time: 11:00 am

Meeting Venue: Government Primary School, Ghulshan-e-Hadeed

Attended by: Naila Parveen (NP)

Conducted by: Ms Fatima , Public Consultation Consultant, HBP

Recorded by: Ms Fatima, Public Consultation Consultant, HBP

Language: Urdu

Preamble: The discussion started with the introduction of public consultation consultant. Ms Fatima briefed about the purpose of the meeting by using the Background Information Document (BID) for the Project and gave a comprehensive description of the proposed Project and its related activities. A copy of the BID translated in Urdu was provided to Ms Parveen. At the end of the informative session, Ms Fatima invited Ms Parveen to share her comments and concerns, which have been documented below. Ms Parveen was assured that her concerns would be communicated to the Project proponent for their consideration and action. Where possible, the response was given from the Project BID.


1. The inhabitants of Gulshan-e-Hadeed should be given first preference in terms of employment.

NP Concern noted.

2. Training and vocational institutes for women should be established to help enable them to earn decent livelihood alongside men.

NP Concern noted.







Stakeholder: Shah Nawaz Goth (Men)

Date: Mar 14, 2015

Time: 11:00 am

Meeting Venue: Residence of Abdul Ghani

Attended by: Maqbool Ahmed Abro (MA) Abdul Ghani (AG) Zulfiqar Ali (ZA) Mir Maqsood Ahmed (MM)



Language: Urdu

Preamble: The discussion started with the introduction of public consultation team members. Mr Ahmed briefed about the purpose of the meeting by using the Background Information Document (BID) for the Project and gave a comprehensive description of the proposed project and its related activities. Copies of the BID translated in Urdu were circulated among the participants. At the end of the informative session, Mr Ahmed invited the participants to share their comments and concerns, which have been documented below. The community was assured that their concerns would be communicated to the Project proponent for their consideration and action. Where possible, the response was given from the Project BID.


1. There are so many educated people in the village and deserve technical jobs in the proposed Engro Powergen Project.

MA Concern noted.

2. In many projects at PQ, the Project proponent states that project will provide job opportunities to local people but never happened. The locals are hopeless that in the proposed Engro Powergen Project they will get employment or any other facility.

ZA Concern noted.

3. Employment opportunities are given to people from the Punjab and other areas. The company should provide employment opportunities to the local unemployed people.

ZA Concern noted.





4. Contractors, who hire people for industries are outsiders and they prefer the people for jobs from there areas. Contractor system for employment of community members in the industries should be abolished and employment should be made in the industries directly or contractor should be hired from the local area.

MA Concern noted.

5. There should be a vocational or technical training center, which should provide trainings to the local communities/inhabitants to enable them to work effectively.

ZA Concern noted.







Stakeholder: Shah Nawaz Goth (Women)

Date: Mar 14, 2015

Time: 11:00 am

Meeting Venue: Primary School, Shah Nawaz Goth

Attended by: Sobia (SB) Nusrat (NS)

Conducted by: Ms Fatima, Public Consultation Consultant, HBP

Recorded by: Ms Fatima, Public Consultation Consultant, HBP

Language: Urdu

Preamble: The discussion started with the introduction of public consultation consultant. Ms Fatima briefed the participants about the purpose of the meeting by using the Background Information Document (BID) for the Project and gave a comprehensive description of the proposed project and its related activities. Copies of the BID translated in Urdu were circulated among the participants. At the end of the informative session, Ms Fatima invited the participants to share their comments and concerns, which have been documented below. The participants were assured that her concerns would be communicated to the Project proponent for their consideration and action. Where possible, the response was given from the Project BID.


1. Employment is desired by the inhabitants of the community.

NS Concern noted.

2. Women want to work and learn skills that can be used to generate livelihood.

SB Concern noted.

Other Comments

1. The women did not show any reservations regarding the proposed Engro Powergen Project and hoped it would improve the socioeconomic conditions in the area by generating employment.







Stakeholder: Pakistan Steel Mills (PSM) Township (Men)

Date: Mar 16, 2015

Time: 11:30 am

Meeting Venue: Office of Mr Tariq Masood, Estate agent at PSM township

Attended by: Tariq Masood (TQ)



Language: Urdu

Preamble: The discussion started with the introduction of public consultation team members. Mr Ahmed briefed about the purpose of the meeting by using the Background Information Document (BID) for the Project and gave a comprehensive description of the proposed project and its related activities. A copy of the BID was provided to Mr Masood. At the end of the informative session, Mr Ahmed invited Mr Masood to share his comments and concerns, which have been documented below. Mr Masood was assured that his concerns would be communicated to the Project proponent for their consideration and action. Where possible, the response was given from the Project BID.

Other Comments

1. No issue/concern was raised by Mr Maqsood.







Stakeholder: Amin Muhammad Baloch (Men)

Date: Mar 13, 2015

Time: 09:30 am

Meeting Venue: Muhammad Yousuf Baloch residence

Attended by: Dildar Ahmed (DA)

Ghulam Hussain (GH)

Muhammad Yousuf Baloch (MB)

Conducted by: Hussain Ali, Public Consultation Consultant, HBP

Waris Ali, Public Consultation Assistant, HBP Sateesh Shah, Engro Powergen

Recorded by: Hussain Ali, Public Consultation Consultant, HBP

Language: Urdu/Sindhi

Preamble: The discussion started with the introduction of public consultation team members. Mr Ali briefed the purpose of the meeting by using the Background Information Document for the Project (BID) and gave a comprehensive description of how the project is to be implemented and related activities. Copies of the BID translated in Urdu were circulated among the participants. At the end of the informative session, Mr Ali invited the participants to share their comments and concerns, which have been documented below. The community was assured that their concerns would be communicated to the Project proponent for their consideration and action. Where possible, the response was given from the Project BID.


3. Our land was acquired by Bhutto’s government and adequate compensation was not paid to us. Our land related legal cases are still pending in the courts.

GH Land acquisition for Port Qasim area is not in the jurisdiction of Engro Powergen.

4. We were settled where Port Qasim is established today. We were re-located and promised jobs, water, electricity and gas. No facilities have been provided to us by the government.

GH Concern noted.

5. We had a functional school in our village which was taken over by Pakistan Navy. Our students do not go to that school anymore because no teachers are available.

MB Concern noted.





6. A waste stream released from Fauji Fertilizer Plant passes along the school. This attracts many insects and triggers different diseases among us and our children.

DA Concern noted.

7. Unemployment is a serious issue in our village. Many people work as daily wage labor and permanent jobs are not provided to us.

DA Concern noted.

8. There are no health facilities available to us and we have to travel far off distances in case of a medical emergency.

DA Concern noted.




Environmental and Social Impact Assessment of LNG Power Plant at Port Qasim Area

Engro Powergen


Stakeholder: Amin Muhammad Baloch (Women)

Date: Mar 13, 2015

Time: 09:30 am

Meeting Venue: Muhammad Yousuf Baloch residence

Attended by:

Conducted by: Fatema Shabbir, Public Consultation Consultant, HBP

Recorded by: Fatema Shabbir, Public Consultation Consultant, HBP

Language: Sindhi

Preamble: The discussion started with introduction by the public consultation consultant from Hagler Bailly Pakistan (HBP). A briefing was given to the participants about the purpose of the meeting along with a comprehensive description of the project. The main points of the background information document (BID) were verbally explained in Urdu and Sindhi. At the end of the informative session, the consultant invited the participants to express or share their concerns. The issues raised are discussed below, along with responses given by concerned persons.


1. One of the major issue that we face is availability of gas. Collection of wood and cooking on wood is very difficult and it will be a major convenience if gas is made available.

Concern noted.

2. Our children do not get quality education. We have a local school but no teachers come here to teach so we cannot send our children to schools. We need funding to hire a teacher at our school.

Concern noted.

3. Wind powered water bore was provided to us by the government but it failed due to high winds. No one repaired it and our men have to travel far distances to fetch water.

Concern noted.





Engro Powergen


Stakeholder: Muhammad Qasim (Men)

Date: Mar 13, 2015

Time: 11:00 am

Meeting Venue: Local restaurant

Attended by: Daad Muhammad (DM)

Rab Nawaz (RN)

Talal Baloch (TB)

Haji Muhammad (HM)

Mir Khan Baloch (MB)







1. We need water supplies and medical facilities in our village. This is the basic requirement of healthy living and we do not have both. Poor water quality leads to many people getting sick in our village.

MB Concern noted.

2. We are ready to provide land free of cost for schools and hospitals in our village.

MB Suggestion noted.





3. Port Qasim authorities and Pakistan Navy has occupied our lands and restricted our access to our own lands. Adequate compensation was not provided to us and their intrusion results in lack of privacy in our own village.

TB Compensation for land acquisition is not in the jurisdiction of Engo Powergen.

4. Over the years many journalists and political parties have claimed to represent us to the Port Qasim authorities and other industrialists operating in Port Qasim area. Those politicians have consumed the funds allocated for us and no development work has ever been carried out. We want proper representation in front of high authorities so that funds allocated for us can be spent in our village towards development activities.

HM Concern noted.

5. Engro should hire local people in their new plant. Whenever we go to these power plants for jobs, we are turned away when we tell them we are locals. Such discriminatory attitude should end and preference should be given to locals.

RN Concern noted.





Engro Powergen


Stakeholder: Muhammad Qasim (Women)

Date: Mar 13, 2015

Time: 11:00 am

Meeting Venue: Daad Muhammad residence

Attended by:






1. The biggest problem that women face in this village is the availability of clean drinking water. We face severe health problems due to poor quality of water.

Concern noted.

2. We do not have gas supply in our village for cooking. We use local wood for such purposes which is a major inconvenience.

Concern noted.

3. We prefer to work and help our families with money but the men of our houses do not allow us to work or go out of the houses.

Concern noted.





Engro Powergen


Stakeholder: Haji Ibrahim (Men)

Date: Mar 13, 2015

Time: 02:00 pm

Meeting Venue: Ali Akber’s shop

Attended by: Abdul Ghani (AG)

Ali Akber (AA)

Mohammad Siddiq (MS)

Mohammad Aslam (MA)

Yar Muhammad Baloch (YB)

Shahid (SA)

Saleem Muhammad (SM)







1. We encourage such projects because we will get jobs and our village will be further developed.

AG Noted.

2. Such projects will bring in immense social benefits for our people given that the funding allocated for us is spent on our village.

AG Noted.

3. Plant is at a considerable distance from our village and we will not be majorly affected in terms of air quality and water quality.

AG Noted.





4. We were relocated when land was acquired for development of Port Qasim area. The distribution of relief funds after that was unfair and some villages got more benefit than others.

SM Land acquisition for Port Qasim area is not under the jurisdiction of Engro Powergen.

5. Three main issues of this village in the order of priority are unemployment, clean water and health facilities.

YB Concern noted.

6. Some NGOs are working to provide relief but they have concentrated their efforts on the villages which are located on the other side of the railway track because they have better representation on the institutional level. Facilities provided there include water filter plant, schools and health facilities. Villages on this side should also get some relief.

AG Concern noted.





Engro Powergen


Stakeholder: Haji Ibrahim (Women)

Date: Mar 13, 2015

Time: 02:00 pm

Meeting venue: Abdul Ghani residence

Attended by:



Language: Sindhi/Urdu



1. Our land was acquired by Port Qasim authorities and adequate compensation was not paid to us.

Land acquisition for Port Qasim area is not under the jurisdiction of Engro Powergen.

2. We need provision of gas, health facilities and clean drinking water.

Concern noted.





Engro Powergen


Stakeholder: Mir Khan Baloch (Men)

Date: Mar 13, 2015

Time: 04:00 pm

Meeting Venue: Agriculture field

Attended by: Mohammad Ramazan (MR)

Mohammad Amin (MA)







1. The most important issue in our village is unemployment. We are not given job opportunities at industries in Port Qasim area. Very few people are employed there and that also on contractual basis. We need full time jobs.

MA Concern noted.

2. Medical facilities are too far from our village and in cases of emergencies we face many deaths due to travelling distances.

MR Concern noted.

3. Lack of educational facilities are ruining our next generation and we need good schools equipped with good teachers so that our next generation is not left deprived.

MR Concern noted.

4. The impact of emissions should be mitigated.

MR Concern noted.





Engro Powergen


Stakeholder: Mir Khan Baloch (Women)

Date: Mar 13, 2015

Time: 04:00 pm

Meeting venue: Muhammad Ramazan residence

Attended by:






1. Main issue that we face is the lack of education opportunities for our children. We want our children to study and excel in life.

Concern noted.

2. Source of livelihood is very unstable in our village because most of our men work as daily wage labor or on contractual basis. We need a permanent and stable source of income.

Concern noted.





Engro Powergen


Stakeholder: Haji Ghulam Muhammad (Men)

Date: Mar 14, 2015

Time: 10:00 am

Meeting Venue: Muhammad Sudheer residence

Attended by: Muhammad Sudheer (MS)

Saleem (SA)

Nuzeer Ahmed (NA)

Ashfaq Baloch (AB)







1. We have water connections from the government but water is only supplied to us once a week and that is also not enough to be supplied to the whole village.

MS Concern noted.

2. Lack of power supply leads to limited water in the village because water cannot be pumped without electricity.

NA Concern noted.

3. Unemployment is a major issue in the village. First priority should be given to the locals when recruiting for the new power plant.

NA Concern noted.





4. We have many cases of Hepatitis B and C in our village. Many people have died due to such health issues. These illnesses occur due to poor quality of water and lack of health facilities in our village.

AB Concern noted.





Engro Powergen


Stakeholder: Haji Ghulam Muhammad (Women)

Date: Mar 14, 2015

Time: 10:00 pm

Meeting venue: Muhammad Sudheer residence

Attended by:

Conducted by: Zainab Lotia, Public Consultation Consultant, HBP

Recorded by: Zainab Lotia, Public Consultation Consultant, HBP




1. Our lives are very dull with hardly any entertainment or basic facilities provided to us.

Concern noted.

2. Liver problems, Hepatitis B and C, and other health issues are very common in our village. We need proper health facilities and clean water supply system.

Concern noted.

3. Electricity issues are a major concern in out village.

Concern noted.

4. Our closest markets are based in Gagar Pathak which is far from our village. A local market will be useful where we can buy our daily required items.

Concern noted.





Engro Powergen


Stakeholder: Haji Jhangi Khan (Men)

Date: Mar 14, 2015

Time: 01:00 pm

Meeting Venue: Office of the Local Councilor

Attended by: Ali Ahmed (AA)

Abdul Wahid (AW)







1. We have a schools built by Human Development Foundation and Fauji Fertilizer. The girls only school is working fine but there are no teachers in the other school due to lack of funding.

AA Concern noted.

2. We have many health issues in our village such as Hepatitis B and C. We need vaccines and clean water to avoid further outbreaks of these diseases.

AA Concern noted.

3. Most of our men are unemployed or work as daily wage labor. We want permanent employment statuses at factories in Port Qasim area.

AW Concern noted.





4. We have educated people in our village willing to teach at the schools but we do not have funding to pay them salaries.

AW Concern noted.

5. We need an ambulance to transport patients to medical facilities in Gulshan e Hadeed in cases of emergencies.

AA Concern noted.





Engro Powergen


Stakeholder: Haji Jhangi Khan (Women)

Date: Mar 14, 2015

Time: 01:00 pm

Meeting venue: Ali Ahmed residence

Attended by:






1. We want our children to get educated and progress in life but schools here do not have any teachers and our next generation is suffering.

Concern noted.

2. We have many cases of Hepatitis B and C in our village. We need vaccination campaigns to get everyone vaccinated.

Concern noted.

3. We need some form of leisure or entertainment activity for women in our village. Currently the only time we go out of the village is to the shrine in Thatta or in Karachi (Abdullah Shah Ghazi).

Concern noted.





Engro Powergen


Stakeholder: Haji Khan Zohrani (Men)

Date: Mar 14, 2015

Time: 02:00 pm

Meeting Venue: Ghulam Qadir residence

Attended by: Imtiaz Ali (IA)

Ghulam Qadir (GQ)

Mumtaz Ali (MA)







1. We are promised jobs by survey teams but our needs are never attended to. When we go to factories for jobs, we are turned away once they know we are from the local area.

GQ Concern noted.

2. Many of our young are matric pass and do not have jobs. We should get technical jobs at the factories and should not be considered for jobs such as gate-keeper, peon etc.

GQ Concern noted.





3. We do not have health facilities in our village and our sick people have to be taken far off areas for medical treatment. The delay in medical help makes the condition of our patients critical and many of them die due to this.

MA Concern noted.





Engro Powergen


Stakeholder: Haji Khan Zohrani (Women)

Date: Mar 14, 2015

Time: 02:00 pm

Meeting venue: Ghulam Qadir residence

Attended by:






1. We face serious health problems due to smoke and waste streams generated from factories in Port Qasim area. Companies should provide health facilities for the treatment of illnesses that are triggered due to their waste.

Concern noted.

2. We do not have a school for girls to give them education at primary level. Only secondary level is available for girls.

Concern noted.

3. We do not have adequate clean drinking water available which leads to many health problems in our village.

Concern noted.

4. Safe delivery of babies is difficult due to non-availability of mid-wife in our village. Women have to be taken to other villages where medical facilities are available.

Concern noted.





5. We have locally developed skills such as embroidery and pillow making but we are not given an opportunity to develop small scale industry and sell our products. Our men do not allow us to work.

Concern noted.

6. We have serious problem of sewerage lines. Gutters overflow all the time in front of our houses and in streets leading to further health issues.

Concern noted.





Engro Powergen


Stakeholder: Humar Khan (Men)

Date: Mar 14, 2015

Time: 03:30 pm

Meeting Venue: Nawaz Ali Baloch residence

Attended by: Nawaz Ali Baloch (NB)

Muhammad Amin (MA)

Arshad Nawaz (AN)







1. The most serious issue of our village is availability of clean drinking water. We need at least 2-3 bores to supply water to all the houses in our village.

NB Concern noted.

2. We have unemployment issues in our village and we think this is due to limited education and lack of technical skills among our people. For this we need good education system in our village. We require schools properly equipped with teachers so that our children are not deprived of quality education.

NB Concern noted.





3. We are happy with Engro’s contribution in our village in terms of provision of jobs and other facilities. We need more funding to recruit teachers for our school.

NB Noted.

4. An industry-village liaison committee should be set up by selecting representatives from the local villages and industries. This committee should be responsible for implementing humanitarian efforts, ensuring jobs to locals and working on matters of mutual interest.

MA Suggestion noted.





Engro Powergen


Stakeholder: Humar Khan (Women)

Date: Mar 14, 2015

Time: 03:30 pm

Meeting venue: Nawaz Ali Baloch residence

Attended by:






1. We have many health issues in our village such as lung problems, breathing issues and Hepatitis B and C.

Concern noted.

2. We have skills and can make different products to be sold in the market but we are not given opportunities to develop such means of livelihood.

Concern noted.

3. We need provision of gas so that we are not dependent on wood for cooking purposes.

Concern noted.





Engro Powergen


Stakeholder: Pir Bux (Men)

Date: Mar 14, 2015

Time: 05:00 pm

Meeting Venue: Lal Khan residence

Attended by: Pir Buksh (PB)

Lal Khan (LK)

Ghulam Qadir (GQ)







1. We live far off from major settlements and are deprived of basic necessities of life such as electricity, water and gas.

LK Concern noted.

2. We were relocated by Port Qasim authorities and were promised jobs. However, we are not given opportunities to work at factories in Port Qasim area and have no other means of livelihood.

LK Concern noted.

3. Our children suffer from malnutrition and do not have food or clean water for consumption. We require job opportunities so that we can support our families.

LK Concern noted.





Engro Powergen


Stakeholder: Pir Bux (Women)

Date: Mar 14, 2015

Time: 05:00 pm

Meeting venue: Lal Khan residence

Attended by:






1. We are disconnected from the rest of the villages and basic necessities of life. We do not have electricity, gas, water, school, hospital or any other facility provided by the government.

Concern noted.

2. Many women face general health problems and complications during child birth. Due to absence of adequate facilities, ill people die in the village.

Concern noted.





Engro Powergen


Stakeholder: Soomar Jhokio (Men)

Date: Mar 16, 2015

Time: 09:00 am

Meeting Venue: Local Councillor office

Attended by: Abdul Buksh (AB)

Allah Buksh Hoath (AH)

Muhammad Baloch (MB)

Zahir Shah (ZA)

Hafeez Muhammad (HM)







1. Main issues in our village is the provision of basic facilities such as water, electricity and sewerage system.

AB Concern noted.

2. The villagers have pooled in money to build electricity infrastructure in the village but it is not provided by K-Electric and is illegal. We want installation of legal transmission lines and proper electric system in our village.

ZA Concern noted.





3. Only part of the village is connected with water supply system. The supply to those houses is very limited because water cannot be pumped due to lack of power supply. Other houses have to buy water tankers which is a very expensive option.

ZA Concern noted.

4. We do not have proper education facilities in our village which is ruining the future of our children. We can provide land for construction of a school. We need funding for construction and operation of school.

AH Concern noted.

5. Many people in the village are employed at factories in Port Qasim area and that is the only reason people are living in this village and bearing all the hardships.

AH Noted.

6. Bored water available in the village can only be used for domestic purposes and is not suitable for drinking. We want the government to supply us clean water so that we can live healthy lives.

AH Concern noted.





Engro Powergen


Stakeholder: Soomar Jhokio (Women)

Date: Mar 16, 2015

Time: 09:00 am

Meeting venue: Abdul Buksh residence

Attended by:






1. We do not have clean water supply system installed by the government. We have to order water tankers and that water is also not clean enough which leads to many illnesses such as Hepatitis B and C in our village.

Concern noted.

2. No gas is available in our village and we are dependent upon wood for cooking food.

Concern noted.

3. The closest hospital to our village is located in Gulshan e Hadeed which is far. Emergency cases become very critical while transporting them to the hospital. We want health facilities in our village.

Concern noted.





Engro Powergen


Stakeholder: Natho Tando Khoso (Men)

Date: Mar 16, 2015

Time: 10:30 am

Meeting Venue: Bashir Ahmed residence

Attended by: Bashir Ahmed(BA)

Dharo (DH)

Barkat Ali (BK)







1. We get wood from the forest and burn that for cooking purposes. We should be supplied with gas to address our needs. The Sui Gas pipeline is expected to pass from close to the village so gas provision to us should be a priority.

BA Concern noted.

2. We have instable means of livelihood and work as daily wage labor or on contractual basis. We need permanent jobs so that our livelihood is stable and guaranteed.

BK Concern noted.





3. Since the development of Port Qasim area, our environment has degraded significantly. Our air quality, water quality and sick people, everything has suffered due to pollutants released by factories in Port Qasim area.

BK Concern noted.

4. We do not have representation to the authorities and factory owners in Port Qasim area. We need a body which can represent us and fight for issues such as provision of jobs and basic facilities in our village.

DH Concern noted.





Engro Powergen


Stakeholder: Natho Tando Khoso (Women)

Date: Mar 16, 2015

Time: 10:30 am

Meeting venue: Bashir Ahmed residence

Attended by:






1. Since the development of Port Qasim area, the number of health related issues have increased significantly among locals. Issues such as Hepatitis B and C, paralysis and breathing problems are very common.

Concern noted.

2. We have serious sewerage problems in our village. Gutters overflow most of the time filling our streets with sewerage which leads to numerous diseases among us and our children.

Concern noted.

3. Some of our daughters are educated and willing to work but our men do not allow them to earn livelihood.

Concern noted.

4. Our young sons who have completed matric and intermediate education are unemployed and not given a chance at factories in Port Qasim area.

Concern noted.





Engro Powergen


Stakeholder: Morand Khan Qaisrani (Men)

Date: Mar 16, 2015

Time: 12:30 pm

Meeting Venue: Local school

Attended by: Muhammad Ibrahim (MI)

Char Kaka (CK)

Abdul Qadir (AQ)

Qaisrani Baloch (QB)

Mehdi Shah (MS)







1. We were promised jobs in Port Qasim area at the time of acquisition of this land. However, when we go to these factories, we are turned away the moment they come to know that we are locals. Such discriminatory attitude is not acceptable to us.

CK Concern noted.

2. We have school buildings in our village that some NGOs built us. We do not have funding to operate these schools and hire teachers. We try to pool in money at times and hire teachers on temporary basis.

AQ Concern noted.





3. Gas and water supply are basic necessities of life and we are deprived of both. Poor water quality results in numerous health relates issues among our population.

CK Concern noted.





Engro Powergen


Stakeholder: Morand Khan Qaisrani (Women)

Date: Mar 16, 2015

Time: 12:30 pm

Meeting venue: Muhammad Ibrahim residence

Attended by:






1. Our men have employment issues and most of them work as daily wage labor. We want more jobs of permanent status at factories in Port Qasim area for our men.

Concern noted.

2. Non availability of gas leads to inconvenience because we have to get wood from forest and then cook on burning wood.

Concern noted.

3. Many of us have infertility problems due to pollution from factories in Port Qasim area. We need health clinics in our village to address these issues.

Concern noted.




D.2 Industrial and Instituional Stakeholder Consultations

Engro Powergen Limited Environmental Impact Assessment of 225 MW RLNG CCPP



Stakeholder: Pakistan Steel Mills (PSM)



Engro Powergen Limited (EPL) – Project Proponent

Hagler Bailly Pakistan (HBP) – EIA Consultants

Date: March 18, 2015

Time: 10:30 am

Meeting Venue: Albatross Hall, Arabian Sea Golf and Country Club, Bin Qasim, Karachi

Attended by: Mohsin Ali Khan, In-charge CDB, PSM

M. Habibullah, Senior Engineer CDB, PSM

Dr. Parwaiz Khan, Chief Technical Operator, TSM

Munamul Haque, Head of Logistics, TSM

Athar Khwaja, Technical Manager, EPCL

Salman Makhdoom, Project Engineer, EPL

Sadia Malik, New Ventures Development, EPL

Conducted by: Zirgham Nabi Afridi (ZA), (HBP)

Recorded by: ZA, HBP

Language: Urdu, English

Preamble: The meeting started with an introduction by ZA regarding the purpose of the stakeholder consultation. The introduction included a brief description of the proposed project and related activities. The stakeholders were informed that this would not be the final consultation session and that they could approach the proponent and the EIA consultants any time during the EIA process. The stakeholders were also informed that separate consultations with the International Union for Conservation of Nature (IUCN) and World Wild Fund (WWF) would be conducted the next day. ZA then invited the participants to express and share their concerns. The issues raised are discussed below with the responses provided by the proponent and EIA consultants also included.





1. In general, we have no issues related to the development of the Project. I would just like to share a few friendly tips. If Route 2 for the proposed pipeline is to be used, keep in mind that Sui Southern Gas Corporation Limited (SSGCL) has a pipeline already running through there. EPL may also need to get permission from PQA for the Right-of-Way (ROW) of the proposed pipelines. From experience, I can tell you that the underground water quality in the area may not be suitable for the proposed plant’s use. Using water from the Gharo Creek will be a more practical alternative.

Athar Khwaja, Technical Manager, EPCL

ZA – Your feedback has been noted and it will be a part of the EIA consultation record that will also be shared with the proponent. The representatives of EPL have also heard you today.

2. We have no issues with the proposed Project. However, we have a few questions regarding the gas pipeline which will run from the Engro LNG Terminal at Port Qasim to the Custody Transfer Station (CTS) near the proposed Project-site. What will be the exact route? Will an existing network of gas pipelines be used or will a new pipeline be laid out? We are concerned that if existing pipelines are used, they may adversely impact the existing gas pressure which will affect our industrial processes. On the other hand, we are concerned that during the construction of a new pipeline from the LNG terminal to the CTS, the construction works may block the traffic going in and out of TSM. Trucks carrying iron-ore from the port to our plant is a vital plant process which may be adversely affected by the construction works.

Dr Parwaiz Khan, CTO, Tuwairqi Steel Mills

ZA – The details about the development of the pipeline from the port to the CTS are not within the ambit of the proposed 225 MW power plant. The development of that pipeline is the responsibility of Engro Elengy Terminal Limited (EETL). EETL may have already conducted or may be in the process of conducting relevant environmental impact studies which would take potential impacts from the construction of the pipeline into account. However, during the EIA of this 225 MW power plant, we will try to include any information available on the the proposed gas pipeline you have inquired about.







Stakeholder: International Union for the Conservation of Nature (IUCN)




Time: 11:00 am

Meeting Venue: 1 Bath Island, Clifton, Karachi

Attended by: Muhammad Tahir Qureshi (TQ), Senior Advisor Coastal, IUCN

Nadeem Mirkhas (NM), NRM Coordinator, IUCN

Salman Makhdoom (SM), Project Engineer, EPL

Sameer Zafar (SZ), Business Analyst, EPL

Conducted by: Zirgham Nabi Afridi, Manager Environmental Programs, Hagler Bailly Pakistan (HBP)

Recorded by: ZA, HBP

Language: English/Urdu

Preamble: The meeting started with an introduction by ZA regarding the purpose of the stakeholder consultation. The introduction included a brief description of the proposed project and related activities. The stakeholders were informed that this would not be the final consultation session and that they could approach the proponent and the EIA consultants any time during the EIA process. ZA then invited the participants to express and share their concerns. The issues raised are discussed below with the responses provided by the proponent and EIA consultants also included.


6. In the immediate north of the proposed Project-site there lies a green patch. This patch is host to a rich biodiversity. Hog Deers and Houbara Bustards have been spotted here. In vegetation, Commiphora Mukul are widely found here. This plant species is important for locals who live around the PQA area and visit this area for grazing. The gum extract from this plant has medicinal properties, it is an insect-repellent and has a very pleasant fragrance. We would like this and other such green patches in the PQA to be preserved.

TQ ZA – The proposed Project will be located on a barren piece of land with no vegetation on it. The construction of the proposed Project will be carried out within the boundary wall of the plot and the construction management plan will ensure that there is no construction or material-handling activity that spills outside the boundary wall of the plot. In this way, both the construction and operation phase of the Project will have no adverse impact on the green patch north of the boundary wall.

Regarding your recommendation on





EPL should, on its own, or in conjunction with the PQA, preserve this green patch north of its boundary wall.

the preservation of the green patch, the representatives from EPL have heard you. The recommendation will also be a part of the EIA consultation record in the EIA report.

7. It is mentioned in the Background Information Document (BID), that the rate of water intake by the proposed power plant will be 9,000 m3/h and one of the two proposed options for sourcing water is from a groundwater aquifer. If groundwater exists in PQA it will be in small interconnected pockets due to the rocky geology of the Port Qasim area. At the intake rate proposed for the Project, it will quickly dry out the entire network of underground aquifers in the PQA. Finishing the groundwater may damage the natural process which it may be supporting. For example, vegetation in the PQA may be dependent on the water in the aquifers through their roots extending into the shallow reaches of the groundwater. We would like to suggest that EPL should use water from the Gharo Creek instead.

NM ZA – At the moment EPL is getting water-boring and testing done at the site to see which option for the supply of water will be feasible. Your recommendation has been noted by the representatives from EPL here as well. The EIA report will consider the potential impacts of both options.

8. Regarding the outfall from the proposed Project, I would like to suggest to EPL that it should recycle all of its effluent rather than discharging it into the Gharo Creek. The recycled effluent can be used for watering green areas in the plant or for sprinkling over dust and other purposes. At the moment all of the industries in the vicinity of the proposed Project are discharging their effluent into the Gharo Creek. Anticipated projects in the region will also do the same. The Gharo Creek may be able to absorb the existing effluent pressure, however, with all the industries being planned here in the future, the Gharo Creek may become a dead creek in terms of biodiversity. In time, adjoining creeks may also suffer badly.

TQ ZA – The proposed Project is a natural gas-based power plant which has little to no chemicals present in its effluent discharge. The effluent will primarily consist of concentrated salt water from the cooling-water discharge. In addition, the effluent generated will comply with both the NEQS/SEQS and IFC standards for industrial effluents. Other than this, your suggestion has also been noted.





9. Have you considered the impact from noise from the operation of the plant?

TQ ZA – Noise levels from the plant will comply with the industrial limits prescribed by NEQS and IFC. In addition, there are no senstive receptors in the vicinity of the proposed Project-site which may be adversely impacted by noise from the Project.

10. I would like to make the following recommendations to EPL which I hope they will follow:

EPL should keep at least 5% of the built area in its plant reserved for greenery.

EPL should set aside some of its revenue from this plant to invest back into the ecosystem it will be using. The plant will be using the airshed to release emissions, it will be using Gharo Creek for intake and outfall. EPL should invest back into these ecosystem services from its revenues. At the time of starting operations, a study should be done to identify the ecosystem services being utilized and a mechanism should be developed for paying back to the environment.

NM ZA – Your recommendations have been noted by the representatives from EPL. These recommendations will also be a part of the EIA consultation record in the EIA report.







Stakeholder: World Wildlife Fund Pakistan (WWF)




Time: 2:00 pm

Meeting Venue: Bungalow 46/K, Block 6, P.E.C.H.S, Shahrah-e-Faisal, Karachi

Attended by: M. Moazzam Khan (MK), Technical Advisor (Marine Fisheries), WWF

Altaf Hussain (AH), Manager Conservation, WWF

Saeed ul Islam (SI), Coordinator Conservation, WWF

Umair Shahid (US), NIO Coordinator, WWF

Salman Makhdoom (SM), Project Engineer, EPL

Sameer Zafar (SZ), Business Analyst, EPL

Conducted by: Zirgham Nabi Afridi, Manager Environmental Programs, Hagler Bailly Pakistan (HBP)

Recorded by: ZA

Language: English/Urdu

Preamble: The meeting started with an introduction by ZA regarding the purpose of the stakeholder consultation. The introduction included a brief description of the proposed project and related activities. The stakeholders were informed that this would not be the final consultation session and that they could approach the proponent and the EIA consultants any time during the EIA process. ZA then invited the participants to express and share their concerns. The issues raised are discussed below with the responses provided by the proponent and EIA consultants also included.


1. The option of using groundwater for cooling water purposes will not be feasible. Utilizing groundwater at the rate of 9,000 m3/h may result in sinking parts of the PQA land which will damage existing infrastructure in the area. It will also increase sea water penetration into the PQA.

MK ZA – At the moment EPL is getting water-boring and testing done at the site to see whether using groundwater or water from Gharo Creek will be the suitable option for the supply of water. You point has been noted by the representatives from EPL here as well. The EIA report will consider the potential impacts of both options.





2. What will be the design of the cooling water system? Is it a once-through system? Will there be cooling towers installed? How will the Project be able to achieve the NEQS standards for temperature of the outfall?

MK ZA – At the moment, EPL is in the process of finalizing the design of the proposed Project. Once, finalized, the design will be described in detail in the Project Description section of the EIA report. Regardless of what mechanism is finally chosen, the plant will meet the NEQS, SEQS and IFC standards for effluent discharge.

3. The Background Information Document (BID) has not provided any information on the bio-physical environment around the Project-site. We would like to see this information as well.

AH ZA – The bio-physical and socioeconomic environment will be covered in detail during the EIA. The information collected will be a mix of primary and secondary data and it will be a part of the EIA report. The report will be a public document once it is shared with SEPA. And there will be a follow-up consultation as well where the draft impact assessment information will be shared with all the stakeholders in the process of finalizing the report.

4. We would also like that the EIA report provide some information on the anticipated developments around the Project-site in the PQA.

AH ZA – Information regarding anticipated projects in the area will be provided in the EIA report.

5. We would like to recommend that EPL also considers conducting a cumulative impact assessment study keeping in mind the anticipated developments in the area.

MK ZA – Cumulative impact studies are usually conducted by government bodies or together by a group of developers. It is individually conducted by a single developer if the scale of their impacts contributing to the cumulative impacts is very high. In this case, the proposed Project is a natural gas-based power plant which is considered to be a very clean fuel. The EIA report will provide a comparison between the water consumption, emissions and effluents rate between natural gas based plants and other such as coal-fired plants.



Hagler Bailly Pakistan Appendix E R5A05ENP: 09/29/15 E-1

Appendix E: Background Information Document


Hagler Bailly Pakistan 1

D5BD2ENP: 09/29/15

September 2015

Background Information Document for Environmental Impact Assessment of the Enhanced Capacity

of RLNG CCPP from 225 MW to 450 MW

Introduction and Background

Engro Powergen Limited (EPL) planned to develop a 225 megawatt (MW) re-gasified liquefied natural gas (RLNG) combined-cycle power plant (CCPP) at Port Qasim, Karachi. EPL commissioned an Environmental Impact Assessment (EIA) study to assess the likely environmental and socioeconomic impacts that may result from the development activities of the proposed power plant and to mitigate any potential negative impacts. The EIA process and the report will meet national regulations, the regulatory requirements of the Government of Sindh, and the regulatory requirements of the International Finance Corporation (IFC).

As an integral part of the EIA study, consultations were held with the Project’s stakeholders: persons or groups who are affected by or can affect the outcome of the Project. The findings of the consultation process were incorporated in the draft EIA report compiled for the power plant.

In the course of the feasibility study, EPL decided to enhance the capacity of the proposed power plant to 450 MW from 225 MW. This has resulted in changes in the fuel input, emissions, and water consumption. EPL wishes to communicate the change in the design of the proposed RLNG CCPP with its stakeholders and share the findings of the draft EIA of the 450 MW RLNG CCPP in order to record any concerns of the stakeholders regarding the proposed changes in the project.

This Background Information Document (BID) contains the updated information on the proposed RLNG CCPP, key potential impacts associated with 450 MW CCPP and provides mitigation measures to minimize the adverse impacts of the construction and operation of the power plant.

Specifications of the Proposed RLNG CCPP

The Project is located, approximately, 45 kilometers (km) southeast of the city of Karachi, at the same location where the initially designed 225 MW RLNG CCPP was located. The geographical coordinates of the Project-site are 67° 22' 41.185" E, 24° 47' 28.324" N.

Engro Zarkhez (EZ) and Engro Polymer and Chemicals Limited (EPCL) are located to the west and immediately adjacent to the Project-site. Lotte Chemicals Pakistan (LCP) is located, approximately, 500 m to the east.

A custody transfer station (CTS), built by Engro Elengy Terminal Ltd (EETL), will be located outside the southwest corner of the EPCL facility. The CTS is the point where incoming flow of natural gas from EETL to the Project-site will be metered. Natural gas will be transported from the CTS to the Project-site via an


D5BD2ENP: 09/29/15

underground pipeline which will traverse along either outside the southern boundary wall of the existing EPCL and EZ complex or outside the western and northern boundary wall of the same complex.

The supply of water for the Project will be met by extracting water from the Gharo Creek located to the south of the Project. A water-intake channel will be built through empty plots of land extending approximately 600 m from the southern end of the Project-site and ending at the Gharo Creek.

Effluent streams made up of discharge from the cooling-water process and the RO treatment plant will be discharged into the Gharo Creek. All effluent discharged into the creek will be compliant with both the Sindh Environmental Quality Standards (SEQS) and IFC standards for industrial effluents discharged into the sea.

Effluent being discharged into the Gharo Creek will be carried by either a surface or an underground outfall channel extending south from the Project-site to the creek.

RLNG used by the Project is expected to have a low heating value of 1,050 British thermal units per standard cubic feet (btu/scf) and its composition, in terms of molecular percentage, will be as follows:

Nitrogen –1.5 %

Methane –85.6 %

Ethane –7.8 %

Propone –2.9 %

Butane –1.9 %

Pentane –0.3%

Hydrogen Sulfide, as an impurity in the natural gas, is expected to be 5 milligram per normal cubic meter (mg/Nm3)

Gas-fired plants generally produce negligible quantities of particulate matter (PM) and sulfur oxides (SOx), and levels of nitrogen oxides are about 60% of those from plants using coal (without emission reduction measures). Natural gas-fired plants also release lower quantities of carbon dioxide, a greenhouse gas.1

The Proposed plant is estimated to be constructed within 26-28 months from financial close.

The Exhibit 1 provides the specifications the Project components in comparison with the initial design of the RLNG CCPP. The Project setting and location are provided on a map in Exhibit 2, whereas Exhibit 3 provides the layout of the proposed Project.

1 International Finance Corporation. Environmental, Health, and Safety Guidelines for Thermal Power

Plants. World Bank Group, 2008.


D5BD2ENP: 09/29/15

Exhibit 1: Comparison of 225 MW and 450 MW RLNG CCPP Specifications

Project Component Design Specifications of 225 MW RLNG CCPP

Design Specifications of 450 MW RLNG CCPP

Project location (see Exhibit 2)

Pre-owned Engro Corporation land in PQA eastern industrial zone

Same as of 225 MW

Project area 37 acres (15 hectares) Same as of 225 MW

Gas turbine General Electric (GE) LM6000–PF Sprint with net output of 47.5 MW, or

GE LM6000–PF+ Aeroderivative with net output of 54 MW

GE Frame 6F.03 with net output of 51 MW

Siemens SGT-800 with net output of 47 MW

Siemens SGT-2000E with net output of 166 MW

GE 9F.05 (~299 MW)

Plant factor 92% 92%

Fuel source RLNG RLNG

Fuel Requirement 30 MMSCFD2 60 MMSCFD

Cooling water source Groundwater/sea water Sea water

Cooling Water Supply System (recirculating)3

Water intake 738 m3/hr 1,071 m3/hr

Makeup water 300 m3/hr 670 m3/hr

Potable water requirements

15 m3/hr 11 m3/hr

Emissions

NO2 (mg/Nm3) 51 41

CO (mg/Nm3) 31 99

Brine and Effluent Discharge

Brine Discharge (m3/hr)

384 670

Effluent discharge (m3/hr)

13 56.6

2 Million standard cubic feet per day 3 For 225 MW RLNG CCPP both once through and recirculating water cooling system options were

considered. However, due to substantial water requirement difference between once through and recirculating systems, the recirculating water system was finalized due to its less water requirements for the finalized design of the 450 MW RLNG CCPP


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Exhibit 2: Project Location and Setting


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Exhibit 3: Layout of the Proposed Project


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Key Identified Environmental and Social Issues

The comprehensive baseline studies of the area where potential impact associated with the proposed CCPP are likely to extend and evaluation and assessment of the change in the design of the RLNG CCPP, helped identifying key environmental and social issues associated with the 450 MW RLNG CCPP. The identified issues and proposed mitigation measures are provided below.

Ecological Issues:

The Project-site is located in the PQA industrial estate which is on the northwestern edge of the Indus delta system covering an area of about 600,000 hectares and is characterized by 16 major creeks and innumerable minor creeks, dominated by mud flats, and fringing mangroves. These creeks are home to a considerable population of fish, shrimp and crabs.

Benthic and Pelagic fish communities including Swimming Crabs and Juvenile Shrimps, Artisian Crabs, marine invertebrates like Fiddler Crabs, Pinnotherid Crabs and Mud Skippers and couple of species of turtles are found in the Gharo Creek located to the south of the Project-site.

The brine and industrial water from the power plant operations will be discharged into the Gharo Creek. These effluents will have salinity levels higher than the ambient sea level salinity of the Gharo Creek. Therefore, there is a risk that these effluents will result in degradation of existing sea water quality resulting in deterioration of marine ecological resources of the Creek.

Plume modeling, carried out to identify and assess the impact of effluent discharge, helped determining that the salinity of the brine will dilute to the ambient sea level salinity at an approximate distance of 50 m from the discharge point. Therefore, the impact zone is confined to less than 1 hectare from the discharge point. This shows that impact of the effluent discharge will not be spread over a wide area. To ensure that the impact from the brine and industrial waste discharge remain within the identified impact zone, periodic monitoring will be carried out to record the salinity of the brine discharge.

Air Quality Issues

The Project-site is located in the PQA, with no sensitive receptors including settlements, schools, hospitals and mosques in the vicinity. The Project is surrounded by industries of the PQA eastern industrial zones.

To establish the air quality baseline, sampling was carried out at two location; one to the immediate northeast of the proposed Project site and second at distance of 5 km to the east of the Project site. The sampling results were compared with the secondary data available for the air quality baselines recorded during the previous studies conducted by HBP in the PQA area. On the basis of the above, average concentration of the pollutants around the Project-site was determined which is provided in Exhibit 4.


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Exhibit 4: Average Concentration of Pollutants around the Project Site

SO2

(μg/m3) NO2

(μg/m3) NO (μg/m3) TSP

(μg/m3) PM10

(μg/m3) PM2.5

(μg/m3) CO

(mg/m3) O3 (μg/m3)

14.0 9.6 15.6 271.0 113.5 24.0 1.3 6.5

As the power plant will utilize natural gas as the main fuel source, NO2 and CO are the only two pollutants which will be emitted during the operation of RLNG CCPP. To predict the concentration of these pollutants, dispersion modelling was carried out. Results of the dispersion modeling along the Sindh Environmental Quality Standards for ambient air and International Finance Corporation’s (IFC) Environmental Health and Safety Guidelines for emissions from thermal power plants to determine compliance with these standards is provided in Exhibit 5.

Exhibit 5: Air Quality Modeling Results

Pollutant Averaging Time

Background Concentration

(µg/m³)


Concentration for worst scenario

(µg/m³)

Predicted Ambient


IFC EHS Guidelines

SEQS

NO2 (µg/m³)

24–hr (Max) 28.80 11.37 40.17 – –


8.24 37.04 – 80

Annual (Max)

2.99 31.79 40 40

CO (mg/m3)

8–hr (Max) 2.30 0.04 2.34 – –


0.03

2.33 – 5

1–hr (Max) 0.08 2.38 – 10

Note: “–“indicates that no limit has been prescribed for the given pollutant or the concentration for the given

averaging period for the particular pollutant is not available

Since, even in a very conservative scenario, the increment in concentration of pollutants in ambient air is very low as compared to the limits prescribed in SEQS and IFC EHS guidelines; therefore, no specific mitigation measures are required.

For more information on the EIA contact

Hidayat Hasan Hagler Bailly Pakistan 39, Street 3, E-7, Islamabad Tel: +92 51 261 0200 Fax: +92 51 261 0208 Email: [email protected]

mailto:[email protected]



Hagler Bailly Pakistan Appendix F

R5A05ENP: 09/29/15 F-1

Appendix F: AERMOD Description

F.1 AERMOD Modeling System

AERMOD provides predicted pollutant concentrations for hourly, daily, monthly, and

yearly averaging periods, and complies with the USEPA’s guidelines on air quality

models. The model also accounts for varying wind speeds and directions (sectors), and

has the ability to model seasonal or monthly variations in emissions characteristics. It is

capable of taking into account building downwash, meteorological, and surface data in its

calculations. While AERMOD does not have the built-in capacity to directly process this

data, it is provided with three stand-alone pre-processors to do so: BPIPPRM for building

downwash, AERMET for meteorological data, and AERMAP to calculate surface

characteristics. These pre-processors are discussed below;

F.1.1 AERMET

AERMET requires the user to input hourly surface observation data and twice-daily

upper air sounding data. Site-specific data can also be input, but is not required. The

program uses this data to develop the necessary boundary layer parameters for dispersion

calculation by AERMOD.

F.1.2 AERMAP

The AERMAP pre-processor processes terrain data and prepares a grid of receptors to be

used in the AERMOD program. Elevation and hill height of the receptors from the output

file of AERMAP are used in the AERMOD input file.

F.1.3 BPIPPRM

The building profile input program for PRIME algorithm (BPIPPRM) requires the user to

input the physical characteristics (height, length, width) of buildings and stacks in the

modeled area. The program then determines the emission plume disturbance due to

building downwash.



Hagler Bailly Pakistan Appendix G R5A05ENP: 09/29/15 G-1

Appendix G: Sensitivity Analysis

Scenario 1

Para5meter Units Base case

Case 1 Case 2 Case 3 Case 4 Case 5 Case 6 Case 7 Case 8

Load factor % 100 100 100 90 90 90 80 80 80

Ta1 Tb

2 Tc3 Ta Tb Tc Ta Tb Tc

Temperature K 379.20 389.81 368.60 379.20 389.81 368.60 379.20 389.81 368.60

Flow Rate Nm3/s 515.56 515.56 515.56 464.01 464.01 464.01 412.45 412.45 412.45

m3/s 715.73 735.75 695.71 644.16 662.17 626.14 572.58 588.60 556.57

Stack diameter m 6.75 6.75 6.75 6.75 6.75 6.75 6.75 6.75 6.75

Stack height m 40.00 40.00 40.00 40.00 40.00 40.00 40.00 40.00 40.00

NO2 emission rate

g/s 21.16 21.16 21.16 19.05 19.05 19.05 16.93 16.93 16.93

Exit velocity m/s 20.00 20.56 19.44 18.00 18.50 17.50 16.00 16.45 15.55

NO2 concentration (Annual-max)

µg/m3 2.99 2.62 3.44 3.01 2.66 3.46 3.05 2.70 3.51

NO2 concentration

(24 hour-98th percentile)

µg/m3 8.36 7.66 9.13 8.13 7.53 8.55 7.80 7.38 8.46

1 Ta indicates original temperature of HRSG given by EPL 2 Tb indicates 10 % increase in original temperature of HRSG 3 Tc indicates 10 % decrease in original temperature of HRSG



Hagler Bailly Pakistan Appendix G R5A05ENP: 09/29/15 G-2

24-hour Incremental Concentration of NO2 at Load Factors 80 %, 90 % and 100 %

Annual Incremental Concentration of NO2 at Load Factors 80 %, 90 % and 100 %

7.00

7.50

8.00

8.50

9.00

9.50

10.00

80% 90% 100%

NO

2 C

on

ce

ntr

ati

on

(µ

g/m

3)

Load Factor

10% decrease in original temperature

Original Temperature

10% increase in original temperature

2.00

2.20

2.40

2.60

2.80

3.00

3.20

3.40

3.60

3.80

4.00

80% 90% 100%

NO

2 C

on

ce

ntr

ati

on

(µ

g/m

3)

Load Factor

10% decrease in original temperature

Original Temperature

10% increase in original temperature