Natural Gas Access Improvement Project (Drilling of 4 New Wells (Well Nos.23-26) and Installation of 2 Nos

Natural Gas Infrastructure and Efficiency Improvement Project (RRP BAN 38164)

Initial Environmental Examination

Document Stage: Updated Project Number: P38164 (BAN) September 2013

BAN: Natural Gas Access Improvement Project (Drilling of 4 New Wells (Well Nos.23-26) and Installation of 2 Nos. Process Plants at Titas Gas Field)

Prepared by Bangladesh Gas Fields Company Limited for the Asian Development Bank.

Executive Summary 5 Abbreviation 12 Glossary 13

Chapter - 1 Need for the Project 15

1.1Project Background 1.2 Objective of the Project 1.3 Objective of IEE 1.4 Scope of Work 1.5 Methodology 1.6 The IEE Team 1.7 Limitations

Chapter - 2 Policy and Legal Considerations 22

2.1 Introduction 2.2 Relevant National Policies and Legislation 2.2.1 National Conservation Strategy (NCS) 1992 2.2.2Industrial Policy(1999) 2.2.3National Water Policy (1999) 2.2.4Energy Policy (1995) 2.2.5 Renewable Energy Policy 2.2.6 Petroleum Policy (1993) 2.2.7 Petroleum Act (1974) 2.2.8 Environmental Policy (1992) 2.2.9 Environmental Conservation Act (1995; Amended in 2000 and 2002) 2.2.10Bangladesh Environmental Conservation Act (Amended in 2000) 2.2.11 Bangladesh Environmental Conservation Act (Amended in 2002) 2.2.12 Environmental Conservation Rules (1997) 2.2.13 Mineral Gas Safety Rules 1991( Amendment 2003) 2.1.14 The Penal Code (1860) 2.2.15 Acquisition and Requisition of immovable Property Ordinance (1982) 2.3 Compliance with ADB’s Safeguard Policy Statement 2.4 Compliance with DoE, EIA Guidelines 2.5 Compliance with International Requirements 2.5.1 Rio Declaration 2.5.2 Conservation on Biological Diversity, Rio de Janeiro, (1992) 2.5.3 Others

Chapter – 3 Project Description 30

3.1 Present Status 3.2 Project Location 3.3 Process Description (Glycol Dehydration)

3.4 Basic Data 3.5 Project Components and Phases

Chapter - 4 Baseline Existing Environment 36

4.1 Physical Environment 4.1.1 Introduction 4.1.2 Study Area 4.1.3 Topography 4.1.4 Climate and Rain water 4.1.4.1 Temperature and Humidity 4.1.4.2 Air quality 4.1.4.3 Ambient Noise 4.1.4.4 General Soil type 4.1.4.5 Soil Fertility 4.1.4.6 Land use 4.1.5 Geology and Hydrogeology 4.1.6 Surface Water 4.1.7 Ground Water 4.1.8 Seismicity 4.1.9 River system 4.1.10 Agro-Ecological Zones 4.2 Biological Environment 4.2.1 Introduction 4.2.2 Terrestrial Habitat 4.2.3 Wetland habitat 4.2.4 Fisheries 4.2.5 Endangered and Threatened Species 4.3 Socio-economic Profile of The Project Area 4.3.1 General

Chapter - 5 Public Consultation 44

5.1 Introduction 5.2 Methodology 5.3 Key Findings from Public Consultations 5.3 Expectations of the People 5.5 Public Consultation Results

Chapter - 6 Identification of Potential Environmental Impacts and 48 Mitigation Measures

6.1 Environmental Impacts 6.1.1 General 6.1.2 Identification of Impacts 6.1.3 Anticipated Environmental Impacts and Mitigation Measures 6.1.4 Socio-economic Impact 6.1.5 Disaster Management 6.1.6 Summary 6.2 Environmental Management Plan 6.2.1 General 3

6.2.2Institutional Responsibility 6.2.3 Environmental Monitoring Plan 6.2.4 Safety and Hazard Mitigation Plan for worker and Community 6.2.5 Emergency Response Plan

Chapter - 7 Grievance Redress Mechanism 59

7.1 General 7.2 Grievance Redress Mechanism 7.3 Communication Mechanism to Stakeholder 7.4 Meeting of Grievance Redress Committee 7.5 Closing of Grievance

Chapter - 8 Conclusions and Recommendation 62

8.1 General 8.2 Conclusions 8.3 Recommendation

Annex - 1 Photographs Annex - 2 REA Checklist Annex - 3 Parameters for Environmental Monitoring Annex - 4 Maps and Diagrams Annex - 5 Terrestrial and Wetland Habitat Annex - 6 List of Participants in the Consultation Meeting Annex - 7 No Objection Certificate

EXECUTIVE SUMMARY

General

Bangladesh Gas Fields Company Limited(BGFCL) has intended to Drill of 4 new wells (23- 26) and installation of 2 numbers of process plants at Titas Gas Field. These project components categorized as ‘category B’ for environment as per ADB guidelines and ‘red catagory’ as per Department of Environment, Bangladesh’s categorization. For implementation of the said project, an IEE is required for B category project as per requirement of ADB’s Safeguard Policy Statement (2009). Drilling and Installation of Process Plants and its operation, in general, have temporary environmental impact compared to that of the other industrial projects. Among other, identification of potential impacts of the project activities, both during construction and operational stages, on the various environmental components with the mitigation measures. An environment management plan is proposed to indicate management action on the implementation of mitigation measures. This may be achieved through use of best management practices as well as mitigation procedures and controls which will have minimum adverse impacts on the environment. Objective of the IEE This main objective of the IEE is to conduct preliminary examination of the environmental consequences of the project area, assess potential environmental impacts due to project related activities on the surrounding environment and suggest mitigation measures by consultation with the project affected persons. The objective is also to identify the key environmental resources of the project area and an assessment of the impacts, which might result from the drilling of wells, civil construction work and installation and operation of the gas processing plant of the project. Scope of the IEE The scope of the IEE includes: (i) a review of the policies and guidelines of ADB and the Government of Bangladesh relevant to environmental safeguards and compliances; (ii) an examination of the salient biophysical and socioeconomic conditions of the project area; (iii) an identification of the relevant environmental parameters in the project area through scoping, survey and literature review; (iv) an assessment of the magnitude of the potential impacts of the project actions; (v) identification of mitigation measures and monitoring requirements during implementation; and (vi) description of consultation and disclosure requirements.

Project Component BGFCL has planned to carry out drilling of 4 more new wells at Titas Gas Field has been under Long-Term Gas Production Plan. On the above circumstance, drilling of 2 new appraisal-cum development wells (Titas-23 and 24) and installation of 1(one) gas process plant has been planned at the southern part of Sarail upazila which is located 3 km north from Location-D of Titas Gas Field and other 2 wells (well no.Titas-25 and 26) and installation of 1 (one) gas process plant which is at northern part of Sadar upazila is located 2 km west from Location-D of Titas Gas Field. By drilling of the proposed wells, gas 5

production would not only be increased but also this will enable better sketch of the structure and pay zones of the field. It is expected that an additional quantity of approximately 30MMSCFD (Million Standard Cubic Feet per Day) gas will be produced from each well and an amount of 30 barrel/day as condensate will be produced from each well. Methodology The period of preparing the IEE was from June to September 2013, and field visits for data collection were done in April 2012. The task of preparing the IEE report consisted of the following sequential components: (i) Familiarization with and review of various project actions of the BGFCL projects; (ii) Identification and screening of the environmental parameters relevant to the proposed project actions in the project area through a scoping process; (iii) Assessment of the categorization of the project componants based on magnitude of the potential negative impacts for relevant environmental parameters through the use of rapid environmental assessment(REA) checklists. Formulation of avoidance/ mitigation measures to address the potential negative impacts, and preparation of an environmental management plan(EMP) during the period of project implementation; (iv) Outlining a set of recommendations/ suggestions for institutional strengthening of the BGFCL to develop its in-house capability in environmental assessment tasks, especially issues of implementation, monitoring and compliances of EMP. Baseline Information In order to establish a comprehensive database on the Biophysical baseline conditions existing around the project area, the study team has compiled the required data in relevant chapter. This includes information on parameter such as surface and ground water, air quality, metrology, soils, noise and terrestrial and aquatic ecosystem. Key features of the existing biophysical environment are described below:  The region is characterized by average 2200 mm/year partially in the month of June to October;  The major sources of air pollution in the project area are road dust, motor vehicles, construction dust, wind blown dust from agricultural lands, biomass burning, brick kilns, etc.;  The major habitats present within project area are cultivated land, homestead, vegetation, road side plantation and other vegetation, ponds, wetlands, etc.;  Most of the study is comprised of agricultural land, wetlands for fisheries;  Main crops grown in the study area are Aman and high yielding varities of rice(e.g.Irri paddy) in the main two seasons of the year. Besides these potatoes, vegetables, maize, wheat, mustard, etc. are also cultivated in the project area. Fruits like mango, jack fruit, lemon, and water melon are cultivated in the project area;  The major employment activity in the project area is agricultural production with wage laborers;  The dominant religion in the area is Islam, with some areas of Hindu and a very few numbers of Christian and Buddhist communities; 6

 Except for the Sylhet-Chittagong and Dhaka- Sylhet highways passing by the side of the Titas field the majority of the roads in the area are unpaved.

Anticipated Major Environmental Impacts, Proposed Mitigation Measures Greenhouse Gases The project has the potential to contribute some greenhouse gases to the atmosphere through two avenues:

 Emission of CO2 and NO2 from combustion of petroleum product by project staff, vehicles and generators etc.

 Indirect emission of CO2 through the consumption of natural gas powered electricity.

Mitigation measures will be implemented to reduce the potential impacts to appropriate level. These include:  Regular weekly maintenance of project vehicles to reduce vehicular emissions.  Reducing travel distance and fuel consumption where possible.  Generator use should be kept to a minimum.

Surface Water and Groundwater Potential impacts on local surface water and groundwater quality may arise in different phases of the project, which include impacts from the field camps for construction crews, potential discharges of waste in the local area. Selected mitigation measures for improving impacts on surface and groundwater in and around the study area include:  Drilling fluids, effluents and discharges are to be properly treated before disposal.  Ground water will be used for potable purposes by the construction crew, drilling crew and process plant installation personnel will be tested to ensure that it meets the minimum environmental standards of Bangladesh for safe drinking water.  Containment of sanitary waste should be adequately disposed of to avoid surface and ground water contamination. This sanitary waste will be passed through a septic tank and at last to a soak pit.  There are no components to be evolved that may degrade or contaminate the surface or ground water quality during the installation of the process plants. Most of the Installation works of the process plant welding and these are to be executed during dry season.  During the operation of the process plants the liquid waste i.e. the oily water must be treated by using the effluent treatment plant (ETP) and the treated water will be discharged to the environment.

Soil The main potential impacts on soils expected as part of the project will arise from erosion and sedimentation. Erosion and sedimentation are likely to occur during land developments, trenching activities and when discharging water under sedimentation purposes etc. During trenching top soil shall be segregated from the other soil and shall be put on the top during re-instatement works. Waste

Waste will be generated during well drilling of the wells and it will be one of the most significant potential environmental impacts of the project. The improper disposal of waste has the potential to cause environmental harm though contamination of the surface and groundwater, soils, atmosphere etc. The following indicative mitigation measure will be followed for the management of waste throughout the project:  All the drilling waste shall be carried out and disposed off appropriately at the designated place.  Sanitary waste shall not discharge on or near to any waterway or body of water. This sanitary waste will be passed through a septic tank and at last to a soak pit.  Machinery vehicle maintenance is to be carried out at a designated place.  All effluents are to be properly treated before disposal.  Standard effluent treatment plants are to be procured and built in the process plant area to treat the water during the operation of the process plants.

Noise The construction and drilling of gas wells generates the most noise.Impacts of noise on the local area will be different throughout the different parts of the project implementation time. High intensity of sound could be generated by equipment and machines used for drilling rigs, excavating earth, generation of electricity and welding pipes for long periods of time which may disturb and potentially damage to nearby human population and wildlife. The following mitigation measures are to be taken.  All operations are to be performed at day time as far as practicable.  Selection of low noise plant and equipments.  The noise from the generator can be controlled by housing the unit.  All generators and equipment must be maintained periodically.  A muffler in good working order shall have to be attached to the engine to reduce the level of noise so emitted.  The drilling crew must use the ear plug to protect from the noise during the working hours. Biodiversity Many features of the ecosystem within the respective project areas have been discussed in detail in this instance. Such issues include i) effects of project activities on terrestrial and aquatic ecosystems including species diversity ii) impact of noise and vibration on biodiversity and wildlife. It is recognized that the activities within the project area have the potential impact upon the flora and fauna of the area. As such a number of specific mitigation measures are suggested in order to reduce the potential impact upon the biodiversity of flora and fauna to appropriate levels. These include:  The level of noise made by crews during the work shall be kept to a minimum.  The use of vehicle horns to be avoided whist near colonies of birds and other wildlife.  Recycling of waste water for the protection of biodiversity and wildlife.

Agriculture land and crops 8

When clearing the rig bases, process plant locations and requisitioned areas for the movement of equipment, vehicles etc. and execution of the project, the crops may be damaged. This crop damage shall be properly compensated as per GOB rules, guidelines and the resettlement policy of ADB. Elected representatives from local communities should be allowed to join the committee to ensure justice and transparency during payment of compensation to land and crops damage. Socio-economic Impact The positive socio-economic impacts include availability of less expensive and cleaner burning fuel, temporary employment for the local population and expansion of potential business and industry. The highlights of land use procedure for the construction of well side installations and process plant facilities has been presented in this report. Consultation with Stakeholder Consultation with parties and persons interested in or affected by project activities, forms a critical part of best practice project planning and environmental impact assessment. Early and participative engagement of stakeholders in the project planning phase increases the likelihood of approval by regulatory authorities and the smooth implementation of project activities. Community participation and meaningful public consultation in the event of exigencies has to be encouraged and ensured. Further, formation of strategic alliance with local administrations, health centers, and fire brigades should be helpful. Environmental Management Plan An Environmental Management Plan (EMP) is proposed for this project. This EMP is designed as a practical guide to the implementation of the environment and social mitigation measures in the relevant chapter. It is intended to set out the finer details of what is required "in the field" including the "what, who, how, when and what cost" factors associated with these measures. This EMP will also form the primary mechanism for management, accountability and report on the project's social and environmental performance. It will be a fully integrated and live document which will detail how any potential impact will be managed. The EMP has addressed the following areas with assessment of risks and hazards particularly with reference to those involved in emergency responses applied for drilling of wells and installation activities of the process plant involved in the project:  Damage minimization  Biodiversity management  Archaeological and cultural site management  Socio-economic impact management plan  Air quality management plan  Erosion and sedimentation control plan  Noise and vibration management plan  Waste management plan  Hazardous material management plan  Community health and safety hazards  Work place safety and risk assessment  Emergency response and disaster management plan  Shallow gas migration control at drilling site

 Safety check for drilling and blow out prevention  Spill Control and Collection and  Environment monitoring and reporting plan

Occupational Health and Safety Safety is an integral part of BGFCL operation. It is the part of the company's philosophy to protect employees, contractors, property, the environment and the public. By fulfilling safety responsibilities, employees will share the benefits of a safe work place. The company has its own safety management and mitigation plan and policy. It should be assessed to determine what personal protective and safety equipment is needed and the equipment must be available. A maintenance schedule must be developed for PPE and employees must be trained in fitting, care, maintenance and use of same.

Compliance The BGFCL will ensure that (i) the projects are designed, constructed, and operated in accordance with national environmental procedures and guidelines and with ADB s Environment Policy; (ii) the projects are designed, constructed, and operated in accordance with the EMPs as reflected in the IEEs and EARF; (iii) the environmental management and monitoring plan will be incorporated in bidding documents and civil work contracts and implemented; and (iv) environmental performance reports will be submitted to ADB twice annually during the construction period, including progress made on the mitigation measures, monitoring data, problems encountered, enforcement plan, and any violations.

Conclusion Well drilling and gas process plant construction and operation usually have a temporary environmental impact compared to that of the other industrial projects. The use of best engineering and management practices, mitigation procedures and control will contribute positively in such drilling of wells and the cited construction and operation to have minimum adverse impacts on the environment. The most important measure to achieve a good level of environmental acceptability of the project is adoption of best practices in design, construction and site route selection. Avoiding environmentally sensitive location should be an integral part of the process. Particular attention should be given to fair and equitable compensation for farmers and other individuals affected by land acquisition for the project.

The potential environmental impacts of the projects components covered by the IEE are insignificant, and temporary, which will mostly occur only during the operational stage. All the potential environmental impacts can be mitigated to an acceptable level by adequate implementation of the measures as stated in the EMP. In view of the above findings and the fact that BGFCL will maintain standard quality of implementation of the program with due consideration to standing rules and regulations, the project may be considered viable from the environmental points of view and therefore be considered for implementation by appropriate authority.

ABBREVIATION

ADB Asian Development Bank AER Agro-Ecological Region AQM Air Quality Management BBS Bangladesh Bureau of Statistics BCAS Bangladesh Centre for Advanced Studies BMD Bangladesh Meteorological Department BSCIC Bangladesh Small Cottage Industries Corporation BWDB Bangladesh Water Development Board CGS City Gate Station CSMC Construction Supervision and Monitoring Consultants DAE Department of Agricultural Extension DC Deputy Commissioner DOE Department of Environment DOF Department of Fisheries DTW Deep Tube Well ECA Ecologically Critical Area ECR Environment Conservation Rules 1997 EIA Environmental Impact Assessment EMP Environmental Management Plan EPZ Export Processing Zone GIS Geographic Information System GOB Government of Bangladesh GPS Global Positioning System GSTP Gas Sector Development Program BGFCL Bangladesh Gas Fields Company Limited IEC Important Environmental Component IEE Initial Environmental Examination IUCN International Union for Conservation of Nature and Natural Resources KII Key Information Interview LGED Local Government Engineering Department MMSCFD Million Standard Cubic Feet per Day MOEF Ministry of Environment and Forests NDT Non Destructive Testing NEMAP National Environment Management Action Plan NGO Non-Government Organization NWMP National Water Management Plan PAP Project Affected Person PCP Project Concept Paper SDC Study and Design Consultant SRDI Soil Resource Development Institute TBS Town Border Station TOR Terms of Reference UNDP United Nations Development Programme.

GLOSSARY

Adverse impact: An impact that is considered undesirable. Ambient air: Surrounding air. Aquatic: Growing or living in or near water. Bangla: Bengali language. Baseline (or existing) conditions: The ‘baseline’ essentially comprises the factual understanding and interpretation of existing environmental, social and health conditions of where the business activity is proposed. Understanding the baseline shall also include those trends present within it, and especially how changes could occur regardless of the presence of the project, i.e. the ‘No-development Option’. Bazar: Market. Beel: A ‘back swamp’ or depression.Can be either perennial or seasonal. Beneficial impacts: Impacts, which are considered to be desirable and useful. Biological diversity: The variety of life forms, the different plants, animals and micro organisms, genes they contain and the ecosystems they form. It is usually considered at three levels: genetic diversity, species diversity and ecological diversity. Char: Newly accreted land: Land, sometimes islands, within main river channels and nearby mainland or in the estuary, subject to erosion and accretion. Ecosystem: A dynamic complex of plant, animal, fungal and microorganism communities and associated non-living environment interacting as an ecological unit. Emission: The total amount of solid, liquid or gaseous pollutant emitted into the atmosphere from a given source within a given time, as indicated, for e.g., in grams per cubic meter of gas or by a relative measure, upon discharge from the source. Endangered species: Species in danger of extinction and whose survival is unlikely if the existing conditions continue to operate. Included among those are species whose numbers have been reduced to a critical level or whose habitats have been so drastically reduced that they are deemed to suffer from immediate danger of extinction. Environmental effects: The measurable changes, in the natural system of productivity and environmental quality, resulting from a development activity. Environmental impact assessment (EIA) / Environmental assessment: The systematic, reproducible and interdisciplinary identification, prediction and evaluation, mitigation and management of impacts from a proposed development and its reasonable alternatives, sometimes known as environmental assessment. Environmental Impact: An estimate or judgment of the significance and value of environmental effects for natural, socio-economic and human receptors. Environment Management Plan (EMP): A Plan to undertake an array of follow-up activities which provide for the sound environmental management of a project/ intervention so that adverse environmental impacts are minimized and mitigated; beneficial environmental effects are maximized; and sustainable development is ensured. Environmental Management: Managing the productive use of natural resources without reducing their productivity and quality. Erosion: Process in which wind and water removes materials from their original place; for instance, soil washed away from an agricultural field. Evaluation: The process of looking back at what has been really done or accomplished. Fauna: A collective term denoting the animals occurring in a particular region or period.

Field Reconnaissance: A field activity that confirms the information gathered through secondary sources. This field study is essentially a rapid appraisal. Flora: All of the plants found in a given area. Habitat: The natural home or environment for a plant or animal. Household: A household is identified as a dwelling unit where one or more persons live and eat together with common cooking arrangement. Persons living in the same dwelling unit having separate cooking arrangements constitute separate household. Important Environmental Component (IEC): These are environmental components of biophysical or socio-economic importance to one or more interested parties. The use of important environmental components helps to focus the environmental assessment. Initial Environmental Assessment / Evaluation: Preliminary analysis undertaken to ascertain whether there are sufficient likely significant adverse impacts to warrant a ‘full’ EIA. In some countries, use of initial assessment forms a meaning of “screening” proposed projects. Khal: Small Channel, canal. Land use: Types include agriculture, horticulture, settlement, pisciculture and industries. Mauza: A Bangla word for the smallest government administrative area corresponding to village revenue unit. Mitigation: An action, which may prevent or minimize adverse impacts and enhance beneficial impacts. Negative Impact: Negative change from the existing situation due to the project. Public involvement / Public consultation: A range of techniques that can be used to inform, consult or interact with stakeholders’ affected / to be affected by a proposal. Reversible impact: An environmental impact that recovers either through natural process or with human assistance (e.g. cutting off fish migration by an embankment might be reversible at a later stage if a proper regulator is built). Stakeholders: Those who may be potentially affected by a proposal, e.g. Local people, the proponent, government agencies, NGOs, donors and others, all parties who may be affected by the project or to take an interest in it. Taka: Unit of Bangladeshi currency. Terrestrial: Living on land. Thana: Sub-district level of government administration, comprising several unions under district. Union: Smallest unit of local self government comprising several villages. Upazila: Sub-district name. Upozila introduced in 1982. Zila: Bengali word of district.

Chapter -1

Need for the Project

1.1 Project background: Natural gas is a significant source of commercial and domestic energy in Bangladesh. The government emphasizes on the expansion of gas production capacity for augmenting power generation in the country for promoting extensive industrialization. Country's demand for natural gas is increasing day by day. Current energy policy and the development plans are focused to reduce import of petroleum products and thereby reduce the pressure on the foreign exchange through exploration, production and marketing of natural gas. Accordingly the main objective of the project is to sustain/increase the current production of natural gas from its existing gas fields i.e. Titas Gas Field. Thus a project has been taken named “Gas Seepage Control and Appraisal and Development of Titas Gas Field''. Of them Drilling of 4 new wells (23-26) and installation of two process plants at Titas Gas Field has been planned under the financial assistance of ADB named 'Natural Gas Access Improvement Project, Part-B: Safety and Supply Efficiency Improvement of Titas Gas Field' with a view to enhance the capacity for power generation as well as to meet the natural gas demand of Bangladesh. Bangladesh Gas Fields Company Limited (BGFCL), a company of Petrobangla, under the Ministry of Power, Energy and Mineral Resources of the Government of the Peoples’ Republic of Bangladesh has taken the project under the finance of ADB for: I. Drilling of 4 New Wells (Well Nos. 23-26) at Titas Gas Field; II. Installation of 2 (two) Process Plants (each capacity 75 MMCFD) at Titas Gas Field; and III. Other related civil works It is believed that, the integrated work program would go a long way to cope up with present gas demand and supply scenario and there by ensure more production of natural gas safely and uninterruptedly from this field.

1.2 Objective of the Project The main objective of the project is to establish a sustainable gas production capacity to meet the demand for natural gas of the country. In these regard BGFCL has taken up this project in consideration of the present situation and the future higher gas demand of the domestic, commercial and industrial consumers of the country.

1.3 Objective of IEE According to ADB's Environment Policy 2002, ADB's Environmental Assessment Guidelines 2003, Safeguard Policy Statement (2009) and OM on environmental safeguards the project falls under Category–B, which requires IEE for approval of loan. To obtain approval, this IEE report has been prepared in compliance with the requirements of ADB’s Safeguard Policy Statement (2009). This IEE report is prepared for (i) Drilling of 4 New Wells (23-26) and (ii) Installation of 2 Process Plants at Titas Gas Field. The main objectives of the IEE study are as follows: (i) To identify the major project activities;

(ii) To conduct preliminary examination of the environmental consequences of the project area; (iii) To assess potential environmental impacts due to project related activities on the surrounding environment and suggest appropriate mitigation measures; (iv) To consultation with the project affected persons of the study area to address grievance for proper compensation.

1.4 Scope of Work This IEE report identifies environmental impacts/issues and prepares an outline for mitigation measures of potential environmental impacts. Accordingly, the scope of the IEE report will address the following: - Project Description; - Baseline study; - Environmental and socio-economic impact identification and it’s residual impacts; - Suggestions of mitigation measures for adverse environmental impacts; - Outline of EMP and post project monitoring; and - Public consultation and grievance redress mechanism

Figure 1.1: Location Map Of BGFCL Gas fields

Figure 1.2: Location Map of Gas Fields With PSC Blocks

Figure 1.3: Project Area Showing Administrative Boundary

1.5 Methodology 19

The report is prepared on the basis of primary information collected from the concerned project areas and the basic data and information available in BGFCL. The period of preparing the IEE was from June to September 2013, and field visits for data collection were done in April 2012. The environmental team of BGFCL made their reconnaissance visits to project site and conceived a basic understanding of the project. They have also gathered information on baseline conditions and the public response on the project. Other environmental and socio- economic, agro-climatic and meteorological data etc. were collected from BBS, DOE and concerned authorities and other IEE reports as reference. The task of preparing the IEE report consisted of the following sequential components: (i) Familiarization with and review of various project actions of the BGFCL projects; (ii) Identification and screening of the environmental parameters relevant to the proposed project actions in the project area through a scoping process; (iii) Assessment of the categorization of the project components based on magnitude of the potential negative impacts for relevant environmental parameters through the use of rapid environmental assessment(REA) checklistsFormulation of avoidance/ mitigation measures to address the potential negative impacts, and preparation of an environmental management plan(EMP) during the period of project implementation; (iv) Outlining a set of recommendations/ suggestions for institutional strengthening of the BGFCL to develop its in-house capability in environmental assessment tasks, especially issues of implementation, monitoring and compliances of EMP.

1.6 The IEE Team Bangladesh Gas Fields Company Limited (BGFCL) has prepared this report under the guidance and supervision of Mr. Md. Ali Moktazer, Project Director (Gas Seepage Control and Drilling Project), Mr. Md. Abdul Malek, Deputy General Manager (Envir. and Safety), Mr. Shamsuddin Ahmed, Manager (Envir. Engr.), Mr. Mahfuzur Rahman Talukder, Project Geologist (Gas Seepage Control and Drilling Project) and Mr. Md .Shafikul Islam, Astt. Project Engineer (Gas Seepage Control and Drilling Project).

1.7 Limitations An IEE is generally carried out as an integral part of the Feasibility Study (FS) or together with it and before going into the final design phase and into the construction phase of a particular development project. If so then the findings of the EIA could be incorporated in the project design, overall planning and budget and that the project could be implemented accordingly.

Chapter -2

POLICY AND LEGAL CONSIDERATIONS

Policy and Legal Considerations

2.1 Introduction Development projects are governed by some legal and institutional requirements. So, assessment of relevant legal provisions, policies, strategies and institutional issues are very important for any project proponent or developer before they actually execute a program or plan. The proponent has to be well aware of these requirements and comply with the provisions as applicable and necessary. The following sections review the relevant national legislations and policies along with some international laws. Bangladesh Gas Fields Company Ltd.(BGFCL) will conduct its operations in compliance with local, national and international legislation. In other words, the proposed projects will be executed and operated in accordance with Bangladesh legislations and international agreements to which Bangladesh is a party.

2.2 Relevant National Policies and Legislation The pieces of policy and legislation which apply to such project execution program are described in the following sections.

2.2.1 National Conservation Strategy (NCS) 1992 National Conservation Strategy was drafted in late 1991 and submitted to the Government in early 1992. This was approved in principle; however the final approval of the document is yet to made by the cabinet. For sustainable development in the energy sector, the strategy document offered various recommendations but none was there concerning the present specific project execution program or related matter. For 'Energy and Minerals' sector, the relevant recommendations are : - To use minimum possible area of land in exploration sites; - Rehabilitate site when abandoned; - To take precautionary measures against Environmental Pollution from liquid effluent, condensate recovery and dehydration plants; and - Technology assessment for selection of appropriate technology.

2.2.2Industrial Policy (1999) The National Industrial Policy, 1999 aims to ensure a high rate of investment by the public and private sectors, a strong productive sector, direct foreign investment, development of labour intensive industries, introduction of new appropriate technology, women's participation. Development of small and cottage industries, entrepreneurship development, high growth of export, infrastructure development and environmentally sound industrial development. WTO guidelines have been proposed to be followed in the Industry Policy. Following the guidelines may result in conflicts with intellectual property rights. Guidelines for mitigating such possible conflicts are absent in the policy document. No specific guidelines are given for sustainable extraction and utilization of raw materials for different industries. One of the 17 objectives of the policy (Section 2.12; Chapter II) is "To ensure a process of industrialization which is environmentally sound and consistent with the resource endowment of the country". However, none of the 24 strategies of the policy relate to the environment.

2.2.3 National Water Policy (1999) The National Water Policy of 1999 was passed to ensure efficient and equitable management of water resources, proper harnessing and development of surface and ground water, availability of water to all concerned and institutional capacity building for water resource management. It has also addressed issues like river basin management, water rights and allocation, public and private investment, water supply and sanitation and water needs for agriculture, industry, fisheries, wildlife, navigation, recreation, environment, preservation of wetlands, etc. The water policy, however, fails to address issues like consequences of trans-boundary water disputes and watershed management.

2.2.4 Energy Policy (1995) The National Energy Policy provides for utilization of energy for sustainable economic growth, supply to different zones of the country, development of the indigenous energy sources and environmentally sounds sustainable energy development programs. The Policy highlights the importance of protecting the environment by requiring an EIA for any new energy development project, introduction of economically viable and environment friendly technology. Moreover, one of the seven objectives (Section 1.2) addresses the environment and states, "(vi) to ensure environmentally sound sustainable energy development Programs causing minimum damage to the environment". Seven specific policy recommendations are listed under Chapter 1.9 of energy policy. Of those, the following three are relevant to the present project: - Environmental impact assessment should be made mandatory and should constitute an integral part of any new energy development project. - Use of economically viable environment friendly technology is to be promoted; and - Public awareness is to be promoted regarding environmental conservation.

2.2.5 Renewable Energy Policy (2008) The Government has issued Renewable Energy Policy in 2008 major objective of the policy are; - Enable, encourage and facilitate both public and private sector investment in renewable projects; - Develop sustainable energy supplies to substitute indigenous non-renewable energy supplies; - Scale up contributions of renewable energy to electricity production; - Promote appropriate, efficient and environment friendly use of renewable energy; - Create enabling environment and legal support to encourage the use of renewable energy; - Promote clean energy 2.2.6 Petroleum Policy (1993) The Petroleum Policy has the primary objective of promoting, monitoring, and regulating all activities in the oil and gas sector in relation to exploration, development, refining, marketing and export. The Petroleum Policy mentions the need to "promote Environmental 23

Impact Assessment" in the oil and gas sector and to formulate various laws, rules and policies for fostering safety and environmental protection. The Petroleum Policy further states that private companies, in consultation with the Ministry of Power, Energy and Mineral Resources and Petrobangla, are to contribute towards improving the state of the environment in their area(s) of operation. The Petroleum Policy is now an integral part of the Energy Policy.

2.2.7 Petroleum Act (1974) The Bangladesh Petroleum Act is enabling legislation which allows the Bangladesh Government to enter into all aspects of petroleum exploration, development, exploitation, processing, refining and marketing. In addition, the Government is authorized to enter into Petroleum Agreement(s) with any person(s) for the purpose of petroleum operations. The duties of such person(s) are: - To ensure that petroleum operation is carried out in a proper and workman like manner and in accordance with good oil field practice. - To carry out petroleum operation in any area in a manner that does not interfere with navigation, fishing and conservation of resources. - To consider the factors connected with the ecology and environment. Clause 6(2) of the Act sets out certain details related to environment and safety: "In particular, and without prejudice to the generality of the foregoing provision, a person engaged in any petroleum operations shall, in carrying out such operations in any area: - Control the flow and prevent the waste or escape' in the area, of petroleum or water; - Prevent the escape in that area of any mixture of water or drilling fluid with petroleum or any other matter; - Prevent damage to petroleum-bearing strata in any area, whether adjacent to that area or not; and - Keep separate any petroleum pool discovered in the area."

2.2.8 Environmental Policy (1992) Bangladesh National Environmental Policy of 1992 sets out the basic framework for environmental action, together with a set of broad sectoral action guidelines. The Environment Policy provides the broader framework of sustainable development in the country. It also states that all major undertakings, which will have a bearing on the environment, (including setting up of an industrial establishment) must undertake an IEE/EIA before they initiate the project. Policies of fifteen sectors are described in the Policy. Under the Energy and Fuel sector, the use of fuel that has the least environmental impact is encouraged in Section 3.4.1. Conservation of fossil fuel is stressed in Section 3.4.5 and the need for conducting EIA's before implementation of projects for fuel and mineral resources is stressed in Section 3.4.6. Under the Environmental Action Plan Section of the Policy and sub-section 'Fuel and Energy', it is suggested that: - The use of gas, coal, kerosene and petrol as fuel will be expanded in the rural areas, so that fuel wood, agricultural residues, and cow dung is conserved. This will help the use of agricultural residues, and cow dung etc. as manure; and

- Appropriate measures will be taken to ensure that extraction; distribution and use of natural resources such as oil, gas, coal, peat etc. do not adversely affect air, water, land, the hydrological balance and the ecosystem. Section 3.7 "Forest, Wildlife and Biodiversity" requires: - Conserve Wildlife and Biodiversity, strengthen related research and help dissemination and exchange of knowledge in these areas; and - Conserve and develop wetlands and protection of migratory birds.

2.2.9 Environmental Conservation Act (1995, Amended in 2000 and 2002) The Bangladesh Environment Conservation Act of 1995 (ECA '95) is currently the main legislation in relation to environment protection in Bangladesh. This Act is promulgated for environment conservation, environmental standards development and environment pollution control and abatement. It has repealed the Environment Pollution Control Ordinance of 1977. Prior permission is required from DOE for extraction and production of mineral resources under this act. The main objectives of ECA '95 are: - Conservation and improvement of the environment; and - Control and mitigation of pollution of the environment. The main strategies of the Act can be summarized as: - Environmental Clearance; - Regulation of the industries and other development activities' discharge permits; - Promulgation of standards for quality of air, water, noise and soil for different areas for different purposes; - Promulgation of a standard limit for discharging and emitting waste; and - Formulation and declaration of environmental guidelines. Before any new project can go ahead, as stipulated under the rules, the project promoter must obtain Environmental Clearance from the Director General. An appeal procedure does exist for those promoters who fail to obtain clearance. Failure to comply with any part of this Act may result in punishment to a maximum of 3 years imprisonment or a maximum fine of Tk. 300,000 or both. The Department of Environment (DOE) executes the Act under the leadership of the Director General (DG).

2.2.10Bangladesh Environmental Conservation Act (Amendment 2000) This amendment of the Act focuses on: (1) ascertaining responsibility for Compensation in cases of damage to ecosystems, (2) increased provision of punitive measures both for fines and imprisonment and (3) fixing authority on cognizance of offences.

2.2.11Bangladesh Environmental Conservation Act (Amendment 2002) This amendment of the Act elaborates on: (1) restriction on polluting automobiles, (2) restriction on the sale and production of environmentally harmful items like polythene bags, (3) assistance from law enforcement agencies for environmental actions, (4) break up of punitive measures and (5) authority to try environmental cases.

2.2.12 Environmental Conservation Rules (1997)

These are the first set of rules, promulgated under the Environmental Conservation Act of 1995 (so far there have been three amendments to this set of rules - February and August 2002 and April 2003). The Environment Conservation Rules of 1997 has provided categorization of industries and projects and identified types of environmental assessments needed against respective categories of industries or projects. Among other things, these rules set (i) the National Environmental Quality Standards for ambient air, various types of water, industrial effluent, emission, noise, vehicular exhaust etc., (ii) the requirement for and procedures to obtain environmental clearance, and (iii) the requirement for IEE / EIA's according to categories of industrial and other development interventions. The Rules are not explicit for various oil and gas exploration interventions. Rather, this is covered under the broader heading of "exploration, extraction and distribution of mineral resources" under the Red Category Projects. The proposed project, according to the DOE, is considered under the Red category of the Environmental Conservation Rules, 1997 (Item 65: Exploration, extraction and distribution of mineral resources) [Page 3122 of the Bangladesh Gazette of 28 August 1997].

2.2.13 Mineral Gas Safety Rules 1991 (Amendment 2003) This document is derived mainly from the American Society of Mechanical Engineers (ASME), American National Standard Institute (ANSI) and British Standards (BS), codes and practices etc. and Petroleum Act, 1934. These Rules deal with the materials, design and construction of gas pipelines, pipeline crossings of railways, testing and commissioning, protection against corrosion, pipeline operation and maintenance, storage and distribution, and reporting of accidents. The Rules are quite prescriptive, and include stipulations as to the separation distances between pipelines and the public properties and thoroughfare. The provisions of the rules have been updated through amendment in 2003.

2.2.14 The Penal Code (1860) [Chapter XIV of offences affective Public health, safety, convenience, decency and morals] The Bangladesh Penal Code of 1860 has some valid provisions related to pollution management. Environment protection and protection of health and safety. Some of these are: Article 277: Falling Water or Public Spring or Reservoir; Article 278: Making Atmosphere Noxious to Health; Article 284: Negligent Conduct with Respect to Poisonous Substance; Article 285: Negligent Conduct with Respect to Fire or Combustible Matter; and Article 286: Negligent Conduct with Respect to Explosive Substance.

2.2.15 Acquisition and Requisition of Immovable Property Ordinance (1982) This Ordinance has replaced the Land Acquisition Act of 1894 and the East Bengal (Emergency) Requisition of Property Act of 1948. The Ordinance governs acquisition and requisition by the government of immovable property for any public purpose or in the public interest. It may be noted that contrary to the previous Acts (i.e. Act XIII of 1948), this Ordinance deals only with immovable property. The Ordinance has well-defined procedures regarding payment of compensation for an acquired piece of land. If, for example, the land is used for rice growing, then an amount

equivalent to approximately 1.5 times the market value of a given variety of rice (e.g., paddy) that is currently being (or could be) produced annually is fixed as a yearly lease value. In case of outright purchase (carried out on a 99-year lease), the compensation- value of acquired land varies widely according to the locality, soil fertility, and access to transportation and related infrastructure factors. The current compensation and resettlement provisions are however inadequate both in terms of timing of payments and quantum. The procedures involved are cumbersome and time consuming and often causes hindrance to the smooth execution of the project. Legal provisions covering adequate compensation to the project affected persons, particularly disadvantaged groups such as women and squatters and such other vulnerable groups are yet to be framed.

2.3 Compliance with ADB’s Safeguard Policy Statement ADB’s issued Safeguard Policy Statement (SPS) (2009) and Environment Policy(2002) addresses among others, the environmental parameters for oil and gas exploration and production projects involving IEE studies for B category projects. The project proponent in conducting an IEE shall consult and follow the SPS. The present study and the preparation of this report have taken due cognizance of these policy in order to remain consistent with regard to the structure and contents suggested in the policy.

2.4 Compliance with DOE EIA Guidelines The DOE published EIA Guidelines in 1997 and addresses the IEE and EIA for several industrial sectors and activities. Each Project Proponent shall conduct an IEE or EIA and is expected to consult and follow the DOE guidelines. Figure-2.1 shows the application procedure for obtaining site/environmental clearance.

APPLICATION TO DOE

GREEN AMBER A AMBER B RED

The application should enclose: The application should enclose: The application should enclose: The application should enclose: i. Feasibility Study Report (for proposed i. Feasibility Study Report (for proposed i. General information; i. General information; industry/project); industry/project); ii. Description of raw materials & ii. Description of raw materials & ii. Initial Environmental Examination ii. Initial Environmental Examination finished products finished products (IEE) (for proposed industry/project); (IEE) and Environmental Impact iii. An NOC iii. An NOC iii. Environmental Management Plan Assessment (EIA) report (for iv. Process flow diagram, layout plan, (EMP) Report (for existing proposed industry/project); effluent disposal system; etc. industry/project; iii. Environmental Management Plan iv. An NOC (EMP) Report (for existing v. Pollution minimisation plan; industry/project; vi. Outline or relocation plan; etc. iv. An NOC v. Pollution minimisation plan; vi. Outline or relocation plan; etc.

Obtaining Environmental Clearance Obtaining Site Clearance

Such a clearance will be subject to Applying for Environmental renewal after each three-year period Clearance Obtaining Site Clearance Obtaining Site Clearance

Applying for Environmental Applying for Environmental Obtaining Environmental Clearance Clearance Clearance

Such a clearance will be subject to Obtaining Environmental Obtaining Environmental renewal after each one-year period Clearance Clearance

Such a clearance will be subject to Such a clearance will be subject to renewal after each one-year period renewal after each one-year period

Figure-2.1:Steps Involved in Environmental Clearance following DOE Guidelines

2.5 Compliance with International Requirements Bangladesh has already had accessed to, ratified or signed a number of major international treaties, conventions and protocols related to environment protection and conservation of natural resources which shall have to be complied with during implementation of the project. The pertinent ones of these are highlighted below:

2.5.1 Rio Declaration The 1992 United Nations Conference on Environment and Development (UNCED) adopted the global action program for sustainable development called 'Rio Declaration' and `Agenda 21'. Principle 4 of the Rio Declaration, 1992, to which Bangladesh is a signatory along with a total of 178 countries, states, "In order to achieve sustainable development, environmental protection should constitute an integral part of the development process and cannot be considered in isolation from it".

2.5.2 Convention on Biological Diversity, Rio de Janeiro, (1992) The Convention on Biological Diversity, Rio de Janeiro, 1992-was adopted on 05 June 1992 and entered into force on 29 December, 1993. Bangladesh ratified the Convention on 20 March, 1994. The Contracting Parties of the Convention have committed to: - Introducing appropriate procedures requiring environmental impact assessments of its proposed projects that are likely to have significant adverse effects on biodiversity, with a view to avoiding or minimizing such effects, and where appropriate allow for public participation in such procedures; and

- Introducing appropriate arrangements to ensure that environmental consequences of its programmes and policies, that are likely to have significant adverse impacts on biodiversity, are duly taken into account. Obligation has been placed on State parties to provide for environmental impact assessments of projects that are likely to have significant adverse effects on biological diversity (art. 4).

2.5.3 Others The following conventions and agreements may include provisions relevant to different aspects of oil and gas operations for environmental management, nature protection, and biodiversity conservation: - Convention relative to the Preservation of Fauna and Flora in their Natural State 1933; - International Convention for the Protection of Birds, Paris, 1950; - International Plant Protection Convention, Rome. 1951;

Chapter -3

PROJECT DESCRIPTION

Project Description

3.1 Project Status Bangladesh Gas Fields Company Limited (BGFCL) has planned to carry out drilling of 4 new wells (Well nos. 23-26) and installation of 2 nos. process plants with associated facilities at Titas Gas Field to sustain/increase the current production of natural gas from its existing gas fields. Drilling of 4 more new wells at Titas Gas Field has been foreseen under Long-Term Gas Production and Transmission Plan of Ministry of Power, Energy and Mineral Resources (MoPEMR). On the above circumstance, drilling of 2 new appraisal-cum development wells (Titas-23 and 24) and installation of 1 process plant has been planned at the southern part of Sarail upazila which is located 3 km north from Location-D of the Titas Gas Field and other 2 wells (well no.Titas-25 and 26) and 1 process plant which is at northern part of Sadar upazila is located 2 km west from Location-D of the Titas Gas Field. By drilling of the proposed wells, gas production would not only be increased but also this will enable better delineation of the structure and pay zones of the field. It is expected that an additional quantity of approximately 30 MMSCFD gas will be produced from each well and an amount of 30 barrel/day as condensate will be generated from each well. Accordingly, all preparatory works including design, material procurement and planning of construction work will be in process. Physical interventions may be under taken as soon as possible. 3.2 Project Location BGFCL has planned to drill 2 new wells (Titas-23 and 24) and installation of 1 process plant at Sarail mauza of Sarail upazila under Brahmanbaria district. Other 2 new wells (Titas-25 and 26) and 1 process plant at the mauza Chhatian, Jangalisar, Malihata and Suhilpur of Sadarupazila under district Brahmanbaria. One new process plant with associated facilities will be required to Process Gas from proposed wells to be installed in each proposed locations. The location of the drilling of wells and process plants has been shown in the district map Figure 3.1.

Figure: 3.1 Project Location

3.3 Process Description (Glycol Dehydration) Before entering the natural gas to the absorption tower, wellhead gas with high temperature and pressure is passed through liquid knockout separator where maximum portion of liquid (water and condensate) are separated due to pressure as well as temperature drop. Dehydration of natural gas with glycol solutions is attractive because of the reliability of the operation, the simplicity of the equipment and the relatively low cost of chemicals (Tri-Ethylene Glycol) and utilities. ABSORPTION: In a typical dehydrator, dry lean glycol and wet gas are contacted counter currently within a tower with dry gas exiting from the top of the absorber, and water laden rich glycol coming out at the bottom. In a trayed glycol absorber, the lean glycol is cooled prior to injection on the top tray by heat exchange with the dry gas leaving the tower. Rising gas comes into intimate contact with the glycol absorber; it flows across the tray, through the bubble caps, which consist of inverted and is dispersed into the liquid by means of slots around the rim of the caps. As the gas flows from tray to tray while ascending through the column, it comes in contact with progressively drier glycol. Thus the wettest gas comes in contact with, and gives up water to the wettest glycol, and the driest gas at the top of the column contacts the driest glycol, permitting attainment of thedesired dew point and making the most efficient use of the water carrying ability of the glycol. Rich glycol, after picking up approximately 6% of its own weight in water, flows to the bottom of the tower where it accumulates to a depth of several inches on the chimney tray. After leaving the absorber, the rich glycol is partially preheated by hot lean glycol before flowing to the flash tank and filter. The glycol to glycol exchange occurs in two stages. After one stage of heating, the rich glycol at approximately 175°F., enters the flash tank where dissolved vapors are flashed off. In the flash, tank entrained droplets of hydrocarbon liquid rise to the surface of the liquid where they accumulate as a hydrocarbon layer which can be manually skimmed off through the 1" skim valve as necessary, (to be checked daily). The degassed warm glycol is then filtered to remove particulate matter. A side stream off the filtered glycol is diverted through a charcoal filter where trace amounts of hydrocarbon liquid are removed. 3.4 Basic Data The basic data of the project are furnished in Table 3.1 Table 3.1: Basic Data of the Titas Gas Field Project (Drilling of 4 New Wells and Installation of 2nos. of Process Plant with Associated Facilities) 1 Name of the Project . 'Natural Gas Access Improvement Project, Part-B: Safety and Supply Efficiency Improvement of Titas Gas Field' : “Gas Seepage Control and Appraisal and Development of Titas Gas Field'' 2 Project Executor . Bangladesh Gas Field Company Limited(BGFCL) 3 Project Location . Titas Gas Field (Southern part of Sarial Upazila and Northern part of Brahmanbaria Sadar Upazila under Brahmanbaria district.) 4 Land Requirement 15 acres 5 Final Product . Natural gas and associated condensate 33

6 Total Project cost . BDT 805crore

3.5 Project Components and Phases The major components of the projects are stipulated as below: 1. Pre-operation Phase 2. Operation Phase 3. Post-operation Phase These activities are classified under three distinct phases as described in the following sections.

Activity Potential Environmental Impact Pre-operational phase - Identification of location for drilling of wells - No impact and installation of process plants - Land acquisition - Loss of agricultural land (Details is provided in resettlement plan) - NOC from local authority - No impact - Clearance from DOE - No impact - Detail drawing and design - No impact - Possession of land from DC office - No impact Operational phase - Procurement of materials - No impact -Transportation of construction materials - Air, noise and water pollution - Temporary storage and stack yard - Disturb to local people, dust pollution, noise pollution - Construction of civil engineering structures - Disturb to local people, air, noise and including drill pad and process plants water pollution installation RCC structures - Fire Fighting - Disturb to local people, health and safety hazards - Equipment and vehicle movement - Noise and vibration - Drilling of wells - Noise and vibration, production of solid and liquid waste, water pollution - DST, production testing and commissioning - Noise and vibration and production of of wells liquid waste, water pollution - Construction of process plant - Noise and vibration - Testing and commissioning of process plant - Noise and vibration and production of and cleaning of work sites liquid waste Post-operational phase -Production of natural gas and condensate - Noise and production of waste water, water pollution

Chapter -4

BASELINE EXISTING ENVIRONMENT

Baseline Existing Environment

4.1 Physical Environment 4.1.1 Introduction Baseline data on environment is important to understand existing physical, biological, cultural, economic and social environmental characteristics. This information forms the basis to analyze the probable impacts of the project activities. Mainly there are two principal objectives in examining and defining the existing environment. - To recognize potential environmental impacts of the project and enable mitigation measures to be identified. - To provide a base line against which environmental conditions in the future project may be measured and to document conditions which were either existing or developing before the introduction of the project and not due to the project.

4.1.2 Study Area In this study, the project area of Titas gas field is comprised of Sarail and Sadar upazila under Brahmanbaria district. The total land of the proposed area would be 15.0 acre mostly the private agricultural lands and beels. 4.1.3 Topography Both the gas fields are mainly flat alluvial floodplain area surrounded by plains with somewhat steeper topography. Titas gas field is cut through by one large river Titas. Many minor water ways and canals drain the area. Figure 4.1(Annex - 4) shows the topographic map of Bangladesh including the project area. Titas is about 24 feet above Mean Sea Level (MSL). The area is vulnerable to river floods.

4.1.4 Climate and Rain water The project area is under the typical monsoon climate prevailing in the country. It has three main seasons: - Summer/pre-monsoon - March to May - Rainy season/monsoon - June to October - Winter – November to February

The summer is hot, humid and dry interrupted by occasional heavy rainfall. The rainy season is also hot and humid having about 90 percent of the annual rainfall. During this period the rivers and waterways flood major portions of the project area. The winter is predominantly cool and dry. The project area is marked on the average annual rainfall map of Bangladesh in Figure 4.2 (Annex- 4).

4.1.4.1 Temperature and Humidity Temperature in the project area varies between 40°c in April and May to 10°C in January with an average of 25°C which is close to the national average of 26°C.

In the project area, the relative humidity is the lowest in January to March (74%) and from April there is a steady increase till July (87%). The project area is marked on the average annual mean temperature map of Bangladesh in Figure 4.3(Annex- 4).

4.1.4.2 Air quality The DoE have regular air quality-monitoring program in Dhaka and major divisional cities for measuring ambient air quality or emissions. As a result there are no official air quality data for the project area. However air quality will not be a major environmental concern associated with Drilling, Process plant installations and subsequent production of natural gas. But local air quality would be impaired through improper facility operation and gas flaring activities. Improper gas flaring can be prevented through the implementation of standardized environmental operating procedure in gas fields operation.

4.1.4.3 Ambient Noise The Environmental quality standard for Bangladesh (DOE-1991) has set noise guidelines for industrial sites in Bangladesh. Noise level should not exceed 75 Decibels (dBa) in the daytime and 70 dBa at night. Facility operation should ensure that those noises do not exceed more than 50 meters from the facility. Hearing protection should be provided to workers where noise levels exceed 80 dBa. At present there is no base line data on noise in any of the gas process plants operating in the gas fields. So it is suggested that the Ambient Noise limits in 75 dBa should be established in and around each gas fields and its facilities and compared to that of its background.

4.1.4.4 General Soil type Food and Agricultural Organization (FAO) conducted a number of surveys in the sixties and developed a detailed soil classification of Bangladesh which is now used for various purposes. The FAO classification present a series of 20 soil group" Soil classes of Bangladesh. The numbers used for the soil tracts in the following test is corresponding to the numbers showing in the map (FAO-1988). The list given below shows 20 groups and is roughly self-explanatory. The geographical distribution is shown in the map [General Regional Land types by Alam et al,1990](Figure. 4.4 in Annex- 4). The seismic survey area falls in the soil tract group 4,6,7 and 15, comprises grey floodplain soil non-saline phase to grey floodplain soils and non calcareous dark Grey in Bakhrabad area where as in Titas area it is non calcareous dark gray flood plain soil to Red brown Terrace soils. Following is the Description of soil Tracts The soil Tracts 1. Black Terai soils. 2. Non calcareous brown Floodplain Soils (dominant) and Grey Floodplain Soils 3. Grey Floodplain Soils (dominant) and non Calcareous Brown Floodplain Soils 4. Grey Floodplain Soils, Non-saline Phase 5. Grey Floodplain soils, Saline Phase 6. Grey Floodplain Soils and non-calcareous Dark Grey 7. Non calcareous Dark Grey Floodplain Soils 8. Acid Basin Clays 9. Grey Floodplain Soils 10. Calcareous dark Grey Floodplain Soils and Calcareous Brown Floodplain Soils 11. Peat 12. Acid Sulphate Soils 37

13. Noncalcareous Alluviun 14. Calcareous Alluviun 15. Red-brown Terrace Soils 16. Grey Terrace Soils and Deep Red-Brown Terrace Soils 17. Grey Terrace Soils 18. Grey Piedmont Soils 19. Grey Piedmont Soils and Grey Floodplain Soils 20. Brown Hill Soils Source: Bangladesh Soil Resources, Soil Survey Project, Map 4, Technical Report 3, UNDPFAO.

4.1.4.4.1Soil Fertility Structured dark grey loamy soils on old flood plain ridges and clay in basins. The area is subjected to periodic flooding and sediment deposition, which adds fertility for crop production.

4.1.4.5 Land use The land is generally open and flat, dominated only by small village community. The land is predominantly used for agriculture. Most agricultural plots are less than one acre and on these plots farmers tend to grow one or two major and several other crops every year. Therefore, village farm land will show some. Varity of crops in any season, but most of the land will show the following predominant cropping pattern.

Summer - Aus rice Fall - Aman rice Winter - Boro rice, wheat (DRP-1992a) Besides betel nut, mango, banana and jack fruits are grown on the higher strips of land around villages and along roads and embankments. In the North East side of Titas gas field a Varity of additional crops are grown depending on elevation topography and soils. Numerous small flowering plants grow in the ditches and among the tree groves.

4.1.5 Geology and Hydrogeology The surface soil is alluvial clay topped with organic soil. Between the clay and gas bearing strata, the geology is mostly sandstone. The aquifer is from 100 feet to 400 feet thick, but the lower portion is unusable, due to high salinity.

4.1.6 Surface Water Surrounding the project area, the surface water is used for irrigation, drinking water for domestic animals, bathing, fish cultivation and possibly as potable water in some locations. It is know that increased industrialization, population, use of fertilizers and pesticides increases the exposure of surface water to contamination.

4.1.7 Ground Water The ground water table fluctuation indicates the recharge and discharge to the groundwater reservoir. The highest ground water occurs during the month of August-September when the aquifer recharges fully and the lowest ground water table occurs during April- May due to natural discharge and ground water use for domestic and irrigation purposes. 38

Like other part of the country, ground water is a stable source of water for various activities including irrigation, domestic purpose and industrial applications in the project area. The water table ranges from 250 feet below the surface at Titas.

4.1.8 Seismicity The seismotectonic map of Bangladesh shows the epicenter locations have conformity with the present knowledge of faulting and other structural behaviors of the region. Earthquake events in the shelf-zone are random and follow the occurrence of the surface faults. Bangladesh has been divided into three generalized seismic zones. Zone-1, Zone-II and Zone- III (Figure 4.5 in Annex - 4) on the basis of the distribution of earthquake epicenters and morphotectonic behavior of the different tectonic blocks. Zone-I comprising the northern and eastern region of Bangladesh is the most active zone with basic seismic co-efficient of 0.08. The project area under the zone-II represents the region of recent uplift Pleistocen.and blocks of the Barind and the western extension of the folded belt with moderate seismic co-efficient 0.05. Zone -III is seismically quiet zone with estimated basic seismic co-efficient of 0.04. 4.1.9 River system The rivers that lie within the vicinity of project area are mainly Titas and its tributaries and a number of khals, ponds that carries run off from adjacent areas. Figure 4.6 shows River system of the project area. No impact in river system and no river crossing work will be done in this project. 4.1.10 Agro-Ecological Zones Bangladesh has been divided into 30 agro-ecological zones (AEZ). The project area covers the agro-ecological zone 16 and 19 namely Middle Mehgna River Floodplain and Old Mehgna Estuarine Floodplain. Figure 4.7 shows Agro-Ecological Zones of the project area. 4.2 Biological Environment 4.2.1 Introduction This section describes the floral and faunal diversity of the project area. Experts on flora and fauna have visited the project area to collect first hand data and information (both primary and secondary) to prepare the IEE report. Varieties of plants species and wild animals have been identified and recorded during the preliminary survey. Every species play an important role in its natural community and ecosystem and removal of that species is likely to have adverse impact. Bio- habitant of the study area may be divided in to major types viz, terrestrial and wetland habitat. 4.2.2 Terrestrial Habitat i) Terrestrial flora Terrestrial flora is classified according to their habitats. In the project area, terrestrial floras are present mainly in the homestead regions, roadsides, village groves, playgrounds and high cultivated lands. Human being as well as wildlife uses these flora species for different purposes. They play an important role in the socio-economic and ecological balance. From a rapid field survey covering different terrestrial habitats of the project area, a number of flora species have been identified as shown in Table. 4.1 (Annex- 5).with their scientific names. ii) Terrestrial Fauna Wildlife that fully depends on the terrestrial ecosystems for life, shelter, food and breeding is called terrestrial fauna. A number of terrestrial fauna species have been 39

identified during the brief and rapid assessment in the project area shown in Table 4.2A, 4.2B and 4.2C(Annex- 5).

4.2.3 Wetland habitat i) Wetland flora

Wetland flora plays a vital role in nature. It grows mainly in aquatic habitats vizbeel, ponds, canals, ditches or low lying cultivated lands. From a rapid survey in different wetland and aquatic habitat, a number of species have been identified as shown in Table 4.3(Annex- 5). ii) Wetland Fauna

The wildlife that fully or partially depend on water reservoir such as river, canal and pond etc. for life, shelter, food, nesting, breeding and reproduction inside the water reservoir is known as wetland fauna. Important aquatic fauna comprises some species of amphibians, reptiles, birds and mammals. Aquatic fauna may act as sensitive bio indicators of the altered state of the ecosystem resulting from human influence. In the survey area there are two major type of wetlands namely permanent wetland (rivers, canals and ponds) and seasonal wetlands (agricultural lands during flood).

4.2.4 Fisheries Two hundred and fifty species of fresh water fish have been identified in Bangladesh. The most important species is Hilsha followed by Carps, Catfish, Jeol and Prawns. Bangladesh has the highest rate of fish production unit area (4075kg/sq. km) and fish accounts for 71% of animal protein intake. It is estimated that 73% of rural household undertake some sort of fishing in the course of a year. Small fish ponds in the vicinity of the pipeline routes and the project area neighbourhood contribute significantly to the protein intake of the village family. Average fish production from pond is 750kg/ha. Fish is usually produced in the rivers and wetlands and is cultured in fish farms. It has been reported by Bangladesh Center of Advanced Studies that fresh water fish production has declined significantly due to over fishing, pollution and construction of hydraulic structure. Natural reproduction of fish is tightly bared and linked to cycle of annual flooding. *Source: Field survey database

4.2.5 Endangered and threatened species According to the field survey report, five species were in endangered while six species were in threatened category.

Table 4.4 Endangered and threatened species

Category Endangered Scientific Name Threatened Scientific Name Amphibian JhiJhi Bang Sona Bang Reptiles Gokhra Najanaja GuiShap Varanusbengalensis Udh Mammals Khekshial Vulpesbengalensis Khatash Birds Machranga, Alcedoatthis Pecha Tyto alba/ Atthenebrama HoludPakhi Oriolusxanthornus Kath Thokra Dinopiumbenghalense 40

4.2 Socio-economic Condition of the Project Area

4.3.1 General This section is intended to highlight the socio-economic scenario of the project area and its vicinity. It covers demographic and socio-economic characteristics of the project inhabitants. It is prepared on the basis of primary and secondary sources of data. Concerned persons visited Titas Gas Field area and data have been collected on some selected characteristics of the inhabitants of affected union's villages on population density, household size and other available utility services. The concerned persons have conducted focus group discussion at two different places under Brahmanbaria sadar and Sarial upazila. The study revealed the following salient features of the project area.

Population Density per About 1330 per Km2 Km2 Household Size 5.06per household People by religion Muslim-90.73%, Hindu9.07% and others-0.2% Land Area Most area around project area is cultivable land. Distribution of land by About 95% produce Boro and other paddy crops. While 10-20 cropping intensity % produce robi crop after Aman harvest. Available trees Mango, Blackberry, Mehagoni, Bamboo, Rain tree and a small number of jackfruit trees are available surrounding project area. Rivers and canals Apart from Titas river there is no flowing river in the project area. There is a dead canal. Occupation Agriculture 44.79%, agricultural labourer 15.82%, wage labourer 3.13%, commerce 12.26%, service 6.8%, fishing 2.02% and transport 1.85%, weaving 2.39% and others 10.94%. Local industry Apart from the gas field installations, there is a BSCIC industrial area. A number of brick fields and few rice mills and small industries are situated outside the project area. Utility and services Electricity: At present about 80% households have electricity connected. The rest of the households uses kerosene for lighting purpose. Cooking fuel: Though Titas gas field is very close to them but only 10-15% household have access to natural gas for cooking purpose. Rest of the household use firewood, cow dung, straw and garbage.

Household water use: A significant fraction of the people ranging from 12-25% is using pond/river water for domestic use which is not considered to be safe in most cases. The rest of the population of the project area uses the underground water from shallow or depth tubewell.

Chapter -5

PUBLIC CONSULTATION

Public Consultation

5.1 Introduction BGFCL recognizes the importance of social and environmental factors for successful implementation of the proposed project. BGFCL plans to undertake a comprehensive process of public consultation and environmental investigation. Feedback from the consultation process will play an integral role in development of the social and environmental programs. The purpose of consultation is to inform local inhabitants/primary stakeholders to inform them about the project and to gather their opinion/suggestions about the proposed development program as well as to incorporate their suggestions during project planning and implementation stage. A consultation process was initiated at the commencement of the 43

project. The overall objective was to ensure that stakeholders were kept informed about project proposals and developments, and that they were afforded the opportunity to contribute their views to project planning and the decision making processes.

5.2 Methodology As part of the IEE process, group discussion with stakeholders were organized and conducted to record views and opinions of the stakeholders. Participants in these consultation meetings included elected representatives, local leaders, school teachers, religious leaders, NGOs, women groups, representatives of professional groups like agriculturist, businessmen, etc. Table-5.1 indicates the date and place of the group discussion meetings including the number of participants present at each. Names of participants provided in Annex-6.

Table-5.1: Public Consultation Sessions Organized in the Project Area

SI Date Place No of Participants No. 26-2-2013 Sarial mauza of Sarial union under 1 and Brahmanbaria district 22 03-7-2013 Chhatian, Jangalisar and Malihata mauza of 2 02-7-2013 22 Budhal union under district Brahmanbaria Suhilpur mauza of Suhilpur union under district 3 02-7-2013 12 Brahmanbaria Total 56

Checklist Used For Public Consultation For uniformity and clarity in conducting the public consultation meetings, a checklist as devised by the consultants were used to enable the participants to comprehend the issues easily, so that they could participate in the discussions more effectively and express their opinions and views objectively. This participatory approach was well accepted by all the participants. During the public consultations, social, environmental as well as cross-cutting issues were discussed in detail, including potential impacts of the project activities on environmental and social parameters, identification of sensitive issues, risks, potential threats, public concerns and expectations from the project.

Consultant Checklist - Location of consultation - Name and occupation of participants - Awareness of participants about the project - Description of the project - Benefits of the projects - Impacts of the Project on social and environmental components - Community concerns and perception of the Project - Exception from the project - Suggestions about the Project * No complaints/grievance have received from public.

5.3 Key Findings from Public Consultations

The participants in general welcomed the project and expected that the project will contribute to the national economy in many ways. As reported, the following major issues among others were raised in the public consultation meetings. - Agricultural products including vegetation may be affected. Proper compensation will be paid on the spot to the affected people. - Assembly of people during project activities may damage crops. - Noise pollution from vehicles, drilling activity and equipment at the project sites may cause disturbance to human being and wild-life. - Compensation for land as per government rate would not be a fair compensation to the affected person as it is far below prevailing market rate. - Water pollution of the natural water bodies may be aggravated and should be taken care of as this water is used for agriculture and domestic purposes. - Movement of vehicles may affect mobility of people, especially women, children and disabled persons from one place to another. - There may be air pollution due to dust and gaseous emission which will be minimized through appropriate mitigation measures. - Environmental pollution through sanitation and waste materials as well as other social nuisance should be controlled.

5.4 Expectations of the People The following expectations of the local people were raised during the consultations: - Local personnel should be employed in different activities of the project on a priority basis. - Local businessmen / contractors should be engaged in different phases of the project for construction and development on a 'priority basis. - Compensation payment in any form, if any, should be properly and promptly distributed so that the actual affected person gets his full share and in right time.

5.5 Public Consultation Results The findings as recorded from public consultations have been presented in the Table-5.2 indicating the critical issues. The names of some participants in the meetings are listed at the end of this section

Table-5.2 Public Consultation

Project Name Issue Discussed Issue Raised Suggestion Drilling of 4 New Impact of Build up new New industry will Wells at Titas Gas consultation of new industries develop upon drilling Fields and Installation wells process of new wells and of 2 nos. Process Plants plants installation of gas at Titas Gas Field process plants Reduce Labour should be taken unemployment from respective locality.

Social and Living status will be Economic high. developments Land and Due compensation to property damage be paid according to the up to date price list. Crop damage Due compensation to be paid on the spot Compensation Compensation assessment assessment by DC office and local leader Impact on Fish Must avoid breeding breading and fish season and breeding pass ground Pollution of air Monitoring should be and surface water adopted Sanitary problem Appropriate sanitary system should be developed during project execution. Noise Pollution Appropriate noise mitigation measure will be adopted in drilling site

Chapter -6

IDENTIFICATION OF POTENTIAL ENVIRONMENTAL IMPACTS & MITIGATION MEASURES

6.1 Environmental Impact

6.1.1 General The Important Environmental Components (IEC) likely to be impacted has been described with sufficient rationale in the previous chapter. Based on the IECs under different resources/issues, necessary checklists were prepared under different resources and used in assess the impacts of respective components. As the present study is an IEE study, the impacts have been assessed qualitatively. However, an attempt will be made to assess the impact quantitatively during the EIA study. The following paragraphs describe the qualitative assessment of the environmental and social impacts of the project for the drilling of 4 New Wells (23-26) and Installation of 2 Process Plants at Titas Gas Field during the pre- construction, construction and post-construction phases. 6.1.2 Identification of Impacts In reviewing impacts, this section addresses the following issues: - Air Quality; - Noise and Vibration; - Surface Water Quality; - Groundwater Quality; - Soil Resources; - Land Erosion; - Seismology; - Biodiversity; - Land Use; - Transportation / Traffic; and - Other Social Aspects. The potential environmental impacts of the proposed project have been assessed based on DOE’s EIA guideline, ADB’s Environment Assessment Guidelines (2003), additional reference documents and applied professional judgment. Table-6.1 shows the various project activities and potential negative impacts of the proposed project. Table-6.1: Project Activities and Potential Negative Impacts

Activity Potential Negative Impacts Severity Duration A. Pre-Construction Phase Socio-Economic Land acquisition, Loss of land and crop M P Clearing of access road Loss of vegetation M T Site Development Air pollution N T

B. Construction Phase Air Quality Dust emission from movement of vehicles Air pollution N T Emission of smoke from vehicles, Air pollution N T generators, rotating equipment and machinery. Noise and Vibration Noise from vehicles, drilling other and Nuisance to local people, M T above equipment and machinery livestock etc Surface Water Quality Erosion from disturbed soil Turbidity and sedimentation M T Blockage of natural existing creeks Water logging M T 48

Ground Water Quality Discharge of domestic wastes Contamination of aquifer N T Soil Resources Excavation of soil and land leveling Erosion M T Mixing fertile top soil with unfertile Loss of fertility N to M T subsoil Soil degradation due to N to M T Discharge of toxic wastes pollution M T Movement of heavy vehicles and Soil compaction equipment Biodiversity Discharges of drilling fluids and other Loss of natural vegetation M P waste Loss of plants M P Clearance of vegetation Obstruction to traffic/ animal N T Movement of vehicle movement Nuisance to people and M T Noise from construction and erection animals equipment and the rig and its associated stationary and rotating machinery Other Social Aspects Excavation of land Loss of crop M T Movement of heavy vehiclesand equipment Public nuisance N T Solid waste disposal Interference with navigation/ fisheries Commercial loss M T Protection of works health and safety Loss in workers’ health N T Production testing and flaring from completed wells and purging, testing and commissioning of process plant, pipeline and ancillary facilities. C. Post Construction Phase Security checking of well head and process Disturbance to social life and N T plant wildlife Inadequate periodic monitoring loss to ecology and economy M T Leakages and Line breaks Nuisance to people and M to S T animal and loss to ecology Discharges from operation and and economy. M T maintenance of process plant. loss to ecology and economy Noise from rig equipment demobilization Public nuisance N T

Note: N=Negligible, M=Moderate, S=Severe, T=Temporary, P=Permanent.

6.1.3 Anticipated Environmental Impact and Mitigation Measures

Environmental Possible Mitigation Measures Responsible agency Budget Impact/Issue (BDT)

A. Pre-construction phase

Land acquisition Cash Compensation under Law Deputy Commissioner 20 core (CCL) with the premium Office, Joint Verification Team (JVT) & EA Terrestrial Cutting and filling of soil should be BGFCL BGFCL’s ecosystem kept minimum. Planting of trees and operating buffer strip should be maintained budget

properly Aquatic Special measures should be taken for Site Development Inbuilt in ecosystem rain/natural water flow so that fish Contractor site dev. movement/migration and fish contract breading can not hamper. price

B. Construction Phase

Ambient air - Rig, machinery and equipment Drilling and Process plant Inbuilt in quality during deployed in drilling and plant installation Contractor contract drilling and installation operations shall be price plant installation routinely inspected and maintained in good running condition; - Excavated material, stockpiles and haul roads shall be dampened with water during dry season and ambient conditions - Vehicle speed restrictions shall be imposed to reduce dust generation and dispersion; - Visual inspection of equipment and vehicles shall be conducted on a regular basis to ensure no excessive emissions of black smoke Noise and At the operation of the generator its Drilling and process plant Inbuilt in vibration due to noise level may not exceed 80 dB to installation contractor contract well drilling and 85 dB. This impact will be minor in price operation of the nature and of short duration at the rig process plants and the process plan site at any particular location and drilling site. Limited impacts will occur and contractors will undertake appropriate mitigation measures (e.g. use of silencer, barrier etc.) Generation of Contractor ensure detailed site Drilling and process plant Inbuilt in solid waste, environmental and safety plans installation contractor contract water/mud for the work sites and plant area price during drilling which make adequate budget and and process provision for safe disposal of plants operation waste water/mud and all other wastes and prevention of spillage, leakage of polluting materials, etc. Impact on The welding worker should wear Drilling and process plant Inbuilt in occupational PPE (Personal Protective installation contractor contract health and Equipment) like safety goggles, price safety due to safety helmet, safety shoe, aprons welding and and welding should be done in an sparks activities enclosed area. to the workers, local people 50

and wildlife

C. Post Construction Phase Impact on air Minor impact would be anticipated Process plant installation Inbuilt in quality from the gas process plant. A modern contractor contract gas processing plant would be set up price to minimize the environmental impacts, all trapping and foul gases will be flared at certain height. Impact on water Effluent Treatment Plant (ETP) will Process plant installation Inbuilt in quality be installed with each gas process contractor contract plant to treat the wastewater from the price plant. Condensate will be collected and sent for refining. Noise and Minor impact is anticipated from the Drilling and process plant Inbuilt in vibration of the gas well and process plant. The installation contractor contract process plant process plant and gas wells would be price in an isolated area and sophisticated equipment would be used for gas processing plant so as to minimize noise level within 80 dB to 85 dB. This impact will be minor in nature and of short duration.

6.1.4 Socio-economic Impact The socio-economic impact of the project will be felt at local and national level. That is to say the successful implementation of this integrated project in the respective areas will contribute significantly to the economic growth both at the local and the national level. The potential impact on the socio-economic condition at the local level will be generated primarily from the employment of labour during the project activities All contractors working for the project will engage several local people, thus creating employment opportunities as well as business opportunities for their goods and services. On the other hand the influx of outsiders may also cause some disruption to the social structure of the local people. BGFCL will seek to minimize this impact by introducing a code of Behavior (to be agreed with the local communities). Potential impacts will be temporary and minor in nature. Increased spending in the local economy by outsiders will be a positive impact, although for a period of short duration only.

Mitigation - Procedures for liaison with local people to be established before commencement of the works. BGFCL should clearly explain to local people about the need for the project in both the county and regional contexts. - BGFCL should also reassure the public about compliance with environmental impact mitigation measures and safety measures prepared for local communities; - Local communities must be consulted before commencing any future development projects in or near their community; - Large concentrations of housing for construction laborers should be avoided;

- Staffs are to be recruited locally where feasible. BGFCL shall encourage employing local people during construction work; - Public relations programs with local communities should be continually maintained to advice on risks and safety. It is particularly important to appraise them about the preparations taken to meet any eventualities in course of drilling, construction and testing and commissioning stages; - High standards of project operation, environmental impact mitigation measures and safety procedures must be maintained at all times; - Establish good relationships with local communities and help support their community activities; - To ensure adequate compensation to the project affected people as per the law of the country; and - Representatives from local communities should be allowed to join the committee to ensure justice and transparency.

6.1.5 Disaster Management In order to implement and operate the proposed well drilling and process plant project, the followings are important events that may causes disaster to the environment, lives and properties: a) Fire – Fire is a major disaster and it may occur due to negligence of working personnel/drilling crew at any time at the work place; b) Medical emergency – Due to incident or accident at the work site, the need of medical emergency may arise; c) Spills, leaks and other release of hazardous substances – leakage of gas from high- pressure pipeline and gas well during drilling operation may occur, which will create disaster; d) Natural disaster (i.e. earthquake, flood, tornados, cyclone, storm surge, extreme events, etc.) – The incident of natural disaster e.g. severe earthquake and major floods, cyclone or tornados may occur any time during the construction and operation period. For above mentioned disasters by respective important events, a) fire fighting equipment; b) fast aid and field treatment as well as necessary vehicles for immediate hospitalization; and c) preparation of disaster emergency response plan (DERP) together with the budgetary arrangement are the main measures to manage the occurrence of disaster. Some Preliminary Measures (e.g. local mobilization, local awareness and training, marking of the danger area, fencing of the work place etc.) will be ensured by BGFCL and Contractors to manage the immediate risk of different disaster events. Besides, some Permanent Management System (e.g. regular/periodical monitoring and inspection of BGFCL officials, installation of local unit office etc) will be established by BGFCL to minimize the disaster events with long-term effect.

6.1.6 Summary The findings of the preliminary assessment indicate that the project activities do not present any significant adverse impact on the environment. The potential short-term impacts are largely minor in nature and can be mitigated.

6.2 Environmental Management Plan 52

6.2.1 General An Environmental Management Plan (EMP) is an array of activities suggested for minimizing the effect of the negative impacts (mitigation) and increasing the benefits of the positive impacts (enhancement). The EMP also includes a monitoring plan to check if the intended benefits are accruing and for taking corrective measures before it is too late. The Environmental Management Plan (EMP) is the end-product of the IEE study and should be integrated into the project design for sustainable development of the project. Integration of the EMP into the project design would minimize the effect of the negative impacts and increase the benefits of the positive impacts in addition to creating an opportunity to monitor the changes taking place in the environmental and social components at the pre-construction, construction and post-construction phases. The benefit of the IEE study would not be derived and would remain a theoretical exercise if the EMP is not integrated into the project design. The Environmental Management Plan (EMP) includes the following: i) Mitigation plan containing suggestion on measures aimed at minimizing the effect of the negative impacts; ii) Enhancement plan containing suggestion on measures aimed at increasing the benefits of the positive impacts; iii) Compensation plan suggesting measures required for paying compensation for negative impacts which can not be mitigated; iv) Contingency plan suggesting measures required for taking care of accidental events; v) Environmental monitoring plan for detecting changes taking place due to the proposed interventions. The environmental monitoring plan includes suggestion of indicators on which data are to be collected, location and frequency of data collection and the institutional arrangements for the data collection. vi) Costs of the EMP measures are estimated so that the same may be included in the project cost for economic and financial analysis. However, at this level of IEE study, the EMP is indicative and as such could not be costed. These will be fully addressed at the EIA level of study. Costing of the EMP normally worked out at the EIA level of study with more specific information on the impacts and the EMP measures. In the context of a project, environmental management is concerned with the implementation of the measures necessary to minimize or offset adverse impacts and to enhance beneficial impacts. Unless the mitigation and benefit enhancement measures as identified in the IEE report are fully implemented, the overall environmental benefit cannot be achieved.

6.2.2 Institutional Responsibility The institutional responsibility for implementing EMP mentioned below :

Institutional Impacts Mitigation measures Management actions responsibilities A. Pre-construction phase

Impact on Compensation for Land acquisition notice will be BGFCL, DC and agricultural land permanent loss of land served to the owner well ahead Joint Verification acquisition and crops ; of time; Team (JVC) Provide adequate quick and fair 53

Institutional Impacts Mitigation measures Management actions responsibilities Physiological stress compensation to the real land increase of land value owners in accordance with applicable laws of GOB for land loss Impact on site Site development Description of the Site BGFCL development /earthwork contractors to development works to indicate behave in an that BGFCL view environmentally environmental matters to be of responsible manner considerable importance and that the contract will be administered accordingly.

B. Construction phase

General adverse Contractors to behave in Description of the works to SDC impacts of civil an environmentally indicate that the BGFCL view construction responsible manner environmental matters to be of activities. considerable importance and that the contract will be administered accordingly

Briefing of appointed The Engineer / contractors on mobilization, CSMC regarding sensitive environmental matters and reinforcement of advice regarding contract administration; contracts to be administered accordingly

Impact on pollution Drilling Contractor Description of the works to Drilling Contractor of land and surface ensure detailed site indicate that the Bank and water arising from environmental plans for BGFCL view environmental used mud and other the waste mud and base matters to be of considerable wastes during well camps and other work importance and that the contract drilling. sites, which make will be administered adequate budget accordingly provision for safe disposal of all wastes and prevention of spillage, leakage of polluting materials etc.

Impacts on Contractor ensure Description of the works to Process Plant pollution of land detailed site indicate that the Bank and Installation and surface water environmental and safety BGFCL view environmental Contractor arising from during plans for the work sites matters to be of considerable installation and and plant area which importance and that the contract commissioning of make adequate budget will be administered gas processing and provision for safe accordingly plant. disposal of waste water and all other wastes and 54

Institutional Impacts Mitigation measures Management actions responsibilities prevention of spillage, leakage of polluting materials etc.

C. Post Construction phase

Pollution of land, Proper mitigation’s plans groundwater and are to be developed by surface water BGFCL for each of the Effects monitoring during BGFCL arising from subprojects to handle the operation discharge of various discharges. dehydration units and other wastes and spillages.

SDC=Study and Design Consultant; CSMC=Construction Supervision and Monitoring Consultant DC=Deputy Commissioner; DOE=Department of Environment

6.2.3 Environmental Monitoring Plan

Indicator Location Frequency Monitoring agency Pollution of land and Drilling site Everyday BGFCL surface water arising from (During the used mud and other wastes drilling period) during well drilling. Noise from equipment, Drilling site and Everyday BGFCL drilling rig and generators process plant area (Duration: 1 year) Pollution of land, ground Process plant area Everyday BGFCL water and surface water arising from discharge of dehydration units and other wastes and spillages.

The monitoring program, in view of the possible impacts as assessed earlier, should consider the indicators for the impact assessment related to the following issues: - Air quality monitoring - Noise monitoring - Occupational health and safety monitoring - Water quality monitoring - Community health and safety monitoring - Monitoring for disaster management and emergency response preparedness - Monitoring for social and administrative compliance Besides the above specific monitoring aspects for operations, laboratory tests for specific sampling locations should be conducted.

6.2.4 Safety and Hazard Mitigation Plan for Worker and Community 55

There are always hazards everywhere in any work place. But to work safely, hazards needed to be identified and mitigated properly. Safety is an integral part of BGFCL operation. It is the part of the company's philosophy to protect employees, contractors, property, the environment and the public. By fulfilling safety responsibilities, employees will share the benefits of a safe work place. The company has its own safety management and mitigation plan and policy. To determine compliance with safety and hazard issues while performing a task, the following will be followed: - Employees are to be provided with safe equipment and safe working environment; - Employees are to draw up and ensure the implementation of safe systems and procedures for work which pose acute risk; - Employees are to be provided with adequate personal protective and safety equipments (e.g. PPE); - Arrange safety training for concerned employees on safe work procedures and refresher training; - Employees entrusted by these tasks participate in the development of safe work procedures; - Employees are involved in the maintenance of safe work procedures; - Review records to ensure that employees receive training on hazardous work procedures, codes and practices; and - Where practical, observe employees performing critical tasks to ensure that they follow the operating procedures and general safety; Accidents and near-miss incidents shall be investigated to determine what caused the problem and what action is required to prevent a recurrence. The purpose of impact mitigation and counter measures are to avoid creating negative impacts wherever possible, to minimize impacts where they may be unavoidable and to generate opportunities for improvements or positive impacts where appropriate. It should be assessed to determine what personal protective and safety equipment is needed and the equipment must be available. A maintenance schedule must be developed for PPE and employees must be trained in fitting, care, maintenance and use of same.

6.2.5 Emergency Response Plan As with the emergency preparedness plan Bangladesh law does not yet require Emergency Response Plans at oil and gas facilities. However, like all other industries and installations; gas production and process facilities must have adequate measures against accidents or incidents to meet the emergency. The purpose of having an Emergency Response Plan (ERP) is to: - Assist personnel in determining the appropriate response to emergency situations; - Provide personnel with established procedures and guidelines; - Notify the appropriate Company Emergency Response Team personnel and regulatory/ Govt. agencies; - Manage public and media relations; - Notify the next-to-kin of accident victims; - Promote inter-departmental communications to ensure a “Company wide” co-ordinated emergency response. 56

- Respond to immediate requirements to safeguard the subtending environment and community; Emergency Response Procedures will identify who does what and when in the event of an emergency. Responsibility for who is in charge and their coordination of emergency actions shall be identified. The following are important events that require emergency response procedures: - Fire - Accidents and medical emergency - Spills, leaks and other releases of hazardous substances - Natural disasters (e.g., Earthquakes, floods, cyclone, storm surge, tornadoes, and other extreme climate events, etc.) - Explosion, blow-outs, line breaks and ruptures etc.

Chapter -7

GRIEVANCE REDRESS MECHANISM

Grievance Redress Mechanism

7.1 General ADB's Environmental Safeguards requires the project proponent to establish a mechanism in order to receive and facilitate resolution of affected people's concerns, complaints and grievances about the project's environmental performance. The mechanism shall use an

understandable and transparent process that addresses the affected people's concerns and complaints promptly.

7.2 Grievance Redress Mechanism Grievance Redress Committee (GRC) will be established and maintained to ensure stakeholders participation in the implementation process. Through public consultations, the affected persons (APs) will be informed that they have a right to grievance redress from the BGFCL. The APs can present their grievances or queries to the GRC. Other than disputes relating to ownership right under the court of law, GRCs will review grievances involving all resettlement assistances, relocation and other supports. Grievances will be redressed within a month from the date of lodging the complaints. The GRC will be formed at Union level for any grievances involving resettlement benefits, relocation, and other assistance. The GRC for each Union will comprise of the Project Director, BGFCL, one local elected public representative, one representative of APs and a legal advisor as observer to extend legal support to the committee. The GRCs will be formed and activated during land acquisition process to allow APs sufficient time to lodge complaints and safeguard their recognized interests. Where land acquisition will not be involved but relocation of structures or vacating land from cultivation will be required, the GRCs will facilitate resolution of complaints regarding categorization of vulnerable affected persons, types of structures and eligibility for compensation and assistance within the set guidelines and provisions of the resettlement action plan. Any complaints of ownership or other suits, to be resolved by judiciaries system, will not be resolved in GRCs. The Grievance Redress Committee (GRC) to be formed will be similar to Public Consultative Committee (PCC). In effect, the GRC will work closely with the APs to identify the grievances and redress the same in consultation with other members of the committee as well as the APs. The activities of grievance redress will be monitored by the organization. The committee will meet on monthly basis and take steps to redress the grievance. Different problems will be addressed in different manners depending on the type of grievance; however the generic approach to resolution of all grievances will include the following steps:  The complaint received will be reviewed and screened for the factual details and will be considered for resolution at local level. The grievance will be assessed to determine if the issues rose in the complaint fall within the mandate of the grievance mechanism and the complainants have standing;  If the complainant requires intervention then it will be considered for resolution otherwise it will be rejected and the same will be communicated to the concerned complainant;  The grievance will be evaluated to clarify the issues and concerns raised in the complaint, to gather information on how others see the situation, and to identify whether and how the issues might be resolved. All options for solving problems will be explored, with or without the assistance of independent, third parties: - Internal decision-making processes, whereby issues are handled by designated officials of BGFCL, using stated standards and criteria, to develop and propose a company response to the grievance and to allow for an appeals process; - Joint problem solving, in which BGFCL and the complainant engage in direct dialogue;

- Third-party decision making to offer a solution when a voluntary agreement is not possible; - Grievance tracking, monitoring, and reporting to the community will be undertaken as soon as a mutual consent is arrived at.

7.3 Communication Mechanism to Stakeholder Formal information of Grievance Redress Committee constituted, as suggested above, will be communicated to the respective stakeholders and nominated members of the committee. This communication can be made through personal letters, letter to Unoin Parisad, Unoin Parisad notice board, posters, public announcement at strategic locations such as during respective Unoin Parisad Meetings. The stakeholders will be encouraged to approach this committee with their concerns and suggestions.

7.4 Meeting of Grievance Redress Committee The committee will meet at least once every fortnight in the first 6 months of implementation, and thereafter once, every month. At every Grievance Redress Committee meeting the issues raised in the last meeting and report on action taken, will be summarized. Issues that cannot be resolved at the GRC would be referred/directed to next designated levels. The Committee will convene their meetings as and when required.

7.5 Closing of Grievance The complaints lodged in the GRC Register will be resolved amicably by the above mechanism and closed by informing to the complainant directly with closing signatures on the GRC Register or by sending registered post to the complainant, in case he is not approachable. The resolution shall be informed to respective Union Parisad also in writing for display at a common place for information to interested parties.

Chapter -8

CONCLUSIONS AND RECOMMENDATIONS

Conclusions and Recommendations

8.1 General The IEE of the Proposed Drilling of 4 new Wells (Well No.23-26) and Installation of 2 new Gas Process Plants at Titas Gas Field has been prepared. The Project has been carried out at generic level in terms of both project design and environmental definition. This is believed the appropriate level of assessment for the present stage of project development. The key 61

areas of environmental sensitivity have been identified and the mitigation measures have been proposed. A management process has also been defined which should ensure that environmental sensitivity are adequately addressed at all stages of project development.

8.2 Conclusions Some land owners would lose their land permanently due to acquisition and should be properly compensated. However, the urban and sub-urban areas would be relatively less impacted due to their already degraded condition. The major impacts on environment will be happened during the drilling of the wells and the operation of the process plants. Since the construction and drilling activities will be for short term, all impacts could be mitigated and manageable of proper and adequate measured would be taken in consideration. Again the waste generated during the operation of the process plants that can be managed by installing the proper effluent treatment plant. The following are the main areas where there is little chance of creating environmental impact during construction, drilling and operation of the process plants for the proposed project: - surface water - ambient air - ground water, - soil quality - noise and vibration, - traffic congestion, - disruption to existing drainage pattern, - sanitation hazard - Occupational health and safety - Disaster and emergency situation All the probable environmental impacts that would have chance to occur has been discussed in the IEE report and outline of mitigation measures proposed. The project would have very minimum environmental impact during operational phase except disaster. On the basis of the project summary and other relevant reports it may be concluded that the project stands environmentally sound and sustainable when the recommended mitigation measures and environmental management processes are adopted. The major activities for the installation of the process plants are welding works, radiography and transfer of the chemicals. During these works execution period the employees must use the safety helmet, hand gloves, aprons etc. The benefits of the project will be realized primarily at the level of the national economy. Benefits in the project area will not be that significant except for some short term employment and business opportunities during the construction phase. However, natural gas is an intrinsically clean fuel compared with most alternatives and development of natural gas resources and transportation to the load centers for the consumers of same as fuel and feedstock are environmentally sound options at the local national and global level. The proposed project activities have no significant adverse environmental impact so far as a time bound execution program with application of advanced drilling and construction technology is ensured. The mitigation measures are incorporated well within such codes and

practices of drilling, construction and operation of the wells, process plant and the pipeline system.

8.3 Recommendation Severe weather conditions would have an impact on the project activities and certain component of the project that means civil construction, drilling of wells and operation of the process plants. So it is, recommended that commencing drilling and construction activities in early winter season may help to reap the benefit of full dry spell of the season. Further, - In order to enhance the occupational health and worker safety during the drilling and construction period, construction equipment would -have to be kept in good order. Adequate safety measures should be taken and safety related equipment including personal protective equipment, fire fighting equipment etc. must be used in order to reduce the potential for accidents. - It is recommended that felling of trees should be kept to a minimum. It is very important for the preservation and protection of natural ecosystem and avoiding undesirable erosion/ deposition. Any unavoidable loss should be replenished by undertaking appropriate plantation programme. But, intact as the project location is mainly agricultural land so, felling of trees would not happen. - The major issue is the need to minimize disturbance to the local population in the areas of drilling and process plant construction sites. Effort should be put in to arrive at a fair and equitable level of compensation for farmers, residents and other individuals affected by land taken (permanent and temporary) for the project. A positive policy of employing local people during the construction phase should be adopted. - In the post drilling and construction phase, the environmental impact of the project will be some loss of land utility at the project site and along the pipeline alignments and a risk of discharge of drilling fluids associated liquids and leakage of gas due to improper maintenance or accident. The former can be mitigated by adoption of a fair compensation policy and the latter by adequate maintenance and monitoring. - It is recommended that the hazardous liquid waste that produced during the operation of the gas process must be treated by using the effluent treatment plant. - The implementation of the proposed project will provide supply of clean burning fuel and necessary feed stock and thereby would not only reduce the dependence of Bangladesh on foreign energy resources but also help accruing a good number of benefits in terms of health, agricultural, forestry, commercial and industrial development. To receive these benefits, certain environmental impacts of the project will have to be tolerated. However, the anticipated impacts are mostly of short duration and relatively minor in nature. In view of the above considerations and the fact that BGFCL will maintain standard quality of implementation of the programme with due consideration to all standing rules and regulations.