Initial Environmental Examination

Document Stage: Update

Project Number: P45203 (BAN)
September 2016

People’s Republic of Bangladesh: Natural Gas

Infrastructure and Efficiency Improvement Project
(Component 1 - Installation of Wellhead Gas
Compressors at Location “A” of Titas Gas Field)

Prepared by Bangladesh Gas Fields Company Limited for the Asian Development Bank. This is
an updated version of the draft originally posted in August 2016 available on
https://www.adb.org/sites/default/files/project-document/190161/45203-006-iee-01.pdf.
 CURRENCY EQUIVALENTS
(as of 3 August 2016)

Currency unit – Taka (Tk)

Tk 1.00 = $0.012755
$1.00 = Tk78.40

ABBREVIATIONS

ADB - Asian Development Bank

AIIB - Asian Infrastructure Investment Bank
BGFCL - Bangladesh Gas Fields Company Limited
CITES - Convention on International Trade in Endangered Species of Wild
Fauna and Flora
DOE - Department of Environment
EA - Executing Agency
ECA - Environment Conservation Act
ECC - Environmental Clearance Certificate
ECR - Environment Conservation Rules
EIA - Environmental Impact Assessment
EMP - Environmental Management Plan
EMRD - Energy and Mineral Resources Division
ESMS - Environment and Safety Management System
GoB - Government of Bangladesh
GRC - Grievance Redress Committee
IEE - Initial Environmental Examination
LCC - Locational Clearance Certificate
MOEF - Ministry of Environment and Forests
MPEMR - Ministry of Power, Energy and Mineral Resources
NOC - No Objection Certificate
PIU - Project Implementation Unit
ROW - Right of Way
SPS - Safeguard Policy Statement

WEIGHTS AND MEASURES

o
C - degree Celsius
dB(A) - A-weighted decibel
ha - hectare
Hp - horsepower
lahk - 100,000
ppb - parts per billion
ppm - parts per million
µg/m3 - microgram per cubic meter
m2 - square meter

NOTE
In this report, "$" refers to US dollars.
This initial environmental examination is a document of the borrower. The views expressed
herein do not necessarily represent those of ADB's Board of Directors, Management, or staff,
and may be preliminary in nature. Your attention is directed to the “terms of use” section of this
website.

In preparing any country program or strategy, financing any project, or by making any
designation of or reference to a particular territory or geographic area in this document, the
Asian Development Bank does not intend to make any judgments as to the legal or other status
of any territory or area.
 TABLE OF CONTENTS

Page No.

EXECUTIVE SUMMARY 1
1.0 BACKGROUND 7
1.1 Overview of the Project 7
1.2 Environmental Requirements for the Project 7
2.0 POLICY, LEGAL, AND ADMINISTRATIVE FRAMEWORK 8
2.1 Environmental Requirements of Bangladesh 8
2.1.1 Environmental Agency 8
2.1.2 Applicable Environmental Regulations 8
2.1.3 Relevant International Environmental Agreements 11
2.2 Environmental Requirements of Asian Development Bank
and the Asian Infrastructure Investment Bank 14
2.2.1 Asian Development Bank 14
2.2.2 Asian Infrastructure Investment Bank 15
2.3 Compliance of Component 1 to Environmental Requirements 18
2.3.1 Requirements of DOE 18
2.3.2 Requirements of ADB 19
3.0 DESCRIPTION OF THE PROJECT 19
3.1 Need for the Project 19
3.2 Location of the Project 19
3.3 Major Components of the Project 21
3.4 Reciprocating Compressor 23
3.5 Environmental Considerations 25
3.6 Proposed Project Schedule 25
3.7 Project Activities 26
3.7.1 Pre-construction phase 26
3.7.2 Construction phase 26
3.7.3 Operation phase 28
3.7.4 Decommissioning phase 28
4.0 DESCRIPTION OF THE ENVIRONMENT (BASELINE DATA) 29
4.1 The Titas Gas Field 29
4.2 Existing Natural Gas Process Plant at Titas Gas Field 29
4.3 Physical Environment 30
4.3.1 Topography 31
4.3.2 Climate 31
4.3.3 Air quality 31
4.3.4 Ambient noise 32
4.3.5 Soil type 32
4.3.6 Seismicity 33
4.3.7 Water resources 34
4.4 Biological Environment 35
4.4.1 Terrestrial Habitat 35
4.4.2 Aquatic Habitat 36
4.5 Socio-economic Condition 36
5.0 ANTICIPATED IMPACTS AND MITIGATION MEASURES 37
5.1 Pre-construction stage 40
5.2 Construction stage 40
5.2.1 Site preparation and transport of construction equipment and materials 40
 5.2.2 Installation and testing of compressors and ancillary equipment 42
5.3 Operation stage 43
5.4 Decommissioning stage 45
6.0 ANALYSIS OF ALTERNATIVES 46
7.0 INFORMATION DISCLOSURE, CONSULTATION, AND PARTICIPATION 48
8.0 GRIEVANCE REDRESS MECHANISM 49
8.1 Existing Structure of Handling Grievance at BGFCL 49
8.2 Handling Grievance as Required by SPS 2009 49
9.0 ENVIRONMENTAL MANAGEMENT PLAN 50
9.1 Implementation Arrangements 50
9.2 Environmental Safety Management System (ESMS) at BGFCL 51
9.3 Safety and Hazard Mitigation Plan at BGFCL 52
10. CONCLUSION AND RECOMMENDATION 60

List of Tables
Table 1.1 Project Details 7
Table 2.1 Relevant National Regulations, Laws and Policies 9
Table 2.2 Bangladesh Relevant International Environmental Agreements 11
Table 2.3 Environmental Classification According to SPS 2009 14
Table 2.4 Draft Environmental Classification of AIIB 15
Table 2.5 Comparison of Environmental Safeguard Principles 16
Table 3.1 Features of the Compressor 22
Table 3.2 Chemical Composition of Natural Gas in Titas Gas Field 22
Table 3.3 Project Implementation Schedule 25
Table 4.1 Soils Sampling Analysis, Location A 33
Table 6.1 Comparison of “With Project” and “Without Project” Options 47
Table 7.1 Summary of Initial Consultation 48
Table 9.1 Environmental Management Plan 53
Table 9.2 Environmental Monitoring Plan 59

List of Figures
Figure 2.1 ECC Application Process for Red Category Project 9
Figure 3.1 Location of Titas Gas Field 20
Figure 3.2 Location of Component 1 20
Figure 3.3 General Layout of Compressors 21
Figure 3.4 Proposed Layout of Component 1 with Existing Facility 24
Figure 3.5 Photograph of Reciprocating Compressor 24
Figure 4.1 Plant Layout of Existing Facility at Titas Gas Field 30
Figure 4.2 Natural Gas Process Plant at Titas Gas Field 30
Figure 4.3 Climate Map 32
Figure 4.4 Seismic map of Bangladesh 34
Figure 4.5 Vegetation in Location A, Titas Gas Field 36

List of Annexes
Annex 1 Relevant Environmental Quality Standards of Bangladesh 61
Annex 2 Photographs during site visits to BGFCL on 22-24 August 2016 68
Annex 3 Chance Find Procedure
Annex4 Public Consultation 70
Annex 5 No Objection Certificate from the Local Authority 74
Annex 6 Safety and Hazard Mitigation Plan at BGFCL 75
 EXECUTIVE SUMMARY

Introduction

1. The Project will be funded by Asian Development Bank (ADB) with cofinancing from the
Asian Infrastructure Investment Bank (AIIB) at an estimated total cost of $447.6 million.

2. Component 1 of the Project will involve the installation of wellhead compressors at

Location – A of Titas Gas Field. The Executing Agency (EA) for Component 1 is Bangladesh
Gas Fields Company Limited (BGFCL), which is one of the operating companies of the
Bangladesh Oil, Gas and Mineral Corporation (Petrobangla) under the Energy and Mineral
Resources Division (EMRD) of the Ministry of Power, Energy and Mineral Resources (MPEMR).
BGFCL is entrusted with the production of natural gas from its five producing fields and
processing of gas to the transmission pipeline system.

3. Commercial gas production at the Titas Gas Field began in April 1968. Over time,
wellhead pressure of wells has been decreasing at an average annual rate of 90 pounds per
inch (psi) and within the next 3-5 years, it is estimated that natural gas flow can no longer
maintain the gridline pressure without the installation of compressors before the existing natural
gas process plants at Location A in the Titas Gas Field. Gas compressors will be essential to
augment gas transmission capacity to meet the increasing gas demand.

Project Description

4. Component 1 will be located in about 0.6 hectare (ha) of land within the existing facility
owned by BGFCL at Location A of the Titas Gas Field. No unauthorized public access to
Location A is allowed by BGFCL. The existing natural gas processing facility of BGFCL at
Location A of Titas Gas Field consists of major equipment such as eight glycol dehydration
units, four low-temperature separation (LTS) units, and two LTS units with glycol injection. Two
fractionation units separate the condensate, which is a by-product of gas processing, into liquid
fuel as motor spirit (MS) and high speed diesel (HSD). MS and HSD are sold to Padma Oil
Company Limited, and Meghna Petroleum Limited. The two gas treatment plant and one of the
fractionating plants were financed by ADB.1

5. Component 1 will consist of seven reciprocating compressors with a capacity each of 60

million standard cubic feet (MMSCF) per day of natural gas. Five compressors will be operating
at a time while two compressors will be standby. The compressors will require 5 MMSCF of
natural gas daily as fuel for its operation and 16 tons of water per day for its closed recirculating
cooling water system. Water requirements will be provided through borehole/deep tube well
from the existing BGFCL natural gas processing plant facility. Make up water for the cooling
system will be required only when leakage has occurred at pump packings through years of
operation or when water has been drained to allow system repair. The daily output capacity of
compressed gas from these compressors will be 300 MMSCF. Activities associated with the
installation of the compressors from construction, testing and/or commissioning, and operation
will follow relevant regulations of the Government of Bangladesh (GoB) and applicable industry
and international standards.

1
ADB. Project Performance Audit Report on the Second Natural Gas Development Project. November 1997. Loan
714-Bangladesh: Second Natural Gas Development Project. July 1984.
http://www.adb.org/sites/default/files/evaluation-document/35316/files/pe492.pdf (Accessed 3 August 2016)

1
Environmental Requirements

Government of Bangladesh Requirements

6. Environmental Conservation Act (ECA) 1995 and Environmental Conservation Rules

(ECR) 1997 of the GoB under the Department of Environment (DOE) of the Ministry of
Environment and Forests (MOEF) classify Component 1 as a “red” category project requiring an
initial environmental examination (IEE) for the issuance of the locational clearance certificate
(LCC) and an environmental impact assessment (EIA) for the environmental clearance
certificate (ECC) after obtaining the LCC. However, given that Component 1 will be located
within an existing natural gas facility owned and operated by BGCFL with previous ECCs,
BGFCL requested the DOE on 3 November 2015 for an exemption from submitting an IEE and
EIA but instead consider their submission for an environmental management plan (EMP).
BGFCL has a similar project where it required the installation of six wellhead compressors in
their existing gas fields: Narsingdi Gas Fields (3 compressors), and Titas Gas Field-Location C
(3 compressors). For these wellhead compressors in the two gas fields, DOE issued an ECC 17
July 2014 with EMP as supporting document. Based on the request of BGFCL, the DOE agreed
on 25 January 2016 that for Component 1, an EMP will be submitted for the issuance of the
ECC. On 11 August 2016, DOE issued the ECC to BGFCL for the installation of the seven
compressors in Location A which is valid for one year. The ECC will be renewed subject to
compliance by BGFCL with the terms and conditions set out by the DIOE such as strict
implementation of the EMP. Other existing facilities in the Titas Gas Fields (i.e., natural gas
process plants, drilling of wells, and workover2 for Titas well #21) were issued their ECC by the
DOE.

ADB and AIIB Requirements

7. The Safeguard Policy Statement (SPS) 2009 of ADB sets out the requirements for
environmental safeguard that applies to all ADB-financed projects. The Asian Infrastructure
Investment Bank (AIIB) was established in October 2014 as a multilateral bank and the
Multilateral Interim Secretariat for Establishing the AIIB has developed the Draft Environmental
and Social Framework that completed public consultations on 23 October 2015. The Project will
adopt SPS 2009 as the unified environmental assessment and planning process for
consultation, disclosure requirements and safeguard documentation to meet the safeguard
principles and requirements of both of ADB and the AIIB. Based on SPS 2009, the project is
category B requiring an IEE. Thus, this IEE is prepared to meet the requirements of ADB and
AIIB. Aside from complying with the provisions set forth in SPS 2009, ADB also requires BGFCL
to comply with the environmental requirements of the DOE. BGFCL will provide to ADB the ECC
to be issued by the DOE for Component 1.

Anticipated Impacts and Mitigation Measures

8. Component 1 is not expected to cause significant adverse environmental impacts.

Location A, where the compressors will be installed is within an area considered industrial.
Construction-associated impacts such as increase in noise and dust levels, generation of waste,
disruption to daily activities and local traffic are temporary and of short duration. The
construction and installation of the compressors would not require use of a significant amount of
water to result in generation of significant quantity of wastewater/sludge. BGFCL will require the

2
Gas well workover is a remedial work within the well in an attempt to increase the rate of gas flow.

2
EPC Contractor to prepare a Construction Management Plan describing the procedures and
measures to mitigate these impacts.

9. During operation, BGFCL will require the EPC Contractor, who will continue during the
first year of operation, to prepare a safety management plan and an emergency and disaster
preparedness plan. Staff will be trained on the proper handling and management of the
compressor operations. Daily water requirements for recirculating cooling water system will be
taken from groundwater wells from the existing gas processing facility.

10. Natural gas at Titas Gas Fields is about 97%mole methane (CH4) and does not contain
hydrogen sulfide (H2S). Use of natural gas to fuel the compressors will result to emissions that
are mainly carbon dioxide (CO2). About 272 metric tons (MT) of CO2 emissions per day will be
contributed by Component 1 to greenhouse gas (GHG) emissions or about 99,280 MT CO 2 per
year on a “worst scenario” of operating the seven compressors at the same time. Tree planting
will be done at designated areas in Titas Gas Field not only to serve as sinks for the emissions
but is required by Petrobangla in its key point installation (KPI). Carbon sequestration by trees is
a complex process and involves several factors such as survival rate, species, age of tree to be
planted, soil type, etc. Given these factors, only tree species common to Brahmanbaria will be
planted such as Ashwatha tree (Ficus religiosa) belonging to the mulberry family, and Neem
(Azadirachta indica). The Department of Forest (DOF) will be consulted on the appropriate tree
species to be planted at and around the Titas Gas Field.

11. Over time, compressors wear and may cause leaks of CH4 and volatile organic
compounds (VOCs). These fugitive emissions can be mitigated by techniques such as
replacement of compressor rod packing, replacement of the piston rod, and refitting or
realignment of the piston rod. In May 2016, the US EPA issued the requirements for
reciprocating compressors focusing on monitoring (i.e., record keeping) and reporting (i.e.,
annually) of the condition of rod packing: (i) on or before every 26,000 hours of operation
(operating hours must be monitored and documented), and (ii) every 36 months (monitoring and
documentation of operating hours not required).2 Among others, BGFCL will conduct monitoring
and reporting of the condition of the compressor packing systems as fugitive emissions is a
systems loss with associated costs.

12. Operation of natural gas compressors does not come without risks of explosion and fire
given that natural gas is flammable. The lower explosion limit of CH4 is 5% and the upper
explosion limit is 15% in the presence of an ignition source. This means that CH4 concentration
lower than 5% (“too lean”) and higher than 15% (“too rich) will not cause fire in the presence of
ignition source. Component 1 will be within the area of the existing natural gas processing plant
of BGFCL at Titas Gas Field. Given the capacity of natural gas being processed at this facility
and its national economic significance, BGFCL has an environment safety management system
(ESMS) as well as safety and hazard mitigation plan to address the risks of explosion or fire.
Among others, the operation of BGFCL is subject to the Natural Gas Safety Rules 1991
(amended 2003) and The Factories Act 1965. In August 1993, a team of safety engineering
experts from British Gas experts was engaged to conduct a safety audit of the entire operations
of Petrobangla and concluded that all operating companies (which included BGFCL) are
generally operating an adequate system and provided recommendations for safety program

2
US EPA. Summary of Requirements for Equipment at Natural Gas Transmission Compressor Stations.
https://www3.epa.gov/airquality/oilandgas/may2016/nsps-gas-transmission-fs.pdf. (Accessed 3 August 2016)

3
development which were incorporated in the ESMS.3 ADB provided financing in March 2010 to
cover safety and supply efficiency improvement in Titas Gas Field.4 The Bakhrabad Gas Field
has wellhead compressors since 2007 and no trouble has been encountered during installation
and operation.5 Japan International Cooperation Agency (JICA) has financed the installation of
wellhead compressors for Titas Gas Field Location “C” (three compressors) and Narshingdi Gas
Field (three compressors) and the project was implemented in July 2014 to June 2018.6 BGFCL
also operates Narshingdi Gas Field and thus, has the experience to implement Component 1
following the highest standards and norms on safety.

13. At decommissioning, BGFCL will require the Contractor to prepare a decommissioning

plan following the industry best practice. The decommissioning plan will be submitted to ADB for
review and approval to ensure that it meets SPS 2009 and the World Bank Environmental,
Health, and Safety General (EHS) Guidelines 2007 (or any updates).

14. All the impacts identified for the implementation of Component 1 can be readily mitigated
by proper planning, compliance to design and relevant industry standards, and good
engineering construction and management.

Analysis of Alternatives

15. The production wells at Titas Gas Field that require the installation of wellhead
compressors are located within the existing natural gas facility of BGFCL. With the availability of
a secured space to accommodate the required capacity of the wellhead compressor at Location
A, and connections to water supply, electricity, fire and safety system including road access and
other physical infrastructure, no other sites were considered. Aside from these existing technical
support systems, the future expected capacity of the production wells once Titas well #5 is back
in operation was also considered in selecting Location A. As part of design and planning of
BGFCL, all the locations of the production wells at Titas Gas Field (i.e., Location A, C, E, and G,
etc.) has earmarked land to accommodate the installation of compressors, as and when, the
operation requires.

16. “Without project” option will stall planned national economic development dependent on
a reliable supply of natural gas including the associated jobs that could have been generated.
Without Component 1, the operations of existing industries and residential users of natural gas
will be compromised due to decreasing gas flow from the Titas Gas Fields.

Information Disclosure, Consultation and Participation

17. Initial consultations were carried out on 18 October 2015 at the Union Parisad Office of
Shuhilpur in Brahmanbaria District participated by 36 local residents. Some of the concerns
raised were: (i) potential increase in noise and dust levels, (ii) poor sanitation due to
construction waste, (iii) water pollution of natural water bodies like Titas River, and (iv) potential

3
World Bank. Gas Infrastructure Development Project. 1995. Environment and Safety Assessment Report:
Summary. May 1994. http://www.worldbank.org/projects/P009533/gas-infrastructure-development-
project?lang=en&tab=documents&subTab=projectDocuments. (Accessed 3 August 2016)
4
ADB. Loan 2622/2623-BAN: Natural Gas Access Improvement Project. 2010. http://www.adb.org/projects/38164-
013/main#project-pds. (Accessed 3 August 2016)
5
Japan International Cooperation Agency. Preparatory Survey on the Natural Gas Efficiency Project in the People’s
Republic of Bangladesh. Final Report. March 2014
6
BGFCL. Annual Report 2013-2014. http://www.bgfcl.org.bd/~pavel/images/AnnaulReport2013-14/Page34-41.pdf.
(Accessed 4 August 2016)

4
disruption of local residents in their daily activities during construction. Concerns associated with
construction activities will be of short duration and temporary. Appropriate mitigation measures
will be implemented to address these concerns. Expectations include: (i) local priority in hiring
of workers and staff, (ii) engagement of local businesses/contractors, and (iii) timely and
appropriate compensation to persons that may be potentially affected by Component 1.

18. Consultations will continue during implementation, as and when needed. A one-page
flyer in Bangla about the project brief including the grievance redress mechanism (GRM) will be
made available to the public by BGFCL at the project office and in their offices in Barishar and
Dhaka as well as in their website.

Grievance Redress Mechanism

19. BGFCL has an existing grievance redress system (GRS) which is part of the mandatory
strategic objectives of the Annual Performance Agreement of the GoB. BGFCL signs a yearly
agreement with Petrobangla to comply with GRS. The GRS requires a mandatory designation of
staff as focal point. The name of the designated staff and contact details are disclose to the
website of BGFCL.

20. To meet the requirements of SPS 2009, a grievance redress mechanism (GRM) will be
established by the Project Implementation Unit (PIU) of BGFCL to deal with complaints from
affected persons (APs) that may be potentially raised during the implementation of Component
1. The APs can seek redress of their grievance at three levels: (i) the PIU-BGFCL or through the
representative of the Engineering, Procurement and Construction (EPC) Contractor during
construction phase, (ii) through the grievance redress committee (GRC), and (iii) the appropriate
courts of law.7 GRC will be set up by the PIU-BGFCL as soon as Component 1 commences and
will consist of representative from the EPC Contractor, local government unit, designated staff of
PIU-BGFCL on environmental issues (or a Consultant), and witness of the AP. PIU-BGFCL will
ensure the representation of women in the GRC. The BGFCL staff designated in the existing
GRS required by Petrobangla will be part of the GRC.

Environmental Management Plan

21. An environmental management plan (EMP) was prepared for the impacts identified for
Component 1 (see Table 9.1). An estimated Tk320,000 per year will be allocated to conduct
the activities included in the environmental monitoring plan. This amount will vary depending on
the results during implementation.

22. During construction stage, the EPC Contractor will be responsible for implementing the
relevant requirements in the EMP under the supervision of PIU-BGFCL. Prior to awarding of the
civil works contract, the EPC Contractor will recruit an environmental staff (or a Consultant) to
deal with environmental concerns associated with Component 1. PIU-BGFCL will provide an
orientation to the EPC Contractor(s) and workers on their responsibility to comply with the EMP
and the requirements of ADB and GoB during construction stage and until the end of first year
of the operation stage.

7
Members of GRC will consist of: (i) BGFCL staff designated for GRS, (ii) representative from the EPC Contractor
(during construction phase and first year of operation phase), (iii) local government unit representative, (iv) PIU-
BGFCL designated staff (or consultant) on environmental issues, and (v) witness of the complainant.

5
23. During the second year of the operation stage, PIU-BGFCL will designate a staff who will
be responsible to manage environmental compliance to ADB and GoB. Environmental staff
may come from the Environment and Safety Department of BGFCL or will recruit a staff co-
terminus with the project.

24. Environmental monitoring reports will be submitted by BGFCL to ADB semi-annually

during construction stage and annually during operation stage. These monitoring reports will be
posted to ADB website as provided for in SPS 2009 and Public Communications Policy (PCP)
2011. PIU-BGFCL will ensure compliance to the requirements of ADB and GoB.

Conclusion and Recommendation

25. There is a great need to install compressors at Location A in Titas Gas Field to ensure
the reliable supply of natural gas at the required pressure to facilitate transmission. Location A is
about 0.6 hectare (ha) that will accommodate seven compressors where five compressors will
be in operation at a time while two compressors will be standby.

26. Installation of these compressors will not cause significant adverse environmental
impacts given that it is within an area considered for industrial use. Vegetation is mainly
grassland. The DOE has issued the ECCs for the existing facilities. Since Component 1 is within
an existing facility, the DOE advised the BGFCL to submit an EMP in securing the ECC instead
of the usual IEE and EIA requirements for red category project.

27. Potential environmental impacts during construction stage may include increased level
of noise and dusts, generation of waste from construction works, and disruption to daily
activities in Ghatura mauza in Sadar Upazila, Brahmanbaria. These potential impacts can be
mitigated by best construction engineering practices and adherence to relevant regulations of
GoB and requirements of ADB. Mitigation measures are included in the EMP and the
parameters for monitoring have been identified in the environmental monitoring plan.

28. While the local people consulted support the project, they raised concerns on
compensation and participation in potential business opportunities. Continuous communication
and/or consultations will be conducted during implementation on community safety and
environmental management. Should there be any concerns not addressed during
consultations, a grievance redress mechanism will be will be set up by the PIU-BGFCL.

29. This draft IEE will be publicly disclosed at the ADB website as required by SPS 2009
and PCP 2011. A project brief and/or factsheet which would include details on GRM will be
prepared in Bangla and made available to the public at the PIU-BGFCL field office, in Barishar
and in its liaison office in Dhaka.

30. Component 1 will have potential environmental impacts but these can be readily
mitigated. Overall, the improvement in the supply of natural gas as a result of Component 1 is
expected to contribute in meeting the growing demand for natural gas and in the economic
development of Bangladesh.

6
1.0 BACKGROUND

1.1 Overview of the Project

31. The Project aims to increase the contribution of the energy sector to sustainable
economic growth by financing the improvement of efficiency of gas production from existing gas
field, and expansion of gas transmission pipeline through construction of gas transmission
pipelines. The Project details are shown in Table 1.1. The total financing is estimated at $447.6
million. ADB will arrange financing of the foreign currency cost from its resources and through
cofinancing with the Asian Infrastructure Investment Bank (AIIB).

Table 1.1 Project Details

Project Description Executing Agency

Component 1: Installation of Installation of wellhead gas
Bangladesh Gas Fields
well head compressors compressor at Titas Field
Company Ltd. (BGFCL)
(Location A)
Component 2: Construction of Construction of 36-inch, 181 km
Gas Transmission
Chittagong-Bakhrabad gas Chittagong-Bakhrabad gas
Company Ltd. (GTCL)
transmission pipeline transmission pipeline

32. Physical interventions of the Project will involve two components: (i) installing seven new
wellhead gas compressors; and (ii) constructing 181 km 36 inch Chittagong-Bakhrabad gas
transmission pipeline.

33. As the EAs, BGFCL and GTCL will each set up a Project Implementation Unit (PIU) for
implementing, monitoring, and reporting on the progress of project implementation to ADB and
GoB. The PIU will consist of technical, financial, and procurement staff, while additional
safeguards support will be hired, as and when required. At present, BFGCL, and GTCL have
their own environment unit. PIU will be responsible for safeguards compliance and project
impacts monitoring. If necessary, consulting services will be provided to the PIU as support to
supervision of technical due diligence process, safeguards due diligence, monitoring, and
reporting.

34. A Steering Committee, chaired by the Secretary, EMRD will be established who will be
responsible for coordinating the overall implementation of the Project. Members of Steering
Committee will be the Chairman, Petrobangla, Managing Directors of BGFCL, GTCL and
representatives from the Finance Division, Planning Commission, Economic Relations Division
(ERD), and Implementation Monitoring and Evaluation Division (IMED).

1.2 Environmental Requirements for the Project

35. The Project will adopt the ADB’s Safeguard Policy Statement (SPS) 2009 as the unified
environmental assessment and planning process for consultation, disclosure requirements and
safeguard documentation to meet the safeguard principles and requirements of both of ADB
and the AIIB. Therefore, the Project will follow the environmental policies and review
procedures of ADB as embodied in SPS 2009 as well as the relevant environmental
requirements of the GoB. The Project is classified as Category B on environmental safeguard
based on SPS 2009 which requires the preparation of an IEE.8
8
ADB, Safeguard Policy Statement, June 2009, para. 50, p.19.

7
36. In terms of the environmental requirements of GoB under DOE, the project will be
subject to the provisions set forth in the ECA of 1995 and the ECR 1997. According to these
environmental regulations, the components fall within the Red category requiring both an IEE to
secure the LCC from the DOE and an EIA to obtain the ECC after securing the LCC.

2.0 POLICY, LEGAL, AND ADMINISTRATIVE FRAMEWORK

2.1 Environmental Requirements of Bangladesh

37. The following presents the regulatory agency, process, regulations and international
environmental agreements relevant to the Project.

2.1.1 Environmental Agency

38. The Ministry of Environment and Forests (MOEF) is the agency that plans, promotes,
coordinates and oversees the implementation of programs and plans on environment and
forestry. MOEF manages all national environmental matters and is responsible for activities
such as prevention and control of pollution, forestation and regeneration of degraded areas and
protection of the environment. MOEF also conducts surveys, impact assessment, control of
pollution, research, and collection and dissemination of environmental information and creation
of environmental awareness among all sectors in Bangladesh.

39. MOEF performs its regulatory functions through DOE, which was created in 1989 as the
primary government agency entrusted with regulating and enforcing environmental
management regulations to ensure sustainable development and to conserve and manage the
environment. DOE ensures the consistent application of environmental rules and regulations,
and provides guidance, training and promotional campaign on improving the awareness of
environmental issues.

2.1.2 Applicable Environmental Regulations

40. The main environmental regulations in Bangladesh to ensure that projects are
implemented sustainably include the ECA of 1995 and the ECR of 1997.

41. ECA together with its amendments made in 2000, 2002 and 2010 sets forth the
requirements for the protection of the environment, improvement of environmental standards,
and the control and abatement of environmental pollution. By this Act, DOE is mandated to
undertake any activity needed to conserve and enhance the quality of environment and to
control, prevent and mitigate pollution.

42. The ECR provides for the rules relevant to the declaration of ecologically-critical areas,
securing of environmental clearance certificate, environmental quality standards, acceptable
limits for discharges of waste, and environmental guidelines on pollution prevention. Overall, the
ECA and ECR outline the regulatory mechanism to protect the environment in Bangladesh.

43. Requirement for Environmental Clearance Certificate According to Section 12 of

ECA 1995, no industrial unit or project can be established or undertaken without securing an
ECC from the Director General, DOE. Based on ECR 1997, DOE has classified various
development interventions according to the potential adverse environmental impacts for the
purpose of issuing the ECC. This classification includes: (i) green, (ii) orange-A, (iii) orange-B,

8
and (iv) red. Green category are industries or projects considered to be relatively pollution-free,
thus, no environmental study will be required while the Red category are industries/projects
which may cause significant adverse environmental impacts and therefore, require an EIA.

44. An ECC is issued by the DOE for all existing industrial units and projects, and to all
proposed industrial units and projects under the Green category. For projects and industrial
units classified as Orange-A, Orange-B, and Red, securing the ECC involves two steps: (i)
issuance of LCC, and then (ii) the ECC.

45. The project components (i.e., natural gas compressor, gas transmission pipeline, and
gas distribution pipelines) fall within the Red category following the classification of DOE. As
such, the EAs will be required to secure LCC and ECC. Figure 2.1 shows the process of
securing ECC for a Red category project while Table 2.1 presents the relevant national
environmental regulations, and other laws and policies while Annex 1 gives the relevant
environmental quality standards of Bangladesh.

Figure 2.1 ECC Application Process for Red Category Project

Table 2.1 Relevant National Regulations, Laws and Policies

Regulation Brief Description Remarks

Environment Court Act This Act is under the Judiciary and MOEF The EAs will ensure that all
2000 (amended in 2002 to ensure the resolution of disputes on potential environmental
and 2010) environmental and social damages issues/complaints will be dealt
resulting from any development activities. with effectively at the project
This Act also allows for the completion of level through the Project
environment-related legal proceedings Implementation Unit (PIU). At
effectively. present, the EAs have a
grievance redress system (GRS)
to address project-level
complaints. GRS is part of the
GoB Annual Performance
Management System.

9
 Regulation Brief Description Remarks
ADB requires the establishment
of a grievance redress
mechanism in its funded-
projects known to cause
potential environmental impacts.
Vehicle Act 1927, the These are under the Bangladesh Road BRTA regulations on vehicular
Motor Vehicles Ordinance Transport Authority (BRTA) which emissions and noise will be
1983, and Bengal Motor regulates vehicular emissions and noise complied with by vehicles that
Vehicle Rules 1940 including road safety. may be used during construction
and operation of the project
components.
Factories Act 1965 and These regulations are the Ministry of Workers recruited under the
Bangladesh Labour 2006 Labour which provides for the project will be provided with
occupational rights and safety of factory what is relevant to them as set
workers and the provision of comfortable forth in these regulations.
work environment and reasonable
working conditions.
The Forest Act 1927 Primary aim is to protect the forest No natural gas pipelines will be
(amended in 1982 and resources and this Act is under MOEF. funded if it will traverse identified
1989) protected forest areas.
National Energy Policy Under MPEMR and consistent with Components will be consistent
(NEP) 2008 Vision 2021, this Policy focuses on with NEP 2008.
energy security and efficiency, financial
transparency, cost recovery, and a bigger
role for the private sector. The Policy
also identifies fuel strategies for energy
sustainability and security according to
priority: (i) natural gas, (ii) coal, (iii)
energy efficiency, (iv) renewable energy,
and (v) nuclear.
Telegraph Act 1885 This Act is under the Ministry of Posts The Project will refer to the
and Telecommunication which provides Bangladesh
power to the Telegraph Authority to alter Telecommunications Company
position of gas or water pipes or drain Limited (BTCL) on the selection
(Sect. 14, a and b). of gas pipeline route.
Electricity Act 1910 This Act relates to the supply and use of The Project will refer to the
electrical energy, and which allows any applicable provisions in this Act.
person to secure a license to supply
energy and to put down or place
electrical supply lines for the transmission
of energy. Sect 19(1) of the Act provides
that the licensee, in the exercise of any of
the powers conferred by or under this
Act, will cause as little damage, detriment
and inconvenience as may be, and will
make full compensation for any damage,
detriment or inconvenience caused by
him or by any one employed by him.
Gas Safety Rules 1991 Provides guidelines on the materials, EAs have been complying with
(amended 2003) design and construction of gas these safety rules.
transmission and pipeline industry. This
Safety Rules were based on the
American National Standard Codes for
Gas Transmission and Piping System.

10
 Regulation Brief Description Remarks
The Antiquities Act 1968 Regulation on the preservation and Selection of project sites will
(amended 1976) protection of antiquities. refer to the requirements of this
Act.
Natural Water Bodies According to this Act, the character of Gas transmission and
Protection Act 2000 water bodies i.e. rivers, canals, tanks, or distribution pipelines that will
floodplains identified as water bodies in cross rivers, ponds, canals, and
the master plans or in the master plans drainage channels will refer to
formulated under the laws establishing this Act and will secure the
the municipalities in division and district required approval and
towns shall not be changed without clearances.
approval of concerned ministry. This Act
is under the Rajdhani Unnayan
Kartipakkha/Town Development
Authority/Municipalities.
Wildlife (Protection and The Act provides for the conservation and In December 2013, IUCN
Safety) Act 2012 safety of biodiversity, forest and wildlife of Bangladesh launched its
the country by repealing the existing law flagship project of updating the
relating to conservation and management national Red list.
of wildlife of Bangladesh.
Sites of subprojects will ensure
that no species protected by this
Act and the updated IUCN Red
List (Bangladesh) will be
affected.
Source: ADB Consultant, November 2015.

2.1.3 Relevant International Environmental Agreements

46. Aside from the national environmental regulations, international environmental

agreements where Bangladesh is a party will be considered, as appropriate, in the screening
and final selection of project components. Table 2.2 lists applicable international environmental
agreements that can provide guidance during the site selection and implementation of the
project:

Table 2.2 Bangladesh Relevant International Environmental Agreements

International
Environmental Description Date Ratified Comments
Agreement
Convention Concerning Entered into force on 23 3 November Site selection will refer to the
the Protection of the November 1972, this convention 1983 existing list of natural and cultural
World Cultural and defines and provides for the sites, if available, or consult with
Natural Heritage (Paris conservation of the world`s relevant government agency to
1972) heritage by listing the natural avoid impacts in areas of cultural
and cultural sites whose value and natural heritage value.
should be preserved.
Convention on Wetlands Provides a framework for 21 September Identified Ramsar sites
of International national action and international 1992  Tangauar Haor (Northeast of
Importance especially as cooperation for the conservation Bangladesh) – declared in 1999
Waterfowl Habitat and sustainable use of wetlands  Parts of Sundarban Reserved
(Ramsar 1971) and their resources. This Forest (Southwest of
convention entered into force on Bangladesh) – declared 1992
21 December 1975.

11
 International
Environmental Description Date Ratified Comments
Agreement
Project component site selection
will avoid these two Ramsar
sites.
Convention on Biological A framework for biodiversity, 3 May 1994 Project components will refer to
Diversity (1992) entered into force on 29 the applicable National
December 1993, and requires Biodiversity Strategy and Action
signatories to develop national Plan in selecting the sites. Any
strategies (National Biodiversity replacement of cleared
Strategy and Action Plan) for the vegetation resulting from the
conservation and sustainable project will be consistent with the
use of biological diversity. objectives and priorities of the
Action Plan.
Convention on Entered into force on 1 July 20 November Project components will ensure
International Trade in 1975, this framework addresses 1981 that it will not cause any
Endangered Species of the overharvesting and harvesting and exploitation of
Wild Fauna and Flora exploitation patterns that wild flora and fauna during pre-
(Washington 1973) – also threaten species of flora and construction, construction,
known as CITES fauna. Under this Convention, operation, and decommissioning.
the governments agree to restrict
or regulate trade in species that
are threatened by unsustainable
patterns and to protect certain
endangered species from
overexploitation by means of a
system of import/export permits.
Convention on the Sets the framework for 1 December Consult relevant government
Conservation of Migratory agreements between countries 2005 authorities and/or experts to
Species of Wild Animals that are important to the avoid areas known to be habitat
(Bonn 1979) migration of threatened species. of migratory species of wild
This Convention came into force animals in selecting sites of
on 23 June 1979. project components.
Vienna Convention for A framework for efforts to protect 2 August 1990 Project components will not use
the Protection of the the globe’s ozone layer by chemicals that can affect the
Ozone Layer means of systematic ozone layer such as methyl
22 March 1985 observations, research and chloroform, a solvent generally
information exchange on the used for industrial processes.
effects of human activities on the
ozone layer and to adopt
legislative or administrative
measures against activities likely
to have adverse effects on the
ozone layer.
Montreal Protocol on This international treaty was 2 August 1990 Project components will not use
Substances that Deplete entered into force on 1 January chemicals that can cause harm
the Ozone Layer (a 1989 and is designed to protect to the ozone layer.
protocol to the Vienna the ozone layer by phasing out
Convention for the the production of numerous
Protection of the Ozone substances that are responsible
Layer) for ozone depletion. This treaty
also requires controlling
emissions of substances that
deplete ozone.

12
 International
Environmental Description Date Ratified Comments
Agreement
Kyoto Protocol (1997) An international agreement 22 October 2001 Project components will ensure
adopted on 11 December 1997 zero or minimal fugitive natural
and entered into force on 16 gas emissions.
February 2005, which commits
its Parties to set internationally- Emissions from compressors will
binding emission reduction comply with the limits set by
targets. This agreement is linked DOE.
to the United Nations Framework
Convention on Climate Change
(UNFCCC).
UNFCCC (1992) This framework came into force 15 April 1994 Project components will ensure
on 21 March 1994 and aims to zero or minimal fugitive natural
achieve stabilization of gas emissions.
greenhouse gas (GHG)
concentrations in the
atmosphere at a level low
enough to prevent dangerous
anthropogenic interference with
the climate system.
Basel Convention on the This convention came into force 1 April 1993 Project components will not
Control of Transboundary on 5 May 1992 which aims to generate hazardous wastes.
Movements of Hazardous reduce the amount of waste Disposal of chemicals used (if
Wastes and their produced by signatories and and when needed) will follow the
Disposal (1989) regulates the international traffic instructions in the material data
in hazardous wastes. safety sheet and this convention.
UNESCO World Heritage This convention describes the 3 August 1983 UNESCO World Heritage Sites:
Convention 1972 concepts of nature conservation (Accession)
and the preservation of cultural Accession – the  Sundarbans Reserve Forest
properties. Parties agree to state accepts the (1997)
identify and nominate properties offer or the  Historic Mosque City of
on their national territory to be opportunity to Bagerhat (1985)
considered for inscription on the become a party  Ruins of the Buddhist Vihara of
World Heritage List, gives details to a treaty Paharpur (1985)
of how a property is protected, already
and provides a management negotiated and Project components will make
plan for its upkeep. signed by other sure that site selection will not
states affect these sites.
Source: ADB Consultant, November 2015.

13
 2.2 Environmental Requirements of Asian Development Bank and the Asian
Infrastructure Investment Bank

47. This section discusses the key elements of the environmental requirements of ADB and
the cofinancier, AIIB applicable to the Project.

2.2.1 Asian Development Bank

48. SPS 2009 provides for the environmental requirements and review procedures of ADB
and applies to all projects and grants they finance. SPS 2009 comprises three key safeguard
areas: environment, involuntary resettlement, and indigenous peoples; and aims to avoid
adverse project impacts to both the environment and the affected people; minimize, mitigate
and/or compensate for adverse project impacts; and help Borrowers to strengthen their
safeguard systems and to develop their capacity in managing the environmental and social
risks.

49. At the project identification phase, ADB uses a categorization system to indicate the
significance of potential environmental impacts and is determined by the category of its most
environmentally-sensitive component, including direct, indirect, cumulative, and induced impacts
within the project's area of influence. The project categorization system is described in Table
2.3.
Table 2.3 Environmental Classification According to SPS 2009
Category Definition Assessment Requirement
A Likely to have significant adverse Environmental Impact Assessment (EIA)
environmental impacts that are
irreversible, diverse, or unprecedented,
and may affect an area larger than the
sites or facilities subject to physical
works.
B Likely to have adverse environmental Initial Environmental Examination (IEE)
impacts that are less adverse than
those of Category A. Impacts are site-
specific, few if any of them irreversible,
and in most cases mitigation measures
can be designed more readily than
Category A.
C Likely to have minimal or no adverse No environmental assessment is required
environmental impacts. but the environmental implications of the
project will be reviewed.
FI Project involves investment of ADB FIs will be required to establish an
funds to or through a financial environmental and social management
intermediary (FI). system commensurate with the nature and
risks of the FI's likely future portfolio to be
maintained as part of the FI's overall
management system.
Source: ADB. Safeguard Policy Statement 2009, p. 19. http://www.adb.org/sites/default/files/institutional-
document/32056/safeguard-policy-statement-june2009.pdf.

14
 2.2.2 Asian Infrastructure Investment Bank

50. Established in October 2014 as a multilateral development bank, the Asian Infrastructure
Investment Bank (AIIB) puts forward strong policies on governance, accountability, financial,
procurement, and environmental and social frameworks.9 The Multilateral Interim Secretariat for
Establishing the AIIB has developed the Draft Environmental and Social Framework and has
completed its public consultations on 23 October 2015. AIIB is expecting to have the
Environmental and Social Framework operational by the end of 2015.10

51. The Draft Environmental and Social Framework consist of the environmental and social
policy (ESP) and three mandatory environmental and social standards which set out the
environmental and social requirements applicable to specific aspects of the AIIB operations.11
The environmental and social standards (ESS) are: Standard 1 – Environmental and Social
Assessment, Standard 2 – Involuntary Resettlement, and Standard 3 – Indigenous Peoples.

52. ESP is the overarching policy to facilitate the achievement of AIIB’s mandate in
supporting infrastructure development and in enhancing connectivity in Asia by integrating
sound environmental and social management into its operations. Based on the ESP and ESS,
AIIB classifies its projects according to four categories indicated in Table 2.4.

Table 2.4 Draft Environmental Classification of AIIB

Category Definition Assessment Requirements
A Likely to have significant adverse Environmental and social impact
environmental and social impacts assessment (ESIA) and an
that are irreversible, diverse or environmental and social
unprecedented that may affect an management plan included in the
area larger than the sites or facilities ESIA
subject to physical works.
B It has a limited number of potential AIIB determines the specific
adverse environmental and social environmental and social
impacts; the impacts are not assessment requirements on a
unprecedented, and are neither case-by-case basis.
irreversible nor cumulative; they are
limited to the area of the operation;
and have been successfully
managed using good practice in an
operational setting.
C It is likely to have minimal or no No need for ESIA but a review of the
adverse environmental and social environmental and social
impacts. implications of the operation is
required.
FI Involves financing to or through a
---
financial intermediary (FI)
Source: AIIB. Draft Environmental and Social Framework, 3 August 2015, p.8.

9
AIIB. What is the Asian Infrastructure Investment Bank?. http://www.aiib.org/html/aboutus/AIIB/. (Accessed 17
November 2015)
10
AIIB. Consultations on Draft Environmental and Social Framework.
http://www.aiib.org/html/theme/Consultations_Draft/. (Accessed 12 November 2015)
11
AIIB. Draft Environmental and Social Framework, 3 August 2015.
http://www.aiib.org/uploadfile/2015/0907/20150907061253489.pdf. (Accessed 11 November 2015)

15
53. The ADB and the AIIB agreed to adopt SPS 2009 as the single environmental and social
assessment and planning process for a unified documentation, consultation, and disclosure
requirements to be complied by the EAs. SPS 2009 has 11 environmental safeguard principles
and Table 2.5 presents a comparison of the environmental safeguard principles of ADB, AIIB,
and the GoB. Generally, the environmental requirements of ADB and the AIIB are similar.
However, compared to the GoB requirements, there are several gaps (e.g., setting up of
grievance redress mechanism and public disclosure of environmental reports) but can be readily
addressed and complied with by the EAs.
Table 2.5 Comparison of Environmental Safeguard Principles
ADB AIIB
SPS 2009 Draft Environment and Social GOB
Principles Delivery Process Framework (3 August 2015)
1 Use of screening Uses sector-specific rapid Assigns categories based on  ECA 1995 and ECR 1997
process to environmental potential social and set screening criteria to
determine the assessment checklist for environmental impacts classify industries/projects
appropriate screening and assigns  A – likely to have significant based on potential
environmental categories based on adverse environmental and environmental impacts as
assessment potential impacts: social impacts that are follows:
 A - EIA required irreversible, diverse or
(irreversible, diverse or unprecedented; Environmental Green (pollution-free), Orange-
unprecedented adverse and Social Impact Assessment A, Orange-B and Red (cause
environmental impacts) (ESIA) required significant environmental
 B - IEE required  B - limited number of potential impacts).
 C - no environmental adverse environmental and
assessment required social impacts, not These screening criteria are
but a review of unprecedented, and are neither based on project or industry
environmental irreversible nor cumulative, type and do not consider the
implications limited to the area of the scale and location. The
 FI - ESMS required operation, and have been category determines the level
successfully managed using of environmental assessment.
good practice in an operational
setting; specific environmental
and social assessment
requirements on a case-by-
case basis
 C – minimal or no adverse
impact; no assessment
required but implications
reviewed
 FI – Involves financing through
FI
2 Conduct an  EIA and IEE - Identify  ESIA - Identify potential direct, Industry/project category
environmental potential impacts on indirect, cumulative and Green - no environmental
assessment physical, biological, induced environmental and assessment required
physical cultural social risks and impacts to Orange A - no IEE or EIA
resources, and physical, biological, required but must provide
socioeconomic aspects in socioeconomic (including process flow, lay-out showing
the context of project's impacts on livelihood through effluent treatment plant, etc.
area of influence (i.e., environmental media, health Orange B - IEE required
primary project site and and safety, vulnerable groups, Red - both IEE and EIA are
facilities, and associated and gender) and cultural required
facilities) resources in the context of the
 ESMS for FIs Operation’s area of influence
3 Examine  Analyze alternatives to  Examine alternatives in terms  Regulations (i.e., ECA 1995
alternatives the project's location, of location, design, technology and ECR 1997) do not
design, and technology and components, and their require specifically the
 Document rationale for potential environmental and identification and analysis of
selecting the particular social risks and impacts. alternatives

16
 ADB AIIB
SPS 2009 Draft Environment and Social GOB
Principles Delivery Process Framework (3 August 2015)
project location, design,  Consider "no project"
and technology alternative
 Consider "no project"  Document rationale for
alternative selecting particular alternative
proposed
4 Prepare an  EMP to include  Environmental and social  EMP and procedures
environmental monitoring, budget and management plan (ESMP) to included in the IEE and EIA
management plan implementation be included in the ESIA (i.e., Orange-A, Orange-B,
(EMP) arrangements and Red category projects)
5 Carry out  Starts early and  Begins early in the project  Public consultation and
meaningful continues during preparation stage, is to be participation are not
consultation implementation carried out on an ongoing basis mandatory based on ECA
 Undertaken in an throughout the implementation 1995 and ECR 1997
atmosphere free of  Undertaken in an atmosphere  Grievance redress
intimidation free of intimidation or coercion mechanism is not mentioned
 Gender inclusive and  Gender inclusive, responsive in ECA 1995 and ECR 1997
responsive and tailored to the needs of  EIA format required by DOE
 Tailored to the needs of vulnerable groups includes stakeholders
vulnerable groups  Incorporation of all relevant consultation
 Allows for the views of people affected and
incorporation of all other stakeholders into
relevant views of decision-making.
stakeholders  Set up grievance redress
 Establish a grievance mechanism to receive and
redress mechanism facilitate resolution
6 Timely disclosure  Draft EIA report posted  Draft environmental and social  No requirement for public
of draft on ADB website at least assessment reports before disclosure of environmental
environmental 120 days prior to Board appraisal stage reports but DOE posts the
assessment consideration  Final or updated environmental Minutes of the Meeting on
(including the  Draft EA/EARF prior to and social assessment reports the application for
EMP) appraisal upon receipt environmental clearance
 Final or updated EIA/IEE  Environmental and social certificate to its website,
upon receipt assessment reports during http://www.doe-
 Environmental implementation under the bd.org/minutes.php
monitoring report frameworks upon receipt
submitted by borrowers
upon receipt
7 Implement EMP  Prepare monitoring  Set up procedures to monitor  ECC is subject to annual
and monitor reports on the progress progress of ESMP renewal based on
effectiveness of EMP implementation compliance of the conditions
 Retain qualified and  Document, submit and disclose set by DOE
experienced external monitoring reports
experts or NGOs to  Retain qualified experts to
verify monitoring verify monitoring information
information for Category for Operations with significant
A projects risks and impacts
 Prepare and implement  Use independent advisory
corrective action plan if panels or specialist individual
non-compliance is experts to monitor
identified implementation of complex
 Requires submission of Operation
quarterly, semi-annual,
and annual reports to
ADB for review
8 Avoid areas of Provides guidance on Avoidance of critical areas  ECA 1995 and ECR 1997
critical habitats critical habitats included identifies ecologically-critical
(use of areas and the rules to
precautionary protect them

17
 ADB AIIB
SPS 2009 Draft Environment and Social GOB
Principles Delivery Process Framework (3 August 2015)
approach to the
use, development
and management
of renewable
natural resources)
9 Use pollution  Refers to World Bank’s  Refers to World Bank Group’s  Ambient and emission
prevention and Environmental Health, Environmental, Health, and standards included in ECA
control and Safety (EHS) Safety Guidelines 1995 and ECR 1997
technologies and General Guidelines 2007
practices  If national regulations
consistent with differ, more stringent will
international good be followed
practices  If less stringent levels
are appropriate in view of
specific project
circumstances, provide
full and detailed
justification
10 Provide workers  Refers to EHS General Covers working conditions and  Occupational health and
with safe and Guidelines 2007 (or any community health and safety safety standards included in
healthy working updates) the Factories Act 1965 and
conditions the Bangladesh Labour Law
2006.
11 Conserve physical  Use of field-based  Use of field-based surveys and  Preservation and protection
cultural resources surveys and experts in experts in assessment of cultural resources are
(PCR) and avoid the assessment  Use “chance find “procedures within the Antiquities Act
destroying or  Consult affected 1968.
damaging them communities on PCR
findings
 Use chance find
procedures for
guidance
Source: ADB consultant, November 2015

2.3 Compliance of Component 1 to Environmental Requirements

2.3.1 Requirements of DOE

54. According to Sect 12 of ECA 1995 and ECR 1997, Component 1 is a Red category
project requiring an IEE for the issuance of the LCC and an EIA for the ECC (after securing the
LCC). Given that Component 1 will be located within an existing natural gas facility owned and
operated by BGCFL with previous ECCs, BGFCL requested DOE on 3 November 2015 for an
exemption from submitting an IEE and EIA but instead consider their submission for an
environmental management plan (EMP). BGFCL has a similar project where it required the
installation of six wellhead compressors in their existing gas fields: Narsingdi Gas Fields (3
compressors), and Titas Gas Field-Location C (3 compressors). For these wellhead
compressors in the two gas fields, DOE issued an ECC 17 July 2014 with EMP as supporting
document. Based on the request of BGFCL, the DOE agreed on 25 January 2016 that for
Component 1, an EMP will be submitted for the issuance of the ECC. On 11 August 2016, DOE
issued the ECC to BGFCL for the installation of the seven compressors at Location A. The
ECC is valid for one year and shall be renewed subject to compliance with the 20 terms and
conditions set out by DOE such as strict implementation of the EMP. Another condition is that
all parameters of effluent, gas emissions, noise, and solid waste shall be within the limits of

18
ECR 1997 and in case on non-coverage by ECR 1997, the World Bank Environment, Health
and Safety Guidelines will be adhered to.

2.3.2 Requirements of ADB and AIIB

55. Based on SPS 2009, the Project is category B requiring an IEE. Thus, this IEE is
prepared to meet the requirements of ADB. Aside from complying with the provisions set forth in
SPS 2009, ADB also requires BGFCL to comply with the environmental requirements of the
DOE. BGFCL will provide to ADB the ECC to be issued by the DOE for Component 1.

3.0 DESCRIPTION OF THE PROJECT

3.1 Need for the Project

56. Natural gas is a significant source of commercial energy in Bangladesh and is the prime
mover of its national economy. BGFCL is one of the operating companies under the Bangladesh
Oil, Gas and Mineral Corporation (Petrobangla) entrusted with production of natural gas from its
producing fields and processing of gas to the transmission pipeline system. Titas Gas Field is
one of the six gas fields being operated by BGFCL.

57. Commercial gas production in Titas Gas Field began in April 1968 and over time,
wellhead pressure of some wells has been decreasing gradually. It has been recorded that the
wellhead pressure decreases at an average rate of 90 pounds per inch (psi) per year and is
estimated that within the next 3-5 years, natural gas flow can no longer maintain the gridline
pressure at Location A of the Titas Gas Field without the installation of compressors before the
existing natural gas process plants. Gas compressors will be essential to augment gas
transmission capacity to meet the increasing gas demand.

58.
At present, 25 wells have been drilled at the Titas Gas Field. Out of these 25 wells, nine wells
(Titas# 1, 2, 4, 5, 7, 15, 20, 21 & 22) are adjacent to the site of the seven compressors. From
these nine wells (Location-A: 1, 4, 5, 7, 20, 21; Location-B: 2 and Location-F: 15, 22) about 230-
235 million standard cubic feet (MMSCF) of gas daily is being processed in Location-A. Given
this scenario, installation of seven wellhead gas compressors with a capacity of 60 MMSCF per
day has been considered. Out of the seven wellhead compressors, five compressors will
operate continuously and two compressors will be standby.

3.2 Location of the Project

59. Component 1 will be located within the Titas Gas Field owned and operated by BGFCL.
Titas Gas Field is in Ghatura Mauza in Sadar Upazila under the Brahmanbaria District and is
about 100 km northeast of Dhaka City, and approximately 40 kilometers (km) northwest from
the border of India. About 6,000 square meters (m2) or 0.6 hectare (ha) will be required for
Component 1 but no land acquisition will be needed as this will be located in Location “A” of the
Titas Gas Field. Location “A” is a restricted area and public entry is prohibited. Only authorized
access is allowed. Figure 3.1 shows the location of Titas Gas Field, Figure 3.2 presents the
location of Component 1, and Figure 3.3 shows the overview of Location A.

19
Figure 3.1 Location of Titas Gas Field

Figure 3.2 Location of Component 1

20
 Figure 3.3 Overview of Titas Gas Field Location A

3.3 Existing Natural Gas Facilities at Titas Gas Field

60. There have been 25 gas wells drilled so far at Titas Gas Field. The wells are spread over
nine different locations (i.e., Location-A, B, C, D, E, F, G, H & J) stretched at a distance of about
11 km. A daily average of 508.62 million cubic feet of gas was produced from this field in June
2016. The gas produced has been processed through eight glycol dehydration plants, four low-
temperature separation (LTS) units, and two units of LTS with glycol dehydration.

61. The by-product of gas processing from Titas Gas Field is condensate of about 353 barrels
(bbls) per day. This condensate is further processed in two fractionating plants with a capacity
of about 500 bbls each. The fractionation process yields liquid fuel as motor spirit (MS) and
high speed diesel (HSD). MS and HSD are sold to Padma Oil Company Limited. The two gas
treatment plant and one of the fractionating plants were financed by ADB.12

62. Some of the existing structures that support the operations of the natural gas facility in
Titas Gas Fields include waste treatment plant, waste pond, oil-water separator, pond for fire-
fighting office buildings including a reception and visitors orientation area on safety. An
underground fuel tank with dispensing unit is also part of the entire facility. This fuel dispensing
unit is licensed by the Department of Explosives. There is also a mosque near the office
buildings to serve the BGFCL staff.

3.4 Major Components of the Project

63. The compressor station will consist of compressor and driver units with ancillary facilities,
pipelines and associated valves, and office buildings for control unit. The equipment packages
and installations generally include:
a) Compressor and driver unit
b) Inlet scrubber
c) Inlet filter separator
d) Air cooler
e) Lube oil cooler
f) Liquid/waste storage tank
12
ADB. Project Performance Audit Report on the Second Natural Gas Development Project. November 1997. Loan
714-Bangladesh: Second Natural Gas Development Project. July 1984.
http://www.adb.org/sites/default/files/evaluation-document/35316/files/pe492.pdf (Accessed 3 August 2016)

21
 g) Fuel gas skid
h) Vent stack
i) Station isolation valves
j) Main line bypass valves
k) Flow meters
l) Motor control center/switch gear
m) Suction strainer
n) Anti-surge system
o) Cold recycle valve
p) Gas alternator
q) Fuel gas system and tank
r) Transformer
s) Instrument and utility air package
t) Fire water pumps and tank
u) Borehole and borehole pump
v) Water tank and purifier unit
w) Septic system
x) Security hose
y) Fire hydrant, and;
z) Control room.

64. Associated civil works for compressor foundation and ancillary facilities will be done within
the premises of Titas Gas Field. Figure 3.4 shows the general layout in the existing gas facility
at Titas Gas Field incorporating the proposed seven compressors of Component 1 while Table
3.1 presents the features of the compressor. Table 3.2 gives the natural gas composition in
Titas Gas Field.

Table 3.1 Features of the Compressor

Feature Description
Type of compressor Reciprocating
Total driver/engine power Approx. 14,430 Hp
Total number of units to be installed 7
Number of unit, operation at a time 5
Number of unit, standby 2
Source of fuel Natural gas from gas field
Capacity of each compressor 60 MMSCFD
Suction pressure of compressor 600-700 PSIG
Delivery pressure of compressor Minimum 1,200 PSIG
Daily output capacity of compressed gas 300 MMSCF
Daily fuel requirement for compressors 5 MMSCF
Daily water requirements 16 tons
Source of water supply Borehole/Deep tube well

Table 3.2 Chemical Composition of Natural Gas in Titas Gas Field

Chemical Composition Percent by Mole
Methane, CH4 96.924
Ethane, C2H6 1.805
Propane, C3H8 0.361
i-butane, C4H10 0.087
n-butane 0.052
i-pentane, C5H12 0.022
n-pentane 0.017
Hexane, C6H14 0.039

22
 Chemical Composition Percent by Mole
Heptane, C7H16 0.018
Nitrogen, N2 0.367
Carbon dioxide, CO2 0.308
Source: Japan International Cooperation Agency. Preparatory Survey on the Natural Gas Efficiency Project
in the People’s Republic of Bangladesh. Final Report. March 2014

Figure 3.4 General Layout of Compressors

3.5 Reciprocating Compressor

65. A gas compressor is a mechanical device that increases the pressure of gas by reducing
its volume. Compressors are similar to pumps which can increase the pressure on a fluid and
can transport the fluid through a pipe. Component 1 will install reciprocating compressors.

66. Positive displacement units are those in which successive volumes of gas are confined
within a closed space and elevated to a higher pressure. Reciprocating compressors are
positive displacement machines where the compressing and displacing element is a piston
having a reciprocating motion within a cylinder. As the piston moves forward in the cylinder, it
compresses the air or gas into a smaller space, thus raising its pressure.

67. The reciprocating compressors, which are commonly called "piston compressors,"
compress gas by using a piston, cylinder, and valve arrangement. Major components in a
typical reciprocating compressor are frame or crankcase, cylinder, crankshaft, piston, bearings,

23
and compressor valves. The frame is a heavy, rugged housing containing all the rotating parts
and on which the cylinder and crosshead guide is mounted. The cylinder is a pressure vessel
that contains the gas in the compression cycle. The distance piece provides separation between
the compressor cylinder and the compressor frame. The crankshaft rotates around the frame
axis and drives the connecting rod, piston rod, and piston. The piston is located at the end of the
piston rod and acts as the movable barrier in the compressor cylinder. Bearings located
throughout the compressor frame assure proper radial and axial positioning of compressor
components. Main bearings are fitted in the frame to properly position the crankshaft. The
essential function of compressor valves is to permit gas flow in the desired direction and to
block all flow in the opposite (undesired) direction. Figure 3.4 shows the process flow with
Component 1 synchronized with the existing equipment while Figure 3.5 shows a photograph of
a reciprocating compressor.

Figure 3.4 Proposed Layout of Component 1 with Existing Facility

Figure 3.5 Photograph of Reciprocating Compressor

24
 3.6 Environmental Considerations

68. BGFCL gives special priority on the environment and safety activities at all stages of
their existing installations. Safety rules are properly followed and personal protective equipment
are used by staff.

69. BGFCL has a total of 11 staff under the Environment and Safety Department (ESD). The
ESD manages environment and safety related activities and conducts visits to installations.

70. For Component 1, wastewater that may be generated, which is minimal, will be disposed
of properly in the pond within the existing facility. Wastewater will mainly come from the repair
and maintenance of the compressors. Oil and water separator will be used for oily drains from
repair and maintenance. Wastewater and ambient air quality standards of DOE will be provided
to the manufacturer(s)/supplier(s) of the compressors. Guaranteed emissions from the
compressors will comply with the DOE requirements. The compressors will require 5 MMSCF of
natural gas to power its operations.

71. Saplings of different types of trees species common in Brahmanbaria under the
plantation program of BGFCL will continue as mitigation measure to contain noise levels from
the existing facility and enhance air quality. Aside from the fire-fighting system as part of
emergency preparedness, sufficient number of fire extinguishing equipment is available at
strategic location within the existing facility in the event of fire. BGFCL has an existing
environment safety management system (ESMS) since 2000. The safety and hazard mitigation
plan of BGFCL is given in Annex 5.

72. Trainings on environmental management and safety-related awareness among all

officers and staff are part of continuing human resources development. Special importance is
given on environmental considerations and safety operations associated with the development
activities of BGFCL. No major maintenance works in areas considered critical is done without
prior consultation and clearance from relevant agencies of GoB to ensure occupational and
public safety.

3.7 Proposed Project Schedule

73. Component 1 will be implemented approximately 1,800 days following the 365 days of
operation and maintenance (O & M) by the EPC Contractor. Table 3.3 gives the proposed
implementation schedule.

Table 3.3 Project Implementation Schedule

Activity Target Date

Signing of Loan agreement between GoB and ADB July 2016 (to be updated)
Engagement of Consultant 31 Oct 2016
Floating of the Bid 1 January 2017
Technical bid closing (First stage) 10 March 2017
ADB’s approval on technical bid evaluation (First stage) 30 June 2017
Price bid opening (Second stage) 15 July 2017
ADB’s approval on price bid evaluation report (Second stage) 31 August 2017
Issue of NoA /PG Submission/ Contract signing 1 November 2017

25
 Activity Target Date
L/C opening and request to ADB for issuing commitment letter
1 January 2018
and issuance of commitment letter by ADB
Effectiveness of contract/ commitment of works 1 February 2018
Completion of the works 31 December 2019
O & M by EPC Contractor 31 December 2020

3.8 Project Activities

74. The associated activities in the installation of the wellhead compressors at Location A
are described in the following sections:

3.8.1 Pre-construction phase

75. Major activities at this phase will involve: (a) the technical and financial feasibility study,
(b) suitable site selection, (c) detailed design of the compressor station, (d) environmental
assessment, and (e) the selection and/or awarding of the Contractor for actual physical
installation.

3.8.2 Construction phase

76. During the construction phase, various works such as material procurement and
mobilization, earthworks for site preparation, and civil and electrical works for the installation of
equipment packages will be undertaken. These activities are discussed below:

a. Transportation and handling of equipment and construction materials

77. Construction material and equipment for civil and mechanical works will be transported
using large trailers, lorries and trucks. Permission will be secured from the Roads and Highways
Department for use of the existing access roads to transport these material and equipment.

b. Civil works

78. Earthworks in foundation: The construction work of the compressor station needs
earthworks for excavation of the foundation up to the required depth following the engineering
drawings and specification for the compression station and ancillary buildings. The excavated
earth will be stored temporarily in the nearby open space and will be used to backfill once the
foundation work is completed. Backfilling of the excavated areas will be done by local sand or
any material specified in the design.

79. Foundation treatment: The foundation area will be investigated geo-technically. Results
of geo-technical test will help in designing the foundation of the required structures and in
identifying the type of the foundation treatment required. Various types of treatments such as
wooden bullah piling, pre-cast reinforced cement concrete (RCC) piling or in-situ concrete piling,
sand piling, removal of peat or loose soil will be identified after the geo-technical investigation.

80. RCC work: The RCC works would be required for roof, column, beam, floor, foundation
of steel structure, etc.

26
81. Brick work up to plinth level and superstructure: Brickworks will be done for construction
of office with bricks and coarse sand and cement up to roof level.

82. Back-filling by local sand material: Back-filling will be done by local sand material in the
excavated area of foundation and floor of the building.

83. Plastering and finishing (electric wiring, distemper or plastic paints): Concealed electric
wiring with good quality and proper size of wire are will be done and provision of bulb and
switchboard will be conducted. Plastering of walls inside and outside and the roof of the building
will be done accordingly while curing works will be done for at least three weeks. After the
curing works, distemper of plastic painting will be done on the walls and roof of the building.

84. Sanitary works: Sanitary works such as laying down of sewerage line with either PVC or
RCC, installation, fitting and fixing of toilet accessories will be done for all the buildings.

85. Water supply system: Existing water supply system, where available, will be used for
water requirements in the compressor stations and associated buildings. In places where there
is no supply system, tube wells will be installed to supply water for the workers and staff at the
station.

86. Boundary fencing with concrete pillars and barbed wire: The project site will be protected
from unwanted encroachment and unauthorized public access by fencing the property boundary
with barbed wire fitted with concrete pillar 3 meters (m) apart.

c. Installation of compressor equipment and auxiliaries

87. After completion of the building, all equipment will be installed at the compressor station
(outdoor and indoor) following the specifications and standards of the engineering design
drawings. During the installation of the equipment, solid waste, liquid waste or noise may be
generated. At the same time, accidental failure of the equipment may occur.

d. Safety measures

88. Component 1 will have the following safety measures:

89. Fire-fighting equipment: As the compressor station is a vital installation, fire-fighting

equipment of appropriate specification will be procured and installed.

90. First aid materials: First aid boxes will be kept in designated locations within the
compressor station.

91. Boundary wall and security: A reasonable height of boundary will be constructed and
protection wire will be provided on the walls. Also, trained security guards will be provided.

92. Personnel protective equipment (PPE): All workers and staff will be provided with PPE
and will be required to use the same during construction and operation & maintenance phase.

e. Testing and commissioning of compressors and ancillary equipment

27
93. After installation (outdoor and indoor) works are completed, each equipment will be
tested according to manufacturers’ specifications and GoB relevant standards. If all the tests are
successful, the compressor station will be commissioned accordingly.

f. Tree planting

94. Location A that will accommodate the seven compressors for Component 1 is already a
developed empty land, that is, no clearing of trees will be involved. Thus, there is no need to
replace trees during the construction phase. However, in compliance with the rules for KPI such
as Titas Gas Field, tree planting after the construction phase will be part of site rehabilitation.

g. Safety monitoring and training

95. In BGFCL, there is a field environmental safety committee involved with the environment
and safety issues in the KPI. This committee is part of the ESD and is responsible for
formulating guidelines, developing procedures, and assisting the operating personnel in the field
to implement environment-friendly and safe procedures in their operations. Selected BGFCL
staff participate regularly to health, safety and environment (HSE) training programs in the
country. The Contract of the EPC Contractor will include a condition to provide environmental
and safety trainings on-site to staff.

3.8.3 Operation phase

96. During the operation phase, the compressor station will run with regular maintenance
activities. Emissions from burning natural gas to provide power to the compressors will be
generated. Noise level close to the compressors will be higher during their operation.

3.8.4 Decommissioning phase

97. At the end of its economic life, the compressors may be replaced or totally scrapped.
Location A will be rehabilitated by removing and cleaning of all waste materials and refuse.
Remaining structures that may no longer be useful, concrete and other solid waste material will
be disposed of at an appropriate disposal site. Machine parts and other materials will be sorted
to determine those that can be reused or recycled. Small quantity of wastewater will be
generated due to cleaning of work site at the time of decommissioning of compressors and
hydro testing of pipelines.

28
4.0 DESCRIPTION OF THE ENVIRONMENT (BASELINE DATA)

98. The project area of influence covers the location of the seven wellhead compressors
(about 0.6 ha) within the existing natural gas processing facility of BGFCL in the Titas Gas Field
in Sadar Upazila. Available secondary data used to describe the existing environment is at the
district level of Brahmanbaria.

4.1 The Titas Gas Field

99. The gas field is an elongated structure of north-south asymmetrical anticline measuring
about 19 kilometer (km) by 10 km with a vertical closure of 500 meter (refer to Figure 3.1).
There are eight production wells identified in Titas Gas field (#1, 2, 4, 5, 7, 15, 20, and 22).
According to Petrobangla, the total recoverable gas reserve from the Titas Gas Field is
estimated at 7,582 billion cubic foot (BCF). Commercial gas production from Titas Gas Field
commenced in April 1968 and as of 31 January 2016, about 4,098.82 BCF of natural gas has
been recovered or about 54.06% of total reserves identified.

4.2 Existing Natural Gas Process Plant at Titas Gas Field

100. The proposed site for Component 1 is the Location A which is within the existing natural
gas facility of BGFCL at Titas Gas Field. The DOE has issued the corresponding ECCs for the
natural gas process plants, the production wells, and the workover for Titas well #21 which are
all within the existing Titas Gas Field. Aside from the nine natural gas wells, the existing facility
consists of access roads, low-temperature separators, glycol dehydration towers, generator
house, office administration building, fire-fighting and safety equipment system, heaters, pond,
workshop/maintenance area, and scrap area. There are eight glycol dehydration units to dry the
natural gas, four low-temperature separation (LTS) units, another two units of LTS with glycol
dehydration, and two fractionation units. Gas from Well #15 and Well #22 come from Location F
of Titas Gas Field while gas from Well #2 comes from Location B. Figure 4.1 presents the plant
layout while Figure 4.2 shows the process plants.

101. An estimated 517 MMSCFD of natural gas from this process plant is produced and
supplied to the transmission pipeline systems of Titas Gas Transmission and Distribution
Company Ltd. (TGTDCL) and the Gas Transmission Company Ltd. (GTCL).

29
 Figure 4.1 Plant Layout of Existing Facility at Titas Gas Field

Figure 4.2 Natural Gas Process Plant at Titas Gas Field

4.3 Physical Environment

102. Available secondary data from relevant government agencies were used to describe
the existing environment at the level of Brahmanbaria District. Secondary data were taken
from the District Statistics 2011 published by the Bangladesh Bureau of Statistics in 2013,
Geology Survey of Bangladesh, Library of the Prime Minister’s Office, International Union for
Conservation of Nature (IUCN), and other relevant sources.

30
 4.3.1 Topography

103. Titas Gas Field is located in mainly flat, alluvial floodplain area surrounded by plains
with somewhat steeper topography and is traversed by the perennial Titas River. Aside from
the Titas River, the entire area is also drained by several minor water ways and canals. The
Titas Gas Field is about 24 feet above mean sea level. The area is not vulnerable to river
floods.

4.3.2 Climate

104. Bangladesh is divided into seven climatic sub-regions. Brahmanbaria is located within
the south-central zone characterized by an annual rainfall ranging from 200 cm to 250 cm and
a temperature of 18°C in January and reaches 28 °C in April until July (see Figure 4.3).
According to the District Statistics 2011, data collected by the Bangladesh Meteorological
Department from 2008 to 2011 show an average humidity of 75.2%.

4.3.3 Air quality

105. The DOE conducts regular ambient air quality monitoring through their Clean Air and
Sustainable Environment (CASE) Project covering eight cities in Bangladesh with 11
continuous air sampling stations.13 The CASE project, funded by the World Bank started in
May 2009 and will be until December 2016. Monthly monitoring results were posted in their
website for public information from November 2011 until December 2015.

106. The eight cities include: Dhaka, Gazipur, Narayagonj, Chittagong, Sylhet, Khulna,
Rajshahi, and Barisal. Dhaka has three monitoring stations, Chittagong has two stations and
the rest of the cities have one station each. Parameters being monitored in these stations
include: PM10, PM2.5, CO, SO2, NO2, O3, and hydrocarbons (HC). Out of the 11 sampling
stations of DOE, the nearest station to Titas Gas Field is in Narayagonj. Based on the
monitoring results in December 2015, only NO2, O3, PM2.5 and PM10 were available for
Narayagonj. Results show that NO 2, PM2.5 and PM10 exceeded the ambient air quality
standards of DOE of 53 ppb (24 hr average), 65 µg/m 3 (24 hr average), and 150 µg/m 3 (24 hr
average), respectively. Levels of O 3 both in 1-hr and 8-hr average are way below the DOE
standards of 120 ppb (1 hr) and 80 ppb (8 hr).

107. At Titas Gas Field, ambient air quality sampling was conducted on 20 December 2015
by a third party laboratory in front of the gate of Location A. Results show that suspended
particulates is 40 µg/m 3 (limit is 500 µg/m3) and NOx is 60 µg/m3 (limit is 100 µg/m3). Ambient
level of CO, lead, and SO x are all non-detectable.

13
Ministry of Environment and Forests. Clean Air and Sustainable Environment Project.
http://case.doe.gov.bd/index.php?option=com_content&view=article&id=5&Itemid=9. (Accessed 24 February 2016)

31
 Figure 4.3 Climate Map

4.3.4 Ambient noise

108. The environmental quality standard for Bangladesh (DoE-1991) has set noise
guidelines for industrial sites in Bangladesh. Noise level should not exceed 75 dB(A) during
daytime and 70 dB(A) at night. Facility operation will ensure that these noise levels are not
exceeded in more than 50 m from the facility. There are no settlements within the Titas Gas
Field area as the residential buildings for staff and workers are outside the boundaries of the
facility. Hearing protection or ear muffs are provided to workers where noise levels exceed 80
dB(A). Workers are not required to be at the compressors’ site as these are designed to be
operated and continuously monitored remotely in a separate control room. During inspections
and regular checks, workers will be required to wear earplugs/muffs.

109. Ambient noise level was measured on 20 December 2015 in front of the gate of
Location A in Titas Gas Field and recorded 51.5 dB [the limit for industrial area during daytime
is 75 dB(A)].

4.3.5 Soil type

110. Brahmanbaria is predominantly covered by non-calcareous dark grey floodplain soil.

This type of soil is characterized by dark grey, finely mottled brown, and brown soils with dark

32
grey flood coatings, with seasonally acid top soils and near-neutral sub-soils. This is also
mainly seasonally deeply flooded soils of the old Brahmaputra-Karatoya-Bangali (Part) and
old Meghna estuarine floodplains. The non-calcareous dark grey floodplain soil is slightly acid
to somewhat alkaline in reaction.

111. Soil sampling was conducted on 20 December 2015 in front of the gate of Location A
and the results are given in Table 4.1.

Table 4.1 Soil Sampling Analysis, Location A

Parameter Value
pH 5.6
Total nitrogen, % (w/w) 0.61
Organic matter, % (w/w) 1.2
Potassium, meq/100g 0.12
Phosphorous, ppm 9.21
Manganese, ppm 3.0
Sulfur, ppm 1.12
Magnesium, meq/100g 2.0
Calcium, meq/100g 5.5

4.3.6 Seismicity

112. Bangladesh is divided into three seismic zones: Zone I – Severe (Seismic Factor,
0.08g), Zone II – Moderate (Seismic Factor, 0.05g), and Zone III – Minor (Seismic Factor,
0.04g). Brahmanbaria is located under Zone II representing a region of recent uplift Pleistocene
and blocks of the Barind and the western extension of the folded belt (see Figure 4.4). All the
existing structures in Titas Gas Field were designed incorporating the seismicity of
Brahmanbaria.

33
 Figure 4.4 Seismic map of Bangladesh

4.3.7 Water resources

113. Titas River and its tributaries are the main water resource within the Titas Gas Field.
There are several khals and ponds that carries run off from adjacent areas. In surrounding
areas, surface water is used for irrigation, drinking for domestic animals, bathing, fish cultivation
and possibly as potable water in some locations.

114. The ground water table fluctuation indicates the recharge and discharge to the
groundwater reservoir. The highest ground water occurs during the month of August to
September when the aquifer recharges fully and the lowest ground water table occurs during
April to May. Ground water is a stable source of water supply for various activities including
irrigation, domestic purpose and industrial applications in the project area. In Titas Gas Field,
the water table is 25 feet below the surface. There is a pond at Titas Gas Field reserved for use
during the dry season.

34
 4.4 Biological Environment

115. The allocated area for the compressors within the existing BGFCL gas processing
facility is mainly grassland. The conservation status of species in Bangladesh based on the
IUCN Red List of Threatened Species is being updated which started in December 2013 and
funded by the World Bank. The last assessment specifically by the IUCN Bangladesh was
conducted in 2000.

4.4.1 Terrestrial Habitat

116. According to District Statistics 2011 Brahmanbaria published by the Bangladesh

Bureau of Statistics, the principal trees found in the district are as follows:

 Banyan or commonly known as bat tree (Ficus benghalensis)

 Pipal or ashwatha (Ficus religlosa)
 Neem (Azadirachta indica)
 Bel (Aegle marmelos)

117. Some of the fruit-bearing trees and used medicinally include: rana or petraj
(Aphanamixls polystachia), jarul (Legerstroemia speciosa), jamun (Enginer jambolan), amly-
tentul (Tamariandus indica), mango (Mangifera indica), betel nut (Areca catechu) and
mandar (Erythrina variegata). There are also several species of palms: kadamba
(Anthoephalus cadamba), gab (Diospyros precatorius), date palm (Phoenix sylvestris).
Some of the species used by local people for varying purposes include: Jalpai or olive
(Elaeocarpus tectorius) where the fruit is used as curry; the simul (Bombax ceiba) used as
stuffing for mattresses and pillows; palmyra palm (Borassus flabellifer) where its wood is
used for housing construction and the leaves for making fans of different sizes. Coconut
(Cocos nucifera) is grown abundantly in Brahmanbaria.

118. Some of the trees with commercial value include: karoi (Albizza procera), garjan
(Dipterocarpus turbinatus), and jarul (Legerstroemia speciosa).

119. Most of the species identified in Brahmanbaria are not included in the IUCN Red List
of Threatened Species. However, garjan (Dipterocarpus turbinatus) is listed as Critically
Endangered when assessed in 1998 on conservation status based on habitat loss. 14 IUCN
recognized that the assessment for this species needs updating. Palmyra palm (Borassus
flabellifer L. variety madagascariensis Jum. & H.Perrier) is considered synonymous to the
species, Borassus madagascariensis and evaluated as Endangered by IUCN (2012).15 Location
A for Component 1 is mainly grassland (see Figure 4.5).

120. The Mongoose (Herpestes edwardsi) is common and there are few monkeys
(Macaca mulatta) and squirrels (Callosciurus pygerythrus). Some of the birds include
kingfisher (Alcedo atthis), king crow (Corvus macrorhynchos), wood pecker (Picus
myrmecophoneus), sparrows (Passer domesticus), and moyna (Acridotheres tristis). These
species are listed as least concern in the IUCN Red List of Threatened Species.

14
Ashton, P. 1998. Dipterocarpus turbinatus. The IUCN Red List of Threatened Species 1998: e.T33016A9749000.
(Accessed 27 February 2016)
15
Rakotoarinivo, M. & Dransfield, J. 2012. Borassus madagascariensis. The IUCN Red List of Threatened Species
2012: e.T38452A2869399. (Accessed 27 February 2016)

35
 Figure 4.5 Vegetation in Location A, Titas Gas Field

4.4.2 Aquatic Habitat

121. Some of the commonly available fish in Brahmanbaria are ruhi of salmon (Labeo
rohita), mrigel (Cirrhinus mrigala), kalbous (Labeo calbasu), and katla or carpo (Catla catla).
Shoal fish (Channa striatus), and shing (Heteropneustes fossilis) are also found in large
quantity in beels and khals. Principal varieties of fish are boal/sheatfish (Wallago atttu),
chital (Notopterus chitala), long-whiskered catfish ( Mystus aor), baghair (Bagarius
bagariuis), pangas (Pangasius pangasius), rita (Rita rita), bain or eel (Mastacembelus
armatus), chapila (Gudusia chapra), gulsha (Mystus bleekeri), tengra (Mystus vittatus),
chanda (Mene maculata), kakila (Strongylura strongylura), phalli or flat fish (Notopterus
notopterus), pabda or butter fish (Ompok pabda), chela (Chela atpar), koi or climbing fish
(Anabas testudineus), kholisha (Colisa fasciatus), puti (Barbus puntius), sharputi (Systomus
sarana), taki (Channa punctatus), and walking fish (Ophiocephalus striatus).

122. Of these species, butter fish (Ompok pabda) is listed as Near Threatened by the
IUCN Red List of Threatened Species (2010). 16

4.5 Socio-economic Condition

123. The Bangladesh Bureau of Statistics (June 2012) show that the population of
Brahmanbaria Zila (District) in 2011 reached 2,840,498 consisting of 538,937 households
with an average household size of 5.25. 17 The annual population growth rate is 1.6% while

16
Tenzin, K. & Ng, H.H. 2010. Ompok pabda. The IUCN Red List of Threatened Species 2010: e.T166509A6224736.
http://dx.doi.org/10.2305/IUCN.UK.2010-4.RLTS.T166509A6224736.en. (Accessed 2 March 2016)
17
Bangladesh Bureau of Statistics. Community Report. Brahmanbaria Zila. June 2012.
http://203.112.218.66/WebTestApplication/userfiles/Image/Census2011/Chittagong/Brahmanbaria/Brahmanbaria%
20at%20a%20glance.pdf. (Accessed 24 February 2016)

36
the literacy rate is 45.3%. The population is predominantly rural representing about 84%.
Population density is 1,510 persons per km 2.

124. Religion is represented by 90.73% Muslim and 9.07% Hindu. Occupation is

predominantly in agriculture (44.79%), agricultural labour (15.82%), wage labour (3.13%),
commerce (12.26%), service (6.8%), fishing (2.02%), transport (1.85%), weaving (2.39) and
other services (10.94%).

125. Most of the land within the project area is cultivable land. About 95% produce Boro
rice and other paddy, crops while about 20% produce robi crop after Aman rice harvest.
Other than Titas Gas Field, there are no big industrial areas. However, there are a few rice
mills, brick fields, and small industries.

126. About 80% of the households have electricity, while the rest use kerosene for
lighting. While Titas Gas Field is close, only about 15% of the households have access to
natural gas for cooking. Other households use firewood, cow dung, straw and garbage as
fuel for cooking.

127. Approximately 12-25% of the population use pond or river water for domestic use
while the rest use groundwater from shallow or deep tube wells.

5.0 ANTICIPATED IMPACTS AND MITIGATION MEASURES

128. The main objective of installing compressors is to increase the pressure in the natural
gas pipeline to facilitate transmission. Titas Gas Field will benefit from the new compressors due
to the declining line pressure of extracted gas from the well fields. As such, there is no
alternative site except Location A since the compressor system will be reinforcement for Titas
Gas Field to facilitate an efficient operation of its overall natural gas system.

129. Since the seven new compressors will be installed within an existing facility, an
environmental audit was conducted as part of the environmental assessment. The audit is
required by para. 10, Appendix 1 (p32) of ADB’s SPS 2009.

5.1 Audit and Site Investigation Procedure

130. The audit and site investigation of the existing natural gas facility at Titas Gas Fields was
conducted through a review of available relevant project documents, site visits on 22-24 August
2016, and interviews with key technical staff of BGFCL, the medical doctor at the facility and
security unit.

5.2 Findings and Areas of Concern

131. The seven new compressors will occupy about 0.6 ha of land at Location A in Titas Gas
Field which is a secured and monitored area all the time. Public access is not allowed without
authorization. Table 5.1 presents a summary of the findings while Annex 2 shows the photo
documentation.

Description Findings
Compliance to national environmental  Activities requiring clearance according to ECA 1995
regulations and other laws and ECR 1997 were complied with – drilling of wells,

37
 Description Findings
installation of gas process plants
 Fuel dispensing unit licensed by Department of
Explosives
 Captive power and use of generators with permit to
operate from BERC
 Comply with Petroleum Act 1934 on storage of HSD
and MS
Submission of environmental monitoring  Submits EMP to obtain ECC
reports  Not clear if environmental monitoring report is submitted
to DOE
 Submits monitoring report to ADB for Loan 2622/2633
approved on 26 March 2010
Designated environmental staff  There are 11 staff in the Engineering and Safety
Department.
Occupational health, safety and security  Entire property is well secured by high concrete wall
including emergency preparedness and metal bars
 Clear and visible safety posters on restricted areas,
danger signal switch, procedures on what to do if there
is a fire or suspected gas leak
 Three doctors and three staff manage the medical clinic
and treatment room with sufficient medical supply.
 There are two ambulances, one fire tender vehicle,
several fire hydrants at designated locations, two water
2
ponds for fire-fighting system (about 19,700 m ), and 11
new fire shades. Fire extinguishers are Type 3 – dry
powder, foam and CO2. Expired fire extinguishers are
refilled yearly.
 Personal protective equipment (PPE) are available such
as safety shoes, masks, helmets, googles, ear muffs,
fire protection clothes
 Workers wear PPE if assignment/activities require them
to do so.
 Security gate separates the gas production wells and
the gas processing plant
 Several security posts are located at and around the
property boundary aside from the internal security
personnel. There are three shifts per day. Six security
personnel from security agency work per shift while 15
security staff provided by the Government are assigned
per shift. This gives a total of 63 security personnel per
day.
 There is a designated reception area/orientation room
where visitors are given briefing on safety and security
procedures imposed in the facility.
 Visitors and staff wear identification cards
 Road blocks are in place all the time to secure the area.
 Communications system such as walkie-talkie and siren
are available with emergency procedures
 BGFCL conducted four major fire drills in 2015
participated by all employees of fire safety section of
the field. Local people are not part of the drills.
 Submits regular report to Petrobangla on status of
implementation of ESMS

38
 Description Findings
 Workers injuries for the last 3 years are minor in nature
Waste management  Implements waste minimization and reuse
 Garbage bins are provided for solid wastes and
collection is daily. Dumpsite is located within Titas Gas
Field Location C.
 Plant-related scrap material/recyclables are temporarily
stored in scrap area until auction
 Wastewater – uses oil & water separator for oily
waste/drains and skimming tank for wastewater with
high iron content. Effluent treatment plant involves
aeration, sedimentation, pH adjustment, and chemical
coagulation
 All of the waste containers were not found in right
places and properly labelled. Drawn attention of the
management who pledged to take necessary action
soon.
 A flare of 150 ft continuously emits methane
Water requirements  Rainwater harvesting for the two water ponds in fire-
fighting
 Supply of water is one deepwell and five shallow well
for domestic purposes and process use
Energy consumption  200 kW captive power
Amenities and/or services within the facility  A mosque is located near the administration building and
the Ansar camp is located beside the mosque
Incidence of operational problem  Well #3 was identified as the main source of gas
seepage in March 2007 and following industry rules and
regulations, it was plugged and abandoned in February
2008
 ADB provided funding in March 2010 to address the
problem
 Team of experts carried out field level survey from 29
June 2011 to 26 July 2011 and confirmed seepage
comes from Well #3
Landscape maintenance and good  Grounds are well maintained with trees planted as
housekeeping required by Petrobangla for its key point installations
Capacity building  There are 11 staff on environment and safety but no
exposure to compliance of projects based on SPS 2009

5.3 Corrective Action Plan

132. The following corrective actions are recommended for implementation :

(i) Ensure submission of environmental reports to DOE if required for ongoing project
like drilling of well, installation of compressors, etc.;
(ii) Conduct environmental monitoring at least once a year on ambient air quality, water
quality (e.g., Titas River and groundwater), and noise;
(iii) Ensure proper labelling and storage of drums and other containers for liquid waste
prior to selling/auction to Government-authorized recyclers;
(iv) Ensure good housekeeping at all times;
(v) Continue monitoring of gas seepage particularly at Location A;
(vi) Conduct emergency drills that will involve community participation; and,
(vii) Provide training/workshop on project compliance according to SPS 2009.

39
133. Aside from the implementation of corrective actions above, the associated potential
environmental impacts for the installation of the compressor system are identified and presented
according to project stages as follows:

5.4 Impacts during pre-construction stage

134. Activities in this phase will include the selection of the suitable space for installation of the
gas compressors and the technical assessment on the capacity, type, design, and utilities that
will be required for its operation.

135. Given that flowing wellhead pressure of natural gas will decline over time of continuous
production, BGFCL facilities have allocated space for compressors in the event the operations
would require their installation.

136. Location A, which covers about 0.6 ha of land, is owned by BGFCL and is within the
Titas Gas Field with an existing natural gas processing plant. No land acquisition will be
required and Titas Gas Field is considered an industrial area. Vegetation in Location A is mainly
grassland. Utilities such as power and water supply systems are available. No economic
displacement is expected.

137. DOE has issued the required ECCs for the two natural gas process plants and the well
fields. Since Component 1 will be within an area with issued ECCs from the DOE, BGFCL will
be only required to submit an EMP for Component 1 to DOE in securing the ECC.

5.5 Impacts during construction stage

138. During this stage, activities will include site preparation, transportation of equipment and
construction materials to Location A, installation of compressors, testing and commissioning of
the compressor system, and site clean-up after construction works.

5.5.1 Site preparation and transport of construction equipment and materials

Natural hazards

139. Seismicity Brahmanbaria is within Zone II according to seismicity in Bangladesh. Zone

II means moderate with seismic factor of 0.05g. Existing facilities in Titas Gas Field incorporated
seismicity in their design and will also incorporate in the design specifications of the foundation,
structures, compressors, and ancillary equipment for Component 1.

140. Flooding Titas Gas Field and Location A are developed high land with 7.32 m above
mean sea level (MSL) as the reduced level reference. In 2004, the highest flood level in
Brahmanbaria was recorded at 7.65 m above MSL. Given this, the design of construction works
for Component 1 will take into account the highest flood level.

141. Cyclone Local seasonal storms start in late February and reach its maximum in April.
Severe storms are generally associated with tornadoes. Based on experience by BGFCL, the
Titas Gas Field is not cyclone-prone area.

Impacts on land and vegetation

40
142. Clearing of land and excavation will be done for the foundation of compressors.
Vegetation in Location A is mainly grassland. Earthmoving works may cause potential erosion
and localized flooding. Erosion control measures will be provided, if needed. Construction
management plan will be required from the EPC Contractor to ensure that impacts during
construction will be minimal. Excavated topsoil will be used for backfilling.

143. Areas to be used as workshop involving oil, lubricant and other solvents will be lined with
concrete or any impervious material to prevent soil contamination. An oil-water separator will be
provided in the workshop area.

Impacts on physical cultural resources

144. The site for the seven wellhead compressors is within an area considered industrial and
Titas Gas Field is not identified as a potential cultural interest. Given that excavation and earth
moving works will be involved in the site preparation, Annex 3 presents the chance find
procedures.

Impacts on people

145. Activities during site preparation may cause potential safety risks to workers and
community, occupational and safety risks to workers and staff, and disruption to daily activities
of local people. In terms of safety, BGFCL adheres to the following national regulations: (i)
Mineral Gas Safety Rules 1971, (ii) Natural Gas Safety Rules 1991, (iii) The Bangladesh
Petroleum Act 1974, and the (iv) Factories Act 1965.

146. Some of the common occupational safety risks involve accidents in welding, electrical
works, and use of crane, trench collapse, and fire and explosions. BGFCL has an existing
Safety and Hazard Mitigation Plan as well as the ESMS. However, to prevent these accidents
from happening in Component 1, BGFCL will require the EPC Contractor to prepare a safety
management plan for their approval before any installation works.

147. Location A is within the Titas Gas Field, thus, unauthorized public access is not allowed.
Prior to start of construction, the EPC Contractor will provide fence or barricade, sufficient lights,
clear warning and danger signs, and will assign security personnel to prevent accidents,
trespassing, and pilferage.

148. To minimize disruption in road crossings and daily activities of local people, EPC
Contractor will schedule transportation movements, provide visible warning signs that will be
posted at designated sites within Location A, the adjacent facility and nearby settlements. The
warning signs will also consider people with disabilities. In case heavy equipment and
machinery will be transported to Location A, the EPC Contractor will issue announcements to
local settlements that will be affected through posters/notification or through the local radio
station. Drivers of construction vehicles will be required to strictly follow road regulations
particularly on speed.

149. Due to construction works, there will be additional construction workers and staff at Titas
Gas Field. PIU-BGFCL will conduct briefing to EPC Contractor(s), workers and staff on the
compliance to the requirements of ADB and DOE, create awareness of sexually-transmitted
diseases such as HIV/AIDs, and good housekeeping. The EPC Contractor will be required by
BGFCL to use local labour force for manual work and for clerical and office jobs if they are
eligible.

41
150. To minimize occupational health and safety risks, BGFCL will require the EPC
Contractor to follow the World Bank EHS General Guidelines 2007 (or any updates) and to
provide workers and staff with sanitary facilities, wash areas, safe drinking water, first aid and
fire-fighting equipment (non-ozone depleting), and garbage bins. Aside from these facilities,
workers will be provided with hard hats, safety shoes and belts, and other personal protective
equipment needed to do the work safely. Good housekeeping will be enforced at all times.
Solid waste generated from Location A will be disposed of in authorized and certified landfill in
Brahmanbaria.

151. Periodic and also random safety patrols will be carried out by BGFCL and/or EPC
Contractor to ensure that all works are carried out in a safe manner according to the safety
management plan.

Air and noise impacts

152. Site preparation works will cause increase in dust and noise levels as well as vehicular
emissions. These impacts may come from heavy equipment and construction vehicles working
in Location A as well as from transporting construction materials. Earthmoving works and
excavation may increase dust levels and affect local ambient air quality. Increased noise levels
and vibration may come from excavation works, use of heavy equipment and construction
vehicles. BGFCL will require the EPC Contractor to maintain construction vehicles to meet
emission standards by DOE including the observance of low-speed to reduce noise. Noise-
generating activities will be limited to daytime hours only and there will be no blowing of horns
for vehicles. Warehouse for construction materials will be provided on-site to reduce trips of
material delivery. Opened land areas or sources of dust will be sprayed with water, as needed
while trucks transporting dust-generating construction materials will be covered to contain dust
levels.

Water quality impacts

153. Titas Gas Field is traversed by the Titas River but will not be affected by the construction
activities in Location A. Potential impacts that may affect water quality are generation of sewage
from construction workers and localized flooding which could result in construction delays.
Sanitary facilities will be provided to workers and EPC Contractor will be required to have
stormwater management plan including drainage plan.

5.5.2 Installation and testing of compressors and ancillary equipment

154. During the installation and testing, potential impacts such as public and occupational
health and safety risks, emissions from testing works and generation of waste may result. The
design of the compressors and ancillary equipment will be in accordance with applicable
international safety codes and standards. BGFCL has the experience and track record of safety
operations in the gas sector. Civil, electrical, mechanical, and structural construction works
including the installation and testing of compressors will be undertaken by similarly experienced
international EPC Contractor(s) who use high industry standards of safety and environmental
protection.

155. A safety plan will be prepared by the EPC Contractor for approval by BGFCL prior to
installation and testing works. Liquid waste such as oily and cooling system drains, and spent
lube oil generated during testing will be treated prior to disposal using oil-water separator.

42
 5.6 Impacts during operation stage

156. The presence of additional seven compressors in Titas Gas Field is expected to
generate employment. But may also potentially cause hazards such as fire or explosion due to
operational failure, disturbance to settlements nearest to the BGFCL natural gas facility, may
pose occupational health risks due to noise from compressors, will contribute to greenhouse
gas (GHG) emissions, will use about 16 tons of water daily for its operation, and some drainage
congestion may occur occasionally during monsoon season due to reduced open space.
Drainage congestion can be minimize by proper stormwater design and management.

157. Standard operating and safety procedures following national requirements, industry
standards, and international best practice will be strictly implemented. Since the EPC Contractor
will manage Component 1 during the first year of its operation, BGFCL will require them to
prepare a safety management plan and an emergency and disaster preparedness plan.

Water requirements for cooling

158. The daily water requirements will be for the recirculating cooling water system and will
be taken from groundwater wells from the existing gas processing facility. Make up water will
be needed only when leakage has occurred at pump packings or when water has been drained
to allow for system repair. During the dry season, a reserved water pond will be used as back-
up for deep tube well. Rain harvesting will be done and other water conservation measures will
be explored.

Noise generated by compressors

159. The existing BGFCL facility at Titas Gas Field is considered an industrial area and
settlements are located relatively far from it. Compressors will be within highly sound-insulated
buildings to minimize the noise generated during operation. There is an existing boundary wall
south of the compressor site but protective boundary wall with sufficient height may be
constructed as buffer, if needed. The compressors will be operated by experienced staff that will
observe and monitor the operations for signs of failure or maintenance needs during normal
operation. Operation of compressors can be remotely monitored 24 hours a day in a separate
and centralized computer control room. One of the causes of noise and vibration is dirty and
worn out components, inadequate lubrication, etc. Preventative maintenance of the
compressors will be employed to prevent this. Noise generated by the compressors will be
minimized by the use of engineered noise-suppression devices such as silencers, baffles and
absorbent liners. Workers exposed to high level noise will be required to use earplugs/muffs and
will be rotated every 2 hours.

Contribution to GHG emissions

160. Natural gas at Titas Gas Fields is about 97%mole methane (CH4) and does not contain
hydrogen sulfide (H2S). Use of natural gas to fuel the compressors will result to emissions that
are mainly carbon dioxide (CO2). About 272 metric tons (MT) of CO2 emissions per day will be
contributed by Component 1 to greenhouse gas (GHG) emissions or about 99,280 MT CO 2 per
year on a “worst scenario” of operating the seven compressors at the same time. Tree planting
will be done at designated areas in Titas Gas Field not only to serve as sinks for the emissions
but is required by Petrobangla in its key point installation (KPI). Carbon sequestration by trees
is a complex process and involves several factors such as survival rate, species, age of tree to
be planted, soil type, etc. Given these factors, only tree species common to Brahmanbaria will

43
be planted such as Ashwatha tree (Ficus religiosa) belonging to the mulberry family, and Neem
(Azadirachta indica).18 The Department of Forest (DOF) will be consulted on the appropriate
tree species to be planted at and around the Titas Gas Field.

161. Over time, compressors wear and may cause leaks of CH4 and volatile organic
compounds (VOCs). These fugitive emissions can be mitigated by techniques such as
replacement of compressor rod packing, replacement of the piston rod, and refitting or
realignment of the piston rod. In May 2016, the US EPA issued the requirements for
reciprocating compressors focusing on monitoring (i.e., record keeping) and reporting (i.e.,
annually) of the condition of rod packing: (i) on or before every 26,000 hours of operation
(operating hours must be monitored and documented), and (ii) every 36 months (monitoring and
documentation of operating hours not required).19 Among others, BGFCL will conduct
monitoring and reporting of the condition of the compressor packing systems as fugitive
emissions is a systems loss with associated costs. BGFCL will require suppliers of compressors
to have guaranteed emissions that meet the limits set by the DOE and the World
Bank/International Finance Corporation Environmental, Health and Safety (WB/IFC EHS)
General Guidelines 2007 (or any update).

Risks of explosion and fire

162. Operation of natural gas compressors does not come without risks of explosion and fire
given that natural gas is flammable. The lower explosion limit of CH4 is 5% and the upper
explosion limit is 15% in the presence of an ignition source. This means that CH4 concentration
lower than 5% (“too lean”) and higher than 15% (“too rich) will not cause fire in the presence of
ignition source. The compressors are designed with safety features such as fire-suppression
system that will be triggered by heat, fire or smoke detection, and continuous monitoring
devices along with emergency shutdown systems capable of isolating the station and safely
venting the gas very quickly in the unlikely event of an emergency.

163. Component 1 will be within the area of the existing natural gas processing plant of
BGFCL at Titas Gas Field. Given the capacity of natural gas being processed at this facility and
its national economic significance, BGFCL has an environment safety management system
(ESMS) as well as safety and hazard mitigation plan to address the risks of explosion or fire.
Among others, the operation of BGFCL is subject to the Natural Gas Safety Rules 1991
(amended 2003) and The Factories Act 1965. In August 1993, a team of safety engineering
experts from British Gas experts was engaged to conduct a safety audit of the entire operations
of Petrobangla and concluded that all operating companies (which included BGFCL) are
generally operating an adequate system and provided recommendations for safety program
development which were incorporated in the ESMS.20 ADB provided financing in March 2010 to
cover safety and supply efficiency improvement in Titas Gas Field.21 The Bakhrabad Gas Field
has wellhead compressors since 2007 and no trouble has been encountered during installation

18
US Environmental Protection Agency. GHG Equivalencies Calculator - Calculations and References.
https://www.epa.gov/energy/ghg-equivalencies-calculator-calculations-and-references. (Accessed 3 August 2016)
19
US EPA. Summary of Requirements for Equipment at Natural Gas Transmission Compressor Stations.
https://www3.epa.gov/airquality/oilandgas/may2016/nsps-gas-transmission-fs.pdf. (Accessed 3 August 2016)
20
World Bank. Gas Infrastructure Development Project. 1995. Environment and Safety Assessment Report:
Summary. May 1994. http://www.worldbank.org/projects/P009533/gas-infrastructure-development-
project?lang=en&tab=documents&subTab=projectDocuments. (Accessed 3 August 2016)
21
ADB. Loan 2622/2623-BAN: Natural Gas Access Improvement Project. 2010. http://www.adb.org/projects/38164-
013/main#project-pds. (Accessed 3 August 2016)

44
and operation.22 Japan International Cooperation Agency (JICA) has financed the installation of
wellhead compressors for Titas Gas Field Location “C” (three compressors) and Narshingdi Gas
Field (three compressors) and the project was implemented in July 2014 to June 2018.23
BGFCL also operates Narshingdi Gas Field and thus, has the experience to implement
Component 1 following the highest standards and norms on safety.

164. All the relevant civil, mechanical, structural, and electrical standards will be complied
with. Non-ozone depleting fire-fighting systems will be available at strategic locations within
Location A and security personnel will be provided. Regular drills on emergency preparedness
procedures will be conducted twice a year to train staff and workers in the event of emergency
or disaster. BGFCL will explore the opportunities to involve the settlements in the immediate
vicinity of Titas Gas Field in conducting the drills on emergency preparedness.

5.7 Decommissioning stage

165. This stage will involve dismantling of compressors and ancillary equipment at the end of
its economic life (about 35 years). Dismantling activities may pose occupational and safety
risks, generation of waste, and emissions from hauling vehicles, large construction equipment,
and dust from sources such as structure removal, and dumping. A decommissioning plan
following the industry best practice will be required by BGFCL to the Contractor who will conduct
the dismantling works. The decommissioning plan will be submitted to ADB for review and
approval to ensure that it meets SPS 2009 and the World Bank Environmental, Health, and
Safety General (EHS) Guidelines 2007 (or any updates).

166. All left-over structures, concrete, solid waste materials and other debris will be disposed
of at designated disposal site. Solid waste will be sorted to determine recyclable/reusable
materials that can be sold as scrap or used for other projects while non-hazardous waste will be
sent to appropriate disposal sites.

22
Japan International Cooperation Agency. Preparatory Survey on the Natural Gas Efficiency Project in the People’s
Republic of Bangladesh. Final Report. March 2014
23
BGFCL. Annual Report 2013-2014. http://www.bgfcl.org.bd/~pavel/images/AnnaulReport2013-14/Page34-41.pdf.
(Accessed 4 August 2016)

45
6.0 ANALYSIS OF ALTERNATIVES

167. The primary objective of including Component 1 is to maintain the natural gas flow from
the production wells (i.e., Titas # 1, 2, 4, 5, 7, 15, 20, 21 and 22) to the national grid
transmission and distribution lines. These production wells are located in Location A of the Titas
Gas Fields and their wellhead pressure has been decreasing gradually. To ensure a steady and
reliable flow of natural gas from these production wells, it is crucial to install wellhead gas
compressors before the existing natural gas process plants.

168. Since the production wells are located within the existing natural gas facility of BGFCL,
no other sites were considered except Location A. Location A provides for a secured space
available to accommodate the required capacity of the wellhead compressor. No further land
acquisition is necessary. The water supply, electricity, fire and safety system including road
access and other physical infrastructure are readily available in Location A. Selecting this site is
the optimal and most cost effective. The availability of the required systems to support the
operation of wellhead compressor is the major criteria for selecting Location A.

169. Aside from the availability of technical support systems from the existing facility of
BGFCL, future expected capacity of the production wells was also considered. At present, the
daily capacity from the eight production wells (i.e., Titas # 1, 2, 4, 5, 7, 15, 20 and 22) ranges
from 230 million standard cubic feet (MMSCF) to 235 MMSCF. Additional work from the
suspended Titas production well #21 will result to additional supply of natural gas approximately
12 MMSCF to 15 MMSCF per day. With mainstreaming of Titas well #21, the estimated future
capacity from these nine wells will be 270 MMSCF of natural gas daily. Considering this
estimated capacity, installation of seven wellhead compressors having a capacity of 60 MMSCF
per day will be needed (i.e., five compressors operating and two compressors as standby).

170. A “without project” option will stall planned national economic development dependent
on the reliable supply of natural gas including the associated jobs that could have been
generated. Aside from the planned economic development, the operations of existing industries
and residential users of natural gas will be compromised due to decreasing flow of natural gas
from Titas gas fields. Table 6.1 presents a summary of comparing “with project” and “without
project” options.

46
 Table 6.1 Comparison of “With Project” and “Without Project” Options

Description “With Project” Option “No Project” Option

Supply of natural gas Increase availability and reliable flow of Decreasing flow of natural gas
natural gas for transmission and supply for transport and
distribution to industry, transport, and distribution will continue
residential purposes
Economic development More opportunities for the area to Slower economic development
develop economically due to reliable due to shortage of available
supply of natural gas natural gas
Impacts to ecologically- No impacts expected as the project No impacts
sensitive areas site is within an existing facility owned
by BGFCL which is considered an
industrial area
Impacts to flora and Minimal impacts; the proposed project No impacts
fauna site is mainly grassland and no
presence of mature trees
Greenhouse gas (GHG) Using 5 MMSCF per day of natural gas No GHG contribution
emissions to fuel the operation of the wellhead
compressors will contribute about
272.2 MT CO2 per day.
Water requirements About 16 tons of water will be required No water requirements needed
by the wellhead compressors
Disruption to local Minimal effect (i.e., temporary and No related local disruptions
residents short duration during construction/
installation) since the project site is
located within an existing facility
Employment There will be jobs associated with the No creation of jobs
project during construction and
operation phase.
Living conditions of Potential improvement in living Same level of living conditions
related service areas of conditions due to availability of reliable or likelihood of worsening living
BGFCL flow of natural gas conditions due to poor service of
BGFCL associated with shortfall
in reliable natural gas flow

47
7.0 INFORMATION DISCLOSURE, CONSULTATION, AND PARTICIPATION

171. Location A is within the existing Titas Gas Field which is considered industrial given the
presence of two natural gas process plants and production wells. Initial consultations were
conducted on 18 October 2015 to inform the local residents within the immediate vicinity of Titas
Gas Field about the project and to gather their opinion/suggestions/concerns, if any. The
preliminary consultations were undertaken as part of the preparation of the IEE.

172. Thirty-six participants attended the consultations at Union Parisad Office of Shuhilpur
under Brahmanbaria District (see Annex 3). During the consultation, BGFCL discussed briefly
the features of Component 1 briefly and the potential impacts. BGFCL emphasized that
Component 1 will be located within the existing premises of the Titas Gas Field.

173. Some of the concerns raised by the participants include the following:

 Potential increase of noise levels from vehicles, compressors and equipment at

Location A that may disrupt settlements and wildlife;
 Water pollution of natural water bodies like the Titas River as the water is used for
agriculture and other domestic purposes;
 Movement of vehicles may affect the mobility of people, especially women, children
and disabled person from one place to another;
 Potential air pollution due to dust and gaseous emissions from compressors; and,
 Environmental pollution due to poor sanitation during construction, waste materials,
and other social nuisance should be controlled.

174. Aside from these concerns, the participants will be expecting for the following:

 Local residents should be employed in different activities during implementation of

Component 1 on a priority basis.
 Local businessmen/contractors should be engaged in different phases of
Component 1 during construction and development on a ‘priority’ basis.
 Compensation in any form should be properly and promptly given so that the actual
affected persons can get their full share at the right time.

Table 7.1 presents the summary of the initial consultations.

Table 7.1 Summary of Initial Consultation

Items Discussed by Issue Raised by

BGFCL’s Response
BGFCL Stakeholders
Features of Component 1 Build up new industries New compressors will sustain gas
and the impacts during production from wells
implementation in Location Reduce unemployment Labour will be taken from respective
A of Titas Gas Field locality
Social and economic Living standards will improve
developments
Timely compensation to Monitoring of payment
affected persons
Potential pollution of air and Monitoring will be implemented
surface water
Movement of vehicles may Local traffic management plan

48
 Items Discussed by Issue Raised by
BGFCL’s Response
BGFCL Stakeholders
disrupt mobility of local people
Sanitary problem Appropriate sanitary facilities will be
provided to workers during
construction
Increased noise level Appropriate noise mitigation measures
will be implemented at the
compressors’ site

175. Consultations will continue, as appropriate during implementation. A one-page flyer in

Bangla about Component 1 and information on GRM will be made available to the public at the
project site and at the BGFCL office in Birashar, Brahmanbaria and in Dhaka. Brief information
about Component 1 will also be made available at the BGFCL website. Information disclosure
will refer to the Right to Information Act 2009 of GoB and the policies of ADB: SPS 2009 and the
Public Communications Policy (PCP) 2011.

8.0 GRIEVANCE REDRESS MECHANISM

8.1 Existing Structure of Handling Grievance at BGFCL

176. At present, handling of grievance at the BGFCL is within the Grievance Redress System
(GRS) which is part of the mandatory strategic objectives of Annual Performance Management
(APM) of the GoB (represented by the Energy and Mineral Resource Division). BGFCL has
signed an agreement with Petrobangla on 28 October 2015 to comply with GRS. This
agreement will be signed and renewed annually.

177. GRS requires the mandatory designation of staff as Focal Point and consequently
disclose the name of the designated staff and contact address in the company’s website.
Following the requirements of GRS, BGFCL has designated a staff and publish the same at the
BGFCL’s website. Compliance to GRS is a Performance Indicator in the APM.

8.2 Handling Grievance as Required by SPS 2009

178. To ensure that complaint(s) will be addressed properly during the implementation of
Component 1, the Project Implementation Unit (PIU) will establish a grievance redress
mechanism (GRM).

Objectives of GRM

179. GRM will ensure a process of receiving and resolving complaint(s) promptly from
persons that may be affected by Component 1. Following the requirements of SPS 2009, the
GRM will involve a process that is understandable, transparent, gender-responsive, culturally-
appropriate, and easily accessible to affected persons without cost and retribution.

Structure of GRM

180. Affected persons (APs) can seek redress of their grievance at three levels: (i) the PIU-
BGFCL or through the representative of the Engineering, Procurement and Construction (EPC)

49
Contractor during construction phase, (ii) through the grievance redress committee (GRC), and
(iii) the appropriate courts of law.24

181. PIU-BGFCL will set up a grievance redress committee (GRC) as soon as the ADB and
GoB approve the project. The GRC will continue to function from construction until the operation
phase and will consist of representatives from the EPC Contractor (during construction), local
government unit, designated staff of PIU-BGFCL on environmental issues (or Consultant), and
witness of the complainant. BGFCL will ensure the representation of women in the GRC. The
BGFCL staff designated in the existing GRS required by Petrobangla will be part of the GRC.

182. GRC will be responsible for resolving complaint(s) and will convene once a month to
review the complaint(s) received, if any. GRC will resolve complaint(s) within 30 days from the
date of receipt and will keep a record indicating the name of complainant and nature of
complaint, status of resolving the complaint, decisions or actions undertaken, and the date the
decision was effected. Records on grievances will be summarized and included in the
environmental monitoring reports to be submitted by BGFCL twice a year to ADB during
construction phase and annually during operation phase.

183. PIU-BGFCL will disclose the grievance redress procedure to project stakeholders such
as the contact person and details on how and where to contact them, how to file a grievance,
and the time for the GRC to resolve the concerns. The PIU-BGFCL will review the
implementation of the GRM regularly to assess the effectiveness of the process and to examine
their ability to address grievances. The cost of implementing the GRM will be part of the
administration cost borne by PIU-BGFCL.

9.0 ENVIRONMENTAL MANAGEMENT PLAN

184. The environmental management plan (EMP) presents the activities to be undertaken in
every phase of project implementation to minimize the adverse impacts and to enhance positive
impacts. EMP also includes the monitoring and institutional arrangements needed. Table 9.1
presents a summary of the EMP while Table 9.2 presents the monitoring plan.

185. As part of project's readiness and compliance to environmental requirements of GoB,

Annex 3 presents the No Objection Certificate (NOC) from the local authority. NOC is one of
the documents required to secure the LCC from the DOE.

9.1 Implementation Arrangements

186. BGFCL will set up a PIU responsible for project management and safeguards
compliance monitoring of EPC contractor during the construction stage. The EPC Contractor will
recruit an environmental staff (or a Consultant) who will be primarily responsible for ensuring
that the EMP is properly implemented during construction. The Environmental staff (or
consultant) of the EPC will coordinate and interact with the PIU on compliance to ADB
requirements, relevant government agencies and local authorities on clearances (as needed),
and will prepare the environment section of the Project’s Quarterly Progress Report (QPR)
submitted to the PIU for review. The environment section in the Project’s QPR will be

24
Members of GRC will consist of: (i) BGFCL staff designated for GRS, (ii) representative from the EPC Contractor
(during construction phase and first year of operation phase), (iii) local government unit representative, (iv) PIU-
BGFCL designated staff (or consultant) on environmental issues, and (v) witness of the complainant.

50
summarized by the PIU and submitted as environmental monitoring reports to ADB at least
twice a year during construction, which will posted on ADB’s website.

187. Should there be any change in the configuration, capacity, or design of the compressors,
this IEE will be revised and/or updated and submitted to ADB prior to any construction works.
BGFCL will be responsible in the revision or updating of the IEE.

188. Prior to any construction work, the EPC Contractor(s) will be informed by the PIU-
BGFCL on their responsibility to comply with the EMP and the requirements of ADB. Specific
responsibilities of the EPC Contractor in the EMP will be monitored by their Environment staff
(or Consultant) for compliance. Overall compliance of the EPC Contractor to the EMP and ADB
requirements will be supervised by the PIU-BGFCL and/or staff of the Environment and Safety
Department of BGFCL. The same implementation arrangements will be followed during the first
year of the operation stage when it will be operated by the EPC Contractor.

189. During the second year of operation stage, PIU-BGFCL will designate a staff who will be
responsible to deal with the environmental issues and compliance to GoB and ADB’s
environmental requirements. DOE requirements will include submission of EMP for Location A
and yearly renewal of ECC. Requirements of ADB will include submission of environmental
monitoring reports annually. The environmental monitoring report will be reviewed by ADB and
posted on their website as required by SPS 2009 and PCP 2011.

190. In the event of non-compliance to any environmental covenant in the loan agreements,
PIU-BGFCL will prepare a corrective action plan (CAP) describing the process and actions they
will undertake to ensure compliance. The CAP will be submitted to ADB for review and
disclosure to their website. BGFCL will submit the environmental monitoring reports starting
from the date the loan became effective.

9.2 Environment Safety Management System (ESMS) at BGFCL

191. As one of the operating companies of Petrobangla, BGFCL also has an existing ESMS
at Titas Gas Field. BGFCL has an Engineering and Safety Department (ESD) with a total of 11
staff. ESD consists of two sections: (i) Environmental Engineering, and (ii) Safety Engineering
with four staff each section.

192. Aside from the relevant environment and safety regulations of GoB, the ESMS provides
BGFCL guidance and tools needed to ensure safe and environmentally-sound operations. The
ESMS consists of 23 elements organized in 10 environment and safety categories where
BGFCL can focus on. These categories include: (1) policy and leadership, (2) continuous
improvement, (3) safety and health, (4) risk management, (5) incident reporting and
investigation, (6) emergency preparedness and response, (7) environmental protection, (8)
training and orientation, (9) community relations, and (10) regulatory requirements.

193. The ESMS Manual covers:

(i) Environment and Safety Guidance Manual – there are 23 elements that provides
guidance needed to meet the environment and safety requirements
(ii) Environment and Safety Procedures Manual – consists of 73 requirements in the
form of procedures

51
194. The ESMS was developed in 2000 by Petrobangla with the assistance of international
experts.

9.3 Safety and Hazard Mitigation Plan at BGFCL

195. Given the nature of natural gas processing, safety is an integral part of BGFCL's
operations to ensure protection of their employees, contractors, properties, the environment and
the public as a whole. Annex 5 presents the details of the safe and hazard mitigation plan.

52
 Table 9.1 Environmental Management Plan

Environmental
Estimated
Component Description of Potential
Project Activity Mitigation/Enhancement Measures Cost Responsible Unit
Likely to be Environmental Impact
($ million)
Affected
Planning and Pre-Construction Stage
 Selection of  Land and  Loss of habitat and vegetation  Use of environmental factors in 0.57 BGFCL
suitable space vegetation clearing selection criteria to minimize potential (for land
for installation of  Land acquisition adverse impacts. development
gas  Change in existing land use  No land acquisition required – site included in
compressors selected at Location A is within Titas the Project
within the Gas Field owned by BGFCL. cost)
premises of  Land development to suit the change
Titas Gas Field in current use.
 Obtain clearance  People  Physical displacement of people and  Location A is a vacant land owned by
from DOE structures BGFCL.
 Procurement  Economic loss to people  No physical or economic displacement
process (Tender  Water  Abstraction of water for compressors  Existing water system at Titas Gas
evaluation, Field will be used.
approval,  Water will come from borehole or
contract deep tube well.
awarding, etc.)  Incorporate water conservation
initiative like rain harvesting.
Construction Stage
Orientation for  People  Awareness of workers on the  Conduct briefing of EPC Contractor(s) Included in EPC Contractor(s),
contractor and environmental requirements and their on EMP, records management, and the costs of PIU-BGFCL, or
workers responsibility reporting. EPC Environmental
 Understanding of EPC Contractor(s) of  Identify areas to be monitored and the Contractor(s) Consultant
their responsibility in implementing the required mitigation measures.
EMP  Create awareness of sexually-
transmitted diseases such as
HIV/AIDs.
Hiring of project  People  Conflict due to potential workers’  EPC Contractor(s) will be required to --- EPC Contractor(s),
staff and workers migration use local labour for manual work and PIU-BGFCL, or
 Dispute over transparency of hiring eligible local workforce for clerical Environmental
and office jobs. consultant
 There is adequate supply of local
labour. Scale of Component 1 is not
expected to cause workers’
migration.

53
 Environmental
Estimated
Component Description of Potential
Project Activity Mitigation/Enhancement Measures Cost Responsible Unit
Likely to be Environmental Impact
($ million)
Affected
Presence of  People  Potential increase in demand for  None required.
workers at services such as food, temporary
--- ---
construction sites housing, etc. will create opportunities
for small-scale business
 Site preparation  People  Potential safety risks to workers and  Location A is within the perimeter of Included in EPC Contractor,
 Transportation of community Titas Gas Field – unauthorized public the costs of PIU-BGFCL, or
equipment and  Disruption to the activities of local access is not allowed. EPC Environmental
machinery to people  Fence or barricade (as appropriate), Contractor consultant
Location A sufficient lights, clear warning signs
and danger signals will be provided
to minimize occupational and safety
risks.
 Assign security personnel to prevent
accidents, trespassing, and pilferage.
 EPC Contractor(s) to direct drivers to
strictly follow road regulations.
 Interference with road crossings  Schedule transportation movements
to minimize disruption of local traffic.
 Danger and clearly visible warning
signs will be posted at designated
sites within Location A and also in the
adjacent facility.
 Construction vehicles to strictly follow
road regulations particularly on speed
 Implement temporary pedestrian
management plan.
 Potential occupational health and  Provide sanitary facilities and wash
safety risks to workers areas.
 Provide safe drinking water and
garbage bins.
 Enforce good housekeeping at all
times
 Provide workers with hard hat, safety
shoes and belts.
 Set up first aid treatment within
construction sites and field office
including fire-fighting system.
 Observance and compliance with
relevant safety measures required by
law and best engineering practices.

54
 Environmental
Estimated
Component Description of Potential
Project Activity Mitigation/Enhancement Measures Cost Responsible Unit
Likely to be Environmental Impact
($ million)
Affected
 Provide communication devices such
as walkie-talkie to designated
workers.
 Follow World Bank EHS General
Guidelines 2007 (or any updates)
 Land and  Loss of habitat for terrestrial flora  Location A is only about 0.6 ha and
vegetation and fauna vegetation is mainly grassland -
minimal vegetation will be cleared.
 Tree planting will be done as required
for KPI after completion of
construction works.
 Excavated soil will be stored in
designated areas and/or borrow
areas following the spoils disposal
plan.
 Will supervise to ensure minimum
area to be used for construction
activities.
 Water  Generation of sewage from  To provide sanitary facilities to
construction workers workers and safe drinking water.
 Localized flooding  Avoid earthworks during rainy season
 Implement drainage and stormwater
management plan.
 Air and  Heavy equipment and construction  EPC Contractor will be required to
noise vehicles may increase vehicular maintain construction vehicles to
emissions minimize vehicular emissions.
 Transport of construction materials to  Will enclose construction sites
constructions sites may increase temporarily to contain dust dispersion.
dust level  Warehouse for construction materials
 Earthmoving works and excavation onsite will be provided to reduce trips
may increase dust levels of material delivery.
 Increase in noise level and vibration  Opened land areas or sources of dust
from excavation and heavy will be sprayed with water (as
equipment and construction vehicles needed).
 Transport of dust-generating materials
will be covered.
 Observance of low speed by vehicles
to reduce noise.
 Noise-generating works will be done

55
 Environmental
Estimated
Component Description of Potential
Project Activity Mitigation/Enhancement Measures Cost Responsible Unit
Likely to be Environmental Impact
($ million)
Affected
between 7AM and 7PM.
 Will require EPC Contractor to
instruct drivers that there will be no
blowing of horns.
 Installation of  People  Public and occupational safety risks  Closely monitor operation as the Included in EPC Contractor,
compressors, machine comes to normal operating overall PIU-
ancillary conditions. construction BGFCL/Supervising
equipment, and  A safety plan will be prepared by the costs Consultant,
piping works EPC contractor for approval by Environmental
 Testing and BGFCL prior to the installation works. consultant
commissioning  Air and  Emissions from testing works  Use of inert gas to purge the
of compressors Noise compressor case or cylinders of air,
needed.
 Will conduct noise quality test to
check with specifications.
 Water  Generation of waste  Liquid waste such as oily and cooling
system drains, and spent lube oil
discharged from
testing/commissioning activities will
be treated prior to disposal. Oil and
water separators will be provided.
Operation Stage
Presence of  People  Hazards such as fire or explosion  Standard operating and safety Included in EPC Contractor
additional seven due to operational failure procedures following national the O & M during the first year
compressors in requirements, industry standards, and costs of O & M, PIU-
Titas Gas Field international best practice will be BGFCL,
strictly implemented. Environmental staff
 An emergency preparedness and or consultant
disaster management plan will be
required from the EPC Contractor.
 Existing environment safety
management system (ESMS) in other
BGFCL facilities will be replicated.
 Staff will observe the compressor
operation for signs of failure or
maintenance needs during normal
operation.
 Will provide security personnel
 All electrical wiring will have
appropriate grounding and

56
 Environmental
Estimated
Component Description of Potential
Project Activity Mitigation/Enhancement Measures Cost Responsible Unit
Likely to be Environmental Impact
($ million)
Affected
deactivation of live power lines during
maintenance work.
 Compressors are designed with
safety features in case of failure such
as fire-fighting system.
 Will maintain and comply with
mechanical, structural, and electrical
standards.
 Generation of employment  Additional staff will be needed during
---
operation of the compressors
 Potential disturbance to settlements  Settlements are outside the
and occupational health risks due to perimeter of Titas Gas Field.
noise generated from compressors  Will provide enclosure of
compressors and ear muffs to Included in
PIU-BGFCL,
workers. the overall
Environmental staff
 Workers exposed to high noise construction
or consultant
levels will be rotated every 2 hours. costs
 Protective boundary wall with
sufficient height will be constructed
as buffer, if needed.
 Air  Contribution to greenhouse gas  About 272 MT of CO2 emissions per
(GHG) day will be contributed by
compressors.
 Common species of trees such as
neem (Azadirachta indica) and
Ashwatha (Ficus religiosa) will be
planted on designated areas within Included in PIU-BGFCL,
the Titas Gas Plant to provide sinks the O & M Environmental staff
for GHG emissions. BGFCL-ESD costs or consultant
together with environmental staff in
PIU (or consultant) will coordinate
with the DOF on the appropriate tree
species to be planted.
 Regular maintenance of equipment
and strict monitoring of leaks.
 Water  Use of 16 tons of water daily to  Reserved water pond will be used as
operate the compressors back-up for deep tube well during Included in PIU-BGFCL,
 Some drainage congestion may occur the dry season. the O & M Environmental staff
 Proper drainage works will be done costs or consultant
during construction stage.

57
 Environmental
Estimated
Component Description of Potential
Project Activity Mitigation/Enhancement Measures Cost Responsible Unit
Likely to be Environmental Impact
($ million)
Affected
Decommissioning Stage
Dismantling of  People  Occupational safety risks  Will prepare a decommissioning plan Included in BGFCL,
compressors and following international best practice, the O & M Environmental staff
ancillary equipment national regulations, and industry costs or consultant
standards
 Land  Generation of solid waste  All left-over structures, concrete,
solid waste materials and other
debris will be disposed of at
designated disposal site.
 Solid waste will be sorted to
determine recyclable/reusable
materials that can be sold as scrap
or used for other projects.
 Non-hazardous waste will be sent to
appropriate disposal sites.
 Air and  Emissions will be generated from  Dismantling activities will be done
noise hauling vehicles, large construction during daytime.
equipment, and dust from sources  Movement of vehicles and
such as structure removal, and equipment will be scheduled to avoid
dumping traffic and excess vehicular
emissions.
 Hauling trucks will be covered and
opened land areas will be sprayed
with water, as needed to control dust
level.
 Water  Generation and disposal of liquid  Small amount of wastewater that will
waste be generated from cleaning the work
site will be discharged into soak well
within the premises of the Titas Gas
Field.
 Spent oil, hydraulic fluids, coolants,
solvents, and cleaning agents will be
treated similar to O & M stage. These
industrial wastes will be placed in
containers, labeled, and transported
or hauled by licensed hauler of
industrial waste.

58
 Table 9.2 Environmental Monitoring Plan
Environment Sampling Amount
Parameter(s) Frequency/Year
Component Station (Lump Sum Tk)
Surface water TDS, COD, BOD, pH, 2 (During dry and monsoon) Pond near main 20,000.00
quality DO,TSS gate at Titas
Gas Field, Titas
River
Groundwater pH, Fe, Mn, As, oil & 2 (During dry season and monsoon Borehole at 50,000.00
grease, Pb, depth of season) Location A
water table (or depth facility
to groundwater)
Drinking Fe, Mn, As, Pb, 2 (During dry and monsoon Location A 50,000.00
water coliform (total or seasons) facility
fecal)
Soil Heavy metal (Pb and 2 (During dry season and monsoon Location A 50,000.00
Cr), oil, and grease season) facility
Note: one sampling for baseline data
on Pb and Cr
Solid wastes Quantity Monthly during construction Location A 50,000.00
(will include sanitary
waste and
housekeeping status)

Road traffic/ Arrangement, safety Daily ocular inspection during From main gate 15,000.00
traffic construction stage and weekly of Titas Gas (cost during
during operation stage Field to operation
Location A stage;
monitoring
cost during
construction
stage will be
included in
EPC
Contractor
budget)
Air CO, NOx, SOx, Lead Twice a year during construction and One sampling 25,000.00
yearly during operation phase point near
Location A
project site and
another
sampling station
1 km downwind
from Location A
Noise Noise level in dB(a) Twice a year during construction and One sampling 10,000.00
yearly during operation phase point near
Location A
project site and
another
sampling station
1 km downwind
from Location A
Health and Incidence of Quarterly during construction stage Construction 50,000.00
safety accidents, outbreak and semi-annually during operation site at Location
of disease(s), number phase A and soon
of absences of after Location A
workers due to illness facility
Total 320,000.00

59
10. CONCLUSION AND RECOMMENDATION

196. There is a great need to install compressors at Location A in Titas Gas Field to ensure
the reliable supply of natural gas at the required pressure to facilitate transmission. Location A is
about 0.6 hectare (ha) that will accommodate seven compressors where five compressors will
be in operation at a time while two compressors will be standby.

197. Installation of these compressors will not cause significant adverse environmental
impacts given that it is within an area considered for industrial use. Vegetation is mainly
grassland. DOE has issued the ECCs for the existing facilities. Since Component 1 is within an
existing facility, DOE advised the BGFCL to submit an EMP in securing the ECC instead of the
usual IEE and EIA requirements for red category project.

198. Potential environmental impacts from during construction stage may include increased
level of noise and dusts, generation of waste from construction works, and disruption to daily
activities in Ghatura mauza in Sadar Upazila, Brahmanbaria. These potential impacts can be
mitigated by best construction engineering practices and adherence to relevant regulations of
GoB and requirements of ADB. Mitigation measures are included in the EMP and the
parameters for monitoring have been identified in the environmental monitoring plan.

199. While the local people consulted support the project, they raised concerns on
compensation and participation in potential business opportunities. Continuous communication
and/or consultations will be conducted during implementation on community safety and
environmental management. Should there be any concerns not addressed during
consultations, a grievance redress mechanism will be will be set up by the PIU-BGFCL.

200. This draft IEE will be publicly disclosed at the ADB website as required by SPS 2009
and PCP 2011. A project brief and/or factsheet will be prepared in Bangla and made available to
the public at the PIU-BGFCL field office, in Barishar and in Dhaka.

201. Component 1 will have potential environmental impacts but these can be readily
mitigated. Overall, the improvement in the supply of natural gas as a result of Component 1 is
expected to contribute in meeting the growing demand for natural gas and in the economic
development of Bangladesh.

60
 Annex 1

Relevant Environmental Quality Standards of Bangladesh

(From the Environment Conservation Rules 1997)

SCHEDULE – 2
Standards for Air
[See Rule 12]

Density in microgram per cusec meter

Suspended
Sl. Sulphur Carbon Oxides of
Categories of Area Particulate
No. Dioxide Monoxide Nitrogen
Matter (SPM)
a Industrial and mixed 500 120 5,000 100
b Commercial and mixed 400 100 5,000 100
c Residential and rural 200 80 2,000 80
d Sensitive 100 30 1,000 30
Notes:
(1) At national level, sensitive area includes monuments, health center, hospital, archeological site, educational
institution, and government designated areas (if any).
(2) Industrial units located in areas not designated as industrial areas shall not discharge pollutants which may
contribute to exceeding the standard for air surrounding the areas specified at Sl. nos. c and d above.
(3) Suspended particulate matter means airborne particles of a diameter of 10 micron or less.

SCHEDULE – 3
Standards for Water
[See Rule 12]

(A) Standards for inland surface water

Parameter
Best practice-based
BOD DO Total Coliform
classification pH
(mg/l) (mg/l) (number/100 ml)
a. Source of drinking water for 6.5-8.5 2 or less 6 or above 50 or less
supply only after disinfecting:
b. Water usable for recreational 6.5 – 8.5 3 or less 5 or more 200 or less
activity :
c. Source of drinking water for 6.5 – 8.5 6 or less 6 or more 5,000 or less
supply after conventional
treatment:
d. Water usable by fisheries: 6.5 – 8.5 6 or less 5 or more ---
e. Water usable by various process 6.5 – 8.5 10 or less 5 or more 5,000 or less
and cooling industries :
f. Water usable for irrigation: 6.5 – 8.5 10 or less 5 or more 1,000 or less
Notes:
1. In water used for pisiculture, maximum limit of presence of ammonia as Nitrogen is 1.2 mg/l.
2. Electrical conductivity for irrigation water – 2,250 μmhoms/cm (at a temperature of 25°C); Sodium less than 26%;
boron less than 0.2%.

(B) Standards for drinking water

SI Parameter Unit Standard
1. Aluminum mg/l 0.2
2. Ammonia (NH3) mg/l 0.5
3. Arsenic mg/l 0.5
4. Barium mg/l 0.01
5. Benzene mg/l 0.01
o
6. BOD5 at 20 C mg/l 0.2
7. Boron mg/l 1.0
8. Cadmium mg/l 0.005
9. Calcium mg/l 75

61
 SI Parameter Unit Standard
*
10. Chloride mg/l 150 – 600
Chlorinated alkanes
Carbon tetrachloride mg/l 0.01
1,1 dichloroethylene mg/l 0.001
11.
1,2 dichloroethylene mg/l 0.03
Tetrachloroethylene mg/l 0.03
Trichloroethylene mg/l 0.09
Chlorinated phenols
12. Pentachlorophenol mg/l 0.03
2,4,6 trichlorophenol mg/l 0l03
13. Chlorine (residual) mg/l 0.2
14. Chloroform mg/l 0.09
15. Chromium (hexavalent) mg/l 0.05
16. Chromium (total) mg/l 0.05
17. COD mg/l 4.0
18. Coliform (fecal) n/100 ml 0
19. Coliform (total) n/100 ml 0
20. Color Hazen unit 15
21. Copper mg/l 1.0
22. Cyanide mg/l 0.1
23. Detergents mg/l 0.2
24. DO mg/l 6.0
25. Fluoride mg/l 1
26. Hardness (as CaCO3) mg/l 200 – 250
27. Iron mg/l 0.3 – 1.0
28. Kjeldahl Nitrogen (total) mg/l 1.0
29. Lead mg/l 0.05
30. Magnesium mg/l 30 – 35
31. Manganese mg/l 0.1
32. Mercury mg/l 0.001
33. Nickel mg/l 0.1
34. Nitrate mg/l 10
35. Nitrite mg/l Less than 1
36. Odor mg/l Odorless
37. Oil and grease mg/l 0.01
38. pH --- 6.5 – 8.5
39. Phenolic compounds mg/l 0.002
40. Phosphate mg/l 6.0
41. Phosphorous mg/l 0
42. Potassium mg/l 12
Radioactive materials Bq/l 0.01
43.
(gross alpha activity)
Radioactive materials Bq/l 0.1
44.
(gross beta activity)
45. Selenium mg/l 0.01
46. Silver mg/ 0.02
47. Sodium mg/ 200
48. Suspended particulate matter mg/ 10
49. Sulfide mg/ 0
50. Sulfate mg/ 400
51. Total dissolved solids mg/ 1,000
o
52. Temperature C 20 – 30
53. Tin mg/ 2.0
54. Turbidity JTU 10.0
55. Zinc mg/ 5.0

62
 SCHEDULE – 4
Standards for Sound
[See Rule 12]

Standards determined at
SI
Category of areas dBa unit
No.
Day Night
a Silent zone 45 35
b Residential area 50 40
c Mixed area 60 50
(mainly residential area, and also
simultaneously used for commercial and
industrial purposes)
d Commercial area 70 60
e Industrial area 75 70
Notes:
1. The time from 6 a.m. to 9 p.m. is counted as daytime.
2. The time from 9 p.m. to 6 a.m. is counted as night time.
3. Area up to a radius of 100 meters around hospitals or educational institutions or special institutions/
establishments identified/to be identified by the Government is designated as Silent Zones where use of horns
of vehicles or other audio signals, and loudspeakers are prohibited.

SCHEDULE – 5
[See Rule 12]
Standards for Sound originating from Motor Vehicles or Mechanized Vessels

Category of Vehicles Unit Standards Remarks

*Motor Vehicles (all types) dBa 85 As measured at a distance of 7.5 meters from exhaust
pipe.
100 As measured at a distance of 0.5 meter from exhaust pipe.
Mechanized Vessels dBa 85 As measured at a distance of 7.5 meters from the vessel
which is not in motion, not loaded and is at two thirds of its
maximum rotating speed.
100 As measured at a distance of 0.5 meter from the vessel
which is in the same condition as above.
* At the time of taking measurement, the motor vehicle shall not be in motion and its engine conditions shall be as follows:-
(a) Diesel engine – maximum rotating speed.
(b) Gasoline engine –at two thirds of its maximum rotating speed and without any load.
(c) Motorcycle – If maximum rotating speed is above 5000 rpm; two thirds of the speed, and if maximum rotating speed is less
than 5000 rpm, three-fourth of the speed.

SCHEDULE – 6
Standards for Emission from Motor Vehicles
[See Rule 12]

Parameter Unit Standard Limit

Black Smoke Hartridge Smoke Unit (HSU) 65
gm/km 24
Carbon Monoxide
Percent area 04
gm/km 02
Hydrocarbon
ppm 180
gm/km 02
Oxides of Nitrogen
ppm 600
* As measured at two thirds of maximum rotating speed.

63
 SCHEDULE – 7
Standards for Emission from Mechanized Vessels
[See Rule 12]

Parameter Unit Standard Limit

*
Black Smoke Hartridge Smoke Unit (HSU) 65
* As measured at two thirds of maximum rotating speed.

SCHEDULE – 8
Standards for Odor
[See Rule 12]

Parameter Unit Standard Limit

Acetaldehyde ppm 0.5 - 5
Ammonia ppm 1- 5
Hydrogen sulfide ppm 0.02 – 0.2
Methyl disulfide ppm 0.009 – 0.1
Methyl sulfide ppm 0.01 – 0.2
Styrene ppm 0.4 – 2.0
Trimethylamine ppm 0.005 – 0.07
Notes:
(1) Following regulatory limit shall be generally applicable to emission/exhaust outlet pipe of above 5
meter height:
Q = 0.108 x He2Cm (Where Q = Gas Emission rate Nm 3/hour)
He = Height of exhaust outlet pipe (m)
Cm = Above mentioned limit (ppm)

(2) In cases where a special parameter has been mentioned, the lower limit shall be applicable for
warning purposes, and the higher limit shall be applicable for prosecution purpose or punitive
measure.

SCHEDULE – 9
Standards for Sewage Discharge
[See Rule 12]

Parameter Unit Standard Limit

BOD5 mg/l 40
Nitrate mg/l 250
Phosphate mg/l 35
Suspended solids mg/l 100
o
Temperature C 30
Coliform Number per 100 ml 1,000
Notes:
(1) This limit shall be applicable to discharges into surface and inland waters bodies.
(2) Sewage shall be chlorinated before final discharge.

SCHEDULE – 10
Standards for Waste from Industrial Units or Projects Waste
[See Rule 13]

Places for determination of standards

SI. Public Sewerage system
Parameter Unit Inland Surface Irrigated
No. connected to treatment at
Water Land
second stage
1 Ammoniacal Nitrogen (as
mg/l 50 75 75
elemental N)

64
 Places for determination of standards
SI. Public Sewerage system
Parameter Unit Inland Surface Irrigated
No. connected to treatment at
Water Land
second stage
2 Ammonia (as free NH3) mg/l 5 5 15
3 Arsenic (As) mg/l 0.2 0.05 0.2
o
4 BOD5 at 20 C mg/l 50 250 100
5 Boron mg/l 2 2 2
6 Cadmium (as Cd) mg/l 0.5 0.05 0.05
7 Chlorine mg/l 600 600 600
8 Chromium (as total Cr) mg/l 0.5 1.0 1.0
9 COD mg/l 200 400 400
+6
10 Chromium (as Cr ) mg/l 0.1 1.0 1.0
11 Copper (Cu) mg/l 0.5 3.0 3.0
12 Dissolved oxygen (DO) mg/l 4.5 – 8 4.5 – 8 4.5 – 8
13 Electrical conductivity (EC) µmho/cm 1,200 1,200 1,200
14 Total dissolved solids mg/l 2,100 2,100 2,100
15 Fluoride (as F) mg/l 2 15 10
16 Sulfide (as S) mg/l 1 2 2
17 Iron (as Fe) mg/l 2 2 2
18 Total Kjeldahl nitrogen
mg/l 100 100 100
(as N)
19 Lead (as Pb) mg/l 0.1 1.0 0.1
20 Manganese (as Mn) mg/l 5 5 5
21 Mercury (as Hg) mg/l 0.01 0.01 0.01
22 Nickel (as Ni) mg/l 1.0 2.0 1.0
23 Nitrate (as elemental N) mg/l 10 Not yet fixed 10
24 Oil and grease mg/l 10 20 10
25 Phenolic compounds
mg/l 1.0 5 1
(as C6H5OH)
26 Dissolved Phosphorous
mg/l 8 8 15
(as P)
27 Radioactive substance To be specified by Bangladesh Atomic Energy Commission
28 pH --- 6–9 6–9 6–9
29 Selenium (as Se) mg/l 0.05 0.05 0.05
30 Zinc (as Zn) mg/l 5 10 10

o
Summer 40 40 40
31 Temperature C
Winter 45 45 45
32 Suspended solids mg/l 150 500 200
33 Cyanide (as Cn) mg/l 0.1 2.0 0.2
Notes:
(1) These standards shall be applicable to all industries or projects other than those specified under the heading “Standards for
sectorwise industrial effluent or emission.”
(2) Compliance with these standards shall be ensured from the moment an industrial unit starts trial production, and in other cases,
from the moment a project starts operation.
(3) These standards shall be inviolable even in case of any sample collected instantly at any point of time. These standards may be
enforced in a more stringent manner if considered necessary in view of the environmental conditions of a particular situation.
(4) Inland Surface Water means drains/ponds/tanks/water bodies/ditches, canals, rivers, springs and estuaries.
(5) Public sewerage system means treatment facilities of the first and second stage and also the combined and complete treatment
facilities.
(6) Irrigable land means such land area which is sufficiently irrigated by waste water taking into consideration the quantity and
quality of such water for cultivation of selected crops on that land.
(7) Inland Surface Water Standards shall apply to any discharge to a public sewerage system or to land if the discharge does not
meet the requirements of the definitions in notes 5 and 6 above.

65
 Annex 3
Chance Find Procedures for Physical Cultural Resources

1.0 Introduction

These procedures describe the measures to be undertaken if an accidental discovery or chance

find, or an encounter with a physical cultural resource (PCR) occurred during the construction
phase. The chance find procedures will be finalized as Physical Cultural Resources Plan
(PCRP) by BGFCL and the Contractor(s), in consultation with the Department of Archaeology
(DOA) or the Ministry of Cultural Affairs to ensure compliance to The Antiquities Act 1968
(amended 1976), National Cultural Policy 2006, and applicable regulations. The PCRP will be
included in the Construction Management Plan that will be required from the Contractor(s).
These procedures aim to identify and promote the preservation, protection, and recording of any
PCR that may be discovered or exposed during the earthmoving works and ground alteration at
Location A in Titas Gas Field.

2.0 Orientation and/or Briefing of Workers

The Contractor(s), with the assistance from the DOA or Ministry of Cultural Affairs and PIU-
BGFCL, will conduct an orientation or training for all workers, particularly those who will be
involved in earth movements and excavation on how to recognize artifacts that they may
encounter or discover.

An archeological map of Bangladesh (if available) will be obtained from the DOA or other
relevant sources to examine if there are potential "hot spots" within Titas Gas Field. This map
will be part of the references on-site to guide the construction supervision staff in determining
the potential "hot spots."

3.0 Procedures

3.1 General

In case a PCR was encountered during excavation, construction activities in the area will be
stopped. The site or area discovered will be marked or demarcated using a global positioning
system (GPS) unit to determine the exact coordinates and photographs will be taken. The
construction supervision staff of the Contractor and PIU-BGFCL site engineer/staff will secure
the site to prevent damage, loss or pilferage of removable objects. The PIU-BGFCL site
engineer or designated staff will be responsible for coordinating with the DOA.

If the encounter involves removable items, a security person will be posted until the
representative of DOA or Ministry of Cultural Affairs arrives to assess and determine its value.
The DOA staff will be responsible in determining the appropriate course of action. Further
excavation or earth moving works may be conducted at the distance and demarcation area
recommended by the DOA staff.

If the chance find will have significant cultural value, this may entail consequent changes in the
lay-out particularly if the discovery is considered or assessed as remains of cultural or
archeological importance that is not removable.

The Contractor will not be entitled for compensation due to work stoppage as a result of the
discovery and its associated subsequent actions.

66
 3.2 Assessment and Recovery

Appropriate heavy equipment such as wheel loader will be made available to recover the
excavated material from the excavation site to allow the geologist onsite or the DOA staff to
inspect, recover or conduct sampling. A safe storage area will be provided to protect the
discovered object. If the chance find is part of a large artifact, deposit or structure, the
inspection or recording will include photography and video on an "as-is, where is" manner. The
exact location will be recorded using a GPS unit.

3.3 Resumption of Work

The Contractor can continue with excavation and construction works within the affected area
after the DOA staff has given clearance. All the discovered objects of value will be given to the
Government.

4.0 Reporting

The Contractor will prepare a Chance Find Report within a week showing the date and time of
discovery, specific location, description of the PCR, and interim protection measures
implemented. This Report will be submitted to PIU-BGFCL who will provide it to the DOA or
Ministry of Cultural Affairs.

67
 Annex 2 Photographs during the audit on 22-24 August 2016

Sign board in Bengali Notice at the Entrance Gate No Smoking sign at the Mosque for Prayer of
near the Gate of Location which says: Special entrance of tank farm Employees within Location
A indicating that this is a Notification A
Restricted Area. Let it be known to all that
Unauthorized entrance unauthorized entrance
and taking of photograph within this boundary is
are not permitted. highly illegal. The
trespassers will be handed
over to the Prosecutors.

Security Guard on duty at Security Guards and visitor Earthquake awareness A view of the continued
the Entrance gate of entry record room near the sign boundary wall around the
Location A with 2 entrance gate area. There entire Location – A
additional Guards from is another room nearby for
the Government orientation of the visitors
before they are allowed to
enter Location A.

68
Fire shed with fire truck Ambulance in the Parking of Fire hydrants in the back Caution Board in Bengali
and fire crew Location A yard of the office building Notifying what to do: a)
of Location A. Such fire when fire is seen and b) If
hydrants are spread over gas leakage or shut down
different locations within of Well/ Plant
Location A.

The doctor with his aids Switch of the siren: ‘Danger Some PPE items in stock Warehouse to facilitate
in the Emergency and Signal Switch ‘ in Bengali as displayed checking and inspection
First aid Treatment Area

69
 Annex 4

Public Consultation

Meeting with Chairman, Councilor and Local People of Shuhilpur Union Porisad
Place: Shuhilpur Union Porisad Office
Date: 18 October 2015

Photo 1

Photo 2

70
Photo 3

71
Attendance Sheet

72
73
 Annex 5
No Objection Certificate from the Local Authority

English Translation of the NOC (below)

It is certified that the people of Shuhilpur Union Parishad No.3 have no objection if Bangladesh
Gas Fields Company Limited install wellhead compressor at their own premises of Location-A,
Mouza: Ghatura, dist: Brahmanbaria. Besides, people of this area will extend necessary co-
operations during project implementation period and will not create any problem.

74
 Annex 6

Safety and Hazard Mitigation Plan at BGFCL

General Safety Procedure (GSP)

The safety policy will be updated from time to time. The policy will be signed and dated by the
Chief Executive Officer. The policy will be discussed with all personnel. The Project Director
should periodically review the policy and reissue the policy. The Gas Safety Rules 1991
(Amendment 2003) shall be followed for the implementation of the project. Detailed rules and
procedures identifying company and legislative requirements and expectations must be
communicated to employees and contractors.

Standard Operating Procedure

To determine compliance with safety and hazard issues while performing a task, efforts should
be made to ensure the following:

 Ensure that employees affected by these tasks participate in the development of safe
work procedures;
 Ensure that employees are involved in the maintenance of safe work procedures;
 Arrange safety training for all concerned employees on safe work procedures and
refresher training thereafter;
 Where practical, observe employees performing critical tasks to ensure Review
records and to ensure that employees receive training on hazardous work
procedures, codes and practices; and that they follow the operating procedures and
general safety; and
 That they follow the operating procedures and general safety.

Safety Orientation and Training

Initial safety training is one of the most important aspects of any safety program. Employees
and contractors must receive some level of basic training, specific to the facility and nature of
the job. It must be ensured that appropriate orientation is given to: Employees, Contractors,
Sub-contractors and Visitors.

The orientation shall also include a review of the following:

 Company safety policy and procedures;
 a Specific job hazards
 Safety precautions
 Job responsibilities
 Regulatory requirements
 Company enforcement policy and
 Worker's right-to-know and authority to refuse unsafe work.

Reporting Incidents and Accidents

All accidents and near-miss incidents shall be investigated to determine what caused the
problem and what action is required to prevent a recurrence. Employees required to perform
investigations shall be trained in accident investigation techniques. The incident/accident
investigation should be a fact-finding exercise rather than fault-finding. The investigations will
focus on collection of evidence to find out the “root cause” of the incident. The
recommendations of the investigation report shall be implemented in phases.

75
The purpose of impact mitigation and counter measures is 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.

Personnel Protective Equipment (PPE)

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 PPE.

Body Parts That Require Protection

The body and its internal organs can be seriously injured, by any violent impact with an object.
A direct blow to any part of a worker’s body, even with protection, can easily result in some
injury, either major or minor. The following eight areas or parts of the body require protection:
 Head
 Eyes
 Torso
 Hearing
 Arms
 Hands
 Legs
 Feet
Head
The worker’s head houses his brain, which controls all the motor and sensory functions of his
body. Any blow to his head, no matter how slight, can be very dangerous and result in injuries
ranging from dizziness to total disability and even death.

Eyes
One of our most valuable senses is light. One must protect his eyes from the dangers of flying
objects, bright light and chemicals. Without eyes one would live a life in total darkness.

Hearing
Hearing damage is not often a result of an accident, unless someone has had a head injury. A
more common problem is hearing loss which can occur one exposed to noise levels above the
exposure limits, as outlined in the Noise Regulation.

The longer one is expected to high noise levels, the greater the potential hearing loss. Hearing
loss associated with exposure to noise tends to be gradual. It may take several years before
one can realize that for some reason he has difficulty hearing normal conversation. Hearing is a
valuable asset which should be preserved, so the worker can have a full and productive life.

Hands
Our hands provide us with the ability to perform a wide variety of tasks ranging from playing a
musical instrument to operating machinery. Hands and fingers are often caught in pinch points,
cut, crushed, burned or broken.

Hands are the second most commonly injured part of the body. Many hands injure are a result
of workers not watching where their hands are being placed, or using their hands to accomplish
tasks for which tools will be used.

76
Arms
The workers arms provide the power to his hands to perform various tasks. Arms are not injured
as frequently as hands, most arm injures happen when the worker is reaching for something.
Since his strength is in his arms, he can injure himself by over-using or straining them. The
worker must also protect his arms against being caught in machinery, burned, crushed or hit. An
injury to the arms severely hampers the use of the hands.

Torso
The torso extends from the top of the shoulders to the buttocks. Injury to this part of the body
usually involves the back. The back is the most commonly injured part of the body. Back injuries
are often a result of poor lifting procedures, or lifting objects that are too heavy or awkward.
Other parts of the torso that can be injured, excluding internal organs, are the chest, sides and
stomach area. Injuries to these parts are usually strains, burns, contusions and lacerations.

Legs
The most injured part of the leg is the knee. These injuries are caused by stress on the knee
from twisting and turning. Other injuries to the upper and lower legs are usually caused by
tripping or falling. This van results in fractures, cuts and contusions.

Feet
Feet are the third most common injured part of the body. Injures to the feet are often caused by
an object being dropped on them. Other injuries to this area of the body include having the foot
run over, twisting an ankle or stepping on a protruding nail which goes through the sole of the
footwear into the foot.

Types and Use of Personal Protective Equipment

In order to protect himself from injury the worker needs two things-the right attitude about safety
and the right personal protective equipment (PPE).

As standard practice, all safety-conscious companies require appropriate personal protective

equipment to be worn at the work site. Workers entering the work site without, personal
protective equipment are prevented from working until they done their protective equipment.
There is a wide variety of personal protective equipment to suit the different types of jobs and
tasks they have to do.

Hard Hat
One of the most important pieces of personal protective equipment is the hard hat. One must
wear an approved hard hat wherever there is a possibility of a hard injury on the job. For the
best protection, make sure it has a good fit by adjusting the headband.

Eye protection
The worker’s eyes are exposed to various hazards based on the type of job he is doing. That’s
why there are three different types of protective equipment for eyes. These are impact glasses
with side shields (prescription impact glasses are acceptable), cover goggles and face shields.
The worker should always check this equipment for defects and fit before using it.

Safety Glasses
Safety or impact glasses will protect the worker from the impact of flying particles when he is:
 Chipping or drilling
 Carrying out NDT work

77
  Grinding and polishing
 Handling wire and strips of material
 Cutting wire and metal
 Using a hammer and chisel on wood, metal or concrete
 Welding

Cover Goggles
The face shield is worn to protect eyes and face from the impact of flying objects and when
mixing chemicals. One can wear the face shield for must jobs where air borne particles are
created, such as using a grinder or chipping a weld. One can increase his protection by wearing
a face shield over his cover goggles when handling hazardous materials.

Hearing Protection
Continued exposure to noise levels over 85 decibels can lead to hearing loss unless one is
wearing appropriate hearing protection. There are three classes of hearing protection: A, B and
C. They come in two basic types of hearing protection-ear muffs which are class A and ear
plugs which can be either class B or C.
Hearing protection must be worn when noise levels are over 85 decibels. Class C ear plugs are
acceptable for noise levels between 85 and 95 decibels. For sound levels of 96 to 105 decibels
glass B ear plug are required. Ear muffs are recommended when noise levels are over 100 and
are required for sound levels of 106 decibels and up.
Wearing both ear plugs and ear muffs in high noise areas will give the worker added hearing
protection. As with all personal protective equipment make sure the worker’s ear muffs and
plugs are in good condition before using them.

Hearing Protectors
Sound level (dBA) Class of Hearing Protectors
85-95 C Class
96-105 B Class
106 or above A Class

Hand Protection
There are three common types of gloves one can use to protect his hands: cloth gloves,
combination cloth and leather gloves, and chemical resistant gloves.

Cloth Gloves
Cloth gloves are used for general purpose work. They will protect workers hands from
scratches, blisters and cuts when he is handling pipes, tools, and other material.

Cloth Leather Gloves

Gloves with leather palms and cloth backing are stronger than cloth gloves. The leather palms
are puncture and tear resistant. This makes them good for handling tools of all kinds, including
shovels and picks.

Responsibility of the Contractor

Potential impacts could originate from contractor's activities. Therefore, BGFCL shall ensure
that Contractors take due responsibility to mitigate these negative impacts. Particularly, BGFCL
will ensure that the Contractor:

78
  Takes reasonable steps to protect the environment and avoid damage and nuisance
arising from their activities and operations.
 Complies with statutes and regulations concerning the execution of work.
 Familiarizes with legislation and regulations relating to environmental protection that
is relevant to their activities.
 Refers to national environmental quality guidelines.
 Be responsible for the costs of cleaning up any environmental pollution resulting from
their activities, if methods for doing so are available and effective.
 Maintains sites under their control in a clean and tidy condition and shall provide
appropriate and adequate facilities for the temporary storage of wastes before
disposal.
 Shall not allow used oil or other petroleum wastes to be used as dust suppressants
and reasonable precautions shall be taken to control and prevent accidental blow off
of gas and/or spillage of petroleum products or discharge into atmosphere or
watercourses.
 Be responsible for the provision of adequate sanitary facilities for the construction
workforce (including those employed under sub-contracts) at construction and camp
sites. Vehicles operated by the Contractor (including sub-contractors) shall be
maintained according to the original manufacturer's specifications and manuals with
particular regard to the control of noise and/or smoke emissions.
 Takes reasonable measures to minimize dust-blow arising from sites under their
control by regular watering of soil stockpiles, bare soil, haul roads, non-surfaced
traffic areas and sources of fugitive dust, when conditions require dust suppression.
 Be responsible to pay compensation upon the appropriate monetary evaluation
applicable to the local market if any damage is incurred to agricultural land or
surrounding homesteads outside of the requisitioned land.
 Precautionary signboards/ danger signals/ propitiatory billboards shall be placed in
appropriate places to notify people about the possible dangers particularly in the eve
of non-destructive testing inspections involving radiations and including but not
limited to hydrostatic testing & commissioning of the pipeline system.
 The contractor will be responsible for prior identification of any other projects around
the project area that could affect the significance of predicted impacts and to take
additional and reasonable mitigation measures required thereof.

Removes equipment, surplus material, rubbish and temporary works and leave the site in a
clean condition to the satisfaction of the company's representatives after completion of
construction activities.

Emergency Response and Disaster Management Plan

The initial response to an incident is a critical step in the overall emergency response. 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.

79
  Notify the next-to-kin of accident victims.
 Promote inter-departmental Communications to ensure a “Companywide” Co-
ordinated emergency response.
 Minimize the effects that disruptive events can have on company operations by
reducing recovery times and costs.
 Respond to immediate requirements to safeguard the subtending environment and
community.

As a general rule, the initial response is guided by three priorities Ranked in importance these
priorities are:

1. People
2. Property
3. Environment

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. Nature of Emergency & Hazardous Situations may be of any or all of the
following categories:

I. Emergency
 Fire,
 Explosion,
 Medical emergency,
 Leaks and other releases of hazardous substances,
 Spillage of toxic chemical, and electrocution.

II. Natural Disasters

 Flood,
 Earthquake/ cyclone,
 Storm/ typhoon/ tornados, and
 Cloud burst lightning.

III. External Factors

 Food poisoning/water poisoning,
 Sabotage, and
 War.

Six Steps in Emergency Response

Step-1)
a) Determine the potential hazards associated with the incident, substance or circumstances
and take appropriate action identify the type and qualities of dangerous goods involved and any
known associated hazards.
b) Determine potential hazards stemming from local conditions such as inclement weather water
bodies etc. and ensure that the initial response team is aware of these conditions.

Step-2)
Determine the source/ cause of the event resulting to the emergency and prevent further losses.

80
Step-3)
Conduct an assessment of the incident site for any further information on hazards or remedies.

Step-4)
Initiate redress procedures.

Step-5)
Report the incidence: its nature cause impact applied redress procedures and any further
assistance required etc., to the appropriate company, government and/or land owner.

Step-6)
Take appropriate steps with respect to hazards to wildlife, other resources and addressing
public and media concerns and issues, as applicable. Response priorities are to protect human
lives, property and the environment.

Emergency Response Planning

The purpose of an Emergency Response Plan (ERP) is to describe the procedures to ensure
the health and safety of staff and the public in the event of any incident. Although Emergency
Response Plans for gas pipelines have a different scope than those of other facilities, the
purpose and key elements of the plans are similar.

Three levels of planning (reduced, normal and special) may be used depending on the particular
circumstance, potential incidence rate and the location and number of residents living in the
community/ locality in close proximity along the project sites. The scope of the ERP is also
dependent on the potential impact of the project activities, complexity of evacuation logistics and
proximity to public facilities. A key feature of all plans is the designation of and Emergency
Planning Zone which defines the area to be evacuated or protected in the event of an
emergency. Another fundamental requirement of Emergency Response Planning is that
discussions occur with local residents and public within the Emergency Planning Zone and must
include any pertinent health factors which must be considered.

The contents of a plan must include a definition of "an Emergency" and an action plan to
address that emergency. This includes defining the "Stages of Alert" that may be applicable for
various aspects of the work. This is important since it requires good coordination between
aspects such as welding, testing, commissioning and Tie-in etc. Each action plan defines what
level of evacuation should be occurring, who should be notified, what monitoring should be done
and when emergency response teams are notified.

Another essential component of an ERP is the definition of responsibilities of the emergency

response personnel including: off-site and on-site personnel, team coordinators, safety and
evacuation personnel, monitoring crews, public relations and government personnel. Evacuation
procedures, evacuation centres, communication systems equipment lists and post emergency
procedures must also be defined.

The roles and responsibilities for the various government departments are to be defined and
coordinated within the plan which should include the provision for the company/government to
establish an on-site command post and a main control headquarters to provide advice to
affected persons, union parishads, local administrations, fire brigade and the media. To ensure
preparedness, there should be provision for testing the response and usefulness of the planned
emergency response exercises. These exercises usually involve the company and contractor

81
personnel as well as various government organizations and the community leaderships that
would be involved in actual emergency incidents.

Specialized Equipment
All relevant emergency equipment should be maintained on site throughout the project. This
includes items such as fire extinguishers/hoses self-contained breathing apparatus (SCBA) and
personal protective gear etc.

The hazardous materials section of the local fire brigade has emergency response units with
specialized equipment that would be appropriate for an explosion incident response. All local
brigades should be checked for their ability to respond to certain incidents and should be
notified of the operations taking place.

Training
It is critical that emergency responders have a clear understanding of the potential problems
that exist as a result of an emergency situation, that they pre-plan for such an event, and have
hands-on training prior to initial response to an actual incident. In-house training programs
should be held by the company and designated first responders to test their capabilities.

Response teams have to be assembled, both on a company and community cooperative basis
to deal with potential emergency situations. A 2-day training program that includes two field
exercises would be effective for the attendees to gain hands-on training in coping with incidents
typical of the gas pipeline construction and operations.

Safety Orientation
Initial safety orientation is one of the most important aspects of any safety program. Employees
and contractors must receive some level of basic training, specific to the facility and nature of
the job. It must be ensured that appropriate orientation is given to all employees, contractors,
sub-contractors and visitors.

The orientation shall also include a review of the following:

 Company safety policy and procedures;
 Specific job hazards;
 Safety precautions;
 Job responsibilities;
 Regulatory requirements;
 Company enforcement policy; and
 Worker's right-to-know and authority to refuse unsafe work.

Approaches to Emergency Response

For this project emergency response systems should be in place to deal with dangerous goods
uncontrolled releases spills, natural calamities fires burns and injuries. There are to be trained
emergency response teams specific contingency plans and incident specific equipment
packages in place to cope with these type of an emergency Should an incident occur immediate
action must be taken to mitigate the impacts.

In order to minimize the possibility of injury to the responders and others it is important that
emergency responders follow a specific sequence of actions as stepped out in the preceding
paragraphs.

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 Figure showing the Approaches to Emergency Response

Guidelines for Disaster Management

Introduction
Disaster management is a four step exercise:
 The design and planning stage,
 The compressors operating stage,
 The short and important stage when disaster actually occurs, and
 The recovery stage.

It is imperative that all safety precautions are rigorously implemented so as to avoid any kind of
accidental occurrence in the first place. At the design stage, this includes incorporating items of
basic engineering planning and design for safety into all processes and providing suitable safety
margins for equipment as per the various safety codes and standards in practice.

At the operation stage, disaster management is mainly preventative in nature, through the use
of appropriate personal protective equipment and safe work procedures.
The disaster stage has the greatest potential for being mismanaged due to the typically
somewhat chaotic and unplanned nature of the event. It is at this stage that pre-planning
becomes critical.

Disaster Management in Operation Stage

Safe operating procedures will be laid down and followed to ensure safety, optimum operation
and economy a safety audit will be undertaken periodically in conjunction with a training
program. Furthermore, all accidents, however minor, will be investigated and reported in order
to provide direct feedback to the operational planning mechanisms.

The risk and reliability assessment studies carried "but at the: design stage will be periodically
reviewed and updated in the light of any actual experiences. This is because most of the

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available data on failure rates" and similar parameters used in these computations are generally
based on US or' European experience, not on those within Bangladesh.

During the operational phase access to work sites will be denied to unauthorized persons.
Regular preventive maintenance and inspection procedures must be implemented and regular
certification of high pressure equipment will be obtained.

These factors if implemented correctly will significantly reduce the possibility for a catastrophic
event occurring.

Level of Incidents
In the event of a disaster at any location within the workplace, the area affected can be
classified in the following four classes:

Level - I Operator level

Level - II Local/community level
Level - III Regional/National level
Level - IV International level

Only Level - I and Level - II class of incidents or accidents will applicable within the proposed
project. Level - I, disasters may be the result of fires, explosions, oil spillages and spontaneous
ignition of inflammable materials. This may affect persons working in and around moving
machinery, other plant and various sites which have been mentioned as potential hazard areas.

Level - II disasters may happen due to sabotage or complete failure of all automatic
control/warning systems, catastrophic failure of fuel oil storage tanks, chemical release or
explosion. Transportation (road and rail) accidents could occur anywhere within or outside the
complex and thus present additional problems of access and loss of time in taking remedial
measures.

Incidents/Accident Investigation & Reporting System

Major disasters are often preceded by a string of minor incidents which are ignored, neglected
or not fully understood. Therefore, a routine system will be enforced to ensure that all accidents
are investigated and reported to the plant supervisors in a specified format such as the
following:

 Background on the factors that might have made the incident possible;
 What form of energy release or toxic substance was involved?
 What was done to prevent accident (who responded and how)
 What effect did it produce on the immediate and surrounding environment?
 What repercussions did the incident have (loss of life damage to equipment and
buildings) and
 Cost estimates of damage done and repairs needed.

Registers of all incidents will be kept and will be analyzed on a regular basis (at least monthly)
to identify trends or patterns in incident occurrence In particular cases this may prevent
significant chronic incidents or single-event events that are the result of an accumulation of
either physically hazardous materials or substances, or operational complacency.

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Preparedness
Having taken all the preventative measures, a Disaster Management Team (DMT) will be
established which would be responsible for preparing a specific Disaster Management Plan for
the project The team should meet at regular intervals to update the Disaster Management Plan
based on accident data and any changes to support agencies The team should also undertake
trial runs in order to be fully prepared and to improve upon the communication links response
time and other critical factors.

Response

I. Set up Disaster Control Room

In the unlikely event of a disaster a Disaster Control Room (DCR) should be set up. The
responsible officers of Disaster Control Group will assemble in the DCR and formulate control
procedures as part of the contingency plans.

The DCR should have links with all site operations and an officer should maintain the DCR at all
times. On receiving information about an accident, the officer should inform the Disaster
Controller (DC) and/or other coordinators immediately.

II. Casualty Services

The Head of casualty services will be the Medical Officer who will secure and provide First Aid
service to first aid patients on the spot.

Emergency Response Plans for Gas Field, Well and Field Camp
The following site specific Emergency Response Plan (ERP) has been developed to cover
specific details for those emergencies which may be encountered during installation
compressors at the fields and field camps. This ERP has been organized such that each of the
anticipated emergencies has an Organization Plan, a List of Responsibilities and a List of
Duties.

Field In-charge have overall operational responsibility of the field. The Operator will be notified
as soon as the emergency reaches Level 2 and will assume overall responsibility and
coordinate closely with the Field In-charge. All personnel, included contractors, must become
familiar with site specific plans and duties. Supervisory personnel shall know and understand
the entire Emergency Response Plan and their responsibilities and duties.

I. Table : Level of Emergencies

EMERGENCIES MAY BE CATEGORIZED INTO THE FOLLOWING THREE LEVELS
Level-1 Emergency is a MINOR EMERGENCY, which can be controlled entirely by
personnel and facilities, located within the immediate vicinity of the
accident/incident site. The types of events that could be described as Level 1
emergencies are those which cause minor property or equipment damage that
are non-disruptive to operations, and do not pose a safety risk to personnel or
property outside of the boundaries of Company property
Level-2 Emergency is a SERIOUS EMERGENCY, which is disruptive but not extensive,
and forces a portion of the Company operation to be temporarily suspended or
shut down. Events or conditions which describe LEVEL 2 Emergencies are
accidents/incidents that endanger the safety of personnel or the public outside of
the boundaries of Company property, or have the potential to endanger the

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 EMERGENCIES MAY BE CATEGORIZED INTO THE FOLLOWING THREE LEVELS
safety of personnel or the public outside of the boundaries of Company property,
and would require the notification of external support services.
Level-3 Emergency is a DISASTER EMERGENCY that forces the indefinite shut down of
Company operations, or a sector of Company operations. Safe operating control
has been lost, causing or having to cause; serious injuries or fatalities among
employees, contractors or the public; extensive damage to Company property or
equipment; or serious harm to the environment.

Field In-charge will assign personnel and duties to the following teams:

 Well Control
 Fire-lighting
 Rescue Pollution
 Control Support.

According to ERP, the Alarms that will have to be activated for emergency are:

 Horn-General rally for fire, gas and pollution &

 Siren - Personnel evacuation of work site.

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