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Environmental Safeguard Monitoring Report
Project No. 45203-006 Semestral Report August 2018
Bangladesh: Natural Gas Infrastructure and
Efficiency Improvement Project (Component 1 –
Installation of Wellhead Gas Compressors at
Location “A” of Titas Gas Field)
Prepared by the Bangladesh Gas Fields Company Limited for the Government of
Bangladesh and the Asian Development Bank.
This environmental safeguard monitoring report is a document of the borrower. The views expressed herein do not necessarily represent those of ADB's Board of Directors, Management, or staff, and may be preliminary in nature. In preparing any country program or strategy, financing any project, or by making any designation of or reference to a particular territory or geographic area in this document, the Asian Development Bank does not intend to make any judgments as to the legal or other status of any territory or area.
Bangladesh Gas Fields Company Limited
Environmental Monitoring Report
(January – June 2018)
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 (BGFCL) for the Asian Development Bank.
August 2018
Environmental Monitoring Report Bangladesh Gas Fields Company Limited (BGFCL)
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TABLE OF CONTENTS
Executive Summary 2
1.0 Introduction 3
1.1 Brief Project Description 3
1.2 Project Progress Status and Implementation Schedule 3
2.0 Compliance to National Regulations 4
3.0 Compliance to Environmental Covenants from ADB’s Loan Agreement 6
4.0 Compliance to Environmental Management Plan 6
5.0 Safeguard Monitoring Results and Unanticipated Impacts 7
6.0 Implementation of Grievance Redress Mechanism and Complaints Received from Stakeholder
11
7.0 Conclusion and Recommendation 11
8.0 Photos 12
Environmental Monitoring Report Bangladesh Gas Fields Company Limited (BGFCL)
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Semi-annual Environmental Monitoring Report
January – June 2018
For Natural Gas Infrastructure and Efficiency Improvement Project (Component 1 – Installation of Wellhead Gas Compressors at Location-A of Titas Gas Field)
Executive Summary
Bangladesh Gas Fields Company Limited (BGFCL) is one of the operating companies of Bangladesh
Oil, Gas & Mineral Corporation (Petrobangla) under the Ministry of Power, Energy and Mineral
Resources of the Government of the Peoples’ Republic of Bangladesh. It is the largest national gas
production company in the country. The company is entrusted with production of natural gas from its
producing fields and processing of gas to the transmission pipeline system. In recent years, wellhead
gas pressure of the producing wells is decreasing due to long time production. In this circumstance,
BGFCL has intended to install wellhead gas compressors at Location-A of Titas Gas. BGFCL is
executing agency (EA) of this project “Natural Gas Infrastructure and Efficiency Improvement Project
(Component 1 – Installation of Wellhead Gas Compressors at Location-A of Titas Field)”. The project
is funded by Asian Development Bank (ADB) with cofinancing from Asian Infrastructure Investment
Bank (AIIB).
BGFCL has carried out Environmental Assessment with environmental management plan (EMP) and
obtained Environmental Clearance Certificate (ECC) from Department of Environment (DoE) for
implement this project. Accordingly, Health, Safety and Environmental (HSE) issues and
implementation of EMP will be included in the tender and subsequently EPC contractor to attract
compliance with these issues. At present no physical works/activities are started at site. So, any
environmental impact has not occurred due this project. During construction and installation stage of
the compressors, BGFCL will regularly monitor the implementation of EMP, HSE issues and provided
with guidelines for safety and Environmental Parameters. As for now, task need to be considered in
priority are to establish an institutional mechanism to manage and monitor the EMP.
The objective of the environmental management and monitoring is to record environmental impacts
resulting from the project activities and to ensure implementation of the “mitigation measures”
identified earlier in order to reduce adverse impacts and enhance positive impacts from specific project
activities. Besides, it would also address any unexpected or unforeseen environmental impacts that
may arise during construction and operation phases of the project.
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1.0 Introduction
1.1 Brief Project Description
Natural gas is the significant source of commercial energy in Bangladesh and it is the prime mover of national economy. Bangladesh Gas Fields Company Ltd. (BGFCL) is one of the largest state-owned natural gas producers of the country. It is a company of Bangladesh Oil, Gas & Mineral Corporation (Petrobangla) under Ministry of Power, Energy and Mineral Resources. BGFCL operates Titas, Habiganj, Narsingdi, Bakhrabad and Meghna Gas Fields. The company is entrusted with production of natural gas from its producing fields and processing of gas to the transmission pipeline system. In recent years, wellhead gas pressure of the producing wells is decreasing due to long time production. In this circumstance, BGFCL has intended to install gas compressors at Location-A of Titas Gas Field under financial assistance from Asian Development Bank (ADB) with cofinancing from Asian Infrastructure Investment Bank (AIIB).
Environmental Clearance for installation of gas compressors are required prior to signing of loan agreement between Government of Bangladesh (GoB) and ADB. The environmental legislation in Bangladesh, particularly, The Bangladesh Environment Conservation Act, 1995 (Amended in 2002), states that any development project shall require environmental clearance from the Department of Environment (DoE), Ministry of Environment and Forest, Government of the People's Republic of Bangladesh. The proposed Project falls under the "Red Category" as per The Environment Conservation Rules, 1997, which requires obtaining clearance from DoE. Preparation of an Environmental Management Plan (EMP) suggesting mitigation measures for minimizing the effects of the negative impacts and enhancement measures for increasing the benefits of the positive impacts.
Due to long time gas production from existing producing fields wellhead pressure of various wells have come gradually down with time. So, installation of compressor is necessary at production field to sustain gas production for maintaining minimum supply pressure in the gas transmission lines. Thus a project has been taken named Natural Gas Infrastructure and Efficiency Improvement Project (Component 1 – Installation of Wellhead Gas Compressors at Location-A of Titas Gas Field) to sustain the current production of natural gas from its existing gas fields. Installation of wellhead compressor is required to sustain gas flow and pressure in the transmission line. BGFCL is the executing agency (EA) of this program.
Objective:
The main objective of the project is to increase wellhead gas pressure in maintaining the gas transmission pipeline pressure.
The objective of the environmental management and monitoring is to mitigate or minimize the possible environmental impacts resulting from the project activities at site and recording the impacts. Besides, it would also address any unexpected or unforeseen environmental impacts that may arise during construction and operation phase of the project.
1.2 Project Progress Status and Implementation Schedule:
Contract has been awarded on 14 January 2018 to Consulting firm under this project. Tender document is being prepared to engage EPC contractor for the installation of Wellhead Compressors with associated facilities. It is noted that no construction has begun at project site. So, no environmental impact has occurred due to this project.
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Project Location:
The proposed compressor site is located within Titas Gas Field premise and operated by BGFCL. Titas Gas Field is in Ghatura mauza in Sadar upazila under Brahmanbaria district and is about 100 km northeast of Dhaka City and approximately 40 km northwest from the border of India. About 6,000 square meters or 0.6 hectare (ha) will be required for installation of compressors and ancillary facilities but no land acquisition will be needed as this site is located in Location-A of the Titas Gas Field. Location-A is a restricted key point installation (KPI) area and public entry is prohibited. Only authorized access is allowed.
Major Components of the Project:
i) Procurement, Installation & Commissioning of 7nos. wellhead compressors each having capacity of 60MMscfd and suction pressure of 600-650 psig & delivery pressure of 1200-1250 psig with associated equipment & facilities at Location-A of Titas Gas Field;
ii) Engagement of Consulting Firm for Consultancy Services; and
iii) Other related works.
Environmental Category:
The ‘‘Natural Gas Infrastructure and Efficiency Improvement Project (Component 1 – Installation of Wellhead Gas Compressors at Location-A of Titas Gas Field)’’ project has been classified by ADB’s Safeguard Policy Statement (2009) as a Category B project. As per the ADB’s “B” categorization, an Initial Environmental Examination (IEE) is sufficient to meet the environmental requirements. An IEE report with Environmental Management Plan (EMP) was prepared and submitted to ADB.
Reporting Period :
This monitoring report is prepared for the period of January to June 2018.
2.0 Compliance to National Regulations
The environmental legislation of GOB emphasizes reducing the negative impacts of
development projects and enhancement of the positive impacts. This conforms to
Bangladesh Environmental Conservation Act (BECA) 1995 and Bangladesh Environmental
Conservation Rules (BECR) 1997. The Bangladesh Environment Conservation Act of 1995
(BECA '95) is currently the main legislation in relation to environment protection in Bangladesh.
This Act is promulgated for environment conservation, environmental standards development
and environment pollution control and abatement. Environmental Conservation Rules (1997)
promulgated under the Environmental Conservation Act of 1995 (so far there have been three
amendments to this set of rules). The Environment Conservation Rules of 1997 has provided
categorization of industries and projects and identified types of environmental assessments
needed against respective categories of industries or projects. The Department of
Environment (DoE) executes the Act under the leadership of the Director General (DG).
Prior permission is required from DoE for extraction and production of mineral resources under
this act. Before any new project can go ahead, as stipulated under the rules, the project
promoter must obtain Environmental Clearance from the Director General. Failure to
comply with any part of this Act may result in punishment.
Environmental Clearance:
The environmental clearance for the project was obtained from Department of Environment (DoE) on 11 August 2016 vide their memo no. DOE/Clearance/5637/2016/34.
Environmental Monitoring Report Bangladesh Gas Fields Company Limited (BGFCL)
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Map 1 Brahmanbaria District Map Showing Project Location
Proposed location for installation of compressors atTitas-A
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3.0 Compliance to Environmental Covenants from ADB Loan Agreement
BGFCL will ensure that the preparation, design, construction, implementation, operation and
decommissioning of the project and all project facilities comply with (a) all applicable laws and
regulations relating to environment, health and safety; (b) the environmental safeguards; and
(c) all measures and requirements set forth in the IEE, the EMP and any corrective or preventive
actions set forth in a Safeguards Monitoring Report. The contractors will submit report on the
implementation of safety issues on regular basis with information that they were conducting
awareness program and meeting up the gaps.
4.0 Compliance to Environmental Management Plan
BGFCL will maintain standard quality of implementation of the program with due consideration
to standing rules and regulations. Compressor installation and operation usually have a minor
environmental impact compared to that of the other industrial projects. The use of best
engineering and management practices, mitigation procedures and control will contribute
positive impact on environment. Project construction and operational activity have minimum
adverse impacts on the environment. The most important measure to achieve a good level of
environmental acceptability of the project is adoption of best practices in design and
construction. Avoiding environmentally sensitive location should be an integral part of the
process.
The potential environmental impacts of the projects components covered by the IEE are
insignificant, and temporary, which will mostly occur only during the operational stage. All the
potential environmental impacts can be mitigated to an acceptable level by adequate
implementation of the measures.
The Initial Environmental Examination (IEE) contained an Environmental Management
Plan(EMP) for mitigation measures in view of the possible impacts due to project activities. The
EMP also includes a monitoring plan for taking corrective measures. Implementation of EMP
would minimize the effect of negative impact and increase the benefits of the positive impacts.
EMP mitigation measures are defined in the institutional responsibility table. The erection and
procurement contractor (EPC) will submit a construction management plan describing the
procedure and measures to mitigate the environmental negative impacts. Necessary clauses
will be incorporated in the tender document as well as in the EPC. The contractor will submit
site activities, implementation of EMP on regular basis. The Environmental Management Plan
contains associated monitoring programs during project implementation period.
Compliance with EMP
Project Activities
Parameter / Indicator
Location Frequency Compliance Status / Remarks
Pre-construction phase
Surface water, ground water, air, noise and soil sampling
Proposed compressor area
Once before construction
Will be complied before construction
Construction phase
Surface water, ground water, air, noise and soil sampling
Proposed compressor area
2 (during dry and monsoon)
Will be complied during construction
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5.0 Safeguard Monitoring Results and Unanticipated Impacts
Environmental Measures:
Environmental monitoring requires a set of indicators that could be conveniently measured, assessed and evaluated periodically to establish trends of impacts. All development project must co-exist satisfactorily with its surrounding environment so as to reduce the environmental impacts caused due to this activity. To control the adverse impact on ambient air, water, noise and safe environmental management plan has to be implemented by the proponents. In view of the possible impacts as assessed in IEE, the following monitoring program are considered for the impact assessment:
- Air quality monitoring
- Noise monitoring
- Occupational health and safety monitoring
- Water quality monitoring
- Monitoring for disaster management and emergency response preparedness
Monitoring:
Construction phase of project has not started. During project execution / implementation stage following parameters will be measured:
- underground water: pH, chloride, calcium, magnesium, iron and arsenic.
- drinking water: pH, chloride, calcium, magnesium, iron and arsenic.
- ambient noise level
- soil quality: Heavy Metal (Pb and Cr), oil and grease
Enhancement Measures
Following measures will be taken during project execution / implementation stage:
- Construction of sanitary latrine and septic tank system (one latrine for 20 persons)
- Waste minimization, recycle and reuse
- Proper disposal of solid waste (in designated waste bins)
- Clean bill of health a condition for employment
- Regular medical monitoring of workers
- Speed reduction to 10 km per hour within the Project area
- Keeping vehicles under good condition, with regular checking of vehicle condition to ensure compliance with national standards
- Watering unpaved/dusty roads (at least twice a day)
- Covering top of trucks carrying materials to the site and carrying construction debris away from the site.
- Use of noise suppressors and mufflers in heavy equipment
- Avoiding, as much as possible, construction equipment producing excessive noise at night.
- Avoiding prolonged exposure to noise (produced by equipment) by workers
- Not using equipment such as stone crushers at site, which produce significant amount of particulate matter.
- Keeping construction equipment and generators in good operating condition
- Using equipment, especially generators with high levels of emission control
- Immediate use of construction spoils as filling materials.
- Immediate disposal of excavated materials.
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- Continuous watering of bare areas
- Good house keeping
- Proper handling of lubricating oil and fuel
- Collection, proper treatment, and disposal of spills
- Local people employed in the project activities
- Using low nitrogen oxide burners
- Provision of silencers for engines
- Regular maintenance of equipment
- Use of ear-muffs and ear-plugs by plant personnel working in the generator and plant.
Mitigation Measure:
Air Quality
Construction materials at the site will be properly covered while hauled and stored, roads properly cleaned and water sprayed in order to minimize concentration of dust in air when dust increases. Vehicle movement to and from the site are properly managed to ensure that is does not significantly aggravate the traffic problem and air pollution. Stone (aggregate) crushing activities are properly done in fine tune batching plant which is far away from the construction site and not allowed within the project premises. Health status of all workers is monitored regularly at the Health Center established at the project site.
Water Quality
The human wastes from the labour camp will be appropriately disposed through construction of sanitary latrines connected to appropriately designed septic tank system (consisting of septic tank and soakage pit). Wastewater generated from different construction activities is not likely to be significant in volume (Max. 1000 litre/day). Disposal of such wastewater will be carried out by draining them in shallow pits (1 to 1.5 m deep) dug in the ground at appropriate locations, and filling them up with sand at the end of the construction phase. In all cases, the wastewater (generated from construction activities) streams will be separated from the storm water stream, which will be disposed separately utilizing the storm water disposal system at the project site.
Noise Level
- Used “quiet” equipment (i.e., equipment designed with noise-control elements);
- Routed truck traffic away from noise-sensitive areas, where feasible;
- Installed sound barriers for pile driving activity, where practicable (e.g., use an acoustic curtain or blanket around the point of impact);
- Unnecessary vehicle movement are avoided
- Switch off the engines while unused.
- Restriction of working hour (allowable working hours 8:00 AM to 6:00 PM).
Solid Waste
The solid wastes of domestic nature generated mainly in the labor sheds will be collected and stored separately (i.e., without mixing it with construction wastes/debris) in appropriate containers within the construction site. The solid wastes generated during project operation period will be collected properly and deposited to designated place and disposed by landfill within the company’s own premises.
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Major Environmental Activities of the Project :
Major Environmental Activities of the project during construction period are given below:
- Influx of workers
- Operation of excavating equipment, generators and compressors
- Transportation of equipment, materials and personnel
- Storage of materials
- Construction activities, including operation of construction equipment
Impact on Water Quality:
The water samples were collected from site of Titas Gas field. The tested results are presented in Tables
Table: 5.1 Underground Water Quality
Monitoring Parameter
Method of Monitoring
Location Baseline Results
Monitoring Results
National Standard
Remarks
- Chloride Titrimetric Titas Location - A
7.2 -- 150- 600 ppm
Parameter measured during IEE
report preparation
on dated 20.12.15
- Manganese AAS ''
ND -- 0.1 mg/l
- Iron AAS '' 1.1 -- 0.3 -1.0 ppm
- Arsenic AAS ''
ND -- 0.05 mg/l
ND : Not Detectable
Table: 5.2
Surface Water Quality
Monitoring Parameter
Method of Monitoring
Location Baseline Results
Monitoring Results
National Standard
Remarks
- DO Multimeter Titas
Location - A 5.8 mg/l -- 5 mg/l or
above Parameter measured during IEE
report preparation
on dated 20.12.15
- pH pH meter '' 7.35 -- 6.5 - 8.5
- BOD5 5 days incubation '' 6.8 mg/l -- 50 mg/l
- COD CRM '' 8.0 mg/l -- 200 mg/l
- Arsenic AAS '' ND -- .2 mg/l
- Iron AAS '' 0.01 mg/l -- 2.0 mg/l
- Salinity Titrimetric '' 88.0 mg/l -- --
- Manganese AAS '' ND -- 5.0 mg/l
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Table: 5.3
Ambient Air Pollution
Monitoring Parameter
Method of Monitoring
Location Baseline Results
Monitoring Results
National Standard
Remarks
Suspended Dust Particle
Gent Sampler Titas Location - A
40µg/m3 - 500 µg/m3 Parameter measured during IEE
report preparation
on dated 20.12.15
SOx '' '' ND - 120µg/m3
NOX '' '' 60 µg/m3 - 100 µg/m3
CO Eagle Sampler
'' 40 µg/m3 - 5000 µg/m3
Lead GTA '' ND - 50 µg/Nm3
Impact on Noise
During construction stage major source of noise is from equipment and transport vehicles. Also noise is produced from generators.
Table: 5.4
Noise level
Monitoring Parameter
Method of Monitoring
Location Baseline Results
Monitoring Results(dB)
National Standard(dB)
Remarks
Shrillness of Sound
Sound Level Meter
Titas Location – A
main gate area
51.5 db - 75 Parameter measured during IEE
report preparation on dated 20.12.15
Table: 5.5
Fertility of soil
Monitoring Parameter
Method of Monitoring
Location Baseline Results
Monitoring Results
National Standard
Remarks
Soil pH HLS Tandon
Titas Location - A
5.6 - National Standard of fertility of soil is not fixed by DoE
yet.
Parameter measured during IEE
report preparation on dated 20.12.15
Total - N '' '' 0.61 %(w/w)
Organic Matter '' '' 1.2 % (w/w)
Potassium (K) '' '' 0.12 meq/100g
Phosphorus (P) '' '' 9.21 ppm
Manganese (Mn) '' '' 3.0 ppm
Sulfur (S) '' '' 1.12 ppm
Magnesium (Mg) '' '' 2.0 meq/100g
Calcium(Ca) '' '' 5.5 meq/100g
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Safety Assurance of the Project Site:
Personnel Safety Equipment (PPE): Use of proper safety materials are mandatory for all at project site. Workers use appropriate personal protective equipment, such as safety boots, helmet, safety belt, safety harness, gloves, protective clothing, goggles and ear protection etc.
Compliance Measures:
Environmental Management Plan (EMP) will be the integral part of contract document. Contactors will take necessary environmental and safety measures at worksite and plant area. This includes reuse/recycle of water, safe disposal of water and other solid waste, prevention of spillage and leakage of polluting materials, periodic checks of personnel health and safety, availability of first aid and medical service, use of personnel protective equipment (PPE) etc.
6.0 Implementation of Grievance Redress Mechanism and Complaints Received from Stakeholder
Grievance Redress Mechanism will be applied to ensure stakeholders participation in the implementation process. Through public consultations, the Affected Persons (AP’s) will be informed that they have a right to grievance redress from the BGFCL. The AP’s can also call upon the support of the BGFCL to assist them in presenting their grievances or queries to the Grievance Redress Committee (GRC). BGFCL has established a GRC comprising PIU & representatives of BGFCL and Local Government Unit on 31 July 2018. Upon engagement of EPC Contractor, 1 (one) representative from the Contractor and 1 (one) representative among the affected people will be included into the GRC. The EA will provide one grievance receiving box at the main gate of the project location (Location-A, Titas Gas Field) at the period of project implementation. Grievances will be redressed within a month from the date of lodging the complaints. In effect, the GRC will work closely with the AP’s to identify the grievances and redress the same in consultation with other members of the committee as well as the AP’s. 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. The activities of grievance redress will be monitored by the organization monthly. It is noted that no complaints were received yet from stakeholders of this project.
7.0 Conclusion and Recommendations
The environmental monitoring report consists of environmental monitoring reporting based on measured ambient air, noise, underground and surface water quality parameters. The work has been done in laboratory. Noise quality was done by noise level meter. House-keeping is also in good condition at the project site. All solid, liquid and hazardous waste will be disposed into the designated container at the plant site. The useable solid wastes will be handed over to proper party for recycling. Liquid hazardous waste will be conserved and will properly clean the storage area. Hazardous waste will be kept at designated places by labeling.
Finally it can be concluded that at present no physical works started at project site. So, no environmental impact occurred in the period of January to June 2018. During the construction period proper mitigation measures will be taken as per EMP.
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Present Condition of Project Site