EIA - SEWAGE WATER TREATMENT PLANT FFC MIRPUR MATHELO

SEWAGE WATER TREATMENT PLANT WITHIN BOUNDARY WALL OF FFC MIRPUR MATHELO

ENVIRONMENTAL IMPACT ASSESSMENT (EIA)

Prepared by:

Suite 4, 2nd Floor, Link Arcade, Model Town Link Road, Lahore Phone: 042-35887517, 35925693; Fax: 042-35855508

Email: [email protected] October-2012

SEWAGE WATER TREATMENT PLANT WITHIN BOUNDARY WALL OF FFC MIRPUR MATHELO

ENVIRONMENTAL IMPACT ASSESSMENT (EIA)

Prepared by:

Suite 4, 2nd Floor, Link Arcade, Model Town Link Road, Lahore Phone: 042-35887517, 35925693; Fax: 042-35855508

Email: [email protected] October-2012

Sewage Water Treatment Plant, FFCL

C O N T E N T S

EXECUTIVE SUMMARY i-vii

1.0 DESCRIPTION OF THE OBJECTIVES OF PROPOSAL 1

2.0 DESCRIPTION OF THE REPORT AND ITS ALTERNATIVES 5

2.1 The status of the report in the project cycle 5 (pre-feasibility, feasibility or detailed design)

2.2 Description of the planning, design and implementation stages 5 2.2.1 Planning 5 2.2.2 Design 5 2.2.3 Implementation 5

2.3 The requirements for raw materials, water, energy and 6 equipment2.3.1 Raw materials 6 2.3.2 Water 6 2.3.3 Equipment 6

2.4 The planed operational characteristics-hours of operation, 6 processes , products

2.4.1 Hours of operation 6 2.4.2 Process 7

2.5 Visual aids (maps of the area, site and plant layout, 8flow charts of production, and photographs of the site and similar projects)

2.5.1 Location map 8 2.5.2 Plant layout 8

2.6 Comparison of report options ( size, siting, technology, 8 layout, energy, sources, sources of raw material)

2.6.1 Size (Capacity of the Plant): 8 2.6.2 Siting (discussion of the project siting alternatives) 8 2.6.3 Technology 9 2.6.4 Layout 9 2.6.5 Energy sources 9

2.7 Summary of the technical, economic and environmental 10features of the report 2.7.1 Technical 10 2.7.2 Economic 10 2.7.3 Environmental 10


3.0 DISCUSSION OF REPORT AND CURRENT LAND USE 12POLICIES

3.1 Land use 12

3.2 Regulatory framework 12 3.2.1 Deregulation of the economy 12 3.2.2 Import policy 12

3.2.3 Infrastructure facilities 123.2.4 Incentives 13

3.3 Legal Framework 133.3.1 National Conservation Strategy (NCS)-Pakistan 14 3.3.2 Pakistan Environmental Protection Act (PEPA), 1997 15 3.3.3 National Environmental Quality Standards (NEQS) 16 3.3.4 Regulations for Environmental Assessment 16 3.3.5 Guidelines for Environmental Assessment 17 3.3.6 Guidelines for the Preparation and Review of 17

Environmental Reports: 3.3.7 Guidelines for Public Consultation: 18 3.3.8 National Resettlement Policy and Ordinance 18

3.4 Institutional Framework 193.4.1 National Environmental Regulatory/Legal Requirements: 19 3.4.2 National Conservation Strategy (NCS) – Pakistan 20 3.4.3 Pakistan Penal Code (1860) 21 3.4.4 Pakistan Environmental Protection Act, 1997 22 3.4.5 Policy and Procedures for the Filing, Review and 23

Approval of Environmental Assessments 3.4.6 Guidelines for the preparation and review of 23

Environmental Reports (NOVEMBER 1997/2000) 3.4.7 Guidelines for Public Consultations 24 3.4.8 National Environmental Quality Standards 24

(NEQS)-1993, Amended August 2000 3.4.9 Guidelines for Sensitive and Critical Areas 25 3.4.10 National Resettlement Policy and Ordinance 25 3.4.11 Forest Act, 1927 26 3.4.12 Industrial Relation Ordinance, 2002 27 3.4.13 Industrial Relations Ordinance 2011 Promulgation 3.4.14 Other Relevant Laws 3.4.15 National Electric Power Regulatory Authority (NEPRA)

Act 1997 3.4.16 Power Policy 1998 3.4.17 Factories Act, 1934

3.5 Environment Related Relevant International Agreements in Pakistan’s context:


4.0 DESCRIPTION OF EXSITING AND EXPECTED CONDITIONS 28

4.1 Spatial and temporal boundaries adopted for the 28various aspects of the study

4.2 Existing (baseline) conditions of the biophysical 28and socio-economic environment, trends and anticipated future environmental conditions should the project not go ahead

4.3 Environmentally sensitive areas of special or unique 28value Physical resources of the project area:4.3.1 Physical resources of the project area 28

4.3.1.1 Topography and geology 29 4.3.1.2 Land 30 4.3.1.3 People 30 4.3.1.4 Languages 32 4.3.1.5 Sports and Entertainment 32 4.3.1.6 Wildlife – Plant 32 4.3.1.7 Industries 38 4.3.1.8 Infrastructure 38 4.3.1.9 Transportation: roads, rail, airports, 39

navigable rivers: 4.3.1.10 Land use planning: 39

4.3.1.11 Power sources and transmission: 39 4.3.1.12 Agricultural and mineral development: 39 4.3.1.13 Quality of life: 40

5.0 EVALUATION OF IMPACTS AND MITIGATION MEASURES 43

5.1 Assessment of any environmental impact on local population 43and the environment during construction and operational phase 5.1.1 Likely adverse impacts from plant during construction 43

5.1.1.1 Environmental Adverse Impacts 43 During Construction

5.1.1.2 Pollution impacts and remedies 44 5.1.2 Environmental Adverse Impacts During Operation stage 45

5.2 The relevant environmental data and predictive methods used 46and any underlying assumptions made

5.2.1 Base line environmental data 46 5.2.1.1 Ambient Air Quality-Ambient 46 5.2.1.1.1 Gaseous 47

5.2.1.1.2 Particulates 47 5.2.1.1.3 Noise Levels 47 5.2.1.1.4 Water Quality 47


5.3 Gaps in knowledge and uncertainties encountered 48

5.4 Compliance with relevant environmental standards 48 5.4.1 Effluents-discharges and environmental controls: 48

5.4.2 Noise Levels 48 5.4.3 Solid wastes: 48

5.5 Assessed significance of the impact stating the standards or 49criteria used as a basis for judgment

5.6 Possible measures for avoiding or mitigating the impact 49

6.0 COMPARATIVE EVALUATION OF ALTERNATIVES AND 51 IDENTIFICATION OF THE PREFFERED OPTION

6.1 Labour 51

6.2 Basic infrastructure 51

6.3 Site availability for the plant 52

6.4 Environment 52

6.5 Energy availability 52

7.0 ENVIRONMENTAL MANAGEMENT PLAN, MONITORING 53PLAN AND PROPOSED TRAINING

7.1 Environmental Management Plan 53 7.1.1 Mitigation/Compensation Measures during 53

Construction Phase 7.1.2 Mitigation/Compensation Measures during Operation Phase 53

7.2 Assigning responsibility for implementation (by name or position) 60

7.3 Reporting and reviewing procedures 62

7.4 Training needs 63

7.5 Third party monitoring 63

7.6 Environment quality control laboratory 64


8.0 REFERENCES 65

9.0 SOURCES OF DATA AND INFORMATION AND LIST 67 OF REFERENCE MATERIAL USED

10.0 TEAM MEMBERS WHO CARRIED OUT THE STUDY AND 68PREPARED THE EIA

11.0 TERMS OF REFERNCES FOR THE ENVIRONMENT REPORT 72

12.0 PUBLIC CONSULTATIONS: 73

ANNEXURES

ANNEXURE-I 77Pakistan Environmental Protection Act, 1997

ANNEXURE-II 102National Environmental Quality Standards (NEQS)-2000 Pakistan

ANNEXURE-III 108National Environmental Quality Standards for Ambient Air (NEQSAA)-2010 Pakistan

ANNEXURE-IV 114Letter from Sindh Irrigation & Drainage Authorty

ANNEXURE-V 115Guidelines for the preparation and review of Environmental Reports, October 1997/2000

ANNEXURE-VI 162The Plant Location Map

ANNEXURE-VII 163The Plant Layout Map

ANNEXURE-VIII 164Guidelines for Self – Monitoring and Reporting by Industry (SMART) Final Report March 1998

ANNEXURE-IX 174Ambient Air Gaseous Monitored Data


ANNEXURE-X 175 Ambient Air Particulate Matter Monitored Data

ANNEXURE-XI 176Noise Levels Monitored Data

ANNEXURE-XII 177Laboratory Analysis Report of Water Samples

ANNEXURE-XIII 182Public Consultations (PC)

PHOTOLOGS


EXECUTIVE SUMMARY


i

EXECUTIVE SUMMARY

Fauji Fertilizer Company Limited (FFCL); at its Plant-III located at Mirpur Mathelo,

Ghotki-Sindh; are in the process of installing a sewage treatment plant for the treatment

of sewage from the FFC Staff Colony. The treatment plant is in its final stage of

completion.

FFCL intend to dispose the treated sewage into nearby Massu Wah canal. The authority

Incharge of the canal asked the company to fist get Environmental Approval (EA)/ No

Objection Certificate (NOC) from the Environmental Projection Agency (EPA),

Government of Sindh as precondition to allow to discharge the treated sewage into the

Massu Wah Canal.

The sewage treatment plant has the capacity to treat 100 m3/hr of sewage being generated

from the Fauji Fertilizer staff colony. According to its capacity, the project falls under

category “A” of the projects requiring EIA report to obtain EA/NOC from the EPA,

Government of Sindh. Therefore, this EIA report is being submitted to the EPA, for

issuance of EA/NOC under the Pakistan Environmental Protection Act 1997, Section 12.

The EIA report has been prepared in accordance with the Government of Pakistan’s

officially approved “Guidelines for the preparation and review of Environmental Reports,

October 1997/revised 2000”.

Ground water is used for all domestic purposes including washing, bathing, cleaning etc.

After use, the waste water will be sent to the sewage treatment plant under reference of

this EIA report. The treatment plant is being installed within the four walls of the staff

colony of FFCL. The electricity requirement of the plant will be fulfilled from the mother

Fauji Fertilizer Company Limited situated adjacent to plant site.

Title and location of the project:

Township Sewage Water Treatment Plant,

FFCL Employees Colony,

Fauji Fertilizer Company Limited,

Mirpur Mathelo, Ghotki, Sindh.


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Head Office:


93-Harley Street, Rawalpindi.

Phone 051-8450001, 051-111 332 111

Name of the proponent:

M/S Fauji Fertilizer Company Limited,

Address as above.

Contact person:

Mr. Sardar Ali,

Manager Production,


Mirpur Mathelo.

Phone: 0723- 652301 EXT 3202 Fax: 0723-661462-63

Email: [email protected]

Environment Consultants:

ECTECH–Environment Consultants;

Suite No. 4, 2nd Floor, Link Arcade,

Model Town Link Road, Lahore

Phone: 042-35887517, 35925693

Fax: 042-35855508

E-mail: [email protected].


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Contribution to economic uplift of the people/ job opportunities

As a result of the project installation, people of the project area will be benefited in a

number of ways.

i) During construction phase local people will get jobs. Maximum unskilled jobs

will be provided to the people of the area; even other jobs wherever suitable

people are available from within the area will also go to them.

ii) During regular operations of the plant if some new persons are to be recruited, the

people of the area will be preferred subject to their suitability for the job.

iii) Employment opportunities will improve overall economic status of the people.

This will bring all out positive, qualitative and quantitative change in the entire

walk of life of these people.

iv) They will be tempted to send their children to schools.

v) The project proponent, like in the past, will try to contribute to the economic

development of the people of the area wherever possible.

vi) Wherever and whenever required, basic infrastructure like roads and other means

of communication will be improved through the project activity. This will bring

an over all socio economic change in all walks of life of the people.

Salient features of the project proposal

This project proposal provides project background including like details of investments,

employment opportunities and type of activities within the mandate of the project.

The proposal highlights the socio economic status of the people of the area and

biophysical conditions. Environmental settings including climate, vegetation, crops,

water, soil, forestry, wildlife, air, heritage, environmental status, and biodiversity,

scientific and historical buildings are also highlighted in this project proposal.


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This proposal provides details of the stages of the project completion from planning to

design and implementation. It also gives rational for site selection while taking into

considerations availability of raw materials, energy, water, environment, space

availability for plant etc. as basic essentials to run the project.

The proposal describes likely adverse impacts that could occur due to the wastes from the

project activity, both during construction and regular operations of the project are also

highlighted. The proposal also provides details of the remedial measures to be adopted to

address the problems of wastes for protection of environment. This EIA Report

recommends Environmental Management Plan (EMP) and Environmental Monitoring

Plan (EMtP).

The pollution controls are to follow compliance with the National Environmental Quality

Standards (NEQS) and Pakistan Environmental Protection Act—1997 (PEPA-1997).

The proposal provides description of the prevailing and future expected conditions

including biophysical and socio-economic conditions, environmentally sensitive areas of

unique or special value especially soils, vegetation, water bodies, fishery, biodiversity,

forestry, wildlife, cultural heritage, scientific institutions, socio-economic scenarios

among many other factors.

Environmental monitoring, to generate baseline data, has been carried out and the

monitored environmental data are provided in this report.

Composition of the team participating in the preparation of this proposal has been given.

The documents consulted during the course of preparation of the proposal are also listed

in this EIA report.


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The major impacts

Plant operations will be under strict environmental controls. Wastes of all sorts i.e.

effluent, gaseous emissions (from vehicular emissions and construction machinery during

construction phase), particulate matter, solid wastes and noise levels will be managed in

environmentally sustainable fashion and in accordance with the NEQS limiting values.

Protection of all segments of environment i.e. forests, biodiversity, buildings, structures,

fishery, aquatic biology, wildlife, cultural or other heritage, vegetation, climate etc. will

be safeguarded as mandatory legal compliance.

Environmental impacts and remedies:

Environmental impacts:

The pollutants to be generated from the project operations and their likely impacts on

people and environment, in case no environmental management is carried out (both

during construction and operation phases) and mitigation measures are briefly

discussed here. However, it must be borne in mind that since the project is to operate

under recommended Environmental Management Plan and in compliance with the

legal requirements of the PEPA-1997 ANNEXURE-I and the NEQS, ANNEXURE-II

obviously adverse impacts are not to occur from the project activity.

a)- Effluents:

In case untreated effluent is discharged into any water body it can deteriorate the

quality of water and may render it unfit for its end use. The treated effluents of plant

will be discharged to main Massu Wah canal which has sufficient capacity to

accommodate the effluent. In this way it will further reduce concentration of the

pollutants and keep canal water safe for its use in irrigation.


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b) - Stack Gaseous Emissions:

Since plant operation does not involve any fuel burning activity, therefore, there are

no gaseous or particulate matter emissions from the plant operation.

c) - Solid wastes:

The solid waste to be generated from the project activity, during construction and

regular operation, mostly include sludge, waste packing, redundant cartons, wood

pieces, metallic pieces, plastic from packing, metallic shavings, plastic and metallic

drums.

With the exception of plastic drums containing chemicals, none of the other solid

wastes will pose any harm either to environment or human beings. The drums will be

returned to their suppliers for recycling. The redundant packing and cartons and other

solid wastes will be sold in the market for reuse.

d)- Noise:

The plant machinery does not contain any machinery which may rub against each

other to produce high noise levels. As such the plant is not going to yield noise levels

beyond the prescribed limits of the National Environmental Quality Standards for

Noise (NEQSN) November 26, 2010- ANNEXURE-III.

Recommendations for mitigation and compensation:

Briefly, the following recommendations for mitigating environmental adverse

impacts are made. For more detailed account refer to Section 5.0.

Implement EMP and EMtP in letter and spirit.

Environmental management staff should be trained adequately.

On site environmental laboratory should be adequately equipped.


vii

Regular monitoring of the desired parameters, as recommended in the EMP

and EMtP, should be adhered to and results be communicated to the EPA

Sindh.

Dusty areas within the plant boundary lines should be kept wet as far as

possible to minimize dust.

Environmental monitoring on monthly basis should be carried out even during

construction to ensure that environmental order is maintained.

Proposed monitoring:

Environmental Management Plan and Environmental Monitoring Plan have been

recommended to further provide safeguards against any possible environmental

damages. For its details reference is made to Serial No: 7.0.

Public Consultations (PCs):

Public Consultations play positive role in managing a project in environmentally

sustainable order. PCs were held with the public of the area of project influence.

Their written comments are appended in this report.

All those participated in the PCs; hope to have job opportunities besides industrial

development of the area as positive step.


1.0 DESCRIPTION OF THE OBJECTIVES OF PROPOSAL


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1.0 DESCRIPTION OF THE OBJECTIVES OF PROPOSAL

Fauji Fertilizer Company Limited (FFCL), at its Plant-III located at Mirpur

Mathelo, Ghotki-Sindh is in the final stage of installing a sewage water treatment

plant model ST 635 CT for the treatment of sewage from its staff Colony.

The project estimated cost is Rs. 12.0 million. The project will spread over an

area of about 625 square feet. The plant has been designed by National Water

Engineering (Pvt) Ltd. Karachi.

The plant has the capacity to treat 100 m3/hr of sewage being generated from the

Staff Colony of Fauji Fertilizer. The design of the plant has been engineered on

simple straight-line logic. All components are independently installed, connected

through pipes and flanges only. The plant is of robust construction and with a

very little care; it can safely be expected to last for more than 25 years.

Ground water is used for all domestic purposes including washing, bathing,

cleaning etc. After use this water will be sent to sewage water treatment plant

which has been installed within the four boundary walls of FFCL.

The treatment plant, with the latest state of the art technology, will be highly

efficient and respond to meet the requirements of the National Environment

Quality Standards (NEQs) Pakistan. As stated, after treatment all the parameters

of treated sewage water are to comply with the prescribed limits of NEQs-

Pakistan ANNEXURE-II.

The treated sewage will be used for irrigation of vegetation, plants and trees

within the boundary walls. However, the left over sewage, if any, will be

discharged into the Masu Wah Canal which is passing between the FFC Township

and FFC plant.


2

According to Pakistan Environmental Protection Agency (PEPA), 1997, Section

12 ANNEXURE-I No Objection Certificate (NOC)/Environmental Approval

(EA) from Environmental Protection Agency (EPA), Government of Sindh is

legal requirement, to start construction and then to discharge the treated sewage

out of the boundary walls of the colony of FFCL. Since it was previously planed

not to discharge any quantity of the treated sewage out the boundary of the FFCL,

therefore, the required EIA report for getting NOC from the EPA was not filed.

It is now planned to discharge the treated sewage in to the Massu Wah canal. The

Authority Incharge of the canal has asked vide his office letter

No.MD/SIDA/6529 dated November 4, 2010 ANNEXURE-IV to get

Environmental Approval from the EPA, Government of Sindh. The Masu Wah

Canal passes between the FFC Staff Residential Colony and FFCL plant.

Thereafter, permission to discharge the treated sewage will be allowed. Therefore,

this EIA report is being submitted to the EPA Sindh for issuance of the EA/NOC

to get EA from the EPA.

Environmental management Plan (EMP) and (EMtP) are operational to further

ensure legal environmental compliance. Biannual overall environmental

monitoring by a third party will further ensure environmentally sound operation

of the plant.

The EIA report deal with the environmental adverse impacts of the project that

could occur during regular operations and the mitigation measures to be adopted

to counter them so as to protect human health and air, soil, water bodies, natural

heritage, wildlife, fishery, vegetation, forestry, biodiversity, historical buildings,

structures, climate, land use, socio economic set up etc. The entire environmental

and social set up of the project area of influence is described.


3

Relevant documents, as required under the project write up, are annexed. Public

Consultation (PCs) was held with the people in the project area. Their recorded

statements are appended at the end of this report. People have no issue for the

project installation and its operation in their area.

The proposal describes Government policies about the need of industrialization of

the country, taking into account the incentives being provided for promoting

industrialization.

Environmental Management Plan (EMP) and Environmental Monitoring Plan

(EMtP) given in this report when practiced, will ensure environmental protection and

safeguards against any possible adverse environmental aspects of the project

activity during operation phases.

The major elements of the EIA report according to the “Guidelines for the

preparation and review of Environmental Reports, October

1997/2000”ANNEXURE-V included:

i- Executive summary.

ii- Description of the objectives of the proposal.

iii- Description of the proposal and its alternatives (status of the proposal in the

project cycle, description of planning, design and implementation stages,

requirements for raw materials, energy and equipment),

iv- Discussion of the proposal and current land use and policies (current land use

controls in the context of the Government policies),

v- Description of existing and expected conditions (boundaries adopted to study

various aspects of the study),


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vi- Evaluation of the impacts and their mitigation (assessment of any impact on

the local population, relevant environmental data, gaps in knowledge,

compliance with relevant environmental standards, assessed significance of

the impacts, possible measures for avoiding or mitigation of the impacts)

vii-Environmental management plan monitoring plan and proposed training

(description of the actions, schedule for operation, assigning responsibility for

operation, monitoring program to assess performance, reporting and reviewing

procedures and outline of training needs).

This Environment Impact Assessment (EIA) report has been prepared according

to the format for preparation of Environmental Impact Assessment Reports (EIA)

ANNEXURE-V, as approved by the Government of Pakistan. This report is to be

submitted to the Sindh Environmental Protection Agency (SEPA), Government of

the Sindh, Karachi for issuance of Environmental Approval (EA) in accordance

with requirements of Section 12 of Pakistan Environmental Protection Act 1997

(PEPA 1997)- ANNEXURE-I.

For further details reference be made to the respective sections of this report


2.0 DESCRIPTION OF THE PROPOSAL AND ITS ALTERNATIVES


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2.0 DESCRIPTION OF THE PROPOSAL AND ITS ALTERNATIVES

2.1 The status of the proposal in the project cycle

(Pre-feasibility, feasibility or detailed design)

The proposal is an integral part of project report in the entire project cycle.

2.2 Description of the planning, design and implementation stages:

It was in the above back ground that the IEE/EIA report has been prepared and

submitted to the SEPA Sindh Environmental Protection Agency for its

consideration to issue NOC. As already mentioned, the project is in its final stage

of construction.

2.2.1 Planning

All planning work relating to the project aspects has been completed.

2.2.2 Design

The project has been designed by highly experienced professionals,

National Water Engineering (Pvt) Ltd. Karachi.

2.2.3 Implementation

The plant is in the final stages of completion


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2.3 The requirements for raw materials, water, energy and equipment:

2.3.1 Raw materials

Following chemicals are being used for treating sewage water:

i) Aluminium Sulphate = 100 Kg/day.

ii) Sodium Hypochlorite = 24 Kg/day.

iv) Ammonium Sulphate/Urea = 15-20 kg/day

v) Polymer = 0.5 kg/day

2.3.2 Water

There is no requirement of water at the plant site.

2.3.3 Equipment:

The major plant equipment is listed as under:

i) Oil and grease skimmer

ii) Primary Clarifier

iii) Lamella Clarifier

iv) Static Mixer

v) Multimedia Rapid Filtration Unit

vi) Dosing Pump

2.4 The planned operational characteristics-hours of operation, processes,

Products.

2.4.1 Hours of operation:

The plant will remain operational for 24 hour per day.


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2.4.2 Process:

Process Description:

The sewage treatment plant installed at the FFC-MM is based on chemical

treatment process, using Al2SO4 as coagulant, and employing LAMELLA

CLARIFIER which ensures laminar flow and high degree of separation of

solid from the suspension in a small space. To remove any floating

material, inorganic compounds and to equalize the flow, a primary

clarifier with flocculation zone has been added. At the start of the system

an O&G skimmer, with jet aeration has been employed to remove

oil/grease

Additionally, it has three MMRF (multimedia rapid filters) units for

polishing and removal of any excess chlorine and colloidal matter. To

complete the loop, the facility has sludge drying beds for sludge storage

with supernatant return to the system and the final discharge of the treated

water for disposal or reuse. The treatment process is described below

Equalization Temp. Control Raw sewage collection

pH Adjustment Treatment P.E. Addition SludgeCoagulation

Sludge PrecipitationSludge Separation (via clarifier) &Treatment

Treated effluent ready for end use

Treated sludge ready for disposal as manure/fuel/landfill

Treated effluent (through weirs)


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2.5 Visual aids (maps of the area, site and plant layout, flow charts of

production, and photographs of the site and similar projects)

2.5.1 Location map

The plant location map is exhibited in ANNEXURE-VI.

2.5.2 Plant layout

The plant layout is shown in ANNEXURE-VII.

2.6 Comparison of proposal options (size, siting, technology, Layout,

energy sources):

2.6.1 Size (Capacity of the Plant):

The quantity of sewage to be treated is the main considerations upon

which plant capacity has been determined.

2.6.2 Siting (discussion of the project siting alternatives)

While taking into consideration project siting alternatives, the most

important and the major parameters taken into consideration included

availability of land, availability of dependable source of energy, labor,

basic infrastructures and environment.

However, in the present case it is a typical situation where the plant is to

be installed to the nearest place of the sewage generation. Since the

purpose of the sewage treatment plant is exclusively to treat the sewage

being generated from the Township of FFCL therefore, this was the only

consideration so specifically to be followed for installation of the pant at


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the project site. Obviously, under the specific need the other parameters

like raw materials, availability of water, labour, basic infrastructure, site

availability for the plant and environment were not applicable for

consideration of alternative to select site.

2.6.3 Technology

The technology is acquired from National Water Engineers (PVT) Limited

Karachi with its most modern features.

2.6.4 Layout

Health, Safety and Environment (HSE); operational requirements,

economic factors and last but not the least Hazardousness and Operability

(HAZOP) play important role in plant layout. Accordingly, these major

factors have been considered while deciding plant lay out.

Environmental considerations have also been taken into account with

special reference to treatment and wastes disposal. Plant layout is shown

in the ANNEXURE-VII.

2.6.5 Energy sources

Total energy required for the plant will be provided by Fauji Fertilizer

Company Limited which is situated adjacent to the plant site.


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2.7 Summary of the technical, economic and environmental features of

the proposal

A brief of technical, economic and environmental aspects of the project is

given hereunder.

2.7.1 Technical

The sewage water treatment plant has been designed and installed by

National Water Engineering (PVT) Limited Karachi. They have

guaranteed that the plant will operate to treat the sewage as required by the

applicable limiting values of the NEQS ANNEXURE-II. Since, the

technology is local; therefore, this will reduce capital cost of the plant, low

expenditure for its repair and maintenance, low cost replacement of

various worn out parts and correspondingly decrease in the capital and

recurring cost on account of repair and maintenance of the plant.

The major technical steps involved in treatment include Oil and grease

Skimming, primary clarifier, Lamella Clarifier, Static Mixer, Multiple

rapid filtration unit.

2.7.2 Economic

The estimated project cost is Rs. 12.0 million

2.7.3 Environmental

This EIA report describes duly likely environmental impacts of various

kinds both during construction and operational phases. It further provides


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the measures to be adopted to mitigate these adverse impacts. For detailed

account of the same reference be made to Section 5.0.

The report also describes details of an Environmental Management Plan,

Monitoring Plan and proposed Training Programme at Serial No: # 7. The

operation of these mechanisms will further ensure adequate environmental

management to undo the adverse impacts of the pollutants to accrue from

the project activity.

And last but not the least, Environmentally sensitive areas of special or

unique value including forestry, biodiversity, fishery, soil, water, heritage,

cultural, scientific, historical buildings, etc. have also been discussed

under Serial No: 4.0.

The proposal concludes as to how all aspects of environment as related to

the project activity will be managed in compliance with the Pakistan

Environmental Protection Act 1997 ANNEXURE-I and the National

Environmental Quality Standards Pakistan ANNEXURE-II.


3.0 DISCUSSION OF PROPOSAL AND CURRENT LAND USE AND

POLICIES AND LEGAL FRAMEWORK


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3.0 DISCUSSION OF PROPOSAL AND CURRENT LAND USE AND

POLICIES AND LEGAL FRAMEWORK

3.1 Land use

The land around the project area is under agriculture use. More than 65% of the

land is owned by the framers themselves and around 35% is cultivated by the

tenant framers. Land holding range from as low as 2.5 acres to well over 1000

acres. Farmers in the area keep small cattle herds of poultry, sheep, goats,

buffalos and cows to supplement their income and to obtain milk and other dairy

products.

3.2 Regulatory framework

Of the salient features of Government policies for facilitating investment in

Pakistan some are described as under:

3.2.1 Deregulation of the economy

Deregulation is the policy of the Government of Pakistan. Under this

policy deregulation of the economy and privatization of the state owned

companies is going on.

3.2.2 Import policy

Import policy has been liberalized to a great extent through giving various

incentives. There is an increased reliance on development of the industrial

sector and enhancement of international trade.

3.2.3 Infrastructure facilities

Infrastructure facilities such as road network, water and power supply,

means of transportation and communications etc. are being improved

speedily.


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3.2.4 Incentives

To keep Pakistan competitive in international markets and support the

viability of investments in the country, the following incentives are

available to both foreign and local investors:

a- initial depreciation allowance (IDA),

b- amortization and

c- normal tax rates.

3.3 Legal Framework:

Comprehensive environmental framework is available in the country covering

environmental management to control environmental degradation.

With the approval of the 18th Amendment in the constitution of The Islamic

Republic of Pakistan-1973, the subject of environment has largely been delegated

to the provinces. The federal Ministry of Environment has been abolished and

instead the Ministry of National Disaster Management has been created under

which Pakistan Environmental Protection Council; Pakistan Environmental

Protection Agency; Pakistan Environmental Planning and Architectural

Consultants Limited; Global Environmental Impact Study Centre; Islamabad

policy, legislation, plans, strategies and programme with regard to disaster

management including environmental protection and preservation, coordination,

monitoring and implementation of environmental agreements with other

countries, international agencies and forums have been put. The Pakistan

Environmental Protection Agency (Pak EPA) looks after the environment related

issues for the federally controlled areas and territories. Lacking laws at the

provincial levels; the laws, rules, regulations etc those already available at the

federal level and operational at the provincial levels will continue as such.

Hereunder, the major legal framework is given:


14

3.3.1 National Conservation Strategy (NCS)-Pakistan.

The National Conservation Strategy (NCS) - Pakistan as approved by the Federal

Cabinet in March 1992 is the guiding document on the environmental issues in

the country (Ref. EUAD/IUCN, 1992). The NCS outlines the country’s primary

approach towards encouraging sustainable development, conserving natural

resources, and improving efficiency in the use and management of resources.

The NCS has 68 specific programs in 14 core areas in which policy intervention is

considered crucial for the preservation of Pakistan’s natural and physical

environment. The core areas that are relevant in the context of the envisaged

project are pollution prevention and abatement, restoration of supporting forestry

and plantations, and preservation of cultural heritage. A mid-term review of the

achievements, impacts and prospects of Pakistan’s NCS was undertaken between

1999-2000.

The Pakistan Environmental Protection Act (PEPA), 1997 ANNEXURE-I is the

legal controlling instrument. The Sindh Environmental Protection Council

(SEPC) is responsible for administering the provisions of the Act.

Among the members of the SEPC, major ones include representatives of the

Provincial Government especially the Sindh Provincial Environmental Protection

Agencies (SEPA), industry, non-governmental organizations, academia,

environment experts, The Sindh Chamber of Commerce and Industry and the

private sector, NGOs etc. The SEPA is required to ensure compliance with the

National Environmental Quality Standards (NEQS) and establish monitoring and

evaluation systems. As a primary implementing agency in the hierarchy, it is

responsible for identifying the need for, as well as initiating legislation whenever

necessary. SEPA is also authorized to delegate powers to its lower staff, one of

the functions of the SEPA is the review and approval of Environmental Impact


15

Assessment (EIA) and Initial Environmental Examination (IEE) reports of the

projects undertaken in its jurisdiction.

3.3.2 Pakistan Environmental Protection Act (PEPA) 1997

Among many other salient features of the Pakistan Environmental Protection Act,

1997 ANNEXURE-I it empowers the Sindh EPA to:

delegate powers, including those of environmental assessment, to the its lower

staff;

identify categories of projects to which the Initial Environmental Examination

(IEE) and Environmental Impact Assessment (EIA) provisions will apply;

develop guidelines for conducting IEE and/or EIA and procedures for the

submission, review and approval of the same;

develop environmental emission standards for parameters such as air, water

and noise and

Enforce the provisions of the PEPA -2011 through environmental protection

orders and environmental tribunals headed by magistrates with wide-ranging

powers, including the right to fine violators of the Act.

The PEPA can frame environmental regulations tailored to the requirements of

the province. They are also required to review and approve EIAs/IEEs of all the

development projects undertaken in the Sindh province.


16

3.3.3 National Environmental Quality Standards (NEQS)

The National Environmental Quality Standards (NEQS) ANNEXURE-II were

first promulgated in 1993 and have been amended in 1995 and 2000.

The following standards are specified therein:

Maximum allowable concentrations of pollutants (32 parameters) in municipal

and liquid industrial effluents discharged to inland waters, sewage treatment

facilities, and the sea (three separate sets of numbers).

Maximum allowable concentrations of pollutants (32 parameters) in Drinking

water (including physical, chemical, biological, organic and radioactive

parameters).

Maximum allowable concentrations of pollutants (16 parameters) in gaseous

and particulate matter emissions from industrial sources.

Maximum allowable concentrations of pollutants in gaseous and particulate

matter emissions from ambient air.

Maximum allowable concentrations of noise in ambient air.

The Guidelines for “Self-Monitoring and Reporting” (SMART) ANNEXURE-

VIII for the industry as approved by the Pakistan Environmental Protection

Council (PEPC) adopted by the PEPA.

3.3.4 Regulations for Environmental Assessment

Under Section 12 (and subsequent amendment) of the PEPA-1997 ANNEXURE-

I, a project failing under any category specified in Schedule I (SRO 339 (I)/2000),

requires the proponent to file an EIA with the concerned PEPA. Projects falling

under any category specified in Schedule II require the proponent to file an EIA

with the federal agency. Within ten working days of the IEE or EIA having been

deposited, the federal/provincial agency will confirm that the document submitted


17

is complete for the purpose of review. During this time, should the

federal/provincial agency require the proponent to submit any additional

information, it will return the IEE or EIA to the proponent for revision, clearly

listing those aspects that need further discussion. Subsequently, the federal agency

shall make every effort to complete an IEE review within 45 days and an EIA

review within 90 days of filing.

At the time of application, the project proponent is also required to pay a specified

official fee to the PEPA to process the case.

3.3.5 Guidelines for Environmental Assessment

The Pak-EPA published a set of environmental guidelines for conducting

environmental assessments and the environmental management of different types

of development projects. These guidelines have been adopted by the Sindh EPA

(SEPA). The guidelines that are relevant to the proposed project are listed below:

3.3.6 Guidelines for the Preparation and Review of Environmental

Reports:

The guidelines on the preparation and review of environmental reports target the

project proponents, and specify:

- The nature of the information to be included in environmental reports,

- the minimum qualifications of the EIA conductors appointed,

- the need to incorporate suitable mitigation measures at every stage of project

implementation and

- the need to specify monitoring procedures.

The report must contain baseline data on the project area, detailed assessment

thereof, and mitigation measures.


18

3.3.7 Guidelines for Public Consultation:

These guidelines deal with possible approaches to public consultation and

techniques for designing an effective program of consultation that reaches out to

all major stakeholders and ensures that their concerns are incorporated in any

impact assessment study.

3.3.8 National Resettlement Policy and Ordinance

At this point, the only legislation relating to land acquisition and compensation is

the Land Acquisition Act (LAA) of 1894. Following a national consultative

process, a national resettlement policy and a related ordinance were drafted. The

draft policy and the ordinance are presently being reviewed by the provinces, and

have yet to be approved and notified by the government. The salient applicable

features of the Draft Resettlement Policy are given below:

The Sindh EPA will be responsible for both environment-related as well as

resettlement-related matters, with overall control of the provincial Planning

and Development (P&D) Department.

All categories of ‘loss’ arising from development projects that entail

resettlement, need to be addressed: these include not only loss of land, built-

up property, other infrastructure, and crops and trees, but also loss of income,

job opportunities, and access to natural resources, etc.

Vulnerable groups whose issues need to be addressed in particular include:

women, children, destitute persons, tribal communities, squatters, those with

usurper rights, and landless groups.

There should be a special emphasis on consultation with affected groups when

preparing a Resettlement Action Plan (RAP).


19

3.4 Institutional Framework

The capability of regulatory institutions for environmental management largely,

ensures the success of environmental assessment for ensuring that development

projects are environmentally sound and sustainable. For decision-making and

policy formulation in the environmental and conservation issues, the institutional

framework, as it exists in Pakistan, is described below.

3.4.1 National Environmental Regulatory/Legal Requirements:

After the 18th Amendment to the Constitution of The Islamic Republic of

Pakistan-1973, the regulation & management of environment has largely

been delegated to the Provinces. The Federal Ministry of Environment has

been abolished and instead the Ministry of National Disaster Management

(MoNDM) has been created which shall be controlling: Pakistan

Environmental Protection Council; Pakistan Environmental Protection

Agency; Pakistan Environmental Planning and Architectural Consultants

Limited; Global Environmental Impact Study Centre; and federal policy,

legislation, plans, strategies and programme with regard to disaster

management including environmental protection and preservation,

coordination, monitoring and implementation of environmental

agreements with other countries, international agencies and forums.

Therefore, wherever the name of the previous Ministry of Environment

(MoE) in mentioned it deemed to mean the MoNDM.

The Pakistan Environmental Protection Agency (Pak EPA) looks after the

environment related issues for the federally controlled areas and

territories. Lacking laws at the provincial levels; the laws, rules,

regulations etc., those already available at the federal level and operational

at the provincial levels will continue as such.


20

3.4.2 National Conservation Strategy (NCS) - Pakistan

The National Conservation Strategy (NCS) – Pakistan, as approved by the

Federal Cabinet in March 1992 is the guiding document on the

environmental issues in the country (Ref. EUAD/IUCN, 1992). The NCS

outlines the country’s primary approach towards encouraging sustainable

development, conserving natural resources, and improving efficiency in

the use and management of resources.

The NCS has 68 specific programs in 14 core areas in which policy

intervention is considered crucial for the preservation of Pakistan’s natural

and physical environment. The core areas that are relevant in the context

of the envisaged project are pollution prevention and abatement,

restoration of supporting forestry and plantations, and preservation of

cultural heritage. A mid-term review of the achievements, impacts and

prospects of Pakistan’s NCS was undertaken between years 1999 - 2000.

The Government of Pakistan promulgated “Pakistan Environmental

Protection Act” in 1977 ANNEXURE-I. Two organizations, the Pakistan

Environmental Protection Council (Pak-EPC) and the Pakistan

Environmental Protection Agency (Pak-EPA), are primarily responsible

for administering the provisions of the Act. The Pak-EPC oversees the

functioning of the Pak-EPA. Among its major members include

representatives of the Federal and Provincial Governments especially the

Provincial Environmental Protection Agencies, industry, non-

governmental organizations, academia, environment experts, Federation of

Chamber of Commerce and Industry and the private sector.

The Pak-EPA, through the Provincial EPAs, is required to ensure

compliance with the National Environmental Quality Standards (NEQS)

and establish monitoring and evaluation systems. As a primary


21

implementing agency in the hierarchy, it is responsible for identifying the

need for, as well as initiating legislation whenever necessary. Pak-EPA is

also authorized to delegate powers to its provincial counterparts, the

provincial EPAs. One of the functions delegated by the Pak-EPA to

provincial EPA is the review and approval of Environmental Impact

Assessment (EIA) and Initial Environmental Examination (IEE) reports of

the projects undertaken in their respective jurisdictions.

3.4.3 Pakistan Penal Code (1860)

The Pakistan Penal Code usually called PPC is a penal code for all

offences charged in Pakistan. It was originally prepared by Lord Macaulay

in 1860 on the behalf of the Government of British India as the Indian

Penal Code. After the partition of British India in 1947, Pakistan inherited

the same code and subsequently after several amendments [e.g. Protection

of Women (Criminal Laws Amendment) Act, 2006, Criminal Laws

(Amendment) Act, 2004 (I of 2005), Criminal Law (Amendment)

Ordinance (LXXXV of 2002), Criminal Laws (Reforms) Ordinance

(LXXXVI of 2002), etc.] it is now mixture of Islamic and English Law.

Pakistan Penal Code is a general criminal law, applies all over the country,

and contains specific provisions on the subject. Thus it prohibits mischief

by killing or maiming animals, or damaging works of irrigation or a river

or a road or a bridge or drain or firing explosive substances with intent to

cause damage. The Code also prohibits public nuisance by acting

negligently to spread the infection of disease or disobeying quarantine rule

or causing adulteration of food or drink or drug, or fouling water or

making the atmosphere noxious to health etc.


22

3.4.4 Pakistan Environmental Protection Act, 1997

The promulgation of the Environmental Protection Ordinance, 1983 was

the first codifying legislation to the issue of environmental protection.

Later, the Government passed the Pakistan Environmental Protection Act

(PEPA), 1997 ANNEXURE-I, which is the basis of IEE/EIA studies

carried out for the projects in Pakistan.

PEPA, 1997 is a fairly comprehensive legislation and provides protection,

conservation, rehabilitation and improvement of the environment. It

contains concrete action plans and programs for the prevention of

pollution and promotes sustainable development. The salient features of

the law are:

It covers the air, water, soil, marine and noise pollution including

pollution caused by motor vehicles.

The Act provides National Environmental Quality Standards (NEQS)

for wastewater, air emissions and noise.

Law provides clear cut guidelines for IEE/EIA for various projects as

per their magnitude and anticipated impacts.

Law also empowers Federal Government to issue notices and to

enforce them for the protection of the environment.

For the effective implementation of the provisions of PEPA, 1997,

Pakistan Environmental Protection Agency, headed by a Director General

was constituted. On the same pattern, Provincial Environmental Protection

Agencies (EPA’s) were created in all the provinces. Environmental

Tribunals were also constituted according to PEPA, 1997.


23

3.4.5 Policy and Procedures for the Filing, Review and Approval of

Environmental Assessments

This document sets out the key policies and procedural requirements. It

contains a brief policy statement on the purpose of environmental

assessment and the goal of sustainable development and requires that

environmental assessment be integrated with feasibility studies. It also

defines the jurisdiction of the Federal and Provincial EPA’s. It lists down

the responsibilities of the proponent and states the duties of responsible

authorities. It provides schedules of reports that require either an IEE or

EIA.

3.3.6 Guidelines for the preparation and review of Environmental

Reports (NOVEMBER 1997/2000)

These guidelines are descriptive documents regarding the format and

content of IEE/EIA reports to be submitted to EPA for “No-Objection

Certificate (NOC)/Environmental Approval (EA)”. Following are the

major areas, which are covered by these guidelines:

The IEE/EIA report (scope, alternatives, site selection, format of IEE

report)

Assessing impacts (identification, analysis and production, baseline

data, significance)

Mitigation and impact management (and preparing an environmental

management plan)

Reporting (drafting style, main features, shortcomings, other forms of

presentation)

Review and decision making (role, steps, remedial options, checks and

balances)


24

Monitoring and auditing (systematic follow up, purpose, effective data

management)

Project Management (inter-disciplinary teams, programming and

budgeting)

3.4.7 Guidelines for Public Consultations

These guidelines deal with possible approaches to public consultation

(PC) and techniques for designing an effective program of consultation

that reaches out to all major stakeholders and ensures the incorporation of

their legitimate concerns in any impact assessment study. These guidelines

cover:

Consultation, involvement and participation of Stakeholders

Techniques for public consultation (principles, levels of involvements,

tools, building trust)

Effective public consultation (planning, stages of EIA where

consultation is appropriate)

Consensus building and dispute resolution

Facilitation involvement (including the poor, women, building

community and NGO capacity

3.3.8 National Environmental Quality Standards (NEQS)-1993,

Amended August 2000

The National Environmental Quality Standards (NEQS) were first

promulgated in 1993 and have been amended in August, 2000

ANNEXURE-II.

The following standards are specified therein:


25

Maximum allowable concentrations of pollutants (32 parameters) in

municipal and liquid industrial effluents discharged to inland waters,

sewage treatment facilities, and the sea (three separate sets of

numbers)

Maximum allowable concentrations of pollutants (16 parameters) in

gaseous emissions from the industrial sources

The Guidelines for “Self-Monitoring and Reporting” (SMART)

ANNEXURE-VIII for the industry as approved by the Pakistan

Environmental Protection Council (PEPC).

A copy of the Government of Pakistan, Gazette Notification dated August

10, 2000 regarding NEQS is attached as ANNEXURE –II.

3.4.9 Guidelines for Sensitive and Critical Areas

These guidelines identify sensitive and critical areas in Pakistan, in

relation both to the natural environment and the cultural aspects.

3.4.10 National Resettlement Policy and Ordinance

At this point, the only legislation relating to land acquisition and

compensation is the Land Acquisition Act (LAA) of 1894. Following a

national consultative process, a national resettlement policy and a related

ordinance were drafted. The draft policy and the ordinance are presently

being reviewed by the provinces, and have yet to be approved and notified

by the government. The salient applicable features of the Draft

Resettlement Policy are given below:

The Pak-EPA will be responsible for both environment-related as well

as resettlement-related matters,


26

The responsibilities for implementation at a provincial level are to be

delegated to the concerned provincial EPAs with overall control of the

provincial Planning and Development (P&D) Departments.

All categories of ‘loss’ arising from development projects that entail

resettlement, need to be addressed: these include not only loss of land,

built-up property, other infrastructure, and crops and trees, but also

loss of income, job opportunities, and access to natural resources, etc.

Vulnerable groups whose issues need to be addressed in particular

include: women, children, destitute persons, tribal communities,

squatters, those with usurper rights, and landless groups.

There should be a special emphasis on consultation with affected

groups when preparing a Resettlement Action Plan (RAP).

The provisions of the Draft Resettlement Policy are consistent with the

requirements of the World Bank OD 4.30 on involuntary resettlement.

3.3.11 Forest Act, 1927

All India Forest Act, 1927 was adopted by the Government of Pakistan,

which was subsequently implemented by the respective provinces.

Basically, the law was enacted to conserve and protect the forest resources

of the country for sustainable development. It lays down Rules and

Regulations for exploitation of various categories of forests such as

reserved, protected or unclassified. Further, the Act spells out the licensing

method for timber cutting, grazing, hunting etc. It also gives the details of

magisterial powers of Forest Department officers and penalties for

offences committed with regard to forest resources and products.


27

3.4.12 Industrial Relation Ordinance, 2002

The ordinance has been promulgated to amend, consolidate and rationalize

the law relating to formation of trade unions, regulation and improvement

of relations between employers and workmen and avoidance and

settlement of any differences or disputes arising between them Pakistan’s

labour laws trace their origination to legislation inherited from India at the

time of partition of the Indo-Pak subcontinent. The laws have evolved

through a continuous process of trial to meet the socio-economic

conditions, state of industrial development, population and labour force

explosion, growth of trade unions, level of literacy, Government’s

commitment to development and social welfare. To meet the above named

objectives, the government of the Islamic Republic of Pakistan has

introduced a number of labour policies, since its independence to mirror

the shifts in governance from martial law to democratic governance.

While Article 18 of the Constitution affords every citizen with the right to

enter upon any lawful profession or occupation, and to conduct any lawful

trade or business, the Industrial and Commercial Employment (Standing

Orders) Ordinance was enacted in 1968 to address the relationship

between employer and employee and the contract of employment. The

Ordinance applies to all industrial and commercial establishments

throughout the country employing 20 or more workers and provides for

security of employment. In the case of workers in other establishments,

domestic servants, farm workers or casual labour engaged by contractors,

their labour contracts are generally unwritten and can be enforced through

the courts on the basis of oral evidence or past practice.

The Constitution of Pakistan contains a range of provisions with regards to

labour rights found in Part II: Fundamental Rights and Principles of

Policy.


28

Article 11 of the Constitution prohibits all forms of slavery, forced

labour and child labour;

Article 17 provides for a fundamental right to exercise the freedom of

association and the right to form unions;

Article 18 proscribes the right of its citizens to enter upon any lawful

profession or occupation and to conduct any lawful trade or business;

Article 25 lays down the right to equality before the law and

prohibition of discrimination on the grounds of sex alone;

Article 37(e) makes provision for securing just and humane conditions

of work, ensuring that children and women are not employed in

vocations unsuited to their age or sex, and for maternity benefits for

women in employment.

3.4.13 Industrial Relations Ordinance 2011 Promulgation

The Government has promulgated Industrial Relations Ordinance 2011.

The Ordinance has been approved by the President on the Advice of the

Prime Minister. The Government has promulgated Industrial Relations

Ordinance, 2011 in view of the current legal vacuum created due to

deletion of the concurrent Legislative List through the 18th Constitutional

Amendment. The Industrial Relations has also been transferred to the

Provinces which have promulgated provincial laws to regulate industrial

relations. However, there is no law in place to deal with Industrial

Relations in the Islamabad Capital Territory or in respect of national level

trade federations and for resolutions of trans-provincial industrial issues.

The Parliament has yet to promulgate the Ordinance as law.


29

3.4.14 Other Relevant Laws

Some of the other relevant laws and legislations are listed below:

Canal and Drainage Act, 1873

The Explosives Act, 1884

The Fire Wood and Charcoal (Restriction ) Act, 1964

Motor Vehicles Ordinance, 1965

The West Pakistan Regulation and Control of Loudspeaker and Sound

Amplifier Ordinance, 1965

Agriculture Pesticides Ordinance, 1971

The Antiquities Act, 1975

3.4.15 National Electric Power Regulatory Authority (NEPRA) Act

1997

The NEPRA Act was approved by Parliament and signed into law in

December 1997. It seeks to create an autonomous, independent regulatory

authority, which will be solely responsible for the power sector. It will be

responsible for the oversight of the power sector and will exercise control

through its power to license power generation, transmission and

distribution. It will regulate tariffs for all these activities. It will perform

its functions through transparent processes to be enshrined in rules that are

being framed in a transparent manner through appropriate rules.

3.4.16 Power Policy 1998

The revised power policy was implemented in 1998. The objective and

intentions of the Government of Pakistan (GOP) to new policy is to move

towards the creation of a competitive power market in Pakistan. It

proposes to do so by restructuring and privatizing the existing thermal


30

power generation, the power transmission and distribution functions and

assets of existing public sector utilities (WAPDA/KESC), by the creation

of a fully autonomous regulatory authority, the National Electric Power

Regulatory Authority (NEPRA), and through its future IPP policy.

The salient features of the Policy are;

The basis for selection of private power project will be minimum

levelized tariff through International Competitive Bidding. Variable

tariffs over the life of the project will be permitted under terms

specified prior to bidding. The process of selection will involve pre-

qualification, issuance of a Request for Reports (RFP), bidding and

evaluation of bids against bid criteria clearly laid out in the RFP.

It is recognized that without a proper feasibility study for a particular

site-specific hydel or indigenous coal based project, it will not be

possible to invite competitive bids and receive firm offers. Thus,

detailed feasibility studies for such projects will be prepared before

bids are invited.

Hydel projects will be implemented on a Build-Own-Operate-Transfer

(BOOT) basis; to be transferred to the province in which it is situated

at the end of the concession period, and thermal projects on a Build-

Own-Operate (BOO) basis.

Competitive Tariffs will comprise an Energy Purchase price and a

Capacity Purchase Price with adequate provisions for escalation.

3.4.17 Factories Act, 1934

There is no independent legislation on occupational safety and health

issues in Pakistan. The main law, which governs these issues, is the

Chapter 3 of Factories Act, 1934. All the provinces, under this act, have

devised Factories Rules. The Hazardous Occupations Rules, 1963 under

the authority of Factories Act is another relevant legislation. These rules


31

not only specify some hazardous occupations but also authorize the Chief

Inspector of Factories to declare any other process as hazardous.

The other related laws are:

Workmen Compensation Act, 1923

Provincial Employees Social Security Ordinance, 1965

West Pakistan Shops and Establishments Ordinance, 1969

Boilers and Pressure Vessels Ordinance, 2002

Chapter 3 of the Act has general provisions on health and safety at the

workplace. Provincial governments are allowed to make rules under this

Act and inspectors under this Act also have discretion in defining the

rules. Chapter 3 talks about various safety arrangements. This list is being

provided just to show how meticulously labor law covers these issues.

Cleanliness

Disposal of wastes and effluents

Ventilation and temperature

Dust and fume

Artificial humidification.

Overcrowding

Lighting

Drinking water

Latrines and urinals

Spittoons

Precautions against contagious or infectious disease

Compulsory vaccination and inoculation

Power to make rules for the provision of canteens

Welfare officer

Precautions in case of fire


32

Fencing of machinery

Work on or near machinery in motion

Employment of young persons on dangerous machines

Striking gear and devices for cutting off power

Self-acting machines

Casing of new machinery

Prohibition of employment of women and children near cotton openers

Cranes and other lifting machinery

Hoists and lifts

Revolving machinery

Pressure plant

Floors, stairs and means of access

Pits, sumps, opening in floors, etc.

Excessive weights

Protection of eyes

Power to require specifications of defective parts or tests of stability

Safety of building, machinery and manufacturing process

Precautions against dangerous fumes

Explosive or inflammable dust, gas, etc.

Notice of certain accidents

3.5 Environment Related Relevant International Agreements in Pakistan’s

context:

Pakistan is a party to the following treaties and agreements in furtherance

of its environmental goals and programme.

Treaty Pakistan Status

Convention on the Protection of Ozone Layer on Ratified


33

Dec 18, 1992.

The Amendment to Montreal Protocol on

Substance that Depleting Ozone layerSigned

UN Framework Convention on Climate Change on

June 13, 1992Signed

Convention on the Continental Shelf on October

31, 1958Signed

The Convention on High Seas on October 31, 1958 Signed

Convention on the Fishing and Conservation of the

living Resources of the High Seas on October 1958. Signed

The UN Convention on Law of the Sea on

December 10, 1982 Signed

The Convention on Territorial Sea and the

Contagious Zone and the Agreement for the

establishment of Network of Aquaculture Centers

in Asia and the Pacific

Signed

The Convention on Wetlands of the International

Importance on July 23, 1976 Ratified

The Convention on protection of the World

Cultural and Natural Heritage on July 23, 1976 Ratified

The Convention on International Trade in

Endangers Spice of Wild Fauna and Flora Signed

The Convention on Conservation of Migratory

Specie of Wild Animal on Dec 01, 1987 Signed

The Convention on Biological Diversity in 1994

and became party to the CBD, Convention duly

recognizes the intrinsic value of biological

diversity, genetic, social, economic, cultural,

educationist, recreational and esthetic values of

Ratified


34

biodiversity and its components

The International Plant Protection Convention. Signed

The Plant Protection Agreement for Area & pacific

regionSigned

The Agreement for the establishment of a

convention for controlling the desert lost in eastern

region of its Distribution Area in South East Asia

Signed

The Treaty Banning Nuclear Weapon Test in the

Atmosphere, in Outer Space and under Water on

March 3, 1988

Signed

The International Convention on Oil Pollution

Preparedness Response and CorporationSigned

The Convention on prohibition of Military or any

other Hostile Use of Environmental Modification

Techniques and Accession of Feb 27, 1986

Acceded

Pakistan became a party to Montreal Protocol by

Ratifying the protocol and its London amendment

on Dec 18, 1982.the subsequent amendments

known as Copenhagen Amendment which,

accelerate the phase out for rectified in Jan 1995.

Signed

Convention of International trade Endangerous

Species (CITS)Signed

World heritage Convention Ramsar Convention Signed

United Nation Convention to Combat Ozone

Depletion (CCD). The convention signed and

ratified in 1996

Signed

Stockholm Convention for Phasing out Parenting

Organic pollutants (POPs) in 2001.Signed


4.0 DESCRIPTION OF EXISTING AND EXPECTED CONDITIONS


28

4.0 DESCRIPTION OF EXISTING AND EXPECTED

CONDITIONS

4.1 Spatial and temporal boundaries adopted for the various aspects of

the study

While carrying out the present study, factors including present environmental

settings and likely future trends around the project site were taken into

consideration. Availability of basic infrastructure, water, raw materials, labor,

transport and electricity were the major among other factors considered in the

project area. Socio-economic conditions were also considered during the course

of the study.

4.2 Existing (baseline) condition of the biophysical and socio-economic

environment, trends and anticipated future environmental conditions

should the project not go ahead

A detailed account the Socio-economic environment is given under serial #

4.3.1.13.

4.3 Environmentally sensitive areas of special or unique value Physical

resources of the project area:

Topography and geology; Soils and Climate; water; Ecological resources:

Fisheries and aquatic biology, Biodiversity, Forestry, Wildlife, scientific

institutions, Socio-economic, Cultural and other heritage.

4.3.1 Physical resources of the project area

Physical resources of the project area are described as below.


29

4.3.1.1 Topography and geology

Pakistan lying in the northwestern part of the Southern Asian

Subcontinent, occupies the western end of the Indo-Genetic Plain,

which is beyond bounded in the north by mountain wall of the

Great Himalayas and their offshoots.

Physiology of the earth is description of the behavior of the upper

crust. The land in this area consists of the alluvial soil deposited by

the waters of the river Indus, so it is naturally very fertile. Almost

60% of the land is cultivated while the rest is under forest. Major

crops are wheat, cotton and sugarcane. Sunflower and a variety of

vegetable are also grown. In addition to the river Indus a number

of canals including Ghotki Feeder provide the necessary irrigation

system.

The area is classified as hot arid on overall basis; however canals

are available for irrigation purpose. December and January are the

coolest months of the year while June and July are the hottest.

Total annual rainfall is in the range of 125 to 250 mm.

More than 65% of the land is owned by the framers themselves and

around 35% is cultivated by the tenant framers. Land holding

range from as low as 2.5 acres to well over 1000 acres. Farmers in

the area keep small cattle herds of poultry, sheep, goats, buffalos

and cows to supplement their income and to obtain milk and other

dairy products.


30

4.3.1.2 Land

The land in this area consists of the alluvial soil deposited by the

waters of the river Indus, so it is naturally very fertile. Almost 60%

of the land is cultivated while the rest is under forest. Major crops

are wheat, cotton and sugarcane. Sunflower and a variety of

vegetable are also grown. In addition to the river Indus a number

of canals including Ghotki Feeder provide the necessary irrigation

system.

Hand pumps and tube wells are also common in this area because

of a very shallow water table which may rise as high as 1.5 feet

below ground in some Katcha area.

The area is classified as hot arid on overall basis; however canals

are available for irrigation purpose. December and January are the

coolest months of the year while June and July are the hottest.

Total annual rainfall is in the range of 125 to 250 mm.

More than 65% of the land is owned by the framers themselves and

around 35% is cultivated by the tenant framers. Land holding

range from as low as 2.5 acres to well over 1000 acres. Farmers in

the area keep small cattle herds of poultry, sheep, goats, buffalos

and cows to supplement their income and to obtain milk and other

dairy products.

4.3.1.3 People

There are several small human settlements in the form of villages

scattered throughout the project area. The main village is usually

surrounded by a number of small settlements named as Goths.


31

These are named after the family chief and are inhabited by the

few households related to these families.

The people living in this area are strongly tied in the tribal systems.

There are more than 50 tribes/sub tribes or castes consisting of

Muslims and Non-Muslims. The prominent ones include:

- Muslims:

Syed, Soomro, Memon, Merani, Bohar, Dakhan, Sanghar, Leghari,

Jaskani, Khosa Baloah, Khohawar, Waso, Chachar, Drigh, Lakhan,

Solangi, Malik, Mahar, Thaheem, Bharo, Manganhar, Ghotta,

Sundrani, Kalora, Bhutta, Machhi, Bozdar, Pitafi, Lond.

- Non-Muslims:

Hindus, Marvani, Oad.

The majority of population is directly or indirectly engaged in the

agricultural activities which continue whole year. The ratio of

farmers, laborers and servicemen is almost uniform throughout the

villages and ranges between

Farmers 70-80%

Laborers 15-20%

Servicemen 05-10%

Majority of the people living in this area belong to the middle and

lower classes. The number of persons in these classes varies from

village to village but normally ranges between


32

Middle class 20-40%

Lower class 60-80%

4.3.1.4 Languages:

Sindhi is the only dominant language of the area which is used as

the official and business language. The literate people have

knowledge of Urdu but English is known only by few highly

educated people. Literacy in the project area very low. In the larger

villages, literacy rate is relatively higher than the smaller ones. In

the main towns of Qadirpur and Goth Jumma, it ranges between 10

to 20% in both sexes while in males it is about 10% age points

more.

4.3.1.5 Sports and Entertainment:

The medium of entertainment and information is radio and

television. There are no proper play grounds or other facilities for

children, and playing in the fields is their favorite pastime.

4.3.1.6 Wildlife - Plant

As mentioned before, about 40% of the land of this area sustains

forest which is classified as thorny forest. A number of tree and

bush species exist here which include Acacia nilotica, Prosopis

julifora, Procopis cineraria, Zizyphus numularia, Arundo donax,

Cymbopogon sp. and Chrysopogon sp. These species of trees grow

in Katcha area, where in Pacca area scattered trees of Acasia

prosopis Zizyphus and Albezzia species are common.

Forests and their approximate acreage are given in the following

table.


33

- Forest Area in acres (Approx.)

Sundarani 1951

Jehanpur 745

Wasti 677

Budh 1197

Bahab 3022

Divisional forest officer is responsible for monitoring and

maintenance of these forests. The officer is stationed in Sukkur.

Also a forest guard is based in Qadirpur who is responsible for

preventing illegal logging.

- Wildlife – Animals

Ghotki project area is quite rich in wildlife due to its diversity of

habitat. The species of birds are especially common, a number of

reptiles and amphibian species are also found here. There is a long

list of mammals, birds and reptiles which are found here.

- Mammals:

Tatera indica (Antilope rat)

Lepus nigricollis (Black napedhare)

Herpestes edwardsi (Grey mongoose)

Hemiechinus auritus (Hedgehog)

Axis procinus (Hog deer)

Mus musculus (House mouse)

Ratus ratus (House rat)

Platanista indi. (Indus dolphin)

Canis aureus (Jackal)


34

Felis chaus (Jungle cat)

Funanbulus fennanti (Northern palm squirrel)

Lutra perspicillata (Otter)

Hystrix indica (Procupine)

Vulpes vulpes (Res fox)

Nesokia indica (Short tailed mole rat)

Sus scrofa (Wild boar)

- Birds:

Acridotheres gingianus (Bank myna)

Lanius vittatus (Bay backed shrike)

Dicrurus adsimilis (Black drongo)

Francolinus francolinus (Black partridge)

Larus ridibundus (Black headed gull)

Podiceps nigricollis (Black necked grebe)

Elanus caeruleus (Black winged kite)

Himantopus himantopus (Black winged stilt)

Bueto bueto (Buzzard)

Bubulcus ibis (Cattle egret)

Corvus splendens (Common crow)

Trunga hypoleucus (Common sandpiper)

Haliaetus leucoryphus (Fish eagle)

Anas querquedula (Gargany)

Francolinus pondicerianus (Grey partridge)

Saxicoloides fulicata (Indian robbin)

Torgos calvus (King vulture)

Vanellus indicus(Lapwing)

Phalacrocorax niger(Little cormorant)

Egretta garzetta(Little egret)

Egretta intermedia(Median egret)


35

Ceryle rudis(Pied kingfisher)

Anas acuta(Pintail)

Ardea purpurea(Purple heron)

Neophron peromopterus(Scavenger vulture)

Alcedo atthis(Small blue kingfisher)

Aquila rapax(Tawny eagle)

Halcyon smyrnensis(White breasted kingfisher)

Amaurornis phoenicurus(Whtie breasted waterhen)

- Amphibians and Reptiles:

Hardella thurgi(Crown turtle)

Trionyx gangeticus(Giant soft shelled turtle)

Kachuga smithii(Hard shelled turtle)

Chitra indica(Soft shelled turtle)

Natrix piscator(Water snake)

- Protected Animals:

Sindh Wildlife Department promulgated an ordinance in 1972 for

protection of Wildlife in the province which contains a list of

protected animals, some of which are found in the vicinity of

project area: Indus Dolphin and Hog Deer are of special

importance as they are endangered animals.

- Protected Birds:

All members of the family Ardeidae: i.e., all Herons, Night

Herons, Paddy Birds, Egrets or Bitterns.

All members of the family Pelecanidae: i.e., all Pelicans.

All members of the family Ciconidae: i.e., all Strokes.


36

All members of the genus Cygnus: i.e., all Swans.

All members of the family Phasianidae: i.e., all Pheasants,

Partridges, Quails, Supurfowls, Jungle fowls and Peafowls.

All members of the genus Heliopais: i.e., all Finfoots.

All members of the family Otidiae: i.e., all Bustards.

Pterocles alchata. – Large Pin-tailed Sandgrouse.

- Protected Mammals:

Macaca speciosa. – Stump-tailed Macaque.

Presbytis obscurus. – Dusky Leaf Monkey.

Vulpes cana. – Boanford’s Fox.

Felis viverrina. – Fishing Cat or Marsh Billi, Mach Bagral.

Azis axis. – Spotted Deer or Chittal, Chitra, Jhank, Pagal,

Hiran, Boro, Khetiya.

Axis porcinus. – Hog Deer or Para.

Boselaphus tragocamelus. – Blue Bull or Nilgai, Gond,

Bain, Ranjh, Rojra.

Platanista gangetica. – River Dolphin or sus, Susu, Susuk,

Sishuk, Bhulan, Sunsar.

- Protected Reptiles.

Crocidilus palustris. – Marsh Crocodile or Muggar, Magar

Mach.

Crocodilus porosus. – Estuarine Crocodile or Maggar.

All Snakes pf the genus Python: i.e., all Pythons, Azdha or

Arar.

All marinr turtles of the genera Dermochelys, Chelone,

Caretta and Eretomichelys i.e., all Leather back, Green or

edible, Hawks bill, Logger head and Tortoise-shell Turtles.

(Source: Sindh Wildlife Department, Karachi)


37

- Indus Dolphin:

According to the Sindh Wildlife Department there are about 16-18

schools of Indus Dolphins between Guddu and Sukkur Barrages

each having 15-30 individuals. Indus Dolphin is very rare and

specialized fresh water dolphin, being confined to fluvial not tidal

water. It differs from most other dolphins due to its broad spade

shaped flippers and the beak which is very long and slender. The

colour of this dolphin is pale brown with slightly paler ventrally.

Adult body length is about 5-6 ft and may weigh up to 100 kg.

They locate objects by sonar or echolocation which is specially

developed in this animal because its eyes have become non

functional lacking any lens.

Indus Dolphins prefer deep running waters and come out of water

surface for breathing every 2-3 minutes interval. Babies breathe

more frequently than the adults. The animals is quite social and

schools of 10 or more individuals circle around and swim together,

but solitary or a pair of animals are also observed.

The animals prey and feed in the early part of night. They

frequently move to shallow waters and enter the side channels of

main river to hunt. These regions are inhabited by small fishes

which form the major part of the dolphin’s diet.

- Hog Deer:

This deer is confined to the river forests in the plains particularly

where there are dense grass patches of Sacchaum and Tamarix.

This is a small ungulate with short delicate legs and bulky heavy


38

body. The General colour is dark olive brown. Adult males stand

24-28 inches high at the shoulders and measures 42-44 inches from

nose to tip of the tail. The females are slightly smaller than the

males and lack horns. The horns of male are 12-14 inches long

borne on hairy pedicles.

With the increase in cultivated area right up to the banks of river, it

is now confined to isolated pockets of jungles in the less accessible

regions. Main population of Hog Deer now survives in the Indus

River Forest Reserves of Sindh.

Hog Deer is not a social animal and lives solitary existence. In

feeding habits they are largely nocturnal. One of the principal food

of this animals is young leaves of Euphratic Poplar.

Other mammals include Wild Boar and Porcupine which are

considered pests for the crop.

4.3.1.7 Industries:

The project area is not yet developed in industrial terms. Qadirpur Gas

field, Fauji Power Plant, Mari Gas Field, Engro Chemicals, Liberty Power,

Engro Energy are some worth mentioning units present in the project area.

4.3.1.8 Infrastructure:

The area is supplied electricity from the National Grid of Water and Power

Development Authority. Almost all the bigger villages are connected

through roads the district head quarter of the area. Even small connecting

roads are available. Some big villages are supplied drinking water from

civil water supply. Variety of private road transport in the form of buses


39

and wagons are available to reasonable extent. Underground water from

shallow depth is also used for irrigation and drinking.

4.3.1.9 Transportation: roads, rail, airports, navigable rivers:

There is a reasonable network of roads connected by small roads in the

area. Virtually most of the villages are connected with each other through

these roads. The country’s main railway line also passes through Mirpur

Mathelo. There is Sukkur & Rahim Yar Khan airports in the project

around. River Indus and its tributaries canal flows near to the project site.

4.3.1.10 Land use planning:

The entire land use planning is carried out according to the provincial

laws. Under the present Government system, the District Government is

responsible for all land use planning.

4.3.1.11 Power sources and transmission:

WAPDA power network operates in the area. Transmission of power is

through overhead electric transmission lines. National grid is the source of

all power in the area.

4.3.1.12 Agricultural and mineral development:

Land holdings are very small. Agriculture mainly depends upon rain

water. Underground water form shallow depth is also used for agriculture

but due to cost factor this is unaffordable by many people. Agriculture

alone cannot sustain life of the people.


40

Natural gas is also available and exploitation of gas is going on for the last

so many decades. This exploitation is on major scale.

4.3.1.13 Quality of life:

- Socioeconomic values:

The land around the project area is not arid completely as canal water is

also available for irrigation. Average land holdings are very small. The

people also supplement their income also by rearing of goats, sheep and

cows on a limited scale. The people of the area are generally poor.

Since the area is not yet industrialized, therefore, job opportunities are

very less. A large number of the people do mostly labor and other menial

work especially at Islamabad, Faisalabad, Lahore and Karachi. However,

some are working in Middle East. Fairly over 10% of the younger

generation is in Pakistan Army.

There is also a highly educated, affluent and well placed segment of the

society in the area. Their way of life can be compared with that of any

developed segment of the society of Pakistan. They provide leadership

role for development of other classes of the society. They are quite helpful

to the people of their areas. They serve as Beacon house for the other low

placed class. Their role in the development of the area and society is quite

important.

People mostly follow old traditions in almost all walks of heir life. Elders

are very much respected and play vital role in decision-making. Old

people are mostly illiterate. Old customs are being practiced. Arranged

marriage system is followed and it is quite successful. People are proud of

their traditions and customs. Joint family system prevails and people reap


41

the fruits of this system. Families are quite coherent. Guests are welcome

as a tradition from the old past. Life style is simple.

Due to awareness about the importance of education most of younger

generation, including both sexes, is now trying to get education. There is a

rising trend in the society to change their old traditional socioeconomic

pattern of life. Print and electronic media are playing great role in bringing

tangible change in the old pattern of life.

- Public health:

Only small scale dispensaries are available at some villages of the area.

However, at Mirpur Mathelo, District hospital is run by Government.

- Recreational resources and development:

With the exception of the Sukkhur Barrage there is no other worth

mentioning recreational facility in the project area. Even the lake is not

developed befitting of requirements. The area is arid and rain is quite

scanty. There is worth mentioning development in the area in terms of

industry. There are many industries in the area including Engro

Chemicals, Liberty Power, Engro Energy, Mari Gas Filed, Fauji Power,

and Qadirpur Field.

- Cultural and aesthetic values:

Old traditional cultural and aesthetic values prevail among most of the

people. Where some people belong to middle class, there a large number

of the people are living life below poverty levels. However, media is

playing a big role to bring change in the traditional aesthetic values

presently prevailing among a large cross section of the society. There is


42

also a section of affluent people who follow even the modern aesthetic

pattern of life. A tangible change is appearing among a cross section of the

society who is trying to pursue the modern aesthetic values of life.

Financial and religious factors influence aesthetic and culture values of a

society. People are religiously having strong commitment to Islam. This

relation contributes to good aesthetic and cultural values among the

people.

Area around the project site is not completely arid zone; agriculture also

depends on irrigation (Canals). Some people own small land holdings.

Agriculture depends upon rain water and that too on very limited scale.

People cannot sustain life on this single agriculture source. Resultantly,

aesthetic and cultural practices of a poor and medium type of society are

dominant among a large cross section of the society.

On the over all basis, century old traditions of typical villages of Sindh are

prevalent in culture and aesthetic sense of life. Most of the people follow

quite old type of life, rituals and traditions.

Most of the old people are illiterate but awareness and importance of

education is attracting the people to send their wards to schools mostly up

to primary level and some inclination to high school education is also

shown.

Mostly, customs and rituals are primitive in nature. Some modernization

in the existing cultural values is appearing among those educated and

economically well off and those frequently mixing with urban society.


5.0 EVALUATION OF IMPACTS AND MITIGATION MEASURES


43

5.0 EVALUATION OF IMPACTS AND MITIGATION MEASURES

Evaluations of the likely adverse impacts of the project activity on the

environment and mitigation measures to be adopted are discussed as below:

5.1 Assessment of any environmental impact on local population and the

environment during construction and operational phase

The possible adverse impacts that could appear on the environment from the

project operation, both during construction and regular operation are described

hereunder. These are followed by description of the mitigation measures to be

adopted to manage them.

It is pertinent to note at the very outset that the project is to be operated in

accordance with the legal requirements of PEPA-1997 and the NEQS Pakistan.

EMP and EMtP, as recommended in this EIA report at Serial No: 7 are to be

strictly adhered to. Further, the project proponent has filed with the EPA Sindh,

written Affidavit and Undertaking on judicial papers, that the project throughout

its life will be operated under Environmental Management Order. Failing

compliance with the legal requirements invites heavy penalties resulting in

ultimate closure of the project in case of continued violence of the NEQS goes on

beyond the legally prescribed limits of time. These conditions provide safeguards

to the environment against pollution from the project both during construction and

regular operation.

5.1.1 Likely adverse impacts from plant during construction

5.1.1.1 Environmental Adverse Impacts During Construction

The likely adverse environmental impacts to occur due to the

project activity during construction phase are described as below:


44

5.1.1.2 Pollution impacts and remedies

Excavation, construction activities, moving vehicles, machinery,

materials transport activity and plant installation are the likely

main sources of pollution during construction phase.

Extremely low concentrations of pollutants including emissions of

sulphur dioxide (SO2), nitrogen oxides (NOx), carbon monoxide

(CO); particulate matter (PM) and noise from construction

machinery and vehicles to be used to transport materials of

construction. Sewage will be generated from the construction camp

for labour especially. Dust (PM) will also be generated especially

during excavation for civil construction, moving machines and

transport.

Construction activities will be carried out according to a well

planed action plan based on sound environmental management and

controls principles. Construction plan was prepared also keeping in

view avoiding maximum use of machinery at the same time.

Minimum number of machines and execution of minimum number

of operations/construction/plant installations jobs at a time will be

followed. Under all these construction and other operations

gaseous emissions, particulate matter and noise from the

machinery and vehicles will be the minimized and curtailed within

limited area of the project. Therefore, pollution factor will be

further reduced at source. As far as possible construction work was

carried out during day time.

Vehicles to visit the site, carrying plant machinery and other

materials are not to stampede at the project site. Rather their visit


45

was regulated under a well considered plan. They will approach

the project site at different intervals of time and in limited number.

Only vehicles of the latest models were engaged for the project

work. Therefore, all type of pollutants including gaseous, PM,

noise levels and so on was curtailed through these programming

and management mechanisms of number and time of visits of the

vehicles.

During construction sewage and spilled water in limited quantity

was generated from construction activity. This will be discharged

to main effluent pond from where it will be use for irrigation

purposes.

Even during plant machinery installation period the best

environmental management practices are to be strictly followed

according to a plan encompassing environmental element.

- Solid wastes:

Solid wastes in the form of Concrete, steel strips, plastic sheets,

steel and brick pieces, redundant aggregate and iron scrap will be

the major solid wastes. While brick pieces and redundant aggregate

from civil construction work will be retained for any further walls

foundations fillings, the rest of the items fetch a lot of market

where it will be sold for reuse.

5.1.2 Environmental Adverse Impacts During Operation stage:

Environmental pollution on all accounts from the project activity on

regular basis shall be managed by strict compliance with the

Environmental Management Plan (EMP) and Environmental Monitoring


46

Plan (EMtP) as recommended in this EIA Report and following

environmentally sustainable practices/cleaner production practices.

- Effluent:

As already mentioned that this is a sewage water treatment plant and

the treated sewage will meet the limiting values of the applicable

parameters as required according to the NEQS limiting value.

- Noise:

The plant has neither any process, nor operations nor the equipment to

be used for the treatment which will produce any noise.

- Solid wastes:

Night soil will be the semisolid waste. This will be treated to the extent

where its usefulness as organic mineral could be use as fertilizer.

5.2 The relevant environmental data and predictive methods used and any

underlying assumptions made

5.2.1 Base line environmental data

In order to know about the existing status of environment on the project site,

baseline environmental monitoring was carried out. The ambient monitored data

regarding Sulphur dioxide (SO2), Nitrogen Oxides (NOx), Carbon monoxide

(CO), PM and noise levels and water quality are exhibited in ANNEXURES–IX,

X, XI and XII. These data are necessary for any further reference and for its use

by EPA Sindh or the project proponent for a variety of their end uses.


47

5.2.1.1 Ambient Air Quality-Ambient

Details of the status of ambient gaseous pollutants and particulates are

reported hereunder:

5.2.1.1.1 Gaseous

Ambient air quality monitoring was carried out on the project site.

DRAGER, Germany manufactured ambient air quality monitoring

equipment was used. Monitoring was carried out for Sulfur dioxide

(SO2), Nitrogen oxides (NOx, NO and NO2) and Carbon monoxide

(CO). The monitored data are exhibited in the ANNEXURE-IX.

5.2.1.1.2 Particulates

Ambient particulates monitoring was also carried out at the project

site. Iso-Kinetic the Casella System (Instrument) designed to

comply with BS 3405 and ISO-9096 for compliance monitoring of

particulate matter (particulates) was used for the monitoring. The

base line/background data generated on the basis of this

monitoring are shown in the ANNEXURE-X.

5.2.1.1.3 Noise Levels

LEADER Sound Level Meter, Japan was used for noise levels

monitoring. The monitored data are reported in the ANNEXURE-

XI. Noise levels monitoring was done at the project site to have

background environmental data.

5.2.1.1.4 Water Quality

Water samples collected from the project site were tested in

laboratory. The test result of the water samples are reported in the

ANNEXURES-XII.


48

5.3 Gaps in knowledge and uncertainties encountered

No data gap/knowledge or uncertainties were experienced throughout the course

of the preparation of this EIA. The information and documents required were

available with the project proponent.

5.4 Compliance with relevant environmental standards

5.4.1 Effluents-discharges and environmental controls:

About 100 m3/hr treated sewage water; will be generated. The effluent

after its treatment to the required levels of the applicable NEQs will be

discharged in to main Massu Wah canal which has very vast dilution

capacity of the sewage, thus further reducing the levels of the pollutants in

the already treated sewage.

5.4.2 Noise Levels

The plant has neither any process, nor operations nor the equipment to be

used for the treatment which will produce any noise. Therefore, noise

levels will remain within the prescribed limits of the NEQS ANNEXURE-

III.

Proper repair and maintenance of the equipment/ machinery, timely

replacements of parts of machinery and equipment will be ensured in

order to avoid sound levels during plant operational condition.

5.4.3 Solid wastes:

Night soil will be the semisolid waste. This will be treated to the extent

where its usefulness as organic mineral could be use as fertilizer.


49

5.5 Assessed significance of the impact stating the standards or criteria

used as a basis for judgment

Since no gaseous emissions are resulting from the present project, hence every

segment of the environment and human health are going to be protected.

The project is to run under strict environmental controls in compliance with the

SEPA 1997 and the NEQS Pakistan as legal binding. Under these environmental

control operations, human health and environment will be well guarded. The solid

wastes will be disposed off in the market under a well guarded and tracked

system.

5.6 Possible measures for avoiding or mitigating the impact

While the possible measures for avoiding or mitigating impacts from the project

activity have been described at the respective places in the preceding parts of this

report, yet the following measures are also recommended for adoption to further

ensure environmental protection.

i- “Cleaner Production” and “Good House Keeping” should be adhered to as it

goes a long way to:

- minimize resource inputs thus enforcing rational use of the resources and

their saving,

- reduce wastes generation,

- reduce losses,

- reduce water consumption,

ii- As far as possible economies on the use of water so that the sewage volume is

reduced. This will result in resource conservation and pollution abatement

besides saving the lot of recurring cost to be incurred on the treatment.


50

iii- As far as possible use automatic shut off taps. This will result in resource

conservation and pollution abatement besides saving the lot of recurring cost

to be incurred on the treatment.

iv- Use of water in floor washing should be restricted to reduce the sewage. This

will result in resource conservation and pollution abatement besides saving the

lot of recurring cost to be incurred on the treatment.


6.0 COMPARATIVE EVALUATION OF ALTERNATIVES (SITING) AND IDENTIFICATION OF THE PREFERRED OPTION


51

6.0 COMPARATIVE EVALUATION OF ALTERNATIVES (SITING) AND

IDENTIFICATION OF THE PREFERRED OPTION

A comparative evaluation of the alternatives and identification of the preferred

options has been given under Serial No 2.6.2.

6.1 Labour

Although for the sewage treatment plant no surplus labour is required because of

its availability with FFCL, yet if required at any time it is easily available in the

project area.

6.2 Basic infrastructure

The project relates to the treatment of sewage from the FFCL staff colony.

Therefore the sewage treatment plant is necessarily to be sited very near to the

colony.

The night soil/sludge from the plant is very rich soil nutrients and organics. This

is a very good part substitute for synthetic fertilizer. In order to transport it from

the plant site to the farmer in the area for its use as fertilizer free of cost, there is a

good infrastructure of roads in the area. This will facilitates convenient and cost

effective transportation of the sludge to it’s endues places.

The project site is sited in the area where the land around is under extensive

agriculture use. Therefore, the sludge to be supplied to the farmers free of cost

will save them a lot of money as point substitute for synthetic fertilizer.

Telephone, telecommunication including telephone, internet and electricity are

available at the door steps of the project site.


52

6.3 Site availability for the plant

Land for the plant is conveniently available at the present site where the plant is

being constructed.

6.4 Environment

The plant, though being constructed near to the residential colony of FFCL staff,

yet the operation of the plant will be carried out with all necessary precautions to

avoid any pollution from the treatment. For this even the wind direction has been

taking care of to avoid drift of the bad smell from the plant to the residential area.

The duly treated sewage will be ultimately used for irrigation within the project

site and left over will be discharged in to main Massu Wah canal. This EIA report

has been prepared to get permission from the EPA Sindh and the Competent

Authority Incharge of the Massu Wah canal for discharging treated sewage into

this canal. Therefore, there is no possibility of any pollution to accrue from the

treated effluent.

6.5 Energy availability:

The electric power required to run the plant is available right at the plant site there

fore this factor also goes in favor of sitting the plant at its present location.


7.0 ENVIRONMENTAL MANAGEMENT PLAN, MONITORING PLAN AND PROPOSED TRAINING


53

7.0 ENVIRONMENTAL MANAGEMENT PLAN, MONITORING PLAN AND

PROPOSED TRAINING

This section dilates upon the followings:

i- Environmental Management Plan (EMP),

ii- Environmental Monitoring Plan (EMtP),

iii- Assigning Responsibility for Implementation of the EMP and EMtP

iv- Reporting and reviewing

v- Proposed Training and

vi- Third party monitoring

7.1 Environmental Management Plan

7.1.1 Mitigation/Compensation Measures during Construction

Phase

These are presented in Table – 7.1 below.

7.1.2 Mitigation/Compensation Measures during Operation Phase

These are presented in Table – 7.2 below.


54

Mitigation / Compensation Measures During Construction Phase

Table - 7.1

Potential Mitigation Action

Impact

Air Quality 1. Vehicles transporting loose construction material

(clay, sand etc) to be covered with tarpaulins.

2. Limit on speed and movement of vehicles, where

considered appropriate speed-breakers should be

installed.

3. Use low emissions trucks for material transport

where possible (e.g. diesel particulate filter)

4. Routine service and maintenance of vehicles and

machines to reduce engine emissions.

5. During periods with abnormal wind speeds, in

particular during dry weather conditions, workers

on the construction site should be provided with

adequate inhalation and eyes protection gears. In

case particulates in air hamper a clear view over the

site completely, so that safety is impaired, the

construction should be interrupted until weather

conditions improve.

6. To reduce generation of dust in the construction

process, onsite roads and parking areas, as far as

possible, would be constructed with asphalt over a

compacted sub base.


55

7. Spraying exposed soil with water to reduce PM

emissions and particulate matter deposition. Water

to be applied at a rate to maintain a moist surface,

but not to create surface water runoff or erosion

conditions.

8. Provide wheel washers to remove particulate matter

that would otherwise be carried offsite by vehicles

that would decrease deposition of particulate matter

on area roads and subsequent entrainment from

those roads.

9. Routing and scheduling construction trucks to

reduce delays to traffic during peak travel times

would reduce secondary air quality impacts caused

by a reduction in traffic speeds while waiting for

construction trucks.

10. As far as possible planting vegetative cover

(matching the local climate), as soon as possible

after grading, would reduce windblown particulate

matter in the area.

Surface Water 1. All liquid materials and lubricants (e.g. sanitary

waste water, etc.) that accumulate during

construction phase shall be stored in closed septic

tanks, and in containers or barrels stored in

specifically identified areas at the construction site.

2. Packaging material like bags of cement etc. shall be

stored in containers to avoid leaching out of any

remaining particles in the event of rain fall, etc


56

Water Supply 1. During construction, non-potable water would be

supplied by trucks to provide dust control.

2. Potable drinking water for construction workers

would be provided by a water service to be

contracted by the site contractor.

________________________________________________________________________

Ground Water 1. Any liquid material and lubricants (e.g. hydrostatic

testing water and wastewater) that accumulate

during the construction phase should not infiltrate

into the soil that have a direct contact to the ground

water. Septic tanks shall be used for any waste

water collection. Each tank, when filled and closed,

should be brought to the closest wastewater

treatment plant for further treatment.

2. Closed tanks should be removed from the site as

soon as possible and should not be allowed to

remain on the construction site as an interim storage

until the end of the construction phase.

3. Monitoring of the characteristic of waste water

collected in the septic or other tanks should be

carried out on routine basis.

4. Maintenance and washing of all heavy mobile

machinery & vehicles should be carried out at

adequate service stations.

5. Maintenance and re-fueling (if necessary) of any

construction equipment shall be done at a decent

distance from the excavation area and only be

undertaken on sealed area. Any re-fuelling must be

handled carefully taking particular attention to not

spilling any fuel.


57

6. On site storage of fuel, engine oil and lubricants (if

any) shall be in locked tanks, sealed and shadow-

roofed area.

7. On site storage of fuel, engine oil and lubricants that

might be stored shall be collected at the end of

construction phase and brought to either a disposal

point for hazardous waste or be brought back for re-

use to the place it was rented for the purpose of this

construction.

Solid Waste 1. All solid wastes shall be disposed off according to a

set procedure and record of sales will be kept to

track at any time when it is required.

2. The contractors to whom any waste is to be sold

shall be fully made aware of the environmental

impacts and health effects of the waste to be sold to

him. He shall be provided instructions for

reuse/handling of such wastes in environmentally

sustainable way.

________________________________________________________________________

Soil 1. Construction activities must be limited to the

designated areas.

2. Re-filling of excavated soil should be done as far as

possible. Where possible the excavated soil should

be reused.

3. Prevention measures should be developed in the

event of an accident or threat (e.g. massive,

uncontrolled leakage of waste water into unsealed

soil on-site).


58

Fauna and flora 1. Planting of indigenous grass, trees and bushes

between the edge of the site and the adjacent un-

utilized area should be carried out. If not earlier

practicable, such measures should be implemented

after the completion of all construction activities.

2. Development of green strips of suitable vegetation

should be done along the access roads.

Noise 1. Power mechanical equipment like bulldozers, air

compressors, concrete pumps, excavators, concrete

mixers etc. shall only be used with low sound

power, whenever possible.

2. Optimize transportation management to avoid

needless truck trips; avoidance of truck movements

in residential areas at least during night time.

3. The building machinery equipment shall be well-

maintained and serviced regularly during

construction phase.

4. Silencers or mufflers on construction equipment

shall be used.

5. Whenever possible, mass construction material and

excavated soil shall be stored in direction of the

nearest habitat as noise barrier.

6. Construction activities shall be scheduled in such a

way that noise intensive operations side by side

with an increased net noise level will be avoided.

7. Workers on the construction site should be

equipped with ear protection in particular those

directly exposed to higher noise levels.


59

Mitigation / Compensation Measures During Operation Phase

Table 7.2

Potential Mitigation Action

Impact

Landscape 1. To the extent possible, develop a green belt along

the facilities boundary area and other open spaces,

to create to some extent a natural landscape. The

flora to be used for such green belt should be

tolerant to the local climate.

Ambient Air Quality 1. Since the sewage treatment is based on aerobic

process therefore monitoring of ambient air for

odour, SO2 and NO3 will be carried.

Surface Water 1. Treated sewage, as described in this report, will be

discharged into the Masu Wah canal. It will be

therefore important that no leakage of this water

during its transfer from the plant to the canal

should take place.

So also the raw sewage should not spill on the

ground. This will require proper piping system

from the point of its generation up to the sewage

treatment plant.

Ground Water 1. Regular inspection of facilities for intercepting

leaking and spilled liquids shall be carried out near

the sewage treatment plant.


60

2. All chemicals to be used for the treatment of the

sewage treatment plant shall be handled only in

appropriate segregated, sealed and bundled areas at

site.

Solid Waste 1. All solid wastes shall be disposed off according to a

set procedure and record of sales will be kept to

track at any time when it is required.

2. The contractors to whom any waste is to be sold

shall be fully made aware of the environmental

impacts and health effects of the waste to be sold to

him. He shall be provided instructions for

reuse/handling of such wastes in an environmentally

sustainable way.

Noise 1. Though the process and the equipment to be used

for sewage treatment have no component which

could generate noise beyond the permissible limits

of the NEQs yet as a precautionary measure the

equipment needs to be timely repaired and maintain

including its lubrication.

Safety 2. Workers should be obliged to use ear protection in

areas within the plant and for specific work that

exceed the tolerable maximum noise limits.

________________________________________________________________________

7.2 Assigning responsibility for implementation (by name or position)

In order to ensure implementation and effective operation of the EMP and EMtP,

it is of utmost importance that responsibilities be fixed to specific persons so that

each one of them should be answerable in case of lapse or mishap. Accordingly,

hereunder the same responsibilities have been described:


61

Official concerned Responsibility

1- General/Plant/Manger

2- Shift Engineer

i- Ultimate in-charge and responsible for all the

operations of Environmental Management Plan

(EMP) and EMtP set up.

ii- He will be responsible to ensure smooth

functioning of the E.M. system

iii- Daily progress on the state of the

environmental status will be reported to

Concerned incharge of the plant by Shift

Engineer/In -charge.

iv- All other E.M. matters , issues and problems

will be reported to him (for rectification) by the

concerned incharge of the Unit DM-PRD-UTY.

v- He will work as bridge between the

Government concerned authorities, the senior

most management of the project.

vi- He will be answerable to the higher

management in all matters relating to EMP &

EMtP and report at least monthly about the state

of the EMP &EMtP operations.

i- During his shift timings, he will be responsible

to ensure smooth functioning of the entire EMP

& EMtP.

ii- He will be responsible to rectify any problem

regarding environmental matter.

iii- He will directly report to the DM-PRD-UTY

for all matters relating to EMP & EMtP on daily

basis.


62

3- Plant Operator

4- Laboratory Chemist

i- He will be responsible to ensure proper

disposal of the effluent and PM and sound levels

monitoring systems.

ii- He will maintain all records of monitoring of

the entire elements of the EMP.

iii- He will report to the Shift Engineer/In-Charge

about matters relating to EMP &EMtP operations

on daily basis and earlier if so required.

i- He will be responsible to carry out all

laboratories testing of waste water at all levels.

ii- He will perform all other lab. testing as may

be required from time to time in the interest of

effective operation of the EMP &EMtP.

iii- He will maintain records of the entire EMP &

EMtP operations.

iv- He will daily report to the Shift Engineer/In-

charge about the matters relating to the E.M.P.

operations.

7.3 Reporting and reviewing procedures

Environmental monitoring program will be the guiding principle and

reporting will be done regularly on monthly basis according to the formats

of the SMART program as annexed ANNEXURE-VIII. At the plant level,

all the monitored data will be reviewed and scrutinized at the level of Shift

Engineer and on monthly basis at the TSM level. The data will be

documented according to appropriate format at the project level.


63

7.4 Training needs

In order to effectively operate the EMP all the staff to be engaged in this

activity should be trained extensively.

All the environment management staff to be engaged for dealing with

effluents disposal, monitoring and testing should be duly trained.

Laboratory chemist should be trained in all operations of laboratory testing

of the effluents and other relevant materials/samples. He should be trained

in applying analytical methods/techniques of testing, data processing,

interpretation and reporting. He should know the local laws, rules

regulations as applicable to the testing of effluents.

The person to carry out environmental monitoring should be extensively

trained to handle his job capably. Training program should include use of

monitoring instruments, data generation, processing, interpretation,

recording and presentation.

7.5 Third party monitoring

Third party monitoring should be carried out and reported to the EPA,

Sindh on regular basis. After the plant start up, once a comprehensive

monitoring report should be carried out for all NEQS parameters for

normal plant operations. This is to establish that the plant does meet the

environmental commitments made in the EIA Report. This monitoring,

preferably, should be carried out by a third party. Thereafter, subsequent

regular monitoring will be restricted to priority parameters as suggested in

the SMART.

Reporting will be done according to the format as given in the SMART.


64

Although noise levels monitoring schedule is not given in the SMART, yet

it is preferable to monitor them on the plant site boundary lines monitored

at least monthly.

All monitoring data should be reviewed and analyzed regularly in

comparison with the NEQS limiting values. And in case of any

deviation/violation immediate necessary corrective actions should be

taken.

Reporting of all the monitored data should be done to the EPA, Sindh.

Overall monitoring, biannually by a third party, will be preferable.

7.6 Environment quality control laboratory

Of the major items for an environment laboratory the followings need to

be present:

All chemicals (A.R. grade), apparatus and glassware ( A- grade)

required for reliable testing of the following parameters:

Temperature, pH, BOD5, COD, TSS,TDS, Oil & Grease

Noise level meter.

Effluent sampling equipment.


8.0 REFERENCES


65

8.0 REFERENCES

The following documents, reports were consulted during the preparation of this

report.

i. Guidelines for the preparation and review of Environmental Reports,

Pakistan Environmental Protection Agency, Government of Pakistan,

October, 1997/2000.

ii. Introduction to Environmental Impact Assessment; J. Glasson, R. Therivel

and A. Chadwick, UCL Press Limited, University College, London.

iii. Environmental Guidelines for Selected Industrial Projects, Office of the

Environment, Asian Development Bank, 1993.

iv. Guidelines for Self- Monitoring and Reporting by the Industry,” Final

Report, March 1998, approved by Pakistan Environmental Protection

Council (PEPC), August 1999.

v. Pollution Prevention and Abatement Handbook, The World Bank, 1998.

vi. Shreve’s Chemical Process Industries, McGraw-hill Book Company,

N.York; 5th Edition, 1985.

vii. Faith, Keyes and Clark’s, Industrial Chemicals, A Willey Interscience

Publication, N. York, 4th Edition, 1975.

viii. Perry’s Chemical Engineer’s Handbook, McGraw-hill Book Company,

N.York, 6th Edition, 1984.

ix. National Environment Quality Standards for Municipal and Liquid

Industrial Effluents, Statutory Notification (S.R.O.), Government of

Pakistan, Ministry of Environment, Local Government and Rural

Development, S.R.O.549 (1)/2000, Islamabad, the 8th August 2000.

x. Pakistan Environmental Protection Act, 1997.

xi. The Pakistan National Conservation Strategy, Environment and Urban

Affairs’ Division (presently- Ministry of Environment, Urban Affairs and

Wild Life), Government of Pakistan, Islamabad.


66

xii. Standard Methods for the Examination of Water and Wastewater, 19th

Edition, 1995, Prepared and published jointly by: American Public Health

Association, American Water Works Association, Water Environment

Federation; Publication office: American Public Health Association, 1015

Fifteenth Street, NW Washington, DC 2005.

xiii. STANDARD HANDBOOK OF ENVIRONMENTAL ENGINEERING,

BY Robert A. Corbitt, 1989, McGraw- HILL, INC.; New York, USA.

xiv. PAKISTAN: GEOGRAPHY, ECONOMY & PEOPLE by Oxford Press

Singapore.

xv. Career’s Geography of Pakistan, Published by Career’s Books Publishers,

Lahore; 2003.

xvi. International Finance Commission (IFC) Environmental, Health and

Safety Guidelines, Environmental and Social Guidelines for Occupational

Health & Safety (June 2003).

xvii. Government of Pakistan, Pakistan Environmental Protection Agency,

Policy and Procedures for Filing, Review and Approval of Environmental

Assessment, 2000.

xviii. The Canal and Drainage Act, 1873.

xix. The Factories Act, 1934.

xx. The Regulation of Mines and Oil-Fields and Mineral Development

(Government Control) Act, 1946.

Xxxiii Environmental Assessment Requirements and Environmental Review

Procedures of the Asian Development Bank, 1993.

xxi. Environmental Impact Assessment – Basic Procedure for Developing

Countries, United Nations Environmental Program, 1998.

xxxiv. The World Bank Operational Directive 4.00 Annexure A, Environmental

Assessment, 1999.

xxxv. The World Bank Operation Policy 4.01 Annexure B, “Content of an

Environmental Assessment Report for Category A Projects”, 1999.

xxxvi. Seismic Zones of Pakistan, by Pakistan Meteorological Department.

xxxvii. Information gathered through discussions with the staff of the project.


9.0 SOURCES OF DATA AND INFORMATION AND LIST OF REFERENCE MATERIAL USED


67

9.0 SOURCES OF DATA AND INFORMATION AND LIST OF REFERENCE

MATERIAL USED

Baseline environmental data was gathered through on site monitoring. This

included data regarding ambient air quality (CO, SOx and NOx), Particulate

Matter, water quality and sound levels.

Environment monitoring and laboratory testing of samples by M/S ECTECH-

Environment Consultants was carried out through APEX Environment

Laboratory, certified as Environment Laboratory, by the Environment Protection

Department, Government of the Punjab.

Other sources of data are the documents listed under Serial No: 8.


67

9.0 SOURCES OF DATA AND INFORMATION AND LIST OF REFERENCE

MATERIAL USED

Baseline environmental data was gathered through on site monitoring. This

included data regarding ambient air quality (CO, SOx and NOx), Particulate

Matter, water quality and sound levels.

Environment monitoring and laboratory testing of samples by M/S ECTECH-

Environment Consultants was carried out through APEX Environment

Laboratory, certified as Environment Laboratory, by the Environment Protection

Department, Government of the Punjab.

Other sources of data are the documents listed under Serial No: 8.


10.0 TEAM MEMBERS WHO CARRIED OUT STUDY AND PREPARED THE EIA


68

10.0 TEAM MEMBERS WHO CARRIED OUT STUDY AND PREPARED

THE EIA

Team members who participated in various activities of this study and preparation

of this report are listed hereunder with their qualifications, experience and

assignment carried out by each one of them.

Name of the EIA/IEE

teamQualification and brief experience

Position in the EIA Team

and role*

Dr. Muhammad Hanif

(Chief Executive)

ECTECH-Environment

Consultants

and

APEX Environment

Laboratory

A-Qualifications:

1- M.Sc. (Chem. Tech.) Punjab Uni; Lahore; 1962.

2-Ph.D. (Chemistry) Charles University, Czech Republic; 1968.

3- Post Doctorate-Alex. Humboldt. Foundation, Senior Post

Doctorate Fellow, Germany; 1974-75.

B-Experience/past Positions:

1-Director General (R), PCSIR Labs. Complex, Lahore.

2-Director General (Ex.)

Ministry of Environment, Local Government and Rural

Development, Govt; of Pakistan.

3- (ex.) Consultant Environment, Category-A,

Asian Development Bank.

4- (ex.) Consultant Environment, UN—ESCAP

5- Worked on World Bank Funded Project.

6- Author of the National Environment Quality Standards

(NEQS)

7- Author of:

i -104 Scientific Research papers

ii - Over 60 technical end project reports on environment.

8- Carried out EIA for more than 120 projects.

9- Prepared about 30 SEIA reports for International

funding by The World Bank, Asian Development Bank,

- Project Team Leader.

-Principal author of the EIA

report.

- Coordination, supervision,

guidance and co author of the

EIA report.

-Over all monitoring of the

project work, supervision,

guidance and participation in

all activities to ensure quality

of work.


69

International Finance Corporation (IFC), Oversees Private

Investment Corporations (OPIC) USA , DEGH Germany

and for many Consortiums of Banks and other financing

Agencies.

9--Among many others, EIA carried out on behalf of the Asian

Development Bank regarding Katmandu Valley (Nepal)

Industrial Sites.

10-EIA-Saindak Gold/copper Project, Pakistan.

11-EIA Pakistan Steel, Karachi;

12-ESIA Report (According to OPIC Environmental Handbook

Format) for D.G. Cement Company Limited, Kallar Kahar,

District Chakwal, Pakistan.

- ESIA Report (According to OPIC Environmental

Handbook Format) for Lucky Cement Limited, Pezu,

District Lakki Marwat, North West Frontier Province,

Pakistan.


Handbook Format) for D.G. Cement Limited, Kallar

Kallar Kahar/ Khairpur Project, District Chakwal

Pakistan.


Handbook Format) for Chakwal Cement Company

Limited, District Chakwal Pakistan.


Handbook Format) for Packages Limited, Lahore.

Mr. Muhammad Saif-Ur-

Rehman

-B.Sc. (Chemical Engineering), Punjab Uni, Lahore, Pakistan.

-M.Sc. (Applied Environmental Sciences),

Punjab Uni. Lahore, Pakistan.

- Special B.Sc. Final Year thesis was completed on

Environmental Management Practices and Waste Water

Treatment Technologies.

-General Manager, APEX Environment Lab.

-Chief Engineer Monitoring, ECTECH

-Experience in Environment:

For the last over 10 years working in the field of environment

on the following subjects:

-Senior Team Member

-Project on site monitoring &

related activities.

- Co-author of the EIA report.

- Collection of demographic

data.

- Preparation of environmental

management plan.


70

- Prepared 10 EIA reports, in the field of cement, textile, oil

& gas, power generation, fertilizer, power alcohol and chemical

industry.

-Designing, fabrication, installation and operation of Waste

Water Treatment Plants; So far three plants have been

installed.

- Carrying out environmental Audit: Around 18 industrial

units have been completed so far.

- Lab. Testing of effluents and water: For the last 5 years lab.

testing services have been provided.

-Full time participation in the assignments under serial 12 –

under Dr. M. Hanif’s contributions.

Mr. Muhammad Anees. B.A; L.L.B; Expert on Environment Law

- Full time participation in the assignments under serial 12 –

under Dr. M. Hanif’s contributions (legal aspects).

Guidance on various aspects of

Environmental Law as

applicable to EIA.

Environmentalist.

Preparation of Environmental

management plan,

Mr. Muhammad Mujahid

M.Sc. (Env. Sciences), University of the Punjab, Lahore

M.Phil (Env. Sciences), University of the Punjab, Lahore

- Senior Lab. Analyst,

APEX Environment Laboratory &

Senior Monitoring Engineer

-Senior Environmentalist

ECTECH-Environment Consultants

-Environmental monitoring of over 25 projects for EIA reports

plus help in writing these reports. Also participated in

- EIA Report (According to OPIC Environmental Handbook

Format) for 10 projects.

- IEE reports of 15 projects.

On site monitoring and lab.

testing of samples and data

processing.

- Report writing.

-Preparation of environmental

management plan

- Environmental

monitoring

- Lab. Testing of

pollutants

Mr. Hasnain Sabir M. Phil Environmental Sciences

(GCU Lahore)



processing.

- Report writing.



71

management plan

Mr. Adnan Latif M.Sc. (Env. Sciences), University of the Punjab, Lahore

.-Senior Environmentalist,

APEX Environment Laboratory

-Senior Monitoring Engineer



plus help in writing these reports.

Also participated in

- EIA Report (According to OPIC

Environmental Handbook Format) for 10 projects.

- IEE reports of 20 projects.

-On site monitoring and lab.


processing.

- Report writing.


management plan

- Environmental monitoring

- Lab. Testing of pollutants

- Data processing /handling

Mr. Mudassar Adil M.Sc. Environmental Sciences

(G.C University Faisalabad)

Lab. Analyst,


Monitoring Engineer






processing.

- Report writing.


management plan

Mr. Zahir Sajjad M.Sc Environmental Sciences

(P.U Lahore)

Lab. Analyst,

APEX Environment

Laboratory

Monitoring Engineer

ECTECH-Environment

Consultants

Mr. Zohaib Ahmad M.Sc Chemistry (Analytical)

(University of Gujrat)


Monitoring Engineer




Lab. Analyst,

APEX Environment

Laboratory

Monitoring Engineer

ECTECH-Environment

Consultants

*Only the main roles of the team members are given. However, their role was not

restricted to these only; rather it also includes many other studies in their respective fields

as required by the matrix of this proposal.


11.0 TERMS OF REFERNCES FOR THE ENVIRONMENT REPORT


72

11.0 TERMS OF REFERNCES FOR THE ENVIRONMENT REPORT

Terms of reference for the synthesis of this Environmental Impact Assessment report are

attached at the ANNEXURE-V.


12- PUBLIC CONSULTATIONS (PCs)


73

12.0- PUBLIC CONSULTATIONS (PCs)

Public consultations were held collectively and individual with the people of the

project area. Even written views of the participants of the area were taken. These

are exhibited as ANNEXURE-XIII.

SUMMARY FINDINGS:

Socio-economic baseline conditions

Socio-economic status of the people of the project area are described hereunder.

The people whose interviews were record as apart of the public

consultations come mostly from the villages situated within about 5 km

radius of the project site.

Drinking water availability, educational and medical facilities in the

villages under reference of this study were adequate and good in

condition,are satisfactory..

Availability of public transport is a miss match with the requirement.

In villages major source of income is agriculture.

Fairly large number of the farmers rear buffalows and cows to sell milk as

their second source of income. In some cases this is the only source of

income for some people.

Old social order of life prevails and by and large, social harmony prevails.

Elders are very much respected and they have great say in decision

making.

Traditional type of conservative society and for those matter traditional

socio-cultural values is dominant in every walk of life. Though print and

electronic media have started bringing a change in the over all pattern of

life style.


74

Joint family system is the order of the day.

Some of the women help in some agriculture activities while others are

restricted to house keeping.

Though there is awakening about the importance of education, yet due to

insufficient number of educational institutes the percentage of school

going children is yet not up to the mark.

Majority of the old generation is uneducated. But new generation is

showing interest in getting education.

On the overall basis it is concluded that socio-economic conditions of the people

yet need drastic improvement. On the over all basis, people do face hardship

regarding basic amenities, education, health, employment and means of

communication especially transport.

Community awareness and perceptions about the project:

FFC the mother project is very much known in the area because it has

been contributing a lot for the welfare of the people of the area. Among its

major contributions include provision of Sona Hospital, Sona Public

School (English Medium School) and donation of Coronary Care Unit

Machines in District Head Quarter Hospital (DHQ).

Since the waste treatment plant is a very localized and small project,

therefore a few people closely linked with the FFC are aware of the

project. But the people have positive attitude because of its importance to

treat the sewage about which the people are well aware the pollution and

sanitation problems they face every day in their life due sewage.

Their perception is that the Fauji Fertilizer plant in the area is very

beneficial for the community and the area and the associated activity of


75

the treatment plant being installed by the company will provide them, free

of cost the sludge for their land.

They foresee positive impacts out of it, like free of cost the organic

manure in the form of sludge. This will partly substitute the costly

fertilizer they are using now.

The people perceive overall positive social impacts by the installation of

the Plant. They have positive attitude towards the project installation.

They are apprehensive of environmental aspects of the project.

At the same time they foresee that the project management will feel their, social,

moral and legal obligation and bring in Environmental Management Order

whereby the environment will not be tempered.

Social impacts:

It can be safely concluded that social and economic impacts clearly dominate the

minor few negative impacts of environment.

Positive impacts:

The conclusions of the study prove that the positive economic and social

impacts of the Plant are far too dominant.

People foresee that they will receive a fair quantity of the sludge from the

treatment plant free of cost which will partly replace the use of fertilizer so

costly.

They feel that the Plant and its related activities would provide a base for

economic benefit change.

From the above discussion, one can conclude that positive impacts including

improvement in economic factor.


76

Recommendations and mitigation measures

As result of the PCs the following recommendations are made:

The management of the Project should measure up to the positive expectations

of the people of the area and offer them maximum employment opportunities

whenever it is possible.

Environmental protection according to the legal requirements should be

ensured throughout the project operational life thus guaranteeing protection of

the environment and human health.

Sustainable development approach through conservation of natural resources

management would be the best strategy.

Implementation of the Environmental Management Plan and Environmental

Monitoring Plan, as recommended in this report, should be ensured.

Conclusions:

As a result of the PCs and the facts reported in this EIA report, it is concluded that

the Plant will not have any significant negative impacts on the people or

environment around the project area. However, the recommendations and

mitigation measures need to be fully implemented by the plant management in

their true spirit. The people welcome the project.

On the basis of the above, the project merits for grant of NOC by the EPA Sindh.

ANNEXURES

ANNEXURE-I

PAKISTAN ENVIRONMENTAL PROTECTION ACT 1997

77

78

79

80

81

82

83

84

85

86

87

88

89

90

91

92

93

94

95

96

97

98

99

100

101

ANNEXURE-II

National Environmental Quality Standards (NEQS)-Pakistan

102

103

104

105

106

107

ANNEXURE-III

National Environmental Quality Standards for Ambient Air (NEQSAA)-2010 Pakistan

108

109

110

111

112

113

ANNEXURE-IV

Letter from Sindh Irrigation & Drainage Authority

ANNEXURE-V

Guidelines for the preparation and review of Environmental Reports, October 1997/2000

115

Guidelines for the preparation and

review of Environmental

Reports

November 1997/2000

116

117

118

119

120

121

122

123

124

125

126

127

128

129

130

131

132

133

134

135

136

137

138

139

140

141

142

143

144

145

146

147

148

149

150

151

152

153

154

155

156

157

158

159

160

161

ANNEXURE-VI

The Plant Location Map

ANNEXURE-VII

The Plant Layout Map

ANNEXURE-VIII

Guidelines for self – Monitoring and Regarding by Industry (SMART) Final Report March 1998

164

165

166

167

168

169

170

171

172

173

ANNEXURE-IX

Ambient Air Gaseous Monitored Data

ANNEXURE-X

Ambient Air Particulate Matter Monitored Data

ANNEXURE-XI

Noise Levels Monitored Data

ANNEXURE-XII

Laboratory Analysis Report of Water Samples

ANNEXURE-XIII

Public Consultations (PC)

PHOTO LOGS

Different Views Around Project Site

On Site Monitoring For Baseline Data

Public Consultants