R4 v03fbe eia of cpp project bin qasim fertilizer complex-unprotected

Associated with PA Consulting Group Technical, Management, and Economic Counsel

Hagler Bailly Pakistan

Final Report – R4V03FBE

Coal Power Plant (CPP) Project Fauji Fertilizer Bin Qasim Complex

Environmental Impact Assessment

February 19, 2014

Associated with PA Consulting Group Technical, Management, and Economic Counsel

Hagler Bailly Pakistan

Coal Power Plant (CPP) Project Fauji Fertilizer Bin Qasim Complex

Environmental Impact Assessment

Final Report

HBP Ref.: R4V03FBE

February 19, 2014

Fauji Fertilizer Bin Qasim Limited (FFBL)

Bin Qasim, Karachi

EIA of CPP Project Bin Qasim Fertilizer Complex

Hagler Bailly Pakistan Executive Summary R4V03FBE: 02/19/14 ii

Executive Summary

Fauji Fertilizer Bin Qasim Limited (FFBL) is operating an Ammonia-Urea-DAP fertilizer

Complex1 in-addition to utilities and off-sites in the Eastern Industrial Zone of Port

Muhammad Bin Qasim Authority (PQA). FFBL intends to install a coal power plant

(CPP) plant (the ‗Project‘) within the existing complex of the fertilizer plant (the

‗Complex‘); a need which has arisen due to shortages in the supply of natural gas in

Pakistan. In this regard, FFBL has initiated an Environmental Impact Assessment (EIA)

to evaluate the likely environmental and socioeconomic impacts that may result from

Project activities and to recommend appropriate mitigation measures for the same. The

EIA process and the report will meet the national regulations and international

environmental guidelines.

FFBL acquired the services of Hagler Bailly Pakistan (Pvt.) Ltd. (HBP) to undertake the

EIA study. As part of the EIA process, an audit of the existing plant was conducted in

June 2013 and a field visit was undertaken by five members of the EIA team in July 2013

to investigate and collect environmental and socioeconomic baseline data.

Project Setting

The Complex lies about 45 km southeast of the city of Karachi, inside the Eastern

Industrial Zone of PQA, which is a designated industrial zone (Exhibit I and Exhibit II).

The Complex is spread across 350 acres (142 hectares) of land and borders a developed

industrial estate towards the east and south. The estate to the west of the Complex is yet

to be developed. The Complex is located at a distance of about one kilometer from the

National Highway (N5), which links Karachi to southern Sindh and the rest of the

country.

Project Outline

FFBL‘s existing fertilizer plant is operating on natural gas. The current shortfall in the

availability of natural gas in Pakistan has affected fertilizer production adversely. Under

the proposed Project, the fertilizer plant‘s steam and power generation processes will be

shifted from natural gas to a coal-based power plant. The main components of the Project

are briefly described in Exhibit III, while the layout of the existing facilities at the

Complex and the proposed site for the installation of the Project is given in Exhibit IV.

1 The existing complex has been assessed and certified to meet the requirements of IS0 14001:2004, ISO

9001:2008 and OHSAS 18001:2007. 2 Fauji Fertilizer Bin Qasim Ltd. (n.d.). Corporate History. Retrieved September 1, 2013, from FFBL:


Hagler Bailly Pakistan Executive Summary R4V03FBE: 02/19/14 iii

Exhibit I: FFBL Coal-Based Power Plant (CPP) Project Setting in Pakistan


Hagler Bailly Pakistan Executive Summary R4V03FBE: 02/19/14 iv

Exhibit II: FFBL Coal-Based Power Plant (CPP) Project Setting


Hagler Bailly Pakistan Executive Summary R4V03FBE: 02/19/14 v

Project Rationale

The establishment of the CPP project shall help reduce dependency on natural gas, which

is already short in supply in the country, and result in better operational flexibility for the

existing fertilizer complex. It will also help alleviate the power crisis in the country by

exporting electricity to the National Grid. In addition, employment will be generated with

the continuation of the existing fertilizer operation and the installation of the Project thus

contributing towards socioeconomic improvement.

Crippling natural gas shortages in Pakistan have adversely affected not only FFBL‘s

fertilizer production, but also other industries across the country as well.

By installing two coal-based CFB boilers at the existing FFBL complex, the company

will save natural gas and thus dependency on natural gas will be reduced by approx. 24%

which is beneficial not only for FFBL as well as for the country.

FFBL is the only fertilizer complex in Pakistan producing both DAP fertilizer and

Granular Urea. It makes up for about 45% of the demand for DAP and about 13% for

Urea in the domestic market.2 The quantity of fertilizer products produced by FFBL has

already been affected by the shortage of natural gas in the country and with the demand-

supply gap for gas in the country only widening in the foreseeable future. This gap will

continue further until and unless new gas reserves are made operational or gas imports

(Pak-Iran & LNG, etc) added to the country‘s supply system.

The adverse impact from natural gas shortage will be felt by all fertilizer units resulting

in a shortfall of Urea and DAP production in the country as a whole. This would place an

additional burden on the national exchequer as urea would have to be imported to meet

the shortfall in the country. The price of urea & DAP would rise as a result, affecting

agricultural production resulting in an inflationary pressure on basic food commodities.

Agricultural exports would also become more expensive and, thus, less competitive in the

international market.

Use of coal-based CFB boilers will provide operational flexibility to FFBL by leaving

them with sufficient natural gas as feedstock to maintain production. Retaining existing

facilities and expanding the FFBL complex with the new CPP project will not only help

retain current employees but also generate more employment. On the economic level,

stability in the supply of urea and DAP to the market will result in the stability of

Pakistan‘s agriculture sector. This Project will serve as a model and beacon to other

industries who are using natural gas as fuel for steam and power generation.

The Proposed Project

FFBL‘s fertilizer plant operates on natural gas, and the current shortfall in the supply of

natural gas in the country has affected the plant‘s fertilizer production adversely. Under

the CPP Project, the fertilizer plant‘s steam and power generation processes will be

shifted from natural gas to coal as fuel.

The main components of Project include:

2 Fauji Fertilizer Bin Qasim Ltd. (n.d.). Corporate History. Retrieved September 1, 2013, from FFBL:

http://www.ffbl.com/profile


Hagler Bailly Pakistan Executive Summary R4V03FBE: 02/19/14 vi

Two equal-sized circulating fluidized bed (CFB) boilers and auxiliaries

Three equal-sized condensing steam turbine generators (STGs) and auxiliaries

Steam turbine generator (STG) on 50 Hz for power export, grid interconnection

facilities and auxiliaries

Transformer unit and auxiliary transformers

Power switchyard and substation

Two weighing bridges

Coal unloading station

Coal storage yard

Coal handling system, including conveyors, junction towers, stacker-cum-

reclaimer, crushers, coal sampler, and magnetic separator

Limestone unloading, storage area, crushing hall and handling system

Fly ash handling system, including fly ash silos for each boiler

Bottom ash handling system, including bottom ash hopper, ash screw coolers and

silos for each boiler

Common stack with two inner flue gas ducts for each boiler

Emission monitoring system on each boiler flue gas duct

Induced draught cooling towers with auxiliaries, such as circulating pumps,

chemical dosing system, closed loop cooling water system and side-stream filters

Boiler feedwater (BFW) de-aeration system and auxiliaries

Elevators for boilers

Wastewater collection, recovery and disposal system

Miscellaneous buildings, such as;

CPP control room, Electrical substation and rack room

Area operator cabins

Workshop and stores

Truck parking area

Guard house and reception house at new gates

Green belt area (plantation).

The Project comprises of two subcritical CFB combustion boilers, each able to generate

up to 250 t/h of steam at 50~95 bar absolute (bar) and 463~510 oC.

The steam generated by these boilers will be used for power generation by steam turbine

generators (STGs), while part of the steam (200 t/h at normal operating conditions and

260 t/h at peak capacity) will be letdown and de-superheated to 42 bar and 380 oC,

respectively, for utilization within the existing Fertilizer Complex.


Hagler Bailly Pakistan Executive Summary R4V03FBE: 02/19/14 vii

FFBL has kept extra margin in the two coal -based CFB boilers and auxiliaries to

generate additional power of up to 70 MW at 50 Hz from the Steam Turbine Generators

for export to Pakistan National Electric Grid. The CPP will have a capacity to generate

approximately 110~120 MW of power.

The fuel resource for the new plant is sub-bituminous coal, sourced mainly from

Indonesia and South Africa. The design range for coal is provided in Exhibit III. The

coal will be received via ships of 40,000 to 60,000 deadweight tonnage (DWT) and will

be unloaded either at Karachi Port (KP) or Port Qasim (PQ). Once the Pakistan

International Bulk Terminal (PIBT) at PQ is ready, this will become the main port

receiving coal for the Project. Trucks of 55 t capacity will transport the coal from the port

to the Complex.

Exhibit III: Design Range of Coal used for the CPP Project

Coal Range

Minimum Maximum

Heating Values (at 25 °C, as received; ar)

LHV kcal/kg 3105 6927

LHV kJ/kg 13000 29000

HHV (indicative only) kJ/kg 14000 30500

Proximate Analysis (ar)

Moisture % ar 6.0 26.0

Volatile Matter % ar 18.5 40.0

Fixed Carbon % ar 19.0 60.0

Ash % ar 3.0 27.0

Ultimate Analysis (ar)

Moisture % ar 6.0 26.0

Ash % ar 3.0 27.0

Carbon % ar 36.0 80.0

Hydrogen % ar 2.0 7.0

Nitrogen % ar 0.5 2.1

Chlorine % ar 0.0 0.2

Sulfur % ar 0.2 4.0

Oxygen % ar 3.5 14.3

Fluor % ar 0.0 0.025

The Project will be equipped with the following systems and equipment to ensure

compliance with national and international environmental standards and emission limits:


Hagler Bailly Pakistan Executive Summary R4V03FBE: 02/19/14 viii

Selection of Circulating fluidized bed (CFB) boiler technology, which results in

reduced generation of NOx owing to low operating furnace temperature.

De-sulfurization with the help of sorbent (limestone) inside the CFB boilers to

capture and to prevent SOx emission

Fabric bag house filters for de-dusting of fly ash from coal combustion to prevent

particulate matter emission

Emission monitoring system at flue gas ducts of each CFB boiler outlet to

monitor NOx, SOx, PM, CO, temperature, CO2 and O2.

The quantum and type of waste water are different from the existing fertilizer complex as

there will be no process plant. Effluents will comprise of mainly cooling tower

blowdown and stormwater. There will no chemical and oily effluent under normal

operating conditions, however, provision of spill prevention, control and recovery will be

provided. Therefore, effluents from the CPP Project will result in only a slight addition to

the existing volume of effluents, mainly on account of cooling water blowdown and

stormwater (during rain).

A number of ash disposal sites are considered. FFBL plans to acquire existing industrial

scrap yards in PQA and in the vicinity of the Complex or suitable low lying areas for the

disposal of these ashes. In either case, the ash will be covered after filling to minimize

dust emissions. Other options also include an ash disposal site at Pakistan Steel Mills

(PSM) and utilization of a local electricity supply company‘s land reclamation project.

Environmental Impact of CPP Project

Air Quality Impacts

The main mode of air pollution from a thermal power plant is point emission—emissions

from the boiler and the combustion of fuel (such as coal) results in the emission of

various types of pollutants from the boiler‘s stack. The main pollutants are particulate

matter, oxides of nitrogen (NOx), and sulfur dioxide (SO2). To ensure protection of

human health, standards and limits have been prescribed by national regulatory

authorities on the maximum acceptable concentration of these pollutants in the ambient

air. The impact of the proposed project was assessed using US EPA approved ambient air

quality model in order to ensure compliance with the ambient air quality standards and

guidelines.

Applicable Standards

The primary pollutants of concern are particulate matter, oxides of nitrogen (NOx), and

sulfur dioxide (SO2). The NEQS for ambient air quality applicable to the project are

shown in Exhibit IV.


Hagler Bailly Pakistan Executive Summary R4V03FBE: 02/19/14 ix

Exhibit IV: NEQS for Ambient Air Quality for the Pollutant of Concern

Pollutants Time-weighted Average

Concentration in Ambient Air

Sulfur Dioxide (SO2)

Annual Average* 80 μg/m3

24 hours** 120 μg/m3

Oxide of Nitrogen as (NO) Annual Average* 40 μg/m3


Oxide of Nitrogen as (NO2) Annual Average* 40 μg/m3


Respirable particulate Matter. PM10 Annual Average* 120 μg/m3


Particulate Matter. PM2.5 Annual Average* 15 μg/m3


1 hour 15 μg/m3

* Annual arithmetic mean of minimum 104 instruments in a year taken twice a week 24 hourly at uniform interval

** 24 hourly /8 hourly values should be met 98% of the in a year. 2% of the time, it may exceed but not on two consecutive days.

Air Quality Model

To predict the increment of the pollutants in the ambient air due to the power

plant the United States Environmental Protection Agency‘s regulatory model

AERMOD was used. The modeling area was defined as 16 km × 16 km with the

FFBL in the center. The size of the area was defined considering the following

points in the pre-run of model. Distance from the center of FFBL at which the

pollutants concentrations become negligible

Location and distance of other sources of emissions, if any.

Location and distance of receptors

Pre-processed hourly meteorological data for the meteorological station at Karachi for the

year 2011 was purchased and used in the model.

Modeling Scenarios and Inputs Parameters

Emissions from the fertilizer plant were estimated for two scenarios as follows:

1. Existing Scenario—Total 10 stacks were assumed to be functioning in the

Existing Scenario using natural gas as fuel for the utility gas turbines (HRSG and

Auxiliary Boilers). Exhibit V lists the stacks under the Existing Scenario.


Hagler Bailly Pakistan Executive Summary R4V03FBE: 02/19/14 x

Exhibit V: Stack Identification for Existing Scenario

Sections Stack ID Ref. Number

DAP DAP Plant Stack DX-531

Urea

Granulator Scrubbers UX-670

Coolers Scrubbers UX-670

4 kg/cm2 Absorber UX-331

Low-Pressure Absorber UX-331

Ammonia

Waste Heat Recovery Boiler V-405

Reformer Furnace Stack F-101

Fired Heater Stack F-1003

Utility Gas Turbine HRSG SX-601

Auxiliary Boiler SX-601

2. CPP Scenario after conversion on coal—Total 9 stacks were assumed to be

functioning. Utility gas turbine stacks will not operate in this scenario. However,

one stack using coal as fuel will operate instead. Therefore, CPP boiler stack

using sub-bituminous coal was assumed to be operational under CPP Scenario.

Results

The predicted increments in pollutant levels are presented in Exhibit VI. To assess the

total impact of plant on the air quality in surrounding environment, background levels

were added to the incremental pollutant levels predicted by the Model. Exhibit VII

shows the comparison of results with the NEQS.

Exhibit VI: Predicted Increment to the Pollutant Levels

Pollutant Averaging Time Increase in Concentration (µg/m³)

Existing Scenario CPP Scenario

SO₂ 24-hr (98th Percentile) – 70.24

Annual – 22.70

NO₂ 24-hr (98th Percentile) 18.8 33.63

Annual 6.8 11.83

PM₁₀ 24-hr (98th Percentile) 20.06 20.41

Annual 7.62 8.03

PM2.5 1-hr (Highest) 22.6 22.6

24-hr (98th Percentile) 6.68 6.79

Annual 2.54 2.67


Hagler Bailly Pakistan Executive Summary R4V03FBE: 02/19/14 xi

Exhibit VII: Predicted Pollutant Concentrations

Pollutant Background Concentration

Levels

(µg/m³)

Averaging Time

Incremental Concentration Level

(µg/m³)

NEQS (µg/m³)

Predicted Concentration Level

(µg/m³)

Existing Scenario

CPP Scenario

Existing Scenario

CPP Scenario

SO₂ 22.8

24-hr (98th Percentile)

- 70.24 120 22.8 93.04

Annual - 22.70 80 22.8 45.5

NO₂ 13.4


18.8 33.63 80 32.2 47.03

Annual 6.8 11.83 40 20.2 25.23

PM₁₀ 97.3


20.06 20.41 150 117.4 117.7

Annual 7.62 8.03 120 104.9 105.3

PM2.5 62.7

1-hr (Max.) 22.6 22.6 15 85.3 85.3


6.68 6.79 35 69.4 69.5

Annual 2.54 2.67 15 65.2 65.4

The results of the air dispersion modeling indicate that SO2, NO2, and PM10

concentrations in the air with the CPP in operation will be compliant with national

ambient air quality standards.

The results also show that the concentrations of PM2.5 both in 24-hr (98th Percentile) and

annual periods will exceed the NEQS limit owing to prevailing concentration levels.

Background concentration of PM2.5 from natural as well as anthropogenic sources is

already well above the limits set in NEQS. The maximum increase in PM2.5

concentrations due to the Project will be less than 10% of the existing levels. In most of

the air shed it will be less than 5%. Thus the increase due to the project can be

considered insignificant. Further, the PM2.5 limit requires rationalization as it is

significantly more stringent than corresponding standards. FFBL will formally approach

SEPA to review the PM2.5 limits to rationalize them. Other potential developers of coal-

based power plants have also approached SEPA and SEPA has indicated their willingness

to undertake a review of the PM2.5 limits in view of the evidence and discussion

presented recently in another EIA.

Air Quality Impacts from Coal-Handling at the FFBL Coal Yard

Dust emissions from coal handling and storage can be significant if not controlled.

However, if standard dust control techniques are used the emissions can be reduced

significantly. The smaller the particle size of the material on the surface of a road or an

exposed surface, the more easily the particles are able to be picked up and entrained in

the wind. Moisture binds particles together preventing them from being disturbed by


Hagler Bailly Pakistan Executive Summary R4V03FBE: 02/19/14 xii

wind or vehicle movements. Each coal type and grade has a unique moisture content

above which dust emissions are substantially reduced. FFBL will install a dust

monitoring and suppression system to regulate potential dust generated at different

locations throughout the coal handling process from the point it arrives at the ports, to its

injection into the boilers.

Impacts on Water Resources

The existing urea and diammonium phosphate (DAP) manufacturing processes at the

FFBL fertilizer complex generate a variety of wastewater streams. Out of these, cooling

water blow-down (cooling water treatment program uses environmentally-friendly

chemicals), effluents from the demineralization plant and stormwater effluents are

discharged into the PQA drain outside FFBL‘s battery limits. The CPP project will result

in an addition in the volume of the cooling water blow-down generated from existing

plant operations. However, the blowdown will also be utilized for ash conditioning and

thus, effluent generation will be further curtailed. Moreover, the blowdown water shall

also be utilized for horticulture purposes thereby reducing discharge of blowdown as

effluent to the fullest. The over-all volume blowdown water will be well below the

designed cooling water blowdown volume of the existing fertilizer complex.

Prior to its discharge into the PQA drain, the wastewater, comprising mainly of cooling

tower blowdown and stormwater, will be treated in the same fashion as existing effluents

to meet the specifications of the National Environmental Quality Standards (NEQS).

According to the audit of the existing plant, the effluents discharged are within the limits

prescribed by NEQS. In some cases, the effluent levels have been reduced to a level well

below the acceptable limit.

Socioeconomic Impacts

The Project activities will result in a positive impact on the existing socioeconomic

environment of the area covered in the socioeconomic study. The study area (the ―CPP

Site Surroundings‖) is located within a 5 km radius with the Complex at the center. The

positive socioeconomic impacts of the Project include:

Positive impact to Pakistan‘s economy due to restoration of production capacity;

Generation of employment opportunities during Project construction and

operations.

Environmental Management Plan

A comprehensive environmental management and monitoring plan has been developed.

It includes the following:

1. Identification of institutional responsibilities

2. Institutional strengthening and capacity building of FFBL

3. Reporting and feedback mechanism

4. Performance indicators

5. Environmental Mitigation Plan

6. EMP for Waste Management


Hagler Bailly Pakistan Executive Summary R4V03FBE: 02/19/14 xiii

7. Environmental Monitoring Plan

8. Construction Management plan

9. Coal dust management plan

10. Ash management plan

11. Social augmentation plan

12. Grievance redress mechanism

13. Air quality monitoring program

Conclusions

The proposed CPP project entails construction of new coal-based boilers and steam

turbine generators (STGs) to replace existing natural gas-based boilers and gas turbines.

The findings of the study indicate that the CPP project will have positive impacts on the

socioeconomic environment through direct and in-direct employment generation; and,

increased business opportunities. The continuation of existing fertilizer plant operation

using coal-based power will be beneficial to the company through stability of production,

and, to the country as a whole through the reduction in dependence on dwindling natural

gas supply as fuel and stability of the agricultural sector of the economy through

consistent supply of fertilizers at affordable rates.

Among the potential negative impacts of the Project, the main concern is the possible

deterioration of air quality around the CPP project area. However, FFBL has undertaken

a number of design measures to ensure that gaseous emissions from the Project are in line

and well within the levels prescribed by NEQS and IFC guidelines.

The results of the air dispersion modeling in Section 9.4.2 indicate that SO2, NO2, and

PM10 concentrations in the air with the CPP in operation will be compliant with national

ambient air quality standards as well as IFC guidelines.


annual periods will exceed the NEQS limit. As discussed in Section 5.1.3, background

concentration of PM2.5 from natural as well as anthropogenic sources is already well

above the limits set in NEQS. The maximum increase in PM2.5 concentrations due to the

Project will be less than 10% of the existing levels. In most of the air shed it will be less

than 5%. Thus the increase due to the project can be considered insignificant. Further,

the PM2.5 limit requires rationalization as it is significantly more stringent than

corresponding standards. FFBL will formally approach SEPA to review the PM2.5 limits

to rationalize them. Other potential developers of coal-based power plants have also

approached SEPA and SEPA has indicated their willingness to undertake a review of the

PM2.5 limits in view of the evidence and discussion presented recently in another EIA.


FFBL fertilizer complex generate a variety of wastewater streams as stated in

Section 3.2.8. There are two disposal options for the plant effluents. All chemical

effluents are directed to an evaporation pond. Whereas benign effluents such as cooling

water blow-down, effluents from the demineralization plant and stormwater effluents are


Hagler Bailly Pakistan Executive Summary R4V03FBE: 02/19/14 xiv

combined and discharged into the PQA drain outside FFBL‘s battery limits. The effluents

discharged into the PQA drain are within the limits prescribed by NEQS.

The same disposal scheme will be followed for the effluent generated by the CPP project.

The three wastewater streams from the existing plant operations that are being discharged

into the PQA drain are from the:

Cooling water blow–down, at a rate of 2,200 m3/day;

Demineralization wastewater (after neutralization), at a rate of 216 m3/day, and;

Stormwater runoff.

In the existing Complex, the designed discharge of cooling tower blowdown was

7,776 m3/day. However, due to water conservation measures such as increasing cooling

water cycles in the existing cooling tower and use of blowdown water for horticulture

purposes, the existing blowdown discharge rate into the PQA drain is around

2,200 m3/day.

Without adding a new wastewater stream, the CPP project will generate about 70 m3/hr

only or 1,680 m3/day, of cooling tower blowdown which will, partly, be used for ash

conditioning as well as for horticulture. Therefore, the net effect from the blowdown

water from the CPP project will be an additional 1,200 m3/day to the existing cooling

water blowdown. Therefore, coupled with the demin wastewater, a total of 3,616 m3/day

of effluent will be discharged into the PQA drain once the Project becomes operational.

The effluent will ultimately discharge into the sea though a dedicated PQA drain.

Presently the effluent is discharged into the PQA drain flows into the Ghaghar Nullah, a

natural rain water course, from where the effluents end up in the sea. FFBL will

collaborate with PQA to prevent access of the people of the surrounding communities to

the Ghaghar Nullah by putting up notice boards and initiating an awareness campaign.

Moreover, the PQA has planned the installation of an industrial sewage treatment plant

which will treat the waste generated by the industries in the PQA to further reduce the

pollutant levels in the effluent.

In view of the above and assuming effective implementation of the mitigation measures

and monitoring requirements as outlined in the Environmental Management Plan (EMP)

(Appendix E), it can be concluded that the proposed CPP project—with 2 × 250 t/h CFB

boilers, 3 × 16 MW (based on 60 Hz) Steam Turbine Generators (STGs), STG for power

export of up to 70 MW) along with auxiliaries to be installed within the existing FFBL

complex—will comply with all the Pakistan regulatory requirements with the exception

of ambient air quality standards PM2.5. It has been recognized that national standards for

ambient air quality will require revision. This issue has been discussed with the Sindh

Environmental Protection Agency and they have expressed willingness to review the

standards.


Hagler Bailly Pakistan Contents R4V03FBE: 02/19/14 xv

Contents

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

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

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

1.3 Statement of Need .................................................................................... 1-7

1.4 Introduction to the EIA ............................................................................. 1-7

1.4.1 Objectives of the EIA ........................................................................ 1-8

1.4.2 Scope of the EIA .............................................................................. 1-8

1.5 Approach and Methodology .................................................................... 1-9

1.6 Regulatory Requirements ...................................................................... 1-10

1.7 Report Organization ............................................................................... 1-11

2. Legal and Institutional Framework ................................................ 2-1

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

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

2.1.2 Pakistan Environmental Protection Act, 1997 ................................... 2-2

2.1.3 Rules and Regulations under Pakistan Environmental Protection Act, 1997 ................................................................................................. 2-3

2.1.4 Other Relevant Laws ........................................................................ 2-5

2.2 Environmental Guidelines ....................................................................... 2-7

2.2.1 Sectoral Guidelines for Environmental Reports—Major Chemical and Manufacturing Plants, 1997 .............................................................. 2-7

2.2.2 Environmental Assessment Procedures, 1997 ................................. 2-7

2.2.3 World Bank/IFC Environmental Guidelines ....................................... 2-8

2.3 Institutional Framework ........................................................................... 2-8

2.4 Applicable Standards and Target Limits ................................................ 2-9

3. The Existing FFBL Fertilizer Plant ................................................. 3-1

3.1 FFBL Setting ............................................................................................. 3-2

3.2 Salient Features of the Existing FFBL Fertilizer Complex ..................... 3-5

3.2.1 Description ....................................................................................... 3-5

3.2.2 Plant Capacity .................................................................................. 3-5

3.2.3 Process Details ................................................................................ 3-5

3.2.4 Raw Materials .................................................................................. 3-9

3.2.5 Power Generation .......................................................................... 3-10

3.2.6 Water Requirements ...................................................................... 3-10


Hagler Bailly Pakistan Contents R4V03FBE: 02/19/14 xvi

3.2.7 Solid Wastes .................................................................................. 3-12

3.2.8 Liquid Effluents ............................................................................... 3-13

3.2.9 Tank Farm Area Effluents ............................................................... 3-19

3.2.10 Gaseous Emissions ........................................................................ 3-22

3.3 Assessment of the Existing FFBL Plant ............................................... 3-28

3.3.1 Data on Gaseous Emissions .......................................................... 3-28

3.3.2 Data of Effluents ............................................................................. 3-28

3.3.3 Summary of the Results ................................................................. 3-29

4. The Proposed CPP Project ............................................................. 4-1

4.1 Coal–Based Circulating Fluidized Bed (CFB) Boiler .............................. 4-7

4.2 Fuel Firing System ................................................................................... 4-8

4.3 Air and Flue Gas System ......................................................................... 4-9

4.4 Water Steam Cycle ................................................................................. 4-10

4.5 Dedusting ................................................................................................ 4-10

4.6 Stack ....................................................................................................... 4-12

4.7 Steam Turbine Generators (STGs) ........................................................ 4-12

4.8 Coal Handling and Storage .................................................................... 4-12

4.8.1 Stockpile ........................................................................................ 4-13

4.8.2 Stacker ........................................................................................... 4-14

4.8.3 Reclaimer ....................................................................................... 4-14

4.8.4 Coal Handling from Coal Yard to Boiler Bunkers ............................ 4-14

4.8.5 Fugitive Dust Suppression and Prevention of Spontaneous Combustion .................................................................................... 4-14

4.8.6 Coal Transportation from Ports to FFBL Plant Site ......................... 4-14

4.9 Limestone ............................................................................................... 4-15

4.10 Gaseous Emissions and Control ........................................................... 4-17

4.11 Wastewater Handling, Recovery and Disposal .................................... 4-18

4.11.1 Effluents Containing High Suspended Solids Content .................... 4-18

4.11.2 Chemically Contaminated Effluents ................................................ 4-18

4.11.3 Water Steam Cycle Effluents .......................................................... 4-18

4.11.4 Sanitary Wastewater ...................................................................... 4-19

4.12 Ash Production and Disposal ................................................................ 4-19

4.12.1 Bottom Ash ..................................................................................... 4-19

4.12.2 Fly Ash ........................................................................................... 4-19

4.12.3 Dumper Trucks ............................................................................... 4-20

4.12.4 Ash Disposal Site ........................................................................... 4-20

4.13 Emergency Diesel Generator ................................................................. 4-20

4.14 Fuel and Utilities Consumption ............................................................. 4-20


Hagler Bailly Pakistan Contents R4V03FBE: 02/19/14 xvii

4.15 Cooling Water System ........................................................................... 4-21

4.15.1 Recirculating Cooling Water Induced Draft Cooling Tower ............. 4-21

4.15.2 Closed Cooling System .................................................................. 4-22

4.15.3 Auxiliary Cooling System ................................................................ 4-22

4.16 Electrical System .................................................................................... 4-22

4.17 Firefighting and Explosion Protection .................................................. 4-25

4.18 Firefighting System ................................................................................ 4-26

4.19 Explosion Protection .............................................................................. 4-28

5. Description of the Environment ..................................................... 5-1

5.1 Physical Environment Baseline ............................................................... 5-1

5.1.1 Topography and Landuse ................................................................. 5-1

5.1.2 Climate ............................................................................................. 5-3

5.1.3 Air Quality......................................................................................... 5-6

5.1.4 Water Resources ............................................................................ 5-12

5.1.5 Traffic ............................................................................................. 5-20

5.1.6 Noise Survey .................................................................................. 5-32

5.2 Ecological Baseline ................................................................................ 5-37

5.2.1 Scope ............................................................................................. 5-37

5.2.2 Sampling Plan and Methodology .................................................... 5-37

5.2.3 Results and Discussions ................................................................ 5-43

5.2.4 Conclusions .................................................................................... 5-51

5.3 Socioeconomic Environment ................................................................ 5-51

5.3.1 Scoping .......................................................................................... 5-51

5.3.2 Socioeconomic Baseline Survey .................................................... 5-55

5.3.3 FFBL Site Surroundings ................................................................. 5-57

5.3.4 Ash Disposal Sites ......................................................................... 5-63

5.3.5 Transport Corridor .......................................................................... 5-67

6. Stakeholder Consultations ............................................................. 6-1

6.1 National Regulations and International Standards for Stakeholder Consultations ........................................................................................... 6-1

6.1.1 Pakistan Environmental Law ............................................................ 6-2

6.1.2 International Standards .................................................................... 6-3

6.1.3 Good Practice Principles .................................................................. 6-3

6.2 Stakeholder Identification and Analysis ................................................. 6-4

6.3 Consultation Methodology ...................................................................... 6-5

6.3.1 Consultation Material ........................................................................ 6-5

6.3.2 Community Consultation Mechanism ............................................... 6-5

6.3.3 Institutional Consultation Mechanism ............................................... 6-8


Hagler Bailly Pakistan Contents R4V03FBE: 02/19/14 xviii

6.3.4 Documentation and Reporting ........................................................ 6-12

6.4 Summary of Concerns ........................................................................... 6-12

7. Environmental Screening ............................................................... 7-1

7.1 Screening Methodology ........................................................................... 7-1

7.2 Development of Screening Matrix ........................................................... 7-2

7.3 Summary of Project Impacts ................................................................... 7-2

8. Analysis of Alternatives .................................................................. 8-1

8.1 No Project Alternative .............................................................................. 8-1

8.2 Site Selection for CPP .............................................................................. 8-3

8.3 Selection of Coal-type for the Project ..................................................... 8-3

8.4 Transportation of Coal to Project Site .................................................... 8-4

8.5 Boiler Technology .................................................................................... 8-8

8.5.1 Pulverized Coal-based Boilers .......................................................... 8-8

8.5.2 Circulating Fluidized Bed Combustion ............................................ 8-10

8.5.3 Proposed Technology for Boiler Combustion .................................. 8-11

8.6 Particulate Matter Emission Controls ................................................... 8-12

8.7 SO2 Treatment Options .......................................................................... 8-16

8.8 NOx Treatment Options .......................................................................... 8-17

8.9 Ash Handling and Disposal ................................................................... 8-20

8.9.1 Ash Recycling Options ................................................................... 8-20

8.9.2 Ash Disposal Site Options .............................................................. 8-22

9. Project Impacts and Mitigation ...................................................... 9-1

9.1 Impact Assessment Methodology ........................................................... 9-1

9.2 Identification of Potential Environmental Impacts ................................. 9-2

9.3 Construction Phase .................................................................................. 9-7

9.3.1 Drainage and Stormwater Run–off ................................................... 9-8

9.3.2 Disposal of Waste ............................................................................ 9-9

9.3.3 Soil and Water Impact ...................................................................... 9-9

9.3.4 Contamination Prevention ................................................................ 9-9

9.4 Operation Phase ..................................................................................... 9-11

9.4.1 Impacts on Water Resources ......................................................... 9-11

9.4.2 Impacts on Air Quality .................................................................... 9-15

9.4.3 Air Quality Impacts from Coal–Handling at the FFBL Coal Yard ..... 9-28

9.4.4 Ash Disposal and Management ...................................................... 9-32

9.4.5 Port Impacts ................................................................................... 9-33


Hagler Bailly Pakistan Contents R4V03FBE: 02/19/14 xix

9.5 Ecological Impacts ................................................................................. 9-34

9.5.1 Waste from Project Construction and Operations ........................... 9-34

9.6 Socioeconomic Impacts ......................................................................... 9-35

9.6.1 Positive Economic Impact of CPP Project ...................................... 9-35

9.6.2 Employment Opportunities ............................................................. 9-36

9.6.3 Traffic Impacts ................................................................................ 9-37

10. Conclusion ..................................................................................... 10-1

Appendices:

Appendix A: National Environmental Quality Standards and International Finance Corporation Guidelines

Appendix B: Socioeconomic Survey Form

Appendix C: Background Information Document

Appendix D: Institutional Stakeholder Attendance Record

Appendix E: Environmental Management Plan


Hagler Bailly Pakistan Exhibits R4V03FBE: 02/19/14 xx

Exhibits

Exhibit 1.1: FFBL Coal-Based Power Plant (CPP) Project Setting in Pakistan ........ 1-2

Exhibit 1.2: FFBL Coal-Based Power Plant (CPP) Project Setting ........................... 1-3

Exhibit 1.3: Brief Description of Main CPP Project Components .............................. 1-4

Exhibit 1.4: Layout of the Existing and Proposed Facilities at FFBL Fertilizer Plant Complex ........................................................................ 1-6

Exhibit 2.1: EIA Review and Approval Procedure .................................................... 2-4

Exhibit 2.2: Comparison of NEQS and IFC Guideline Limits for Emission of Key Pollutants from Coal-Based Power Plant ................ 2-10

Exhibit 2.3: Comparison of NEQS and IFC Guideline Limits for Ambient Air Quality ............................................................................. 2-10

Exhibit 2.4: Comparison of NEQS and IFC Guideline Limits for Key Liquid Effluents (mg/l, unless otherwise defined) ......................... 2-11

Exhibit 3.1: Components of the Existing Plant to be Replaced, Modified or Retained, and Main Components of the CPP Project ......... 3-1

Exhibit 3.2: Setting for the CPP Project and Existing FFBL Plant Site ..................... 3-3

Exhibit 3.3: FFBL Fertlizer Complex Location .......................................................... 3-4

Exhibit 3.4: Site Layout of Existing FFBL Plant and Proposed CPP Project ............ 3-7

Exhibit 3.5: Detailed Layout of Existing FFBL Plant and Proposed CPP Project ...... 3-8

Exhibit 3.6: Wastewater Sources, Designed Flows and Treatment of Effluents Discharged into the PQA Industrial Drain ......................... 3-13

Exhibit 3.7: Wastewater Sources, Flows and Treatment of Effluents Discharged into the Evaporation Pond ................................................ 3-14

Exhibit 3.8: Design Cooling Tower Blowdown Analysis ......................................... 3-15

Exhibit 3.9: Design Specifications of Demineralization System Effluents ............... 3-15

Exhibit 3.10: Design Characteristic of Demineralization Effluents Composition after Neutralization ......................................................... 3-17

Exhibit 3.11: Design Discharge Characteristics from Chemical Sewer to Evaporation Pond after Treatment ...................................................... 3-18

Exhibit 3.12: The PQA Drain at the Northeast Corner of the FFBL Complex ........... 3-21

Exhibit 3.13: Photographs of the PQA Drain Channel ............................................. 3-22

Exhibit 3.14: Characteristics of Emissions from Gas Turbine .................................. 3-24

Exhibit 3.15: Characteristics of Emissions from Heat Recovery Steam Generator .. 3-24


Hagler Bailly Pakistan Exhibits R4V03FBE: 02/19/14 xxi

Exhibit 3.16: Characteristics of Emissions from Auxiliary Boiler............................... 3-25

Exhibit 3.17: Characteristics of Emissions from Primary Reformer Furnace (Ammonia Plant) ................................................................... 3-25

Exhibit 3.18: Characteristics of Emissions from Waste Heat Recovery Boiler (Ammonia Plant) ....................................................... 3-26

Exhibit 3.19: Characteristics of Emissions from Scrubbers (Urea Plant) .................. 3-26

Exhibit 3.20: Characteristics of Emissions from DAP Plant ...................................... 3-27

Exhibit 3.21: Summary of FFBL‘s Gaseous Emission Compliance with NEQS and EFMA / Plant Design Limits .............................................. 3-30

Exhibit 3.22: Summary of FFBL‘s Effluent Compliance with NEQS and EFMA / Plant Design Limits ................................................................ 3-31

Exhibit 4.1: Layout of the CPP Project ..................................................................... 4-3

Exhibit 4.2: Brief Description of Main Components of the Project ............................ 4-4

Exhibit 4.3: Project Setting Showing Coal Transport Routes and Ash Disposal Sites ................................................................................ 4-6

Exhibit 4.4: Major Components of the Circulating Fluidized Bed Boiler .................... 4-8

Exhibit 4.5: An Illustration of the Bag House with Fabric Filters ............................. 4-11

Exhibit 4.6: Main Components of the Bag House .................................................. 4-11

Exhibit 4.7: Design Range of Coal used for the CPP Project ................................. 4-13

Exhibit 4.8: Limestone Handling System for the CPP Project ................................ 4-16

Exhibit 4.9: Stacks in the Existing FFBL Complex ................................................. 4-17

Exhibit 4.10: Design Flow Rates of NOx, SOx, PM10 and PM2.5 for FFBL Plant with CPP Project. ............................................................. 4-17

Exhibit 4.11: Estimated Daily and Yearly Quantities of Fly Ash and Bottom Ash Produced by the CPP Project from 2 CFB Boilers based on 330 days of operation (Design/Reference coal) ................... 4-19

Exhibit 4.12: Consumption of Fuel (Design Coal) for 2 boilers and Utilities by the CPP Project ............................................................................. 4-21

Exhibit 4.13: Expected Water Consumption at the CPP Project .............................. 4-21

Exhibit 4.14: Proposed Site for FFBL Grid Station ................................................... 4-24

Exhibit 4.15: Distance from the Grid to the Electricity Towers ................................. 4-25

Exhibit 5.1: Industries Located in the Vicinity of the FFBL Plant .............................. 5-2

Exhibit 5.2: Seasonal Characteristics of the Climate of Karachi ............................... 5-3

Exhibit 5.3: Average Temperatures (oC) of Karachi Airport Meteorological Station .. 5-4

Exhibit 5.4: Rainfall measured at Karachi Airport Meteorological Station ................. 5-5


Hagler Bailly Pakistan Exhibits R4V03FBE: 02/19/14 xxii

Exhibit 5.5: Mean Wind in the Study Area ............................................................... 5-5

Exhibit 5.6: Major Sources of Air Emissions in the Industrial Set-up around Plant Site .................................................................................. 5-6

Exhibit 5.7: Description of Ambient Air Quality Sampling Sites ................................ 5-7

Exhibit 5.8: Location of the Ambient Air Quality Sampling Sites .............................. 5-8

Exhibit 5.9: Details of Ambient Air Quality Sampling Parameters and Equipment .... 5-9

Exhibit 5.10: Deployment Photographs of Equipment for Testing Air Quality ........... 5-10

Exhibit 5.11: Ambient Air Quality Results in the Study Area .................................... 5-11

Exhibit 5.12: Coordinates of Water Sampling Sites ................................................. 5-13

Exhibit 5.13: Water Sampling Locations .................................................................. 5-14

Exhibit 5.14: A Compilation of Results for Water Samples from the Project Area .... 5-15

Exhibit 5.15: The PQA Drain at the Northeast Corner of the FFBL Complex ........... 5-18

Exhibit 5.16: Photographs of the PQA Drain Channel ............................................. 5-19

Exhibit 5.17: Summary of Traffic Survey Details ...................................................... 5-20

Exhibit 5.18: Location of the Traffic Survey Points................................................... 5-21

Exhibit 5.19: Vehicle Classification .......................................................................... 5-22

Exhibit 5.20: Traffic Survey Locations T1 & T4 in Main Landhi Industrial Area Road and T3 in Sunset Boulevard, DHA Phase II. ..................... 5-24

Exhibit 5.21: 1-Hour Traffic Count from 2100 – 2200 Hours at Sampling Point T1- Main Landhi Industrial Area Road, on the 26th July 2013 .... 5-25

Exhibit 5.22: Hourly Traffic Count for 24 Hours from 0900 hours at T4 – Main Landhi Industrial Area Road, on the 29th July 2013 ........... 5-25

Exhibit 5.23: Traffic Survey T2 at Salar Khan Jokio Road and N5 near Ash Disposal Site ‗Option 3‘ ................................................................ 5-29

Exhibit 5.24: A Truck on the Single-lane, Blacktop, Salar Khan Jokio Road ............ 5-30

Exhibit 5.25: 1.5-Hour Traffic Count from 1000 – 1130 hours at S ampling Point T2- Salar Khan Jokio Road. ......................................... 5-30

Exhibit 5.26: Night-Time Hourly Traffic Count for 8 Hours from 2300 to 0700 at T3 – Sunset Boulevard, on the 30th July 2013. ......... 5-31

Exhibit 5.27: Summary of Noise Survey Locations and Durations ........................... 5-32

Exhibit 5.28: Location of the Noise Survey Points ................................................... 5-33

Exhibit 5.29: Noise Survey at N1 – Main Landhi Industrial Area Road, and N2 – Sunset Boulevard, Defence Phase 2. .................................. 5-35

Exhibit 5.30: Summary of the Noise Survey ............................................................ 5-36

Exhibit 5.31: Chart Displaying LAeq and LAF Sound Measurements at Noise Survey Location N1 .................................................................. 5-36

Exhibit 5.32: Chart Displaying LAeq and LAF Sound Measurements at Noise Survey Location N2 .................................................................. 5-37


Hagler Bailly Pakistan Exhibits R4V03FBE: 02/19/14 xxiii

Exhibit 5.33: Coordinates of Ecological Sampling Locations ................................... 5-38

Exhibit 5.34: Map of Ecological Sampling Locations in Project area and Vicinity ..... 5-39

Exhibit 5.35: Description of Sampling Stations at Sampling Point E4 ...................... 5-41

Exhibit 5.36: Map showing Sampling Stations at Sampling Point E-4 ...................... 5-42

Exhibit 5.37: Mangrove Vegetation at Low Tide, and Domestic Camels Feeding in the Study Area .................................................................. 5-43

Exhibit 5.38: Male and Female Uca Spp (fiddler Crab) ............................................ 5-44

Exhibit 5.39: Borrowing habitat of Boleophthalmus (mud skipper) spp .................... 5-44

Exhibit 5.40: Species Distribution Pattern of the Marine Invertebrate Taxa, Surveys Conducted in July 2013. ........................................................ 5-45

Exhibit 5.41: Shannon Weiner Biodiversity Index at Sampling Point E-4 ................. 5-46

Exhibit 5.42: Local fisherman netting fish, coastal fish Mugil cephalus (Boi) ............ 5-46

Exhibit 5.43: Signs of Jackal at Sampling Point E-6 ................................................ 5-47

Exhibit 5.44: Asian Migratory Bird Flyways .............................................................. 5-49

Exhibit 5.45: Diversity of Bird Fauna at Korangi/Phitti Creek System ...................... 5-50

Exhibit 5.46: Scoping Exercise for the EIA‘s Socioeconomic Component ................ 5-52

Exhibit 5.47: Project Setting .................................................................................... 5-54

Exhibit 5.48: List of Surveyed Settlements .............................................................. 5-55

Exhibit 5.49: Location of Surveyed Settlements ...................................................... 5-56

Exhibit 5.50: Demographic Profile of the CPP Site Surroundings ............................ 5-57

Exhibit 5.51: Housing Structures in the Study Area ................................................. 5-59

Exhibit 5.52: View of Shops in the Study Area ......................................................... 5-59

Exhibit 5.53: View of Mosques in the Study Area .................................................... 5-60

Exhibit 5.54: Water Supply and Storage Sources in the Study Area ........................ 5-61

Exhibit 5.55: Education Institutions in the Study Area .............................................. 5-62

Exhibit 5.56: Ash Disposal Site Options .................................................................. 5-64

Exhibit 5.57: Photographs of Ash Disposal Site - Option 2 ...................................... 5-65



Exhibit 5.60: List of Interviewed Locations ............................................................... 5-69

Exhibit 5.61: Interview Locations along the Coal Transport Corridor from FFBL to KPT ............................................................................... 5-70

Exhibit 6.1: Project Stakeholders ............................................................................. 6-5

Exhibit 6.2: List of Communities Consulted ............................................................. 6-6


Hagler Bailly Pakistan Exhibits R4V03FBE: 02/19/14 xxiv

Exhibit 6.3: Locations of Community Stakeholder Consultations ............................. 6-7

Exhibit 6.4: Photographs of the Community Consultations ...................................... 6-8

Exhibit 6.5: List of Institutional Stakeholders ........................................................... 6-9

Exhibit 6.6: Map of Institutional Stakeholder Locations .......................................... 6-11

Exhibit 6.7: Photographs of the Institutional Consultations .................................... 6-12

Exhibit 6.8: Summary of Concerns and Relevant Measures .................................. 6-13

Exhibit 6.9: Detailed Log of the Consultations ....................................................... 6-21

Exhibit 7.1: Environmental Screening Matrix ........................................................... 7-5

Exhibit 8.1: A Comparison of the Quality of Thar Lignite with I mported Bituminous Coal ...................................................................... 8-4

Exhibit 8.2: Comparisons of Coal Properties ........................................................... 8-4

Exhibit 8.3: Route Options ....................................................................................... 8-6

Exhibit 8.4: CPP Project Setting illustrating Coal Transport Route Options from the Ports to FFBL Plant ................................................................ 8-7

Exhibit 8.5: Type of PF Firing System ..................................................................... 8-9

Exhibit 8.6: Classification of Pulverized Coal plants ................................................ 8-9

Exhibit 8.7: Technical and Economic Status of Coal Combustion Technologies .... 8-12

Exhibit 8.8: Particulate matter control technologies ............................................... 8-13

Exhibit 8.9: NOx Control Options for Coal-Based Boilers ....................................... 8-18

Exhibit 8.10: Estimated Daily and Yearly Quantities of Fly Ash and Bottom Ash Produced by the CPP Project ............................................................. 8-22

Exhibit 8.11: Location of Cement Plant Accessible to FFBL .................................... 8-23

Exhibit 8.12: Ash Disposal Site Options .................................................................. 8-24


Exhibit 8.14: Photographs of Ash Disposal Site – Option 3 ..................................... 8-25


Exhibit 9.1: Screening of Environmental and Social Impacts of the Proposed Activities ............................................................................... 9-3

Exhibit 9.2: NEQS for Ambient Air Quality for the Pollutant of Concern ................. 9-15

Exhibit 9.3: Stack Identification for Existing Scenario ............................................ 9-16

Exhibit 9.4: Common Model Inputs for Stack under All Scenarios ......................... 9-17

Exhibit 9.5: Scenario Based Model Inputs for Stacks ............................................ 9-17

Exhibit 9.6: Pollutant Flow Rates Assumed for Modeling ....................................... 9-17


Hagler Bailly Pakistan Exhibits R4V03FBE: 02/19/14 xxv

Exhibit 9.7: Predicted Increment to the Pollutant Levels ........................................ 9-19

Exhibit 9.8: Predicted Increment to the Annual NOX Levels (µg/Nm3) .................... 9-20

Exhibit 9.9: Predicted Increment to the Annual PM10 Levels (µg/Nm3) ................... 9-21

Exhibit 9.10: Predicted Increment to the Annual PM2.5 Levels (µg/Nm3) .................. 9-22

Exhibit 9.11: Predicted Increment to the Annual SOx Levels (µg/Nm3) .................... 9-23

Exhibit 9.12: Predicted Increment to the Annual NOx Levels (µg/Nm3) .................... 9-24

Exhibit 9.13: Predicted Increment to the Annual PM10 Levels (µg/Nm3) ................... 9-25

Exhibit 9.14: Predicted Increment to the Annual PM2.5 Levels (µg/Nm3) .................. 9-26

Exhibit 9.15: Predicted Pollutant Concentrations ..................................................... 9-27


Hagler Bailly Pakistan Introduction

R4V03FBE: 02/19/14 1-1

1. Introduction

Fauji Fertilizer Bin Qasim Limited (FFBL) is operating an Ammonia-Urea-DAP fertilizer

Complex in-addition to utilities and off-sites in the Eastern Industrial Zone of Port

Muhammad Bin Qasim Authority (PQA). FFBL intends to install a coal power plant

(CPP) (the ‗Project‘) within the existing complex of the fertilizer plant (the ‗Complex‘); a

need which has arisen due to shortages in the supply of natural gas in Pakistan. In this

regard, FFBL has initiated an Environmental Impact Assessment (EIA) to evaluate the

likely environmental and socioeconomic impacts that may result from Project activities

and to recommend appropriate mitigation measures for the same. The EIA process and

the report will meet the national regulations and international environmental guidelines.

FFBL acquired the services of Hagler Bailly Pakistan (Pvt.) Ltd. (HBP) to undertake the

EIA study. As part of the EIA process, an audit of the existing plant was conducted in

June 2013 and a field visit was undertaken by five members of the EIA team in July 2013

to investigate and collect environmental and socioeconomic baseline data.

1.1 Project Setting

The Complex lies about 45 km southeast of the city of Karachi, inside the Eastern

Industrial Zone of PQA, which is a designated industrial zone (Exhibit 1.1 and

Exhibit 1.2). The Complex is spread across 350 acres (142 hectares) of land and borders

a developed industrial estate towards the east and south. The estate to the west of the

Complex is yet to be developed. The Complex is located at a distance of about one

kilometer from the National Highway (N5), which links Karachi to southern Sindh and

the rest of the country.

1.2 Project Outline

FFBL‘s existing fertilizer plant is operating on natural gas. The current shortfall in the

availability of natural gas in Pakistan has affected fertilizer production adversely. Under

the proposed Project, the fertilizer plant‘s steam and power generation processes will be

shifted from natural gas to a coal-based power plant. The main components of the Project

are briefly described in Exhibit 1.3, while the layout of the existing facilities at the

Complex and the proposed site for the installation of the Project is given in Exhibit 1.4.


Hagler Bailly Pakistan Introduction R4V03FBE: 02/19/14 1-2

Exhibit 1.1: FFBL Coal-Based Power Plant (CPP) Project Setting in Pakistan



Exhibit 1.2: FFBL Coal-Based Power Plant (CPP) Project Setting



Exhibit 1.3: Brief Description of Main CPP Project Components

Component Description

Site preparation The existing gas fired boilers and power system will remain in their original place and, therefore, no major decommissioning will be required. New facilities will be installed on an empty open space availaible in the existing fertilizer complex for which the site will be prepared as follows

Clearing of area;

Excavation, filling and leveling of the site; and

Development of sediment control measures

New facilities FFBL plans to install new coal power plant at an empty space situated within the existing fertilizer complex. The Project consists of two equal capacity circulating fluidized bed (CFB) boiler units, each of 250 Met/hr. Out of the 500 Met/hr of steam produced by the two boilers, about 140 Mett/hr will be used to operate three steam turbine generators each with a capacity of 16 MWe. Power produced by these will be sent to the existing 13.8 kV grid inside the FFBL Complex to supply power to the existing fertilizer plant which operates at 60 Hz and is not connected to the national grid connection. About 200 Met/hr of steam during normal operation will be used as process steam for the manufacture of fertilizer.

FFBL has kept extra margin in the two coal based CFB boilers and auxiliaries capacities to generate additional power at 50 Hz from dedicated Steam Turbine Generator for export to Pakistan National Electric Grid.

Coal storage facilities at the port(s)

Coal will be transported, initially, from Karachi Port using existing port facilities and eventually from Port Qasim. No new waterfront facility or expansion of the existing coal yard will be required at Karachi Port. Pakistan International Bulk Terminal Limited (PIBT) is already in the process of developing a coal, clinker and cement terminal at Port Qasim which will also handle FFBL‘s coal supply, along with that for other customers..

Transportation and storage of coal

From the two Karachi ports, the coal will be transported to the Project site via trucks. It will then be stacked in a dedicated coal yard, to be set up within the CPP project site, from where it will be reclaimed and used as fuel in the CFB boilers.

Ash disposal Two distinct types of ash are generated during combustion of coal in a CFB boiler: bottom ash and fly ash. Bottom ash consists of larger particles that exit the bottom of the boiler, while fly ash consists of finer particles that exit the boiler with the flue gas and are recovered in the de-dusting process. FFBL plans to acquire suitable low lying areas for the disposal of these ashes, which will be covered properly after filling to minimize dust generation. The options for ash disposal sites include vacant plots within Pakistan Steel Mills‘ existing scrap and slag yard, a vacant soil excavation site, and an empty plot of land east of the Complex. Utilization of the ash in local cement and concrete brick manufacturing plants will also be considered. In addition to these options, following the practice in vogue internationally, CFB ashes can be considered for other applications with less stringent specifications, which include soil stabilization, road base and structural fills.




Emission Control

The Project will be equipped with the following systems and equipment to ensure compliance with national and international environmental standards and emission limits:

Selection of Circulating fluidized bed (CFB) boiler technology, which results in reduced generation of NOx owing to low operating furnace temperature.

De-sulfurization with the help of sorbent (limestone) inside the CFB boilers to capture and to prevent SOx emission

Fabric bag house filters for de-dusting of fly ash from coal combustion to prevent particulate matter emission

Emission monitoring system at flue gas ducts of each CFB boiler outlet to monitor NOx, SOx, PM, CO, temperature, CO2 and O2.

Effluents The over-all volume of effluents outside FFBL complex battery limit will increase slightly when the CPP project becomes operational mainly on account of stormwater (only during rainfall) and cooling tower blowdown. However, despite the increase, the total volume would still remain below the designed volume for the existing complex. It is planned to recover and re-use stormwater (when there is no rainfall) for dust suppression and fire mitigation at coal stock pile, etc. Moreover, chemicals used in cooling water treatment will be environmentaly friendly thus allowing the tower blowdown water to be used for horticulture and for bottom and fly ash conditioning. There will be no chemical and oily effluent generated during normal operation owing to limited use, however, in case of abnormal operation, a spill-control arrangement has been incorporated in the plant design.

Stormwater from the existing Complex is discharged into Port Qasim Authority's drain channel after removal of suspended solids, which discharges the effluent into a natural rain-water course, which empties into a creek near the Arabian Sea. The effluents discharged into the drain channel include stormwater and cooling water blowdown. The effluents from the CPP project will also be discharged into the same Port Qasim drain channel and flow will be mainly cooling tower blow down and stormwater during rain. All effluents discharged outside FFBL Complex will be within the NEQS limits.



Exhibit 1.4: Layout of the Existing and Proposed Facilities at FFBL

Fertilizer Plant Complex



1.3 Statement of Need

The establishment of the CPP project shall help reduce dependency on natural gas, which

is already short in supply in the country, and result in better operational flexibility for the

existing fertilizer complex. It will also help alleviate the power crisis in the country by

exporting electricity to the National Grid. In addition, employment will be generated with

the continuation of the existing fertilizer operation and the installation of the Project thus

contributing towards socioeconomic improvement.


fertilizer production, but also other industries across the country as well.

By installing two coal-based CFB boilers at the existing FFBL complex, the company

will save natural gas and thus dependency on natural gas will be reduced by approx. 24%

which is beneficial not only for FFBL as well as for the country.


Granular Urea. It makes up for about 45% of the demand for DAP and about 13% for

Urea in the domestic market.3 The quantity of fertilizer products produced by FFBL has

already been affected by the shortage of natural gas in the country and with the demand-

supply gap for gas in the country only widening in the foreseeable future. This gap will

continue further until and unless new gas reserves are made operational or gas imports

(Pak-Iran & LNG, etc) added to the country‘s supply system.


in a shortfall of Urea and DAP production in the country as a whole. This would place an


the shortfall in the country. The price of urea & DAP would rise as a result, affecting

agricultural production resulting in an inflationary pressure on basic food commodities.

Agricultural exports would also become more expensive and, thus, less competitive in the


Use of coal-based CFB boilers will provide operational flexibility to FFBL by leaving

them with sufficient natural gas as feedstock to maintain production. Retaining existing

facilities and expanding the FFBL complex with the new CPP project will not only help

retain current employees but also generate more employment. On the economic level,

stability in the supply of urea and DAP to the market will result in the stability of

Pakistan‘s agriculture sector. This Project will serve as a model and beacon to other

industries who are using natural gas as fuel for steam and power generation.

1.4 Introduction to the EIA

This Environmental Impact Assessment (EIA) was conducted to meet the regulatory

requirements of Pakistan contained in the Pakistan Environmental Protection Act, 1997,

and its associated rules and regulations. Wherever needed, reference is also made to the

International Finance Corporation‘s (IFC) best practice guidelines such as the , which

includes, for example, Environmental Health and Safety Guidelines 2007.





The EIA of modifications / additions to existing projects require that the assessment shall

cover the entire facility—the existing and the new or modified facility—and demonstrate

that the facility after completion of the modification will comply with environmental

standards and guidelines. An audit of the existing facility was conducted in advance of

the full EIA to determine whether the existing facility complied with national regulatory

and international financing agencies‘ environmental requirements.

The pertinent environmental parameters for gaseous emissions and industrial effluents for

which limits have been stipulated in the NEQS, and limiting values prescribed by the IFC

guidelines, were the focus of the audit. Relevant data was sought from the client and a

two-day field visit was also undertaken on June 19 and 20, 2013 during which the

relevant areas and processes of the existing FFBL plant were visited.

The results of the audit indicated that the existing fertilizer complex, technology and

processes are fundamentally compliant with both NEQS and IFC guidelines.

1.4.1 Objectives of the EIA

The objectives of EIA are to:

Assess the existing environmental conditions in the Project area, including the

identification of environmentally sensitive areas.

Assess the proposed Project activities to identify their potential environmental and

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

Propose appropriate mitigation and monitoring measures that can be incorporated

into the design of proposed activities to minimize any environmentally adverse

effects as identified by the assessment.

Assess the proposed Project activities and determine whether they comply with

the relevant environmental regulations of Pakistan.

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

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

requirements.

1.4.2 Scope of the EIA

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

following:

Construction of the CPP project at the existing plant site

In- land coal transportation to the site

Coal storage area reclamation and construction within the plant site.

Operation of the new CFB boilers and auxiliaries

Ash disposal activities

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

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



Task 1: Collection of baseline information on climate, soil quality, water quality, air

quality, noise levels, socioeconomic conditions and biological resources

(discussed in Sections 3, 4, 5 and 6 of this report)

Task 2: Assessment of the expected atmospheric emissions from the new CPP plant

at the FFBL Complex, determination of their impact, and recommendation

of appropriate mitigation measures, if needed (Section 9)

Task 3: Assessment of the likely impact of the CPP project on the water quality of

the surrounding area (Section 9)

Task 4: Assessment of the impact of the project on the wildlife and marine ecology

in the surrounding area (Section 9)

Task 5: Assessment of the socioeconomic impact of the project on the surrounding

community (Section 9)

Task 6: Development of an impact mitigation plan for the Project (Section 9).

1.5 Approach and Methodology

The assessment was conducted with the following objectives:

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

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

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

environment during the construction and operation phases of the project, in order

to identify issues of environmental concern; and

3. To recommend appropriate mitigation measures that can be incorporated into the

design of the project to minimize any adverse environmental impacts identified.

The methodology adopted for the assessment consisted of the following steps:

1. Review of regulatory requirements based on: a) a preliminary assessment of

proposed activities and the Project area; b) screening of relevant laws to prepare a

list of those that are applicable; and c) review of the laws to identify specific

regulatory requirements.

2. Collection of information on proposed project activities, project design and

schedule, with an emphasis on aspects that have an interface with the natural and

social environment.

3. Secondary literature search to collect environmental data about the Project area.

4. Site visits for collection of primary data related to various environmental aspects

of the Project area.

5. Evaluation of environmental data and proposed project activities to identify

environmental parameters that are likely to undergo significant change due to the

proposed project.

6. Evaluation of each likely change in order to identify adverse environmental

impacts.



7. Identification and evaluation of measures to mitigate the adverse impacts.

8. A stakeholder consultation to document the concerns of the local community and

other stakeholders, and to identify issues that may require additional assessment

in order to address these concerns.

Baseline Data Collection

Detailed environmental baseline surveys were conducted to collect primary data on the

Project area to help identify sensitive receptors. Along with the primary data, secondary

data were available from environmental studies previously conducted in the region for

other projects. Aspects that were covered during the survey included:

Community and socioeconomic indicators

Air quality

Traffic

Noise

Sensitive receptors

Marine ecology

Water quality, and

Soil.

Impact Assessment

Each of the potential impacts identified during the scoping phase was evaluated using the

environmental, socioeconomic, and project information collected. Wherever relevant,

quantitative models were used to predict the potential impact. In general, the impact

assessment discussion covers the following aspects:

The present baseline conditions

The potential change in environmental parameters likely to be affected by project-

related activities

The prediction of potential impacts

The evaluation of the likelihood and significance of potential impacts

The defining of mitigation measures to reduce impacts to as low as practicable

The prediction of any residual impacts, including all long- and short-term, direct

and indirect, and beneficial and adverse impacts

The monitoring of residual impacts.

1.6 Regulatory Requirements

The proposed fertilizer complex will be subject to the pertinent legislative and regulatory

requirements of the Government of Pakistan and the Government of Sindh. The legal

statutes that have been reviewed include the Pakistan Environmental Protection Act, 1997



and the National Environmental Quality Standards (NEQS), 19934, and there subservient

rules, regulations, guidelines and standards.

1.7 Report Organization

Section 1 (Introduction) provides an overview of the project, introducing the project

sponsors, and outlining the scope of this study.

Section 2 (Legal and Policy Framework) briefly discusses existing national policy and

resulting legislation for sustainable development and environmental protection, and then

presents the legislative requirements that need to be followed while conducting an EIA.

Section 3 (The Existing FFBL Fertilizer Plant) describes the salient features of the

existing fertilizer plant.

Section 4 (The Proposed CPP Project) contains information about key features of the

proposed Project, such as its location, design, construction, operation, products and raw

material requirements, suppliers, power generation, and waste disposal arrangements.

Section 5 (Description of the Environment) documents in detail the existing physical,

biological, and socioeconomic conditions around the Project site and relevant

transportation and access routes.

Section 6 (Public Consultation) presents the objectives and outcomes of the public

stakeholder consultation that was conducted during the EIA.

Section 7 (Environmental Screening) elaborates on the screening methodology adopted

for the EIA of the CPP project. It also briefly describes environmental issues that are not

expected to be significantly affected by the Project.

Section 8 (Analysis of Alternatives) discusses the alternatives to the Project that were

considered, and the reasons for their rejection.

Section 9 (Project Impacts and Mitigation) presents an assessment of the Project‘s

impact to the physical, biological, and socioeconomic environment, as well as

recommended mitigation measures.

Section 10 (Conclusions) will summarize the findings and recommendations of this EIA

study.

4

Including the latest NEQS rules: National Environmental Quality Standards (Self-Monitoring and Reporting by Industries) Rules, 2001


Hagler Bailly Pakistan Legal and Institutional Framework

R4V03FBE: 02/19/14 2-1

2. Legal and Institutional Framework

This chapter outlines the environmental and social legislation, standards and codes of

practice governing this Environmental Impact Assessment (EIA) and the Project. This

Environmental Impact Assessment (EIA) was conducted to meet the regulatory


and its associated rules and regulations. However, since reference is made to international

best practice in some sections of the report, IFC guidelines on phosphate and nitrogenous

fertilizers have also been included in this section.

2.1 Statutory Framework

The development of statutory and other instruments for environmental management has

steadily gained priority in Pakistan since the late 1970s. The Pakistan Environmental

Protection Ordinance, 1983, was the first piece of legislation designed specifically for the

protection of the environment. The promulgation of this ordinance was followed in 1984

by the establishment of the Pakistan Environmental Protection Agency (Pak EPA), the

primary regulatory body dealing with environmental issues. Significant work on

developing environmental policy was carried out in the late 1980s, which culminated in

the drafting of the Pakistan National Conservation Strategy. Provincial environmental

protection agencies were also established at about the same time. The National

Environmental Quality Standards (NEQS) were established in 1993. The enactment of

the Pakistan Environmental Protection Act (PEPA), 1997, conferred broad-based

enforcement powers to the environmental protection agencies. The publication of the

Pakistan Environmental Protection Agency Review of IEE and EIA Regulations (IEE-

EIA Regulations), 2000, provided the necessary guidelines on the preparation,

submission, and review of initial environmental examinations (IEE) and environmental

impact assessments (EIA). In addition to the PEPA 1997, Pakistan‘s statute books contain

a number of other laws that have clauses concerning the regulation and protection of the

environment.

2.1.1 Constitutional Provision

Prior to the 18th

Amendment to the Constitution of Pakistan in 2010, specific legislative

powers had been distributed between the federal and provincial governments as defined

in two ‗lists‘ attached to the Constitution as ‗Schedules‘. The ‗Federal List‘ covered

subjects over which the federal government had exclusive legislative power, while the

‗Concurrent List‘ contained subjects regarding which both the federal and provincial

governments could enact laws. The subject of ‗environmental pollution and ecology‘ was

included in the Concurrent List and hence allowed both the national and provincial

governments to enact laws on the subject. However, as a result of the 18th

Amendment

this subject is now largely assigned exclusively to the domain of the provincial

governments. The main consequences of this change are as follows:



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The erstwhile Ministry of Environment at the federal level has been abolished, its

functions relating to local environmental management having been transferred to

the provinces. The country‘s international environmental obligations, however,

will be managed by a newly created federal Ministry of Climate Change.

The Pakistan Environmental Protection Act, 1997 (PEPA 1997) is technically no

longer applicable to the provinces. The provinces are required to enact their own

legislation for environmental protection. It is understood that to ensure legal

continuity, PEPA 1997 continues to be the legal instrument in Sindh for

environmental protection till enactment of a new provincial law in its place.

It is anticipated that the provincial acts will be based on the PEPA 1997 and will provide

the same level of protection. The following discussion is, therefore, based on the

provisions of PEPA 1997.

2.1.2 Pakistan Environmental Protection Act, 1997

PEPA 1997 is the basic legislative tool empowering the government to frame regulations

for the protection of the environment. The act is applicable to a broad range of issues and

extends to air, water, industrial liquid effluent, marine, and noise pollution, as well as to

the handling of hazardous wastes. The following articles of PEPA 1997 have a direct

bearing on the proposed Project:

Article 11(1): ―Subject to the provisions of this Act and the rules and regulations

made thereunder, no person shall discharge or emit or allow the discharge or

emission of any effluent or waste or air pollutant or noise in an amount,

concentration or level which is in excess of the National Environmental Quality

Standards…‖

Note: NEQS have been established for gaseous emission, liquid effluent, ambient air

quality, noise, and drinking water. The proposed Project needs to comply with all such

applicable standards.

Article 12(1): ―No proponent of a project shall commence construction or

operation unless he has filed with the Federal Agency5 an Initial Environmental

Examination or, where the project is likely to cause adverse environmental effects

an Environmental Impact Assessment, and has obtained from the Federal Agency

approval in respect thereof.‖

Note: The EIA of the proposed Project will be submitted to the Sindh Environmental

Protection Agency (EPA) for approval.

Article 12(3): ―Every review of an environmental impact assessment shall be

carried out with public participation…‖

Note: The Sindh EPA will organize public hearing for the proposed Project.

5 The term ‗Federal Agency‘ refers to the government agency which has the power or to which powers

have been delegated to implement the provisions of this Act. In case of this Project, the concerned agency is the Sindh EPA.



R4V03FBE: 02/19/14 2-3

Article 14: ―No person shall generate, collect, consign, transport, treat, dispose of,

store, handle or import any hazardous substance except (a) under a license issued

by the Federal Agency and in such manner as may be prescribed; or (b) in

accordance with the provisions of any other law for the time being in force, or of

any international treaty, convention, protocol, code, standard, agreement or other

instrument to which Pakistan is a party.‖

As per Article 14(1), the requirements of Article 14 are applicable ―in such manner as

may be prescribed.‖ PEPA 1997 defines ‗prescribed‘ to mean as prescribed under the

rules made under the Act. Hazardous Substances Rules were drafted by Pakistan EPA in

2003, but were never notified. Therefore, this article of the PEPA 1997 is not enforceable

and will not affect the proposed Project. However, best industry practice and

internationally acceptable guidelines for hazardous substances would be used for the

proposed Project.

2.1.3 Rules and Regulations under Pakistan Environmental Protection Act, 1997

Pakistan Environmental Protection Agency Review of Initial Environmental Examination and Environmental Impact Assessment Regulations, 2000

The IEE-EIA Regulations, 2000, prepared by the Pakistan EPA under the powers

conferred upon it by the PEPA 1997, provide the necessary guidelines on the preparation,

submission, and review of Initial Environmental Examinations (IEEs) and Environmental

Impact Assessments (EIAs).

Categorization of projects requiring IEE and/or EIA is one of the main components of the

IEE-EIA Regulations, 2000. Projects have been classified on the basis of expected degree

of adverse environmental impact. Project types listed in Schedule II of the regulations are

designated as potentially seriously damaging to the environment and require EIA, and

those listed in Schedule I as having potentially less adverse effects and require an IEE.

Fertilizer plants are included in Schedule II (List of Projects Requiring an EIA) under

Category B, ‗Manufacturing and Processing‘. ‗Project‘ is defined in PEPA 1997 as ―any

activity, plan, scheme, proposal or undertaking involving any change in the environment

and includes (f) alteration, expansion, repair, decommissioning or abandonment of

existing buildings or other works, roads or other transport systems, factories or other

installations.‖ As the proposed Project involves the installation of a new coal power plant

within the existing fertilizer plant, it falls within the classification for Schedule II and an

EIA has therefore been prepared for it.

The following sections of the IEE-EIA Regulations, 2000, have a bearing on the

proposed Project‘s EIA:

Regulation 6: ―(1) The Federal Agency may issue guidelines for preparation of an

IEE or EIA, including guidelines of general applicability and sectoral guidelines

indicating specific assessment requirements for planning, construction and

operation of projects relating to a particular sector; (2) where guidelines have

been issued under sub-regulation (1), an IEE or EIA shall be prepared, to the

extent practicable, in accordance therewith and the proponent shall justify in the

IEE or, as the case may be, EIA and departure therefrom.‖ The relevant guidelines

are discussed in Section 2.3 below.



R4V03FBE: 02/19/14 2-4

Regulation 8: ―(1) Ten paper copies and two electronic copies of an IEE or EIA

shall be filed with the Federal Agency; (2) Every IEE and EIA shall be

accompanied by (a) an application, in the form set out in Schedule IV, and (b)

copy of receipt showing payment of the review fee.‖

The prescribed procedure for review of EIA by the EPA is described in Regulations 9-14

and is depicted in Exhibit 2.1.

Exhibit 2.1: EIA Review and Approval Procedure



R4V03FBE: 02/19/14 2-5

Key features of the review process include:

On acceptance of the EIA for review, the EPA will place a public notice in

national English, Urdu and local language newspapers informing the public about

the project and where its EIA can be accessed. It will also set a date for a public

hearing on the project, which shall be at no earlier than 30 days after the

publication of the notice.

If it considers necessary, the EPA can form a ‗committee of experts‘ to assist the

EPA in the review of the EIA. The EPA may also decide to inspect the project

site.

Article 12(4) of PEPA 1997 binds the EPA to ―communicate its approval or

otherwise within a period of four months from the date the initial environmental

examination or environmental impact assessment is filed, complete in all respects

in accordance with the prescribed procedure, failing which the initial

environmental examination or the environmental impact assessment, as the case

may be, shall be deemed to have been approved to the extent to which it does not

contravene the provisions of this Act and the rules and regulations made

thereunder.‖ Regulation 11 of the IEE-EIA Regulations, 2000 states that the EPA

―shall make every effort to carry out its review… of the EIA within ninety days,

of issue of confirmation of completeness.‖

Self-Monitoring and Reporting by Industry Rules, 2001

Under the National Environmental Quality Standards and Self-Monitoring and Reporting

(SMART) by Industry Rules, 2001, industrial units are responsible for monitoring their

gaseous and liquid discharges and reporting them to the relevant environmental

protection agency. The Project is being constructed within the existing FFBL fertilizer

plant which manufactures both nitrogenous and phosphate fertilizers and, hence, falls

under the ‗nitrogenous and phosphate fertilizer plants‘ section in Schedule I (Category A)

of industrial categorization and reporting procedure for SMART. Projects falling under

this category are required to submit environmental monitoring reports to the relevant

authorities on a monthly basis. The Project proponents shall report their emission and

effluent data to the Sindh EPA in accordance with these rules.

2.1.4 Other Relevant Laws

Port Qasim Authority Act, 1973

This Act provides for the establishment of the Port Qasim Authority, defines its

functions, powers and internal organization, and lays down rules relative to the

management of and navigation in marine ports and inland waterways. The particular

sections applicable to the Project are:

Section 71(B) (2): ―No Owner, Agent or Master of a vessel, or any industry,

manufacturing establishment, mill, factory or any kind, cargo handling company,

terminal operator, etc., shall discharge any solid or liquid, waste, oily, noxious

radioactive and hazardous substances, bilge discharges, residues and mixtures

containing noxious solid and liquid wastes, de-blasting of un-washed cargo tanks



R4V03FBE: 02/19/14 2-6

and line washing, garbage, emission of any effluent or waste or air pollution or

noise in any amount concentration or level in excess of the National

Environmental Quality Standards, or standards, which may be specified, from

time to time, by the Authority for Port limits.‖

Section 71(B)(3): ―Any person contravening the provisions of sub-section (2)

shall be liable to penalty as determined and notified by the authority from time to

time for each contravention in addition to the charges for cleaning of the Port and

removal of pollution therefrom.‖

Section 71(C)(1): ―No proponent of a project shall commence construction or

operation unless he has filed with this Authority as Initial Environmental

Examination or, where the project is likely to cause an adverse environmental

effect, an Environment Impact Assessment, and has obtained from the authority

approval in respect thereof.‖

Section 71(C (2): ―The Authority shall: (a) review the initial environmental

examination and accord its approval, or required submission of an Environmental

Impact Assessment by the proponent; or (b) review the Environmental Impact

Assessment and accord its approval subject to such condition as it may deem fit to

impose, or require that the Environment Impact Assessment be re-submitted after

such modification as may be stipulated.‖

The Forest Act, 1927

This act empowers provincial forest departments to declare any forest area as ‗reserved‘

or ‗protected‘. The act also empowers the provincial forest departments to prohibit the

clearing of forests for cultivation, grazing, hunting, removing forest produce, quarrying,

felling, and lopping. It is anticipated that some clearing of vegetation may be required for

FFBL CPP site preparation, but since the area is not a designated reserve forest this law

will have no implication on the Project.

Factories Act, 1934

Particular sections of the act applicable to this project are:

Section 13(1): ―Every factory shall be kept clean and free from effluvia arising

from any drain, privy or other nuisance.‖

Section 14(1): ―Effective arrangements shall be made in every factory for the

disposal of wastes and effluents due to the manufacturing process carried on

therein.‖

Section 16(1): ―In every factory in which, by reason of the manufacturing process

carried on, there is given off any dust or fume or other impurity of such a nature

and to such an extent as is likely to be injurious or offensive to the workers

employed therein, effective measures shall be taken to prevent its accumulation in

any work-room and its inhalation by workers and if any exhaust appliance is

necessary for this purpose, it shall be applied as near as possible to the point of

origin of the dust, fume or other impurity, and such point shall be enclosed so far

as possible.‖



R4V03FBE: 02/19/14 2-7

Section 16(2): ―In any factory, no stationary internal combustion engine shall be

operated unless the exhaust is conducted into open air and exhaust pipes are

insulated to prevent scalding and radiation heat, and no internal combustion

engine shall be operated in any room unless effective measures have been taken to

prevent such accumulation of fumes therefrom as are likely to be injurious to the

workers employed in the workroom.‖

Section 20(1): ―In every factory, effective arrangements shall be made to provide

and maintain at suitable points conveniently situated for all workers employed

therein a sufficient supply of wholesome drinking water.‖

Section 26(1) d(i): ―In every factory, the following shall be securely fenced by the

safeguards of substantial construction which shall be kept in position while the

parts of machinery required to be fenced are in motion or in use, namely (a) every

part of an electric generator, a motor or rotary convertor.‖

2.2 Environmental Guidelines

2.2.1 Sectoral Guidelines for Environmental Reports—Major Chemical and Manufacturing Plants, 1997

These sectoral guidelines deal with major chemical and manufacturing plants which are

defined as those that involve the production or storage of chemical substances (including

reactive, toxic or flammable liquids, vapors, gases, and solids), including inorganic

chemicals industries such as fertilizer manufacturing plants. The guidelines are meant to

assist project proponents in identifying key environmental parameters that require to be

addressed through appropriate mitigation measures and alternatives, which should be

considered in the actual EIA.

2.2.2 Environmental Assessment Procedures, 1997

The federal EPA of Pakistan, in collaboration with other key stakeholders, including

provincial EPAs, other agencies, NGOs, academics and other stakeholders, has prepared

comprehensive procedures and guidelines for the environmental assessment of

development projects in the country. The following are the relevant guidelines applicable

to the project:

Policy and Procedures for the Filling, Review, and Approval of Environmental

Assessments, which sets out key policy and procedural requirements. They contain a brief

statement outlining the purpose of environmental assessments and the overall goal of

sustainable development, and also states that environmental assessment should be

integrated with feasibility studies.

Guidelines for the Preparation and Review of Environmental Reports, which cover the

following:

Scoping, alternatives, site selection, and format of environmental reports

Identification, analysis and prediction, baseline data, and significance of impacts

Mitigation and impact management and preparing an environmental management

plan



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Reporting

Review and decision-making

Monitoring and auditing

Project management.

Guidelines for Public Consultation, which covers the following:

Consultation, involvement and participation

Identifying stakeholders

Techniques for public consultation (principles, levels of involvement, tools,

building trust)

Effective public consultation (planning, stages of EIA where consultation is

appropriate)

Consensus-building and dispute resolution

Facilitating involvement (including the poor, women, building community, and

NGO capacity)

2.2.3 World Bank/IFC Environmental Guidelines

World Bank/IFC guidelines for health and safety and discharge of effluents and

emissions from the following three documents have been used for comparison where

relevant:

Environmental, Health and Safety Guidelines,

Phosphate and Nitrogenous Fertilizer Manufacturing,

Thermal Power Plants.

These environmental, health, and safety (EHS) guidelines are technical reference

documents with general and industry-specific examples of ‗good international industry

practice‘. The EHS guidelines define performance levels and measures that are generally

considered to be achievable in new facilities employing existing technology at reasonable

costs. Application of the EHS guidelines to existing facilities may involve the

establishment of site-specific targets, based on environmental assessments and/or

environmental audits, as appropriate, with a suitable timetable for achieving them.

2.3 Institutional Framework

The success of environmental assessment as a means of ensuring that development

projects are environmentally sound and sustainable depends in large measure on the

environmental management capability of regulatory institutions. In this regard, the

existing institutional framework for decision-making and policy formulation on

environmental and conservation issues in Pakistan is briefly described below.



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An Environment and Alternate Energy Department has been functioning in the

Government of Sindh since 2002, under which the Sindh EPA operates. The latter is the

environmental monitoring and regulating agency for the province with the following

main functions:

Enforcement of PEPA 1997

Enforcement of NEQS

Implementation of Self-Monitoring and Reporting Tool (SMART)

Review of EIAs and IEEs

Providing advice to the government on issues related to the environment

Coordination of pollution prevention and abatement measures between

government and non-governmental organizations

Assistance to provincial and local governments in implementation of schemes for

proper disposal of wastes to ensure compliance with NEQS

Undertake measures to enhance environmental awareness amongst the general

public

Conduct research and studies on different environmental issues

Attend to public complaints on environmental issues.

Carry out any other task related to the environment assigned by the government.

The Sindh EPA will be responsible for the review and approval of the EIA of the FFBL

Coal power plant (CPP).

2.4 Applicable Standards and Target Limits

The complete set of National Environmental Quality Standards is included as

Appendix 1. It includes the following types of standards:

Ambient air quality

Drinking water

Ambient noise

Industrial effluents

Industrial gaseous emissions

In Exhibit 2.2 to Exhibit 2.4, a comparison of NEQS and IFC Guidelines for key

parameters of emission, ambient air quality, and effluent is provided for reference. The

details are found in Appendix A.



R4V03FBE: 02/19/14 2-10

Exhibit 2.2: Comparison of NEQS and IFC Guideline Limits for Emission of

Key Pollutants from Coal-Based Power Plant

Parameter NEQS

(Applicable Standard)

IFC Guidelines

(For Comparison)

Particulate matter 500 mg/Nm3 For NDA: 50 mg/Nm

3

For DA: 30 mg/Nm3

Sulfur oxides 100-500 Tons per day [1] For NDA: 200-850 mg/Nm3

For DA: 200 mg/Nm3

Carbon monoxide 800 mg/Nm3 –

Oxides of nitrogen 260 ng/J of heat input For NDA: 510 mg/Nm3

For DA: 200 mg/Nm3

Notes:

1. For additional parameters and explanation, see complete NEQS and IFC Guidelines in Appendix A.

2. A ―–― in the third column indicates that IFC has not provided any guidelines for the parameter

3. NDA = Non-degraded airshed; DA = Degraded airshed

Exhibit 2.3: Comparison of NEQS and IFC Guideline Limits for Ambient Air Quality


NEQS (Applicable Standard)

IFC Guidelines

(For Comparison)


Annual Average 80 μg/m3

24 hours 120 μg/m3 125 μg/m

3

10 min 500 μg/m3

Oxide of Nitrogen as (NO) Annual Average 40 μg/m3

24 hours 40 μg/m3

Oxide of Nitrogen as (NO2) Annual Average 40 μg/m3 40 μg/m

3


3

Ozone (O3) 1 hour 130 μg/m3

8 hour 160 μg/m3

Suspended Particulate Matter (SPM)

Annual Average 360 μg/m3

24 hours 500 μg/m3

Respirable particulate Matter. PM 10

Annual Average 120 μg/m3 70 μg/m

3


3

Respirable Particulate Matter. PM 2.5

Annual Average 15 μg/m3 35 μg/m

3


3

1 hour 15 μg/m3

Carbon Monoxide (CO)

8 hours 5 mg/m3

1 hour 10 mg/m3

Notes:


2. A ―–― in the third column indicates that IFC has not provided any guidelines for the parameter or they are to be established by the environmental assessment

3. The NEQS for PM 2.5 are not consistent with those for PM10. The issue is under consideration of Sindh EPA.



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Exhibit 2.4: Comparison of NEQS and IFC Guideline Limits for Key Liquid Effluents6

(mg/l, unless otherwise defined)

Parameter NEQS (Applicable Standard)

IFC Guidelines (For

Comparison)

Temperature increase =<3°C –

pH value 6 to 9 6 to 9

Five-day bio-chemical oxygen demand (BOD)5 at 20°C 250 –

Chemical oxygen demand (COD) 400 –

Total suspended solids (TSS) 400 50

Total dissolved solids (TDS) 3,500 –

Grease and oil 10 10

Chlorides (as Cl') 1,000 –

Cadmium (Cd) 0.1 0.1

Chromium (Cr)-Total 1.0 0.5

Copper (Cu) 1.0 0.5

Lead (Pb) 0.5 0.5

Mercury (Hg) 0.01 0.005

Selenium (Se) 0.5 –

Sulfates (SO4) 1000 –

Nickel (Ni) 1.0 –

Silver (Ag) 1.0 –

Total toxic metals 2.0 –

Zinc (Zn) 5.0 1.0

Arsenic (As) 1.0 0.5

Barium (Ba) 1.5 –

Iron (Fe) 8.0 1.0

Manganese (Mn) 1.5 –

Boron (B) 6.0 –

Chlorine (Cl), Residual 1.0 0.2

Notes:


2. A ―–― in the third column indicates that IFC has not provided any guidelines for the parameter or they are to be established by the environmental assessment

3. NEQS are those for the discharge to sewage treatment

6 The NEQS limits selected and used in this report are for effluents discharged ‗into sewage treatment‘

plants. Effluents from the CPP project will be disposed into PQA‘s drain channel. PQA has planned the installation of an industrial sewage treatment plant which will treat FFBL‘s industrial effluent, along with those generated by other industries using the same drain. The treated discharge will ultimately discharge into the sea. As PQA‘s sewerage treatment plant will be built at some point in the future, Section 9,

discusses the potential impacts on the natural rain-water course from FFBL‘s effluent discharged into the PQA drain and proposes mitigation measures accordingly.


Hagler Bailly Pakistan The Existing FFBL Fertilizer Plant

R4V03FBE: 02/19/14 3-1

3. The Existing FFBL Fertilizer Plant

The proposed CPP Project will be installed within Fauji Fertilizer Bin Qasim Ltd.‘s

existing plant which consists of a main fertilizer Complex, as well as a tank farm at Port

Qasim. The Complex includes an Ammonia plant, a Urea plant, a Diammonium

phosphate (DAP) plants and associated utility facilities. The tank farm is used to store

phosphoric acid—one of the raw materials used by the Complex—obtained from

Morocco.

The CPP Project will be an addition to the plant‘s existing natural gas-based steam and

power generation facility. It will also be located within the area available in the existing

facility. No parts or components of the existing facility will be dismantled or

decommissioned. The CPP Project will benefit from the existing infrastructure and

utilities at site through tie-in connections between the CPP Project and the existing

fertilizer complex for certain utilities, such as clarified water, air, power and steam, and

the effluent discharge system. When the CPP Project becomes operational, the existing

natural gas-based boilers and gas turbines in the existing plant will go into standby mode.

Exhibit 3.1 provides a summary of the main components of the CPP Project, along with

a summary of those parts of the existing fertilizer plant that will undergo modifications.

A detailed description will follow in Section 4. This section of the report describes the

main components of the existing fertilizer plant.

Exhibit 3.1: Components of the Existing Plant to be Replaced, Modified or Retained,

and Main Components of the CPP Project

Parts of the Existing Complex Site to be: Major Components of the CPP Project

Replaced Modified (Tie-in Connections with

Existing Plant)

Retained (in Stand-by Mode)

None Potable water Two gas turbines & associated facilities

Coal-based CFB boilers, Fly Ash and Bottom Ash handling system

Fire water Utilities HRSG boiler & associated facilities

Coal handling including coal pile stacker, reclaimer, crusher & conveying system

Industrial water Auxiliary boiler & associated facilities (if required)

Limestone handling area

Feed water IBD & CBD vessels Bag house filters for CFB boilers

Demin water Steam Turbine Generators & accessories, busbar, cabling, grid station for power export

High pressure steam Demineralized water pumps

Low pressure steam Compressed air compressors


Hagler Bailly Pakistan The Existing FFBL Fertilizer Plant

R4V03FBE: 02/19/14 3-2

Parts of the Existing Complex Site to be: Major Components of the CPP Project

Replaced Modified (Tie-in Connections with

Existing Plant)

Retained (in Stand-by Mode)

Natural gas / Purge gas Instrument air dryers

Service and instrument air New cooling water tower with pumps and clarified water pumps for makeup water

Clarified water Stormwater network system

Power supply Main boiler‘s stack

Nitrogen

3.1 FFBL Setting

The Fertilizer Complex is located in Malir, a district in the Karachi Division in the

province of Sindh. The main Complex lies about 45 km southeast of the city of Karachi,

inside the eastern industrial zone of PQA, as shown in Exhibit 3.2. It is located at a

distance of about one kilometer from the National Highway (N5), which links Karachi to

southern Sindh and the rest of the country. The tank farm is located near the liquid cargo

terminal in Port Qasim.

Exhibit 3.3 illustrates the location of the Complex in the PQA; the proposed CPP site is

easily accessible from the National Highway N5. The Port Qasim Authority dual

carriageway connects the plant site to the National Highway.

The geographical coordinates of the project site are as follows:

Main Complex:

Latitude: 24 49‘ 31.7‖ to 24 50‘ 25.0‖

Longitude: 67 24‘ 44.0‖ to 67 25‘ 20.0‖

Tank Farm:

Latitude: 24 46‘ 40.0‖ to 24 46‘ 49.0‖

Longitude: 67 20‘ 0.34‖ to 67 20‘ 9.6‖


Hagler Bailly Pakistan The Existing FFBL Fertilizer Plant R4V03FBE: 02/19/14 3-3

Exhibit 3.2: Setting for the CPP Project and Existing FFBL Plant Site



Exhibit 3.3: FFBL Fertlizer Complex Location



3.2 Salient Features of the Existing FFBL Fertilizer Complex

The salient features of the existing FFBL Complex are as follows:

3.2.1 Description

The Complex covers 350 acres (142 hectares) in the Eastern Industrial Zone of PQA.

Exhibit 3.4 and Exhibit 3.5 present the layout of the main Complex and of the proposed

Project within the existing site. The tank farm area acquired for the storage of phosphoric

acid covers 8 acres (3.2 hectares). The land for the Complex site was acquired by FFBL

after considering various factors, such as the availability of gas and water, access to

highways, and the proximity of the site to the phosphoric acid storage facility at the tank

farm in Port Qasim. The Port Qasim Authority (PQA) approved the allotment of land to

the FFBL in August 1993.

3.2.2 Plant Capacity

The Ammonia plant has a production capacity of 1,570 metric tons per day (MTPD). The

Urea plant‘s wet and granulation/dry sections have production capacities of 1,670 MTPD,

while the DAP plant has a production capacity of 2,230 MTPD.

3.2.3 Process Details

An analysis of plant specifications plays an integral role in assessing compliance of

existing plant processes. The existing plant consists of an Ammonia plant, a Urea plant,

and a Diammonium phosphate (DAP) plant. To operate these plants various utilities units

and raw material storages are also installed.

The main processes are described in following sections.

Ammonia

Synthesis gas for ammonia production requires a high purity mixture of three volumes of

hydrogen and one volume of nitrogen. The ‗steam-methane‘ reforming process is used to

produce the required hydrogen. Nitrogen is supplied by injecting air at an elevated

temperature; the oxygen content is completely consumed by oxidizing a part of the

combustibles in the gas stream.

The process steps involved take place in the following sequence:

1. Feed desulfurization—removal of sulfur compounds from the feed gas

2. Primary steam-methane reforming

3. Air combustion and secondary reforming

4. Carbon monoxide shift conversion

5. Carbon dioxide removal with Benfield solution7

6. Methanation—catalytic conversion of residual carbon oxides to methane

7. Synthesis gas compression

7

Proprietary name.



8. Catalytic conversion of synthesis gas to ammonia

9. Condensation of ammonia

10. Hydrogen recovery unit

11. Recovery of Ammonia from purge gas

Urea

Urea is produced by the reaction of ammonia and gaseous carbon dioxide at about 170 C

to 185 C temperature and 137 kg/cm2 to 148 kg/cm

2 pressure, according to the following

reactions:

2NH3 + CO2 NH2COONH4

NH2COONH4 NH2CONH2 + H2O

In the first reaction, carbon dioxide and ammonia are converted into ammonium

carbamate. The reaction is fast and exothermic. In the second reaction, which is slow and

endothermic, the ammonium carbamate dehydrates to produce urea and water. The

overall conversion efficiency of carbon dioxide in the synthesis section is typically 80 to

81%.

The following process steps are involved in the urea production:

1. Ammonia and carbon dioxide compression

2. Urea synthesis

3. Low pressure recirculation section

4. Pre-evaporation and evaporation

5. Process condensate treatment.

Urea Granulation

Urea granules are produced in a granulation loop designed around a fluidized bed type

granulator with internal urea pulverization. Feedstock is around 96% (by weight)

concentration urea solution sent from the urea wet section via one of the 96% solution

pumps.

Urea formaldehyde solution, fed by means of one of the metering pumps, is added to the

urea solution.

In the granulator, the solution is sprayed at a pressure of about 3 kg/cm2 onto granules

suspended in a fluidized layer.

Ambient air is used as fluidizing gas, supplied by the granulator fluidization air fans.

Atomization air and fluidization air is extracted from the top of the granulator, together

with some entrained dust, washed in the granulator wet scrubber, and discharged into the

atmosphere by the granulator scrubber air fan through the stack.



Exhibit 3.4: Site Layout of Existing FFBL Plant and Proposed CPP Project



Exhibit 3.5: Detailed Layout of Existing FFBL Plant and Proposed CPP Project



Diammonium Phosphate (DAP)

The raw materials required to produce di-ammonium phosphate (DAP) fertilizer are mainly

Ammonia and Phosphoric Acid (52% to 54% P2O5). Sulfuric Acid and Sand are also used as filler

to lower the N:P acid ratio, and adjust the formulation as desired.

The process principle is to neutralize phosphoric and sulfuric acids with liquid or gaseous

Ammonia and to subsequently granulate the neutralization product. Jacobs‘s slurry process

including pre-neutralizer & pipe reactor is integrated into the conventional granulation process;

which consists of:

1. A granulation loop,

2. A conditioning section, and

3. A gas scrubbing section.

Final Products Storage and Bagging

The storage and bagging of final products consists of the following steps:

1. Products to stockyard,

2. Storage and products reclaiming,

3. Screening and conveyors network to bagging, and

4. Products to bagging and shipping.

Products are weighed and transferred to conveyor belts, which discharge them to piles in

the stockyard. The stockyard is arranged in two parallel stockpiles in one common

building. The capacity of each stockpile is 35,000 tons.

The products pass through screening machines en route to the bagging units. In the case

of urea, screening is not required, and the product moves directly to the bagging units.

Once bagged, products are transferred to trucks by eleven truck-loading conveyors. Each

loading bay accommodates one truck at a time. At the shipping outlet, a weighing bridge

with a capacity of 60 tons weighs the outgoing trucks.

3.2.4 Raw Materials

The raw materials going into the existing processes are as follows:

Natural Gas

The primary raw material for ammonia and urea production is natural gas. Natural gas

supplied to the Fertilizer Complex contains 90% methane, 4% nitrogen and 3% carbon

dioxide. The feedstock requirement is estimated to be 70 MMSCFD (million standard

cubic feet per day). The natural gas is transported to the Complex by means of a pipeline.

Phosphoric Acid

Phosphoric acid (H3PO4) is one of the main raw materials required for DAP production,

in addition to ammonia. Phosphoric acid (53% P2O5) is sea-shipped from Morocco and

pumped to the tank farm comprising 4 x 10,000 Metric tons storage tanks installed in a



dyke. From the tank farm phosphoric acid is trucked to the Fertilizer Complex and stored

in the plant‘s storage tanks.

Sulfuric Acid

Sulfuric acid (H2SO4)—consumed in DAP production and water treatment—is trucked to

the Fertilizer Complex. The 98% sulfuric acid is stored in two carbon steel tanks,

installed in cemented retention sumps. One tank is installed for DAP plant while the other

is installed in the utilities area.

Ammonia Storage

Ammonia produced in the Ammonia plant is sent to the Urea and DAP plants and also to

Ammonia storage. The 5,000 metric ton ammonia storage tank has a cylindrical double

wall, flat bottom, an insulated internal suspended deck and a stiffened roof. The

foundation of the tank is raised from ground in order to have free ventilation.

Additionally there is an earth bund around the tank as well as compressors system to cool

and control boil off the vapors as well as inert gas purge, flare and pump out system.

Urea Formaldehyde

Urea formaldehyde is required for urea production and is brought to the Complex via

trucks. The required composition consists of 60% formaldehyde, 25% urea and 15%

water.

Sand

Silica sand is used as filler for DAP and is transported to the fertilizer complex by truck.

3.2.5 Power Generation

The existing Complex has its own 60 Hz power generation system isolated from the

national grid. The Fertilizer Complex requires approximately 21 MW of electricity to

operate, which is supplied together by two General Electric gas-fired turbine generators

(Mark V, Model MS-5001), each with an ISO rating of 26.3 MW(21.3 MW site rating),

and one 2 MW diesel-driven emergency generator.

Each gas turbine is coupled with 36.6 MVA generators with a terminal voltage of

13.8 kV at a frequency of 60 Hz and generator speed of 3,600 rotations per minute

(RPM).

Fuel Requirements

The primary fuel for the existing Fertilizer Complex is natural gas. It is used by gas

turbines producing electricity, the heat recovery steam generators (as a supplementary

fuel), the auxiliary boiler, and the primary reformer furnace. The total fuel requirement is

15 MMSCFD. As described in Section 3.2.4, natural gas is piped to the fertilizer

complex.

3.2.6 Water Requirements

FFBL‘s design water requirement is approximately 7.0 million gallons per day (MGD).



The fertilizer complex raw water is met through following sources as given below:-

Dedicated RCC lined carbon steel water line from Karachi Water and Sewage

Board

PQA arranged water supply

Emergency back-up water line from Pakistan Steel

Break-up of the Fertilizer Complex‘s water intake (design basis) is as follows:

Cooling water make-up requirement 970 m3/h

Demineralized water requirement 180 m3/h

Potable water requirement 20 m3/h

Industrial water including DAP plant 100 m3/h

Total raw water intake 1,270 m3/h

The water systems in use at the Complex are described below.

Raw Water System

The raw water system consists of the following units:

1. Raw water storage,

2. Raw water clarification, and

3. Raw water filtration.

Raw water from the Complex flows into a common raw water/firewater basin with a

capacity of 90,000 m3. From the basin, raw water is pumped to the reactor clarifier and to

the potable water system by three centrifugal pumps (including one standby pump). The

raw water clarification system is designed to remove suspended solids and organic

matter, and consists of a reactor clarifier, polymer dosing skid, alum dosing skid, caustic

dosing skid, and a Sodium hypochlorite dosing skid. Water from the clarifier passes

through sand filters which remove smaller and lighter particles of suspended solids.

Potable Water System

Raw water is treated and then stored in the potable water storage tank. Water from this

tank is distributed throughout the Complex for drinking, safety and emergency showers.

The system consists of the following:

1. 150 m3 storage tank,

2. Two 20 m3/h distributing pumps,

3. Sodium hypochlorite injection system,

4. Iron filter

5. Sand filter and

6. Activated carbon filter.



Firewater System

Firewater storage is common with raw water storage, with a reserve capacity of 5,000 m3

available at all times. The firewater system includes two main firewater pumps and two

jockey pumps, which supply building sprinklers, house systems, and plant fire hydrants.

Cooling Water System

The cooling water system is based on non-chromate (Phosphate based) cooling water

treatment. An open recirculating type cooling tower is provided for the removal of heat

from the process units. The cooling tower system is designed to cool inlet water from

42.3 C to 33.0 C.

Demineralized Water System

Filtered water from the clear well is fed to the demineralization plant for processing into

boiler feedwater. The processed water is stored in the demineralization water storage

tank. The demineralization plant consists of:

1. Two activated carbon filtering units for removal of suspended solids, and

organics.

2. Three cation and three anion units for removal of dissolved solids.

The three-train system allows for two trains to be in service while the third train is in

regeneration mode.

3.2.7 Solid Wastes

There is no solid waste generation from process plants, all off-products and sludge from

urea and DAP plants are recovered and recycled into the respective process. There are

some sludge which is generated from wastewater basins and tank farm during sump / tank

cleaning activities.

The clarifier is used to remove suspended solids from the raw water (see Section 3.2.6

above on Raw Water). However, due to better quality of raw water and prior

sedimentation, the amount of sludge generated is negligible.

Periodic cleaning of phosphoric acid tanks at plant site and Tank Farm Area generates

some sludge; its quantity however, is quite small and it is recovered in the DAP process

to recover the valuable P2O5 content present in the acid sludge.

Solid waste is generated during plant maintenance activities, office works, and

housekeeping.

Solid Waste Disposal

The small quantity of solid wastes generated during waste water basins / sumps are

placed within the complex in the evaporation pond dyke, through contractors.

Solid waste generated during plant maintenance activities, office works, and

housekeeping is accumulated in scrap yard and auctioned to government authorized

contractors having NOCs for recycling and dumping the waste at government approved

sites for safe disposal.



3.2.8 Liquid Effluents

Fertilizer Complex operations generate liquid effluents, mainly stormwater, due to area

washing and cooling tower blowdown. Exhibit 3.6 lists the effluents discharged into the

Port Qasim Authority (PQA) industrial drain, while Exhibit 3.7 lists the effluents that are

diverted to the evaporation pond. The PQA industrial drain channel discharges the

effluents into the rain-water course (Exhibit 3.3), east of the Complex, which flows down

south into a creek near the sea (see Section 5.1.4 for more details on the PQA drain and

Ghaghar Nullah).

A discussion on each stream with respect to its source, treatment and safe discharge is

presented below.

Exhibit 3.6: Wastewater Sources, Designed Flows and Treatment of

Effluents Discharged into the PQA Industrial Drain

Waste Source Designed Flow m

3/day

Optimized Flow

m3/day

2

Recycle Flow

m3/day

3

Net Flow to PQA Drain

4

Remark

Cooling water blowdown

1

7, 776 3,000 700 to 800

2200 Final discharged to the PQA drain, this effluent is within NEQS limit

Demineralization plant effluents

216 216 216 216 Discharged to the evaporation pond or the PQA drain

Stormwater effluents

- - - - For the first 10 minutes, stormwater flows into the storm/oily wastewater sewer, and thereafter, into the PQA drain

1. Notes:- 2.

1. The figure pertains to abnormal water quality. Normal flow is around 80 ~ 120 m3/hr

3.

2. The designed cooling tower blow down flow was optimized by increasing the cycles of concentration

of circulating cooling water. This has resulted in water saving as well as chemicals.

4.

3. For horticultural purpose within existing Complex.

5.

4. This water is also used by Textile institute of Pakistan (TIP)



Exhibit 3.7: Wastewater Sources, Flows and Treatment of

Effluents Discharged into the Evaporation Pond

Waste Source Flow m

3/day

Disposal

Laboratory waste 5.0 Negligible flow and discharge to evaporation pond

2 after neutralization

DAP effluents 532 Recycle to DAP process

Urea effluents - Discharge to evaporation pond in case of plant shutdown or abnormal operation

Storage area effluents - No flow & normally recycled.

Boiler blowdown (from utilities, ammonia plant boilers)

113 Recovery in cooling tower

Oily effluents 3001 Oily water discharge to evaporation pond

after oil removal.

Ammonia plant effluents 30 Discharge to evaporation pond

6. Notes:- 7.

1 The flow figure pertains to abnormal plant conditions. Normally there is no flow from these

locations. 8.

2 The surface area of the evaporation pond is 346.4 m x 263.4 m, and it is 1.9 m deep.

Cooling Tower Blowdown (CTBD)

The cooling tower operates on the principle of evaporation that causes an increase in

concentration of dissolved salts and suspended matter, which need to be removed in order

to avoid scaling of the heat exchange equipment that comes in contact with the cooling

water. The lowering of these impurities to the desired level is achieved largely by

discharging a portion of the cooling water from the system as blowdown on a continuous

basis. The blow composition is presented in Exhibit 3.8.

Disposal

Due to use of environment friendly cooling water treatment chemicals, the cooling tower

blow down water is used at the Complex for in-house horticulture. The remaining

effluents are discharged into the PQA industrial drain from where they are discharged to

the rain-water course (see Exhibit 3.3).



Exhibit 3.8: Design Cooling Tower Blowdown Analysis

Item Quantity

pH 7.5 to 8.5

Calcium (as CaCO3) 500 ppm

Magnesium (as CaCO3) 135 ppm

Chlorides 250-350 ppm

Iron < 2.0 ppm

Phosphate 4-6 ppm

Total suspended solids (TSS) 130 ppm

Total dissolved solids (TDS) 990 ppm

Alkalinity (as CaCO3) 200 ppm

Turbidity 15-130 ppm

Chlorine <0.1 ppm

Silica (as SiO2) 30 ppm

Chemical oxygen demand (COD)1 12.9 ppm

Total organic carbon (TOC) 4.55 ppm

Demineralization Effluents

As described in Section 3.2.6, the demineralized water system includes cation and anion

units. These units are regenerated once every 16 hours of operation, and thus produce

regeneration waste effluents. These effluents are tabulated in Exhibit 3.9.

Exhibit 3.9: Design Specifications of Demineralization System Effluents

Source Flow Rate, m

3/h

Duration, min.

Total Volume,

m3

Frequency Suspended Solids, ppm

Filter backwash 77 15 52 Every 11 hours

250

Cationic exchanger backwash

68 10 11 Every 24 hours

–

Cationic exchanger regeneration

58 60 116 Once a day –

Cationic exchanger up-flow rinse

85 18 51 Once a day –

Cationic exchanger down-flow rinse

68 12 27.3 Once a day –

Anionic exchanger backwash

34 15 17 Every 24 hours

–



Source Flow Rate, m

3/h

Duration, min.

Total Volume,

m3

Frequency Suspended Solids, ppm

Anionic exchanger regeneration

20 60 40 Once a day –

Anionic exchanger up-flow rinse

85 25 106 Once a day –

Anionic exchanger down-flow rinse

68 3 20.4 Once a day –

Treatment and Disposal

All effluents from demineralization are collected in a neutralization tank and treated with

caustic soda and sulfuric acid to bring the pH close to 7 (neutral), prior to its disposal.

The neutralization sequence is automatically initiated upon completion of the

cation/anion regeneration. Under normal plant conditions, the composition of

demineralization effluents after neutralization are as shown in Exhibit 3.10.



Exhibit 3.10: Design Characteristic of Demineralization Effluents

Composition after Neutralization

Item Quantity

Flow rate 9 m3/h

Temperature 33C

pH 6.5-7.5

Chemical oxygen demand (COD) 150

Total suspended solids (TSS) 500 ppm

Total dissolved solids (TDS) 3,500 ppm

Iron <1.0 ppm

After neutralization, effluent from the neutralization tank is routed to the storm-water

channel where it is mixed and diluted with cooling water blowdown before being

discharged to the PQA drain channel . In case of any problems with the neutralization pH

control system, the demineralization effluents are diverted to an evaporation pond located

within the fertilizer complex.

Chemical Wastewater

All liquid effluents which are either alkaline or acidic are collected and sent to a chemical

sewer collection basin. The sources of these effluents are listed below:

1. Phosphoric acid storage (normally no flow, only during rain)

2. Sulfuric acid and caustic storage (normally no flow, only during rain)

3. Laboratory

4. Urea plant contaminated process condensate

5. Oil-free water from oil-water separator


The chemical waste streams are collected into a chemical sewer basin connected through

an underground sewerage network. The basin is a reinforced cement concrete (RCC)

construction, lined with acid-resistant tiles with a total available capacity of 125 m3.

Neutralization of the chemical waste is achieved with the help of sulfuric acid or caustic

soda, as per requirement. Neutralized effluents are discharged into the evaporation pond.

Discharge characteristics of the neutralized effluent are presented in Exhibit 3.11.



Exhibit 3.11: Design Discharge Characteristics from Chemical Sewer to

Evaporation Pond after Treatment

Item Discharge Characteristics After Chemical Sewer Treatment

Flow Rate 60 ~ 80 m3/h

Temperature 35 C

pH 7-9

Chemical oxygen demand (COD) 150 ppm

Total Suspended Solids (TSS) 150 ppm

Total Dissolved Solids (TDS) 3,500 ppm

Iron <2.0 ppm

Chlorides <500 ppm

Oily Wastewater

A separate sewer receives oily effluent streams from various sources within the Complex.

Oily waste sources include:

1. Natural gas station

2. Ammonia compressors

3. Compressor section of urea plant

4. Gas turbine area

5. Maintenance Workshop.


The oily wastes are sent to an oil-water separator, which consist of a rectangular basin of

RCC construction. Oil separation takes place due to the difference in specific gravities of

the two fluids. Being lighter, oil rises to the surface and gets collected by a floating oil

skimmer. The recovered oil is transferred to an oil-decanting tank from where it is

collected in used oil drums prior to disposal to outside agencies. The sludge is recovered

from the bottom of the separator (depending upon requirement) and disposed of through

contractors.

The oil-free water is transferred at a design rate of 52 m3/h from the separator to the

evaporation pond, after neutralization in the chemical sewer basin, as described in the

section above.

Boiler Blowdown

The heat recovery steam generator, auxiliary boiler and waste heat recovery boiler

produce liquid effluents in the form of continuous blowdown. This blowdown is

recovered in the cooling tower basin.



Sanitary Effluents

The plant buildings are a source of sanitary effluents. These effluents are collected

through a piped system and directed to septic tanks from where liquid effluents are

transferred to soakage pits.

Storm Sewer

A separate stormwater system accommodates all runoffs in the Fertilizer Complex,

including rainwater, floor washings and firewater. The plant site has been leveled so it

slopes towards the stormwater drainage system, ensuring that rainwater flows

continuously in the right direction. The stormwater drainage system consists of open

channels of RCC construction of variable width and depth. Steel gratings and RCC pipe

culverts provide for road crossings. The rainwater runoff from the roofs is conveyed

through vertical pipes to the ground and into the nearest open channel. The stormwater

system accommodates a maximum rainfall of 207 mm/day (maximum 50 mm/h).

Stormwater Treatment

All of the rainwater runoff, except for very small and clean areas, is channeled into a

stormwater impoundment, where it is retained for about ten minutes, before its final

discharge.

Stormwater effluents are disposed of outside the Fertilizer Complex through two disposal

routes, one in the northeast corner of the Complex into the PQA industrial drain, and the

other on the southwest side.

3.2.9 Tank Farm Area Effluents

The following liquid effluents are generated at the tank farm area:

1. Sanitary sewer

2. Stormwater

3. Phosphoric acid tanks cleaning

4. Line flushing.

Sanitary Sewer

The small quantity of sanitary effluent is sent to underground septic tank while overflow

from this tank is disposed of into the PQA sewer system in the area.

Stormwater

The stormwater network within the tank farm area is connected with PQA industrial

drainage system outside the tank farm area

Phosphoric Acid Tank Cleaning

Phosphoric acid tank cleaning is carried out as and when required, with one tank cleaned

at a time. Phosphoric tank cleaning is performed with the help of industrial water and all

cleaning effluents recycled to another storage tank to prevent loss of P2O5



Line Flushing Effluent

Effluents generated during phosphoric acid pipeline flushing are recovered in the

phosphoric acid storage tanks. It also includes line flushing from the berth to the tanks.

PQA Drain Channel

The 3 m wide and 4 m deep rectangular reinforced cement concrete (RCC) open-channel

drain shown in Exhibit 3.12 extends approximately 1,410 m east of the Complex and

ends at the rain water course. The nullah then courses south, along the eastern edge of the

PQA for, approximately, 7 km before discharging into a creek near the sea. Exhibit 3.13

contains photographs at various locations along the PQA drain.



Exhibit 3.12: The PQA Drain at the Northeast Corner of the FFBL Complex



Exhibit 3.13: Photographs of the PQA Drain Channel

a. Effluent discharge from FFBL into the drain. b. The PQA drain with FFBL plant in the background.

c. Effluent in the PQA drain.

Rain-water Course (Ghaghar Nullah)

The rain-water course is a natural drain that eventually empties into the Arabian Sea. It

remains dry during most of the year and only flows during the monsoon rains. The PQA

industrial drain discharges effluents into this nullah, which serves as a conduit for

discharging the effluents to the sea.

Evaporation Pond

An excavated and diked evaporation pond receives most of the remaining effluents

generated by the Fertilizer Complex. This pond is located inside the Complex (see

Exhibit 3.4). The pond is about 346 m long, 263 m wide and 1.9 m deep. The

evaporation pond is cleaned every three to five years. Solids deposited in the pond are

scraped and disposed of in a landfill and also used for the compaction and repair of the

pond dikes.

The evaporation pond receives neutralized wastewater coming from the chemical sewer

and the oil-water separator. Under normal Complex operation, its designed capacity is

about 1,800 m3/day.

3.2.10 Gaseous Emissions

Sources of gaseous emissions, when the Complex is in operation, are:



1. Gas turbines

2. Heat recovery steam generator (HRSG)

3. Auxiliary boiler

4. Ammonia plant

5. Urea plant

6. DAP plant

These are discussed further below.

Emissions from Gas Turbines

As described in Section 3.2.5, the power requirements of the Fertilizer Complex are met

by two gas turbines, which are fueled by natural gas.

Oxides of nitrogen (NOx) and carbon monoxide (CO) in the flue gases are automatically

controlled by the gas turbine control system. Flue gases are normally routed to the

HRSG. In the event that the HRSG is not in operation, these gases are vented directly

through a 25 m high stack. The characteristics of the flue gas from both turbines are

tabulated in Exhibit 3.14.

Emissions from Heat Recovery Steam Generator (HRSG)

The HRSG receives heat from the gas turbines‘ flue gases, and uses natural gas as a

supplementary fuel.

HRSG is equipped with low-NOx burners and an automatic combustion control system,

which minimize NOx and CO in the flue gases. These gases are vented through a 73 m

high stack. The characteristics of the flue gases from the HRSG, with gas turbines

running at 70% load, are provided in Exhibit 3.15.

Emissions from Auxiliary Boiler

The auxiliary boiler uses natural gas as fuel. The auxiliary boiler is also equipped with

low-NOx burners and an automatic combustion control system, which minimize the

presence of NOx and CO in the flue gases. These gases are also vented through the 73 m

high stack. The characteristics of flue gases from the auxiliary boiler are tabulated in

Exhibit 3.16.



Exhibit 3.14: Characteristics of Emissions from Gas Turbine8

Parameter Value

Total flow rate 664,000 kg/h

Temperature 482 C

Nitrogen 68.09% (wt.)

Oxygen 13.05% (wt.)

Carbon dioxide 2.71% (wt.)

Water vapor 15.33% (wt.)

Argon 0.82% (wt.)

NOx 65 ppm

Carbon monoxide 10 ppm

Note:- 1

Heat is recovered in HRSG to generate steam prior to release.

Exhibit 3.15: Characteristics of Emissions from Heat Recovery Steam Generator9

Parameter Value


Temperature 224 C


Oxygen 13.05% (wt.)



Argon 0.82% (wt.)

NOx 65 ppm

Carbon monoxide 10 ppm

8 Gas turbines running with 15% excess air. 9 Gas turbines running at 70% load.



Exhibit 3.16: Characteristics of Emissions from Auxiliary Boiler10

Parameter Value


Temperature 160 C


Oxygen 1.03% (wt.)


Water vapor 17.20 (wt.)

Emissions from Ammonia Plant

Major sources of gaseous emissions from the ammonia plant are the primary reformer

furnace and the waste heat recovery boilers.

Flue gases from the primary reformer furnace do not require any treatment and are vented

through its stack at a height of 26 m. Waste heat boiler flue gases are vented via a 25 m

high stack. An automatic combustion control system minimizes the levels of NOx and CO

in the flue gases. Flue gas characteristics of the primary reformer furnace and waste heat

recovery boiler are provided in Exhibit 3.17 and Exhibit 3.18, respectively.

Exhibit 3.17: Characteristics of Emissions from Primary

Reformer Furnace (Ammonia Plant)

Parameter Value


Temperature 260 C


Oxygen 1.0% (wt.)



NOx <100 ppm

Carbon monoxide <20 ppm

10

Auxiliary boiler operating with 15% excess air.



Exhibit 3.18: Characteristics of Emissions from Waste Heat

Recovery Boiler (Ammonia Plant)

Parameter Value


Temperature <170 C


Oxygen 16.06% (wt.)



Argon 0.9% (wt.)

NOx <1 ppm

Carbon monoxide <1 ppm

Emissions from Urea Plant

Gaseous emissions from the urea plant originate from the Urea granulation stack.

Emissions from the urea granulation stack contain urea dust and originate from the

granulator, the first fluidized bed cooler, the second fluidized bed cooler and the

granulation dedusting circuit. Gases coming from the granulator are dedusted in the

granulator scrubber before being vented. Gases from fluidized bed coolers and the

dedusting circuit pass through the coolers‘ scrubber before being vented to atmosphere at

a height of 62 m. Analyses of the emissions from these scrubbers is given in

Exhibit 3.19.

Exhibit 3.19: Characteristics of Emissions from Scrubbers (Urea Plant)

Parameter Granulator Scrubber Coolers Scrubber

Flow rate 323,777 kg/h 244,070 kg/h

Temperature 47 C 34.5 C

Urea dust 0.0027% wt. 0.0028% wt.

Ammonia 0.0067% wt. 0% wt.

Dry air 94.50% wt. 96.87% wt.

Moisture 5.48% wt. 3.11% wt.

Water 0% wt. 0% wt.

Formaldehyde 0% wt. 0% wt.



Emissions from DAP Plant

The primary gaseous pollutants generated by the DAP process include dust, Ammonia

and fluorine. An efficient gas de-dusting and scrubbing system with state of the art dual

mole scrubbing completes the Jacobs conventional Slurry Process which provides both

excellent ammonia recovery and minimum fluorine emission to the atmosphere. All the

pollutants are recovered in dry and wet treatment sections before being released to the

atmosphere. Details of the same are given below.

Dry treatment is achieved in Cyclones and Baghouse Filter to remove / recover the dust

from the gases. Dust originates from the following sources:

1. Dryer.

2. Solid handling equipment (Conveyors, Elevators & Vibrating Feeders) and

process equipment (Screens, Crushers, etc.)

3. Fluidized Bed Cooler (FBC).

After dust removal, gases from the first two sources are sent to wet treatment (scrubbing

system). Gases from the third source i.e. FBC comprise of three parts; after dust removal

one part sent to wet treatment (scrubbing system) while the other two parts are vented to

atmosphere through Stack.

Wet treatment is achieved through chemical scrubbing and is performed in two stages i.e.

in dual mole scrubbing system and tail gas scrubber. Ammonia laden off gases exiting the

reactors and Granulator are scrubbed at first stage in dual mole scrubbing system which is

a two step process. In dual mole scrubbing system off gases are scrubbed in series in two

steps with high & low N/P mole ratio liquor with diluted Phosphoric Acid. Dryer off

gases are, after dry treatment, scrubbed in venture scrubber with low N/P mole ratio

liquor used in dual mole scrubbing system. In second stage; reactors, granulator & dryer

off gases along with one part of Fluidized Bed Cooler (FBC) off gases are scrubbed at

second stage in Tail Gas scrubber with more acidic Sulfuric Acid solution in order to

recover the remaining ammonia from the gases before venting to atmosphere through

Stack. Circulating scrubbing liquor consumed in reactor.

The gases, after passing through the wet and dry treatment sections, will have

characteristics shown in Exhibit 3.20.

Exhibit 3.20: Characteristics of Emissions from DAP Plant

Parameter Value


Temperature 57 °C

Ammonia 0.043% (wt.)


Sulfuric acid 0.0003% (wt.)

Dry matter 0.0049% (wt.)

Dry air 90.76% (wt.)

Water 9.18% (wt.)

Dust 59 ppm



3.3 Assessment of the Existing FFBL Plant

The EIA of additions to existing projects require that the assessment shall cover the entire

facility—the existing and the new or modified facility—and demonstrate that the facility

after completion of the modification will comply with environmental standards and

guidelines. Therefore, an audit of the existing facility was conducted in advance of the

full EIA to determine whether the existing facility complied with the regulatory


and its associated rules and regulations. Reference was also made to the World Bank‘s

Environmental Guidelines 1988, which prevailed at the time the existing plant was built.

The existing fertilizer Complex was designed in the early 1990s based on renowned

European fertilizer technologies licensors after ensuring that the emission and effluents

would be within the limits as specified in the contract between the International

Contractors and FFBL as applicable at that time.

Wherever needed, reference is also made to the currently applicable International Finance

Corporation‘s (IFC) best practice guidelines, which includes, for example, Environmental

Health and Safety Guidelines 2007. Reference is also made to the European Fertilizer

Manufacturers Association (EFMA) Best Applicable Techniques (BAT), 2000.

3.3.1 Data on Gaseous Emissions

Data on gaseous emissions were provided by FFBL and included the following:

CO and NOx emissions, sampled on a weekly basis by FFBL from January 2012

to April 2013 from the two gas turbines, the utilities boilers, and ammonia plant

furnace and boiler.

TPM, NH3 and fluorine emissions, sampled on a monthly basis by FFBL from

January 2012 to April 2013 from the DAP stack and urea stack.

Field sampling and analysis results were also conducted by SGS11 on August 24

and 27, 2012. The monitoring was carried out at one exhaust duct for the

following emissions:

Urea plant stack gas (NH3 & particulate matter)

DAP plant stack gas (NH3, fluorine & particulate matter).

3.3.2 Data of Effluents

Data from FFBL‘s self-monitoring sample analysis exercise was used. Sampling was

done on a daily basis from January 2012 to April 2013.The available data included

information on the following parameters:

11

SGS is a leading inspection, verification, testing and certification company for industrial processes. Services of SGS Pakistan were hired by FFBL to carry out particulate matter sampling and analysis according to international standards. SGS reported their findings of field sampling and analysis conducted on August 24 & 27, 2012 and November 20 & 27, 2012 from wastewater samples, groundwater samples, gaseous emissions monitoring, Isokinetic particulate matter emissions and sampling of fluoride and ammonia from identified stacks.



pH

Chloride

Oil

Ammonia

Free chlorine

TDS

TSS

BOD

COD

Fluoride

Cadmium.

3.3.3 Summary of the Results

Exhibit 3.21 and

Location Gaseous Emission NEQS Compliance (%) EFMA / Plant Design Compliance (%)

Urea Stack TPM 100 100

NH3 – 100

DAP Stack TPM 100 100

NH3 – 100

Fluoride – 100

Gas Turbine 1 CO, NOx 100 –


Heat Recovery Steam Generator

CO, NOx 100 –

Auxiliary Boiler CO, NOx 100 –

Exhibit 3.22 provide a summary of the results of a compliance frequency analysis for the

gaseous emissions and effluent data provided by FFBL. The results indicate almost full

compliance of the samples with prescribed NEQS limits.

The concentration of total particulate matter (TPM) in all the samples from the Urea

Stacks were well within the prescribed NEQS limit of 500 mg/Nm3. TPM in the samples

obtained from the DAP Stack were also fully compliant with the prescribed NEQS limits.

Gaseous emissions sample results for CO, SOx and NOx emissions from Gas Turbines,

Heat Recovery Steam Generators (HRSG) and the Auxiliary Boilers were fully compliant

and well within the prescribed NEQS limits.

FFBL Urea and DAP plants are based on European based process-design licensors M/s

Stamicarbon, Netherland for Urea Wet and Hydro Fertilizer Technology (HFT) Belgium



for urea granulation while.The DAP plant is based on Grande Paroisse/ AZF Process

France. The concentrations of Total Particulate Matter (TPM) for both DAP and Urea

plants are within the limits prescribed by the NEQS.

The existing DAP-Urea complex was designed and based on technology from the early

1990‘s and accordingly the applicable limits for emission and effluents are valid for that

time. The applicable guarantee / make good limits for ammonia and particulate matter

from Urea plant were <200mg/NMC12 and <50 mg/NMC respectively. The same is also

reflected in European Fertilizer Manufacturer Association (EFMA) Best Available

Techniques (BAT) 2000.

Moreover, third party analysis conducted by SGS in 2012 also indicated that all gaseous

emissions were within the existing complex design limits.

Among the parameters analyzed for effluents, the only parameters not in full compliance

with NEQS standards during the entire sampling time period were the Free Chlorine,

TDS and Ammonia content of the effluents.

Based on above, the results indicate that the existing plant set-up, technology and

processes are fully compliant with NEQS limits, existing plants design limits, EFMA and

fundamentally also compliant with IFC guidelines. Few periodic non-compliance with

IFC standards shown in the results can be ascribed to production schedules mainly on

account of fluctuations and shortages of gas supply rather than any inherent non-

compliance in the design and operation of the existing plant. FFBL has already taken

steps to ensure rectification through more stringent in-house controls.

.

Exhibit 3.21: Summary of FFBL‘s Gaseous Emission Compliance with

NEQS and EFMA / Plant Design Limits

Location Gaseous Emission NEQS Compliance (%) EFMA / Plant Design Compliance (%)

Urea Stack TPM 100 100

NH3 – 100

DAP Stack TPM 100 100

NH3 – 100

Fluoride – 100



Heat Recovery Steam Generator

CO, NOx 100 –

Auxiliary Boiler CO, NOx 100 –

12 mg/NMC = milligrams per Normal Meter Cubed. Normal, in this connection, means a temperature of 0

degrees Celsius and a pressure of 1.013 bar, the conditions at which one mole of an ideal gas has a volume of 22.413837 liters.



Exhibit 3.22: Summary of FFBL‘s Effluent Compliance with NEQS and EFMA / Plant

Design Limits

Effluents NEQS Compliance (%) EFMA / Plant Design Compliance (%)

pH 100 100

Chloride 100 –

Oil 100 –

NH3 99.5 99

Free chlorine 99.6 –

TDS 99 –

TSS 100 97

BOD 100 –

COD 100 –

Fluoride 100 100

Cadmium 100 100


Hagler Bailly Pakistan The Proposed CPP Project R4V03FBE: 02/19/14 4-1

4. The Proposed CPP Project

FFBL‘s fertilizer plant operates on natural gas, and the current shortfall in the supply of

natural gas in the country has affected the plant‘s fertilizer production adversely. Under

the CPP Project, the fertilizer plant‘s steam and power generation processes will be

shifted from natural gas to coal as fuel.

The main components of Project include:

Two equal–sized circulating fluidized bed (CFB) boilers and auxiliaries

Three equal–sized condensing steam turbine generators (STGs) and auxiliaries

Steam turbine generator (STG) on 50 Hz for power export, 132KV inter-

connection grid facilities and auxiliaries

Transformer unit and auxiliary transformers

Power switchyard and substation

Two weighing bridges

Coal unloading station

Coal storage yard

Coal handling system, including conveyors, junction towers, stacker–cum–

reclaimer, crushers, coal sampler, and magnetic separator

Limestone unloading, storage area, crushing hall and handling system

Fly ash handling system, including fly ash silos for each boiler

Bottom ash handling system, including bottom ash hopper, ash screw coolers and

silos for each boiler

Common stack with two inner flue gas ducts for each boiler

Emission monitoring system on each boiler flue gas duct

Induced draught cooling towers with auxiliaries, such as circulating pumps,

chemical dosing system, closed loop cooling water system and side–stream filters

Boiler feedwater (BFW) de–aeration system and auxiliaries

Elevators for boilers

Wastewater collection, recovery and disposal system

Miscellaneous buildings, such as;

CPP control room, Electrical substation and rack room

Area operator cabins

Workshop and stores

Truck parking area



Guard house and reception house at new gates

Green belt area (plantation).

A detailed layout plan of the Project is shown in Exhibit 4.1, and the main components

of the Project are described briefly in Exhibit 4.2. Exhibit 4.3 illustrates the location of

the Project and highlights the coal transport routes from the Karachi Port (KPT) and Port

Qasim (PQ) to the Complex. It also marks options for possible ash disposal sites.



Exhibit 4.1: Layout of the CPP Project



Exhibit 4.2: Brief Description of Main Components of the Project


Site preparation The existing gas fired boilers and power system will remain in their original place and, therefore, no major decommissioning will be required. New facilities will be installed on an empty open space availaible in the existing fertilizer complex for which the site will be prepared as follows

Clearing of area;

Excavation, filling and leveling of the site; and

Development of sediment control measures

New facilities FFBL plans to install new coal–based steam and power facilities at an empty space situated within the existing fertilizer complex. The Project consists of two equal capacity circulating fluidized bed (CFB) boiler units, each of 250 Met/hr. Out of the 500 Met/hr of steam produced by the two boilers, about 140 Mett/hr will be used to operate three steam turbine generators each with a capacity of 16 MWe. Power produced by these will be sent to the existing 13.8 kV grid inside the FFBL Complex to supply power to the existing fertilizer plant which operates at 60 Hz and is not connected to the national grid connection. About 200 Met/hr of steam will be used as process steam for the manufacture of fertilizer.

FFBL has kept extra margin in the two coal fired CFB boilers and auxiliaries capacities to generate additional power at 50 Hz from dedicated Steam Turbine Generator for export to Pakistan National Electric Grid.

Coal storage facilities at the port(s)

Coal will be transported, initially, from Karachi Port using existing port facilities and eventually from Port Qasim. No new waterfront facility or expansion of the existing coal yard will be required at Karachi Port. Pakistan International Bulk Terminal Limited (PIBT) is already in the process of developing a coal, clinker and cement terminal at Port Qasim which will also handle FFBL‘s coal supply, along with that for other customers..


From the two Karachi ports, the coal will be transported to the Project site via trucks. It will then be stacked in a dedicated coal yard, to be set up within the CPP project site, from where it will be reclaimed and used as fuel in the CFB boilers.

Ash disposal Two distinct types of ash are generated during combustion of coal in a CFB boiler: bottom ash and fly ash. Bottom ash consists of larger particles that exit the bottom of the boiler, while fly ash consists of finer particles that exit the boiler with the flue gas and are recovered in the de–dusting process. FFBL plans to acquire suitable low lying areas for the disposal of these ashes, which will be covered properly after filling to minimize dust generation. The options for ash disposal sites include vacant plots within Pakistan Steel Mills‘ existing scrap and slag yard, a vacant soil excavation site, and an empty plot of land east of the Complex. Utilization of the ash in local cement and concrete brick manufacturing plants will also be considered. In addition to these options, following the practice in vogue internationally, CFB ashes can be considered for other applications with less stringent specifications, which include soil stabilization, road base and structural fills.




Emission Control



De–sulfurization with the help of sorbent (limestone) inside the CFB boilers to capture and to prevent SOx emission

Fabric bag house filters for de–dusting of fly ash from coal combustion to prevent particulate matter emission

Emission monitoring system at flue gas ducts of each CFB boiler outlet to monitor NOx, SOx, PM, CO, temperature, CO2 and O2.

Effluents The over–all volume of effluents outside FFBL complex battery limit will increase slightly when the CPP project becomes operational mainly on account of stormwater (only during rainfall) and cooling tower blowdown. However, it is planned to recover and re–use stormwater (when there is no rainfall) from the CPP plant for dust suppression and fire mitigation at coal stock pile, etc. Moreover, chemicals used in cooling water treatment will be environmentaly friendly thus allowing the tower blowdown water to be used for horticulture and for bottom and fly ash conditioning.

Stormwater from the existing Complex is discharged into Port Qasim Authority's drain channel after removal of suspended solids, which discharges the effluent into a natural rain–water course, which empties into a creek near the Arabian Sea. The effluents discharged into the drain channel include stormwater and cooling water blowdown. The effluents from the CPP project will also be discharged into the same Port Qasim drain channel and flow will be mainly cooling tower blow down and stormwater during rain. All effluents discharged outside FFBL Complex will be within the NEQS limits.



Exhibit 4.3: Project Setting Showing Coal Transport Routes and Ash Disposal Sites



4.1 Coal–Based Circulating Fluidized Bed (CFB) Boiler

The Project comprises of two subcritical CFB combustion boilers, each able to generate

up to 250 t/h of steam.

The steam generated by these boilers will be used for power generation by steam turbine

generators (STGs), while part of the steam (200 t/h at normal operating conditions and

260 t/h at peak capacity) will be letdown and de–superheated to 42 bar and 380 oC,

respectively, for utilization within the existing Fertilizer Complex.

FFBL has kept extra margin in the two coal fired CFB boilers and auxiliaries to generate

additional power at 50 Hz from a dedicated Steam Turbine Generator for power export to

Pakistan National Electric Grid. The CPP has a power generation capacity between 110

and 120 MW.

The major components of a CFB boiler are the furnace, the cyclone, the loop seal and the

convection pass, as depicted in Exhibit 4.4. In the furnace, coal, along with the bed

material, is fluidized with primary air. Combustion takes place as the solid particles rise

in the furnace, and heat is transferred to the membrane water wall tubing that forms the

walls of the furnace and the radiant super–heater surfaces, if any.

From the silos, coal and limestone will be injected into the boiler via feeding systems

operating in conjunction with the relevant automatic control systems. The hot combustion

gases with the entrained solids exit at the top of the furnace into the cyclone. The cyclone

separates the solids from the combustion gases and returns the solids, including any

unburned solid fuel, through a loop seal to the furnace. The lower section of the furnace

includes a water–cooled air distribution grid and a bottom ash removal system. Fly ash is

removed from the lower part of air heater and from the fabric filters in the de–dusting

equipment.

The boiler convection surfaces will be cleaned by conventional soot blowers. The

injected limestone reacts with the sulfur released from the fuel to capture the SO2 and

form CaSO4. The reaction requires that there is always an excess amount of limestone

present. The required amount of excess limestone is dependent on a number of factors,

such as the amount of sulfur in the fuel, the temperature of the bed, cyclone efficiency,

and the physical and chemical characteristics of the limestone. Provisions will be made

for primary and secondary air supply to the furnace. Primary air is supplied through the

lower wind box to the fluidizing grid, and provides the initial fluidization air flow. The

secondary air provides a staged combustion effect to ensure high combustion efficiencies

and to minimize NOx production.

Flue gas and some particulate matter leave the cyclone collector and go through the

convection pass which contains a superheater, economizer banks, and air preheaters. The

flue gas then enters fabric filters where particulate matter is removed in compliance with

environmental regulations.

Clean flue gas is discharged to the stack via the induced draft fan. Feedwater enters the

economizer, picking up heat before entering the drum. Water flows from the drum to the

lower furnace headers via downcomers. The furnace is arranged for complete natural



circulation. The density difference between the water and the steam/water mixture creates

a natural pumping action. The steam/water mixture is separated in the drum.

Dry saturated steam leaves the drum and is sent to the convection walls, then to the

superheater. Heat from the flue gases is transferred to the steam in the superheater tube

bundles. The superheater bundles will be arranged in multiple stages with attemperation

between each stage. Superheated steam exits the outlet header of the final superheater and

enters the main steam pipe.

Exhibit 4.4: Major Components of the Circulating Fluidized Bed Boiler

4.2 Fuel Firing System

The fuel firing system comprises of coal and limestone bunkers, coal and limestone

feeders, coal and limestone piping, and burners. The fuel firing system starts at the inlets

of the bunkers and terminates at the burner nozzles.

For coal to burn in a CFB boiler, the combustion air needs to be heated up to 500–

600 °C. The operation of CFB boilers involves a two–stage combustion process: the

reducing combustion at the fluidized–bed section, and the oxidizing combustion at the

freeboard section. Primary air is supplied from the bottom of the boiler to fluidize coal in

a suspended condition. Secondary air to support coal combustion is supplied above the

combustion zone. The combustion zone consists of fuel, ash and limestone, and bed

materials such as sand.

When coal is fed into the combustion zone, it is heated up by the hot inert material in the

combustion chamber. After coal heats up, it expands, cracks and breaks into smaller

pieces. The air and inert material temperature, as a result, increases up to ~800–900 °C.

As the coal breaks and becomes smaller, combustion flue gas carries the fine particles,

including fine coal and inert materials, towards the cyclone.



In the cyclone, the heavier particles separate from the gas and fall into the hopper of the

cyclone. The heavier particles are then recycled back to the boiler combustion chamber

for recirculation. A complete combustion process typically takes about 50 minutes. Inert

materials consisting of fly ash, sand, limestone and combustion by–product circulate

inside the combustor and separator. When the inert material reaches a certain particle

size, it is separated out from the cyclone. The hot exhaust flue gas from the cyclone

carries the fine particles through the rear horizontal convection pass heat recovery area.

The superheaters and reheaters are located in the convection pass, together with the

economizers.

Flue gas flows through the superheater, reheater, low temperature superheater,

economizer and air preheater. Fine particles will be captured by fabric fiber filters and

transported to dry fly ash silos. The clean flue gas is then drawn by induced draft (ID)

fans and exhausts through the stack to the environment.

Boiler water from the steam drum flows by gravity to the downcomers and inlet headers

of the waterwalls. From the inlet headers, water rises through the waterwalls. As the

water heats up in the furnace, a part of the water in the tubes is converted into a water–

steam mixture. The water–steam mixture will circulate back to the steam drum. Steam

collects at the upper half of the drum and is sent to the heat recovery area. The steam is

piped to the superheater sections and superheated by flue gas. It is then directed from the

superheater outlet header to the high pressure turbine (HP turbine).

4.3 Air and Flue Gas System

Air and flue gas systems will be designed to provide primary air, secondary air, cooling

air, and sealing air as well as to remove flue gases resulting from combustion. Air and

flue gas system will comprise of the following:

Air heaters: Air heaters work on the regenerative principle. Hot combustion

gases and fly ash from cyclones flow through the heat recovery area, superheaters,

reheaters and economizer sections to improve the efficiency of combustion.

Primary air system: Primary air from wind box supplies oxygen to heat up the

bed material, which includes fuel and limestone, in the furnace.

Secondary air system: Secondary air is introduced by secondary air nozzles to

assure solid circulation, to supply uniform air distribution to the upper region of

the furnace, to control excess oxygen, and, to reduce NOx emissions.

Fabric filters: Capture the fly ash present in flue gases.

Induced draft system: Cleaned flue gas is routed from the discharge of the fabric

filters to the inlet of two induced draft fans. These fans are located in the

ductwork leading to the stack.

Soot blowing system: Effectively removes all ash deposits from the heat transfer

surfaces inside the boilers, including air preheaters.

Flue ducts: Two flue duct openings will be provided in a chimney shell near the

ground floor for connecting the flue gas ducts from the fabric filters. Emission



monitoring system (EMS) will be installed to monitor flue gas emissions from the

chimney

4.4 Water Steam Cycle

The conversion of water to steam evolves in three stages:

1. Sensible heat addition,

2. Latent heat addition, and

3. Superheat and reheat.

Sensible heat is the heating of water from its original temperature at intake to boiling

point or saturation point. Addition of latent heat causes the water to boil at saturation

temperature to produce steam. The steam will continue to be heated from its saturation

temperature to higher temperatures by superheaters and reheaters, which helps increase

the power plant‘s output and efficiency.

The water steam cycle essentially comprises of the following:

The steam turbine receives superheated steam from the steam generator to drive

the turbine generator (HP turbine, IP turbine, LP turbine, turbine bypass system,

and turbine drain system),13

Condensing system to condense the steam from the steam turbine and to pump the

condensate to the feedwater system (condenser and condensate pump),

Feedwater system to add sensible heat to condensate and feedwater (deaerator,

feedwater pumps, low pressure (LP) feedwater heaters, high pressure (HP)

feedwater heaters, economizer, boiler feed pump and the connecting piping).

Steam generator to add latent heat to produce steam (steam drum, downcomers,

waterwall).

4.5 Dedusting

Flue gas exiting the furnace contains particulate matter (dust), also called fly ash. The

dedusting technique employed by the Project utilizes fabric filters (FF). Exhibit 4.5

shows an illustration of a typical bag house with FFs.

In a FF, flue gas from the inlet duct reaches filtering compartments where it moves

through the bags at a very low velocity (<1 m/min). Dust is retained by the bags and

accumulates on the outer layer as the gas is de–dusted. Clean gas flows up to the plenum

and enters the outlet duct.

Each compartment of the fabric filter is equipped with shutoff dampers, and consists of

gas–tight steel casing with filter bags supported by steel cages inside. The boiler start–up

procedure shall avoid apparition of condensation inside the filter. The bags will be

cleaned using a supply of compressed online pulse–jet type air. The main parts of a bag

house with FFs are shown in Exhibit 4.6.

13 HP: High pressure, LP: Low pressure, IP: Intermediate pressure.



Exhibit 4.5: An Illustration of the Bag House with Fabric Filters

Exhibit 4.6: Main Components of the Bag House



4.6 Stack

The CPP Project will have a common concrete stack containing two ducts, one for each

boiler. It will include:

An external concrete structure, with an access door at the bottom

Two internal flue gas ducts, with acid– and thermal–resistant material or steel

with internal lining

A ladder allowing access to the top of the stack with safety cage and intermediate

platforms

Measurement holes for independent isokinetic measurements.

The initial design height for the stack is 70 meters.

4.7 Steam Turbine Generators (STGs)

The steam turbines will be of the condensing, no reheat, radial/axial exhaust type and

operate with inlet throttle steam..

Three STGs will be selected, with each to generate 16 MW at 60 Hz. While operating in

parallel, the equal shared load carried by each will be approximately 12 MW. Power from

these turbines will not be connected to the national grid due to a mismatch in the

operating frequencies between the two.

Out of the total expected power generated of 34 MW from the three turbines, 21 MW will

be used to power the Fertilizer Complex, with the remaining amount used to power the

CPP plant auxiliaries.

For power export, a 50 Hz steam turbine generator will produce up to 70 MW which will

be exported to the National Grid.

The main components of the STGs will be:

High pressure outer and exhaust casing, rotor and rotating blades

Regulation and stop valves

Lube oil and control systems

Steam seal system

Control, over speed protection and turbine safety systems

Vibration detection system and alarms

Surface condensers with extraction pumps

Steam bypass arrangement

Generators, exciters and associated control protection, regulation and

synchronization system.

4.8 Coal Handling and Storage

The fuel resource for the new plant will be sub–bituminous coal, sourced mainly from

Indonesia and South Africa. The design range for coal is provided in Exhibit 4.7. The



coal will be received via ships of 40,000 to 60,000 deadweight tonnage (DWT) and will

be unloaded either at Karachi Port (KP) or Port Qasim (PQ). Once the Pakistan

International Bulk Terminal (PIBT) at PQ is ready, this will become the main port

receiving coal for the Project. Trucks of 55 t capacity will transport the coal from the port

to the Complex.

The coal will be weighed prior to unloading at the coal unloading station at the plant site.

From the unloading station it will be shifted to the coal pile area within the plant site.

Coal–receiving, storage and reclaiming and their subsystems are described in the

following sections.

Exhibit 4.7: Design Range of Coal used for the CPP Project

Coal Range Design Coal

Minimum Maximum

Heating Values (at 25 °C, as received; ar)

LHV kcal/kg 3105 6927 5,921

LHV kJ/kg 13000 29000 24,791

HHV (indicative only) kJ/kg 14000 30500 26,170

Proximate Analysis (as received; ar)

Moisture % ar 6.0 26.0 11.0

Volatile Matter % ar 18.5 40.0 38.68

Fixed Carbon % ar 19.0 60.0 39.14

Ash % ar 3.0 27.0 11.18

Ultimate Analysis (as received; ar)

Moisture % ar 6.0 26.0 11.0

Ash % ar 3.0 27.0 11.18

Carbon % ar 36.0 80.0 61.09

Hydrogen % ar 2.0 7.0 5.09

Nitrogen % ar 0.5 2.1 1.01

Chlorine % ar 0.0 0.2 0

Sulfur % ar 0.2 4.0 0.94

Oxygen % ar 3.5 14.3 9.67

Fluor % ar 0.0 0.025 0

4.8.1 Stockpile

The coal yard at the CPP plant is longitudinal with a single stockpile and a storage

capacity about 70,000 to 75,000 Met.



4.8.2 Stacker

One stacker, with a handling capacity of 500 t/h will be utilized for stacking coal. The

capacity is determined by the rate of incoming coal. The coal will enter the storage area

on a conveyor belt running along one side of the pile. The stacker jib is raised and

lowered (luffing movement) in order to reduce dust emission during stacking. The stacker

moves on a rail track (travelling movement). It operates semi–automatically.

For cost reasons, there is no redundancy in the stacking system. In case of stacker

unavailability, pay–loaders or bulldozers, or both, will be used to pile the coal.

4.8.3 Reclaimer

The stockpile is equipped with a portal scraper re–claimer with a reclaiming capacity of

approximately 200 t/h. The capacity is determined by the time required for filling the coal

day–bunkers in the boiler house. The portal scraper consists of a portal frame with a

scraper chain system, which can be raised and lowered. Coal is reclaimed on the outgoing

belt conveyor. The reclaimer operation is fully automated.

4.8.4 Coal Handling from Coal Yard to Boiler Bunkers

From the coal yard, a single belt conveyor line (no redundancy for cost reasons) with a

capacity of carrying 200 t/h will be used to transport the coal up to the crushing house. At

the crushing house, a screen and crusher will reduce the coal to 10 mm aggregate size.

The crushing system will have a crushing rate of 200 t/h, with redundancy.

The coal will leave the crushing house via belt conveyors of a 200 t/h capacity with

redundancy. Sampling equipment, magnetic separators and belt scales will be installed on

these belt conveyors. At the top of the coal bunkers, mobile tripper conveyor, with a

handling capacity of 200 t/h, will feed the bunkers of the two CFB boilers.

4.8.5 Fugitive Dust Suppression and Prevention of Spontaneous Combustion

The belt conveyors will be equipped with enclosures, except where it is not possible due

to position or function, e.g., when passing under hoppers and stacker feed belts.

Fog–type water sprays will be installed at critical places, such as at the extremity of the

stacker boom and conveyor transfer points, to avoid fugitive dust.

A water spray system will be set up in such a way that it surrounds the stockpile with

intermittent water sprays during times when dry weather and/or winds could dry out the

surface of the stockpiled coal. This will prevent the formation of dust at the surface of the

pile and the escape of fugitive dust. Treated wastewater from the plant will be reused to

the maximum extent for dust suppression.

Stockyard management will minimize the risk of overheating and spontaneous

combustion of the coal by strictly limiting the time that coal remains uncompacted.

Long–term strategic coal stocks will be compacted and sealed.

4.8.6 Coal Transportation from Ports to FFBL Plant Site

Coal will be transported, initially, from Karachi Port using existing port facilities and

eventually from Port Qasim. No new waterfront facility or expansion of the existing coal



yard will be required at Karachi Port. The Pakistan International Bulk Terminal Limited

(PIBT) is already in the process of developing a coal, clinker and cement terminal at Port

Qasim which will also handle FFBL‘s coal supply, along with that for other customers.

The latter will be FFBL‘s sole coal supply route once the new terminal becomes

operational.

Coal Transportation from Port to FFBL Plant

The 13 km route shown in Exhibit 4.3 from PQ to the Complex traverses the eastern

industrial estate on internal PQA roads.

The route for coal transportation from KPT to the Complex, shown in the same exhibit, is

made up of parts where industrial traffic, which includes all types of heavy vehicles, is

allowed for 24 hours (segment marked ‗24 hours‘) as well as parts, where heavy traffic is

allowed only between 11 pm and 7 am (segment marked ‘11 pm–to–7 am‘).

4.9 Limestone

The process flow for limestone is shown in Exhibit 4.8. Limestone will be delivered to

the plant by dumper trucks and shall be sourced locally from Thatta, Kotri and

Hyderabad. Approximately 250 t of limestone will be delivered over 10 or 12 trips per

week from the source to plant site via dumper trucks and unloaded in the limestone

storage area within the CPP Project area.

At the limestone unloading station, limestone will be simply dumped in the raw limestone

storage area or directly into an underground receiving hopper that discharges onto a belt

conveyor or bucket elevator. The limestone will then be transported to the raw limestone

buffer silo. The receiving station will include a weighing system, combined with the coal

weighing system. The conveying system will include a magnetic separator.

The limestone will be reduced by a mechanical crusher from particle size of 50 mm to

less than 1 mm. The fine limestone will then be sent to the storage silo, where it will be

pneumatically conveyed to the limestone bin in the boiler house, where it will be ready

for injection into the furnace according to process requirements.



Exhibit 4.8: Limestone Handling System for the CPP Project


Hagler Bailly Pakistan The Proposed CPP Project

R4V03FBE: 02/19/14 4-17

4.10 Gaseous Emissions and Control

At the existing complex there are a total of 10 functioning stacks in different sections

which include DAP, Urea and Ammonia manufacture; and Utility Gas Turbines.

Exhibit 4.9 lists the stacks in the existing complex.

Exhibit 4.9: Stacks in the Existing FFBL Complex


DAP DAP Plant Stack DX–531

Urea

Granulator Scrubbers UX–670

Coolers Scrubbers UX–670

4 kg/cm2 Absorber UX–331

Low–Pressure Absorber UX–331

Ammonia

Waste Heat Recovery Boiler V–405

Reformer Furnace Stack F–101

Fired Heater Stack F–1003

Utility Gas Turbine HRSG SX–601

Auxiliary Boiler SX–601

Once the CPP project becomes operational a total of nine stacks will be functioning. The

gas–based utility turbine stacks will no longer operate. In their place, one stack based on

coal as fuel will operate instead. Exhibit 4.10 presents the design flow rates for NOx,

SOx, PM10 and PM2.5 for the FFBL plant with the CPP project.

Exhibit 4.10: Design Flow Rates of NOx, SOx, PM10 and PM2.5 for FFBL

Plant with CPP Project.

Pollutant Unit Stack ID

DX–531 UX–670 F–101 SX–601 CX–xxx

NOx g/s – – 8.09 0.01 60.36

SOx g/s – – – – 126.06

PM₁₀ g/s 6.97 3.24 – – 4.44

PM2.5 g/s 2.32 1.08 – – 1.48

Note: Stacks that are not mentioned above have zero values for all pollutants

The Project will be equipped with the following systems and equipment to ensure

compliance with national and international environmental standards and emission limits:

Selection of Circulating fluidized bed (CFB) boiler technology, which results in

reduced generation of NOx owing to low operating furnace temperature.



R4V03FBE: 02/19/14 4-18

De–sulfurization with the help of sorbent (limestone) inside the CFB boilers to

capture and to prevent SOx emission

Fabric bag house filters for de–dusting of fly ash from coal combustion to prevent

particulate matter emission

Emission monitoring system at flue gas ducts of each CFB boiler outlet to

monitor NOx, SOx, PM, CO, temperature, CO2 and O2.

4.11 Wastewater Handling, Recovery and Disposal

The quantum and type of waste water are different from the existing fertilizer complex as

there will be no process plant. Effluents will comprise of mainly cooling tower blowdown

and stormwater. There will no chemical and oily effluent under normal operating

conditions, however, provision of spill prevention, control and recovery will be provided

for small chemical handling. Therefore, effluents from the CPP Project will result in only

a slight addition to the existing volume of effluents, mainly on account of cooling water

blowdown and stormwater (during rain). The overall volume of effluent from CPP and

the existing fertilizer complex combined will remain within the design effluent volume

for the existing complex.

Rainwater and water from washing activities will be collected in decantation basin and

reused in the coal yard area while during heavy rain, basin spill over will be provided.

Wastewater from the CPP Project will be categorized and treated as follows:

4.11.1 Effluents Containing High Suspended Solids Content

Effluents from washing activities and floor drains will be recovered in a decantation

basin and then in an oil/water separator. After treatment and filtration, these effluents will

be used for the dust suppression system in the coal pile area, conveyor transfer points

4.11.2 Chemically Contaminated Effluents

Chemicals will be used at cooling tower and boiler feed water (BFW) treatment which,

under normal operation, will not result in effluents except in case of spills if any. The

chemicals used are environmentally-friendly and the same as those used in the existing

plant. All chemical day tanks will be installed inside RCC dyke area to control spills if

any and will be connected to a chemical collecting pit for onward transport (via pump) to

a plant chemical sewer neutralization system prior to discharge to existing complex

Evaporation pond.

4.11.3 Water Steam Cycle Effluents

Water–steam cycle effluents will be recovered and sent to the cooling water basin after

heat recovery.



R4V03FBE: 02/19/14 4-19

4.11.4 Sanitary Wastewater

Sanitary wastewater will be disposed in a properly designed septic tank and soakage pit.

The soakage pit method is already in application at the existing Complex and will

continue to be used to discharge sanitary wastewater from the Project.

4.12 Ash Production and Disposal

The ash resulting from the combustion and flue gas dedusting process will be collected:

At the bottom of the furnace, as bottom ash or bed ash (about 20 to 30% of the

total volume of ash produced)

At the bottom of the air heater hoppers, as fly ash (up to about 5%), and

At the fabric filters, as fly ash (about 70 to 80%).

The collected ash is typically a mixture of fuel ash, unburned carbon residues and—with

the addition of limestone into the bed—calcium sulfate and unreacted lime. Exhibit 4.11

lists the estimated daily and annual quantities of fly ash and bottom ash expected to be

produced by the CPP project.

Exhibit 4.11: Estimated Daily and Yearly Quantities of Fly Ash and Bottom Ash

Produced by the CPP Project from 2 CFB Boilers based on 330 days of operation

(Design/Reference coal)

Total Daily Generation (Tonnes)

Normal Load


BMCR

Yearly Generation (Tonnes)

Normal Load


BMCR Load

Fly ash 75.75 133.44 25,000 45,000

Bottom ash

33.33 67.20 11,000 22,176

Total 109.08 200.64 36,000 67,176

4.12.1 Bottom Ash

Bottom ash is collected at the bottom of the furnace through a chute and extracted via a

screw which also acts as an ash cooler. The bottom ash is then pneumatically (or

mechanically) conveyed to the bottom ash silo. There will be one bottom ash silo per

boiler depending on plant arrangement. The collected bottom ash is evacuated via

dumper trucks.

4.12.2 Fly Ash

Collected fly ash is pneumatically conveyed from the fly ash hoppers to the ash silo.

There will be one fly ash silo per boiler. The fly ash leaving the silo is typically dry, and

shall be moisturized to about 10 to 12% moisture content by total weight of the fly ash

produced. This will be done prior to discharge to the dumper trucks in order to avoid dust

release during transportation. Should the fly ash be recycled, dry fly ash can also be

evacuated via tank trucks without moisturization.



R4V03FBE: 02/19/14 4-20

4.12.3 Dumper Trucks

The dumper trucks shall be covered after loading to ensure that no ash escapes during

transportation. If required, truck bodies and wheels will be cleaned before leaving the

plant to minimize the carrying of ash and dust onto the roadways.

Regarding ash truck logistics at the plant, it is proposed to use the coal weighing system

for this purpose as well. To the extent possible, ash exports shall be managed in a manner

that it does not occur at the same time as the coal supply.

4.12.4 Ash Disposal Site

Among all ash disposal sites considered by FFBL (Section 8.9.1), the three options that

are environmentally and commercially viable are:

Option 1: The slag disposal area owned by PSM outside of PSM plant limit.

Option 2: Barren land located 6 km southeast from the FFBL Complex.

Option 5: K-Electric‘s (formerly KESC) land-reclamation project in the PQA.

Both Option 1 and Option 5 are, however, future projects and may not be available for

ash disposal by the time the Project will become operational. Therefore, the best option

for ash disposal available at the moment is Option 2. Option 2 is a barren and empty

land which was previously used for sand excavation and is located outside the designated

industrial area of the PQA. It lies 6 km southeast of the FFBL Complex at a distance of

300 m from the national highway (N5). Section 9 considers the environmental impacts of

ash disposal at this site and proposes mitigation measures.

In the future, if and when the ash disposal options at PSM and K-Electric become

available, the former will be the best option on account that it is a developed site

designated for slag-disposal by PSM. Along with this option, FFBL may also utilize the

option of disposing ash in K-Electric‘s land reclamation project.

FFBL is also looking to provide the ash to local cement and concrete brick manufacturing

plants and other industries where the ash may be utilized. The ash disposal site options

are discussed in Section 8.9.1.

4.13 Emergency Diesel Generator

The diesel generator‘s function is to ensure the safety of equipment and people in case of

failure of all alternating current (AC) power sources at the plant. Consequently, the

startup reliability and the ability to take on expected loads are considered as essential

design criteria.

The diesel generating unit shall also be capable of handling an additional 10% overload

for 1 hour in every 12–hour period. Minimum continuous power capacity of the diesel set

shall be 400 kVA.

4.14 Fuel and Utilities Consumption

Exhibit 4.12 lists the requirement of different fuels and utilities by the proposed Project.



R4V03FBE: 02/19/14 4-21

Exhibit 4.12: Consumption of Fuel (Design Coal) for 2 boilers and Utilities by the CPP

Project

Coal as fuel (normal load) 992 327,254

t/d t/yr

Coal as fuel (BMCR)

1500

500,000

t/d

t/yr

Limestone (Normal load) 36.0 t/d

12,000 t/yr

Limestone (BMCR) 48.0 t/d

16,000 t/yr

Limestone (Worst coal) 112.8 t/d

40,000 t/yr

Instrument air As required

Service air As required

Service / Industrial water As required

Nitrogen gas As required

Start-up fuel As required

Basis: 330–day operation in a year.

4.15 Cooling Water System

Exhibit 4.13 shows the expected water consumption at the CPP Project. Water

requirements for the Project will be met using the water supply for the existing Fertilizer

Complex. Three types of cooling water systems will be involved in the proposed CPP

plant.

Exhibit 4.13: Expected Water Consumption at the CPP Project

Clarified water as cooling tower make–up from existing Complex 270 ~ 325 m3/h

Potable water/safety eye wash/showers from existing Complex 4.0 m3/h

Demin water from existing complex 20.0 ~ 26 m3/h

Basis: 330–day operation in a year.

4.15.1 Recirculating Cooling Water Induced Draft Cooling Tower

The cooling water will be pumped from a circulating water (CW) pump house to the

condenser, and from condenser outlet water will be sent to the cooling tower. Water

cooled in the cooling tower will be routed to the CW pump house and pumped back to

the condenser in a closed loop. Hence, only cooling water make–up is required to

compensate the losses due to evaporation, drift and blowdown.



R4V03FBE: 02/19/14 4-22

4.15.2 Closed Cooling System

A closed cycle cooling water system will be provided to supply demineralized cooling

water for the following:

Steam turbine generators and lube oil coolers

Fan / Pump bearings / Lube coolers

Any other equipment requiring treated cooling water.

The cooling water will circulate in a closed loop around the plant, and will be used for

removing heat through equipment heat exchangers to cool various plant equipment. Heat

will be dissipated to the auxiliary cooling water system.

4.15.3 Auxiliary Cooling System

Auxiliary cooling water will flow through the secondary side of the plate heat exchanger,

which will absorb the heat from the demineralized cooling water flowing on the primary

side. The auxiliary cooling water returning from the secondary side will join the main

cooling water return line and will be sent to the cooling tower for removing the absorbed

heat. The cold water from the cooling water basin will be pumped again by the auxiliary

cooling water pumps to the secondary side of the plate heat exchanger and the cycle will

thus continue.

4.16 Electrical System

The electrical system for the CPP Project will be based on double radial system

substations. The feeders, transformers, bus work, and all other components on each side

of the double ended substation/switchgear will be rated for 100% of the connected load to

allow for continuous operation through one line.

The electrical system will include the following equipment:

One main medium voltage (MV) 13.8 kV switchgear

Modifications to the existing MV 13.8 kV switchgear

Generators and their protection systems

Generator circuit breakers and neutral point cubicles

Transformers (step–down, 3–winding auxiliary transformers)

Static or brushless excitation systems

Synchronization systems

MV (2.4 kV), low voltage (LV) switchgears and motor control centers

Direct current (DC) UPS systems

Emergency diesel generators (common for all new units)

Electrical modules



R4V03FBE: 02/19/14 4-23

Power and I&C14 cables

Grounding and lightning protection

Electric motors

Updated load management system

Small appliances

60/50 rotary frequency converters and associated switchgear to feed 50 Hz load

Communication system, including public address (PA), telephone, hot lines, etc.

Emergency siren system

Electrical equipment for cathodic protection

Plant and building lighting and hazard warning lights

50/60 Hz , 3 phase and 1 phase power panels and sockets/outlets

All interconnections to existing fire alarms, CO2, PA, telephone, emergency siren,

cathodic protection, etc., systems at the Complex.

The CPP Project‘s electrical system will feed power directly into the existing 13.8 kV

60 Hz fertilizer plant grid, which is completely isolated from the national power grid

operating at 50 Hz. The new steam turbine generators and the existing gas turbine

generators will be able to operate in parallel directly on the 13.8 kV plant grid.

Frequency/speed control and/or droop control shall be used in order to stabilize the

frequency near 60 Hz and to achieve a correct loading distribution between generators.

Start–up power for the new production units will be derived by back–feeding from the

existing 13.8kV system.

Exhibit 4.14 and Exhibit 4.15 indicate the location of the proposed FFBL grid station

and the electricity distribution towers outside FFBL boundary wall. The high voltage

transmission and grid comprises of one step-up, 11/132 KV Power transformer, one

132 KV overhead or underground transmission line about 650 meters long from the

power transformer up to the grid station inside the FFBL complex battery limit. It also

consists of a 132 KV Grid Station comprising of double busbars, one transformer bay,

two outgoing feeder bays and one bus coupler bay. The grid station would be Indoor Air

Insulated.

The 132 KV transmission line will carry electricity from the plant premises to the

132 KV grid transmitting a maximum of 70 MW power to the K-Electric network. There

will be no significant negative impact of the construction of the high-voltage transmission

line and grid station for the Project. The line will be installed in a dedicated corridor

within the existing fertilizer complex which is an industrial land and will not pass over

the existing buildings in the periphery of the plant. Proper mitigation measures will be

adopted according to the Environmental Management Plan. The electricity will be

provided to the K-Electric network/national grid.

14

Instrumentation and Control Cables.



R4V03FBE: 02/19/14 4-24

Exhibit 4.14: Proposed Site for FFBL Grid Station



R4V03FBE: 02/19/14 4-25

Exhibit 4.15: Distance from the Grid to the Electricity Towers

4.17 Firefighting and Explosion Protection

Fire detection and fighting systems will provide fire suppression, independent fire

detection, standpipe and fire hose stations, and portable fire extinguishers to protect the

boiler house, turbine building, auxiliary buildings and equipment in the event of a fire or

explosion. The source of water will be taken from the existing 5000 m3

storage reservoir

for firewater.

The firefighting system and explosion protection system will be designed in accordance

with Pakistani laws and all national and local codes, standards and regulations. The

following international codes and standards will also be considered:

NFPA requirements:



R4V03FBE: 02/19/14 4-26

NFPA 850: ‗Recommended Practice for Fire Protection for Electric

Generating Plants and High Voltage Direct Current Converter Stations‘

NFPA 497: ‗Recommended Practice for the Classification of Flammable

Liquids, Gases, or Vapors and of Hazardous (Classified) Locations for

Electrical Installations in Chemical Process Areas‘

NFPA 70: National Electrical Code

European ATEX directives (94/9/EC and 99/92/EC)

EN50727 Part 2: Safety Requirements for Secondary Batteries, Battery

Installation, and Stationary Batteries

IEC 79 Part 10: Electrical Apparatus for Explosive Gas Atmospheres

Institute of Petroleum IP 15: Area Classification Code for Petroleum Industries,

Part 15

American Petroleum Institute – API Recommended Practice 505, 1st Edition,

1997: Recommended Practice for Classification of Locations for Electrical

Installations at Petroleum Facilities Classified as Class I, Zone 0, Zone 1 and

Zone 2.

4.18 Firefighting System

The purpose of the firefighting system is to protect FFBL‘s personnel through the use of

suitable materials to prevent fires from starting and by the use of equipment and systems

designed to limit the risk of fire and minimizing fire damage. The main objectives

defining the firefighting system design are as follows:

Detect the fire as quick as possible (fire detection)

Prevent spreading of the fire (fire risk areas protected and separated by structural

means)

Fight the fire in the most efficient way

Design access and escape routes properly with appropriate signage and signals

Collaborate closely with competent local fire brigades.

The combustible materials to be used in the CPP Project will mainly be the following

(since the generators will be air–cooled and not hydrogen–cooled, the latter flammable

gas is not a concern):

Coal as main fuel

Natural gas (used for startup of boilers)

Purge gas as secondary fuel continuously burnt in the boilers

Lube oil (steam turbines, generators, pumps and fans), control oil (mainly at

steam turbines), and transformer oil (if any)

Possibly electrical equipment materials and electronic cubicles.



R4V03FBE: 02/19/14 4-27

Water used in the hydrants, sprinkler and spray deluge systems for firefighting will be

supplied from the exiting firewater rings that will be extended around the Project. The

capacity of existing pumps, tanks, etc., shall be verified during basic engineering.

The following fire detection system would be applied to the CPP project:

Smoke detectors (optical) for rooms containing electrical equipment and cables in

closed areas, control room, false flooring in the control and electrical rooms, coal

handling system, coal mills or crushers, boiler areas (burners).

Flame detectors for coal systems (handling and crushing area), gas systems, and

boilers area (burners)

Heat detectors (‗rate of rise‘ heat detector, fixed temperature heat detector, release

sprinklers) for areas with electrical cables, transformers, for coal handling and

crushing systems, for boiler burners, and for gas systems

Manual push button alarms and shutdown for use by personnel

All signals generated by the equipment listed above will be integrated in a

centralized fire detection control unit (i.e., fire alarm panel in the control room).

The following firefighting system will be automatically activated in the respective areas

in case a fire is detected:

Spray deluge system for electrical cable areas, coal systems (handling, crusher)

Sprinkler system for oil systems (lube oil tank, oil tank)

CO2 system or equivalent (automatic release of CO2) for rooms containing

electrical equipment which are not normally occupied

Foam system

Outdoor pillar and indoor fire hydrants (foam/water) connected to the main

firefighting water ring

CO2 bottles and dry powder bottles for manual intervention at appropriate

locations (where applicable).



R4V03FBE: 02/19/14 4-28

4.19 Explosion Protection

All measures will be taken into account to reduce the risk of explosions and

inflammations, and to limit to a minimum potential damage to people and equipment in

case of an explosion.

To protect the installation against explosions, measures will be undertaken to:

Avoid creating explosive mixtures at the site

Avoid ignition when the presence of an explosive mixture cannot be avoided

Implement preemptive safeguards to minimize the damage caused by any

explosion that may occur despite all precautions

All equipment shall be selected/installed as per area classification requirements. Codes

shall be IEC–complaint for European, and NEMA–complaint for American, equipment.15

Regulations similar to EU ATEX directives will also be followed.16

15

IEC: International Electrotechnical Commission; NEMA: National Electrical Manufacturers Association.

16 The ATEX directive consists of two EU directives describing what equipment and work environment is

allowed in an environment with an explosive atmosphere.


Hagler Bailly Pakistan Description of the Environment

R4V03FBE: 02/19/14 5-1

5. Description of the Environment

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

the proposed CPP Project are described in this section. Information for this section was

collected from a variety of sources, including published literature, reports of other studies

conducted in the area, and surveys conducted specifically for this Project.

A field survey was conducted in July, 2013. Stakeholder consultations were also

conducted during this period. Appropriate standard scientific methods have been used for

each component of the study, and are described in the sections covering the respective

components. For all spatial information, Global Positioning System (GPS) was used to

mark the sampling sites. The GPS data were then used to produce maps, using

geographical information system (GIS) software.

In addition to the field visits specifically conducted for this Project, vegetation and

wildlife data for the area were compiled using previously published literature and from

assessments appearing in past studies conducted by Hagler Bailly Pakistan (HBP).

The proposed CPP project, within the existing FFBL complex, is located in the eastern

industrial zone of PQA.

5.1 Physical Environment Baseline

Physical environmental baseline data has been compiled using both primary and

secondary data. Overall the area in the vicinity of the Project constitutes barren land with

industrial units located towards the east and south of the Complex. The industrial estate

in the west of the Complex is yet to be developed.

The general elevation of the area is less than 10 m. Due to its close proximity to the sea,

the area is windy and humid. Data has been acquired from Pakistan Meteorological

Department Karachi Airport Meteorological Station to describe the climate of the area.

Soil and water quality data has been reported using samples collected in the field. A two-

week air monitoring survey was conducted in the proximity of the plant site to establish

ambient air quality baseline.

5.1.1 Topography and Landuse

The general topography of the plant site is flat and the elevation of the plant site and

surrounding areas is approximately 31 m with a general gradient towards the sea.

Port Qasim is located towards the southwest of the Complex. The Arabian Sea is to the

south of the plant site while all the major industries are located immediately in the east

and south of the FFBL plant (Exhibit 5.7).



R4V03FBE: 02/19/14 5-2

Exhibit 5.1: Industries Located in the Vicinity of the FFBL Plant



R4V03FBE: 02/19/14 5-3

5.1.2 Climate

Climate is the average course or condition of the weather at a place usually over a period

of years as exhibited by temperature, wind velocity, and precipitation. The climate at the

CPP site can be broadly categorized as having a hot and dry summer, and, mild winter

with heavy, sporadic, rainfall during the monsoon season.

Broadly speaking, there are four seasons in Pakistan. These seasons are defined on the

basis of temperature and the changes associated with the monsoon season. The southwest

monsoon is a wind system that prevails from April to October in the Indian Ocean, and is

characterized by a reversal in wind direction during the remaining months; and, heavy

rainfall over most of the Indian Subcontinent. Within Pakistan, considerable variation is

found in temperature and monsoonal changes. Thus, the specific characteristics and

duration of seasons depend on geographic location. The general characteristics of the

season near the Complex and surrounding areas are described on the basis of the weather

station closest to it. There is a weather station at Karachi Airport at 24° 54′ N, 67° 08′ E,

approximately 26 km northwest of the plant site. The climatic description of the area

presented in this section is based on the 30-year climatic data of Karachi Airport. The

hottest months are between mid-March to June in which the maximum average monthly

temperature exceeds 40 °C. The winters are mild with temperature dropping to 6 °C in

January. Karachi receives approximately 217.3 mm of rain annually. Almost 80 % of the

rain is concentrated in the monsoon season. The characteristic climatic feature of the four

seasons of Karachi is presented in Exhibit 5.2. Monthly temperature, rainfall and wind

data are provided in Exhibit 5.3 to Exhibit 5.5.

Exhibit 5.2: Seasonal Characteristics of the Climate of Karachi

Season Temperature Rainfall Wind

Summer (Mid-March to mid-June)

The summers are hot with temperature creasing from March 26.2

oC rising up to

40 oC in June.

There are less frequent rain showers in summer with no more than 1 or 2 rainy days in summer. Average total amount of rain in summer is around 10 mm

The wind speed in summer is variable it is around 2.5 m/s in March and rises upto 18 m/s in April and drops to 4 for rest of the season the direction mostly remains towards West

Monsoon (Mid-June to mid-September)

The temperature in monsoon remains high but relatively lowers than summer and oscillates around 32

oC.

Almost 80 % of the yearly rain occurs in the monsoon with July and August being the wettest month.

The wind direction in the monsoon is mostly towards East

Post-Monsoon Summer (Mid-September to November)

The average temperature post monsoon drops and average minimum temperature may reach 12 oC. in November

The post-monsoon remains mostly dry and rainfall in the November is around 1.8 mm

The wind speed in Septembers is around 3.7 m/s and drops to 1.4 m/s in November.



R4V03FBE: 02/19/14 5-4

Season Temperature Rainfall Wind

Winter (December to mid-March)

The winter is mild with January being the coolest month where average minimum temperature falls to 6

oC.

Like the other season except monsoon there is little occasional rainfall. The rainfall in winter is less than 50 mm

The wind speed in the winter season increase from 1.4 m/s in December to 2.6 m/s in March. The wind direction for most part winter season is towards North-East and changes its course towards West in early March

Exhibit 5.3: Average Temperatures (oC) of Karachi Airport Meteorological Station

Month Mean of Monthly Highest Recorded* Lowest Recorded*

Maximum Minimum Value Date Value Date

Jan 29.1 6.1 32.8 16/1965 0 21/1934

Feb 32.0 7.7 35.0 29/1960 2 11/1950

Mar 36.1 12.2 39.0 26/1977 8 2/1939

Apr 40.1 17.7 44.0 16/1947 13 5/1940

May 41.5 22.2 48.0 9/1938 18 9/1960

Jun 40.1 25.4 47.0 18/1979 22 3/1940

Jul 37.5 25.0 42.0 3/1958 22 22/1938

Aug 35.5 23.9 41.7 9/1964 23 12/1933

Sep 37.4 22.7 43.0 30/1951 18 30/1950

Oct 39.3 16.1 43.0 1/1951 10 30/1949

Nov 35.6 11.2 38.5 1/1986 6 29/1938

Dec 31.0 6.8 33.9 8/1963 2 30/1932

Annual 36.3 16.4 48.0 9-May-38 0 21 JAN 34

* Highest and lowest recorded temperatures are based on data collected at the Lahore meteorological station since it was established in 1928

Source: Pakistan Meteorological Department



R4V03FBE: 02/19/14 5-5

Exhibit 5.4: Rainfall measured at Karachi Airport Meteorological Station

Month Mean Monthly (mm)

Wettest Month* Mean Number of Rainy Days

Value (mm) Year

Jan 6.0 66.8 1976 0.5

Feb 9.8 96.0 1979 0.6

Mar 11.7 130.0 1967 0.4

Apr 4.4 52.8 1935 0.3

May 0.0 33.3 1933 0.0

Jun 5.5 85.9 1936 0.7

Jul 85.5 429.3 1967 2.6

Aug 67.4 359.4 1944 2.5

Sep 19.9 315.7 1959 0.7

Oct 10.0 98.0 1956 0.1

Nov 1.8 83.1 1959 0.2

Dec 4.4 63.6 1980 0.7

Annual 217.3 745.5 1944 9.4

* Based on data collected at the Karachi station since it was established in 1928

** ‗Rainy day‘ is defined as a day on which at least 0.1 mm of rain is recorded


Exhibit 5.5: Mean Wind in the Study Area

Month Wind Speed (m/s) Wind Direction

Jan 1.5 NE

Feb 1.9 VRB

Mar 2.6 W

Apr 18.7 W

May 4.2 W

Jun 4.5 W

Jul 4.7 W

Aug 4.4 W

Sep 3.7 W

Oct 2.1 W

Nov 1.4 NE

Dec 1.4 NE

Year 3.0 W

* VRB: Variable




R4V03FBE: 02/19/14 5-6

5.1.3 Air Quality

There are numerous small and large stationary sources of gaseous emissions around the

existing FFBL fertilizer plant (the ‗Complex‘) as it is an industrial area. Some of the

major stationary sources around the Complex are shown in Exhibit 5.6. Emissions from

these sources consist of oxides of nitrogen (NOx), sulfur dioxide (SO2), carbon monoxide

(CO) and particulate matter.

The air quality sampling component of the field survey was conducted from the

11th

to the 27th

of July, 2013. The following pollutants were selected for monitoring

ambient air quality within the 5 km Study Area around the fertilizer complex:

Sulfur dioxide (SO2);

Nitrogen oxides (NOx) including NO and NO2;

Respirable particulate matter (PM10, PM2.5, and Total Suspended Particulate

(TSP))

The selection was based on the expected emissions from the planned operations of the

Project and the level of risk to human health posed by these pollutants.

Sampling Locations

Three locations (A1, A2 and A3) were selected for air quality sampling taking into

account wind direction and the location of receptors close to the Project. All of the

pollutants listed above were tested at each sampling location.

The pattern of wind direction in the Project area is generally from the south to north in

July.17 Sampling site A1 represents ambient air conditions in the upwind direction of the

Project while A2 represents the ambient air conditions in the downwind direction towards

Ghaghar Phattak Colony, a residential area located, approximately, 1 km northeast of the

Project. The location for A3 was chosen taking into account the Arabian Sea Country

Club, a recreational facility located, approximately, 2 km west of the Project.

The sampling locations are listed in Exhibit 5.7 and shown on a map in Exhibit 5.8.

Exhibit 5.6: Major Sources of Air Emissions in the Industrial Set-up around Plant Site

Industries Approximate Distance from CPP Site (kilometers)

Exide Sulfuric Acid Plant 0.5

Geolinks Incineration Plant 3.0

Lotte Pakistan 5.0

Pakistan Steel Mill 6.0

Pakland Cement 15.0

K-ELECTRIC Power Plant 15.0

17 http://www.windfinder.com/windstats/windstatistic_jinnah_airport_karachi.htm



R4V03FBE: 02/19/14 5-7

Exhibit 5.7: Description of Ambient Air Quality Sampling Sites

Sampling Site

Location Parameters Elevation (m)

Latitude (N)

Longitude (E)

A-1 Upwind FFBL towards the south of the Complex

PM10, SO2, NO and NO2

28 24 48 59.5 67 24 51.1

A-2 Downwind of FFBL, towards the North of the Complex near Ghaghar Phattak colony

TSP, PM10, PM2.5, SO2, NO and NO2

34 24 50 38.4 67 25 56.3

A-3 Arabian Sea Country Club, West of FFBL

PM10, SO2, NO and NO2

29 24 49 52.4 67 23 28.5



R4V03FBE: 02/19/14 5-8

Exhibit 5.8: Location of the Ambient Air Quality Sampling Sites



R4V03FBE: 02/19/14 5-9

Methodology

SO2 and NOx were measured using diffusion tubes; whereas PM10 and PM2.5 were

measured using a MiniVol Portable Air Sampler. Details of ambient air quality sampling

parameter and equipment are provided in Exhibit 5.9.

Diffusion tubes were deployed at A1, A2 and A3 on July 11, 2013 and removed for

analysis after two weeks of exposure on July 25, 2013.

From the 19th

of July, 2013, to the 28th

of July, 2013, PM10, PM2.5, and TSP were tested at

the same sampling locations. At sampling point A2 (downwind of FFBL, towards the

north, near Ghaghar Phattak colony) PM10, PM2.5, and TSP were tested, whereas, at

sampling points A1 and A3, only PM10 was tested considering opposing wind direction

and an absence of human receptors (Exhibit 5.7).

Photographs of diffusion tubes and the low-volume sampler installed at the different

sampling locations are shown in Exhibit 5.10.

Exhibit 5.9: Details of Ambient Air Quality Sampling Parameters and Equipment

Parameter Equipment Exposure Duration Location for Sample Analyses

Air Quality

NOx, NO and NO2

Passive Diffusion Tubes 07-11-2013 to 07-25-2013 (Two Weeks)

Gradko Laboratory, UK

SO2 Passive Diffusion Tubes 07-11-2013 to 07-25-2013 (Two Weeks)

Gradko Laboratory, UK

PM10 MiniVol Portable Air Sampler

14 to 24 hours exposure at each sampling point on various dates between 07-19-2013 to 07-28-2013

HBP Laboratory, Islamabad

PM2.5 MiniVol Portable Air Sampler

24 hours exposure at sampling point A3 on 07-23-2013 to 07-24-2013


TSP MiniVol Portable Air Sampler

24 hours exposure at sampling point A3 on 07-27-13 to 07-28-2013




R4V03FBE: 02/19/14 5-10

Exhibit 5.10: Deployment Photographs of Equipment for Testing Air Quality

Photograph 1: PM Sampler deployed in upwind of FFBL, due south of the Complex

Photograph 2: PM Sampler deployed due west of FFBL near Arabian Sea Country Club

Photograph 3: Diffusion tubes deployed due west of FFBL near Arabian Sea Country Club

Photograph 4 : Diffusion tubes deployed downwind of FFBL near Ghaghar Phattak Colony

Results and Conclusion

Key observations are as follows:

At sampling point A1, upwind of FFBL, due south of the Complex, ambient air

concentrations of SO2, NO2, NO and PM10 are 22.8 μg/Nm3, 20.2 μg/Nm

3,

5.4 μg/Nm3 and 117.4 μg/Nm

3 respectively.

At sampling point A2, downwind of FFBL, due north of the Complex, near the

Ghaghar Phattak Colony, ambient air concentrations of SO2, NO2, NO, PM10,

PM2.5 and TSP are 22.5 μg/Nm3, 18.4 μg/Nm

3, 11.1 μg/Nm

3, 142.5 μg/Nm

3,

69.4 μg/Nm3 and 236.1 μg/Nm

3 respectively.

At sampling point A3, near the Arabian Sea Country Club, due west of the

Complex, ambient air concentrations for SO2, NO2, NO and PM10 are

12.2 μg/Nm3, 12 μg/Nm

3, 9.7 μg/Nm

3 and 122.6 μg/Nm

3respectively.

At all sampling points, the results for SO2 and NOx are within the limits prescribed by

both the National Environmental Quality Standards (NEQS), and IFC standards.

However, the baseline values for respirable particulate matter in these locations exceed

the prescribed limits of both standards. The results of the air quality samples taken at the

three sampling locations have been compiled and presented in Exhibit 5.11.



R4V03FBE: 02/19/14 5-11

Exhibit 5.11: Ambient Air Quality Results in the Study Area

All values in μg/Nm3

Location Location Sulfur Dioxide (SO2)

Nitrogen Dioxide (NO2)

Nitrogen Oxide (NO)

Particulate Matter

TSP Less than 10 Microns (PM10)

Less than 2.5 Microns (PM2.5)

A-1 Upwind of FFBL, due south of the Complex

22.8 20.2 5.4 – 117.4 –

A-2 Downwind of FFBL, due north of the Complex near Ghaghar Phattak Colony

22.5 18.4 11.1 236.1 142.5 69.4

A-3 Arabian Sea Country Club, due west of FFBL

12.2 12 9.7 – 122.6 –

NEQS 24-hour (98 percentile) 120 80 150 35

Annual arithmetic mean 80 40 120 15



R4V03FBE: 02/19/14 5-12

5.1.4 Water Resources

The Arabian Sea is the only major surface water body in the region. It is bordered on the

north by Pakistan and Iran, on the west by the Arabian Peninsula, and on the east by the

western coast of India. There are no major permanent water bodies in the immediate

vicinity of the Complex. The main surface water course / channel is the Ghaghar Nullah,

approximately 1.5 km due east of the Complex, which flows into the Gharo Creek, about

10 km south , towards the Arabian sea.

As part of the survey of the physical environment, water samples were taken on the 18th

and 25th

of July, 2013, at six different locations. The water samples taken at the point of

discharge of the FFBL effluents will be used to ascertain the baseline composition of the

effluents while samples taken along the Ghaghar Nullah were taken to investigate the

extent of effluents being discharged there by the industries in PQA. FFBL discharges its

effluents into the Port Qasim Authority (PQA) drainage channel which is an open-

channel drain that begins, approximately, 330 m away from the northeast corner of the

Complex, east from the plant‘s boundary wall. The PQA drain discharges into the

Ghaghar Nullah which flows south into the Gharo Creek.

The coordinates for the exact locations of the sampling sites and the test parameters for

laboratory analysis are given in Exhibit 5.12, and Exhibit 5.13 illustrates the exact

locations of the sampling points on a map. The samples were transported to the testing

laboratory in Islamabad and analyzed for the following parameters.

Physical parameters including pH, TDS and TSS,

Major ions including Sulfate, Fluoride, Chloride, Ammonia and Phosphate,

Oil and Grease,

COD and BOD,

Cadmium.

Other than the above, the water samples taken at the creek, W5 and W6, were also tested

for heavy metals such as Copper, Lead, Arsenic, Mercury, Barium, Boron, Nickel, Silver

and Selenium.



R4V03FBE: 02/19/14 5-13

Exhibit 5.12: Coordinates of Water Sampling Sites

Water Sample Location Date Parameters for Analysis

W1 24°50‗9.20"N

67°26‘16.51"E Ghaghar Nullah 18

th July, 2013

pH, Chloride, Oil & Grease, Phosphate, Ammonia, Free Chlorine, TDS, Sulfate, TSS, COD, BOD, Fluoride, Cadmium, Copper, Lead, Mercury, Selenium, Nickel, Silver, Arsenic, Barium, Boron

W2 24°50‘26.59"N

67°25‘26.08"E

At point of effluent discharge into PQA Drain 18

th July, 2013

W3 24°49‘38.50"N

67°26‘15.22"E Ghaghar Nullah 18

th July, 2013

W4 24°50‘21.41"N

67°25‘14.81"E

Within plant boundary wall just before discharging into PQA Drain. 18

th July, 2013

W5 24°46‘58.44"N 67°26‘24.79"E

Near the creek 25

th July, 2013

W6 24°46‘52.75"N 67°26‘23.39"E

Near the creek 25

th July, 2013



R4V03FBE: 02/19/14 5-14

Exhibit 5.13: Water Sampling Locations



R4V03FBE: 02/19/14 5-15

Exhibit 5.14: A Compilation of Results for Water Samples from the Project Area

Sample ID WFBEW1 WFBEW2 WFBEW3 WFBEW4 WFBEW5 WFBEW6

Coordinates 24°50’9.20"N, 67°26’16.51"E

24°50’26.59"N 67°25’26.08"E

24°49’38.50"N, 67°26’15.22"E

24°50’21.41"N, 67°25’14.81"E

24°46’58.44"N, 67°26’24.79"E

24°46’58.44"N 67°26’24.79"E

Source Type Wastewater Wastewater Wastewater Wastewater Wastewater Wastewater

Location Ghaghar Nullah At point of effluent discharge into PQA Drain

Ghaghar Nullah Within plant boundary wall

Near The Creek Near The Creek

Lab ID. E 04057 E 04058 E 04059 E 04060 E 04072 E 04071

Parameter Analytical Method

Unit Minimum Detection Limit

IFC NEQS

pH US EPA 150.1 0.1 6.0-9.0 6.0-9.0 8.3 8.0 8.3 8.0 7.91 7.96

Chloride SMEW mg/l 5 – 1000 308 269 318 285 31,329 35,317.06

Oil and Grease US EPA 413.1 mg/l 5 10 10 <5 <5 <5 <5 <5 –

Phosphate SMEW mg/l 0.1 – - 1.5 2.01 2.8 3 0.300 0.250

Ammonia SMEW mg/l 0.5 – 40 0.5 <0.5 1.01 0.8 <5 –

Free Chlorine SMEW mg/l 0.1 – 1 0.1 <0.1 0.1 <0.1 <0.1 –

TDS US EPA 160.1 mg/l 10 – 3500 2074 1863 1916 986 60,630 67,112

Sulfate US EPA 375.3 mg/l 10 – 1000 1038 918 915 271 4,668 4,847

TSS US EPA 160.2 mg/l 4 50 400 10 19 51 30 12.80 62

COD US EPA 410.3 mg/l 4 125 400 48 40 36 40 343 1,716

BOD US EPA 405.1 mg/l 5 30 250 11 10 8 10 – –

Fluoride US EPA 340.1 mg/l 0.1 – 10 <0.1 <0.1 <0.1 <0.1 0.45 0.50

Cadmium US EPA 200.8 mg/l 0.003 – 0.1 <0.003 <0.003 <0.003 <0.003 <0.001 –

Phenol US EPA 420.1 mg/l 0.05 – 0.1 – –



R4V03FBE: 02/19/14 5-16

Sample ID WFBEW1 WFBEW2 WFBEW3 WFBEW4 WFBEW5 WFBEW6

Coordinates 24°50’9.20"N, 67°26’16.51"E

24°50’26.59"N 67°25’26.08"E

24°49’38.50"N, 67°26’15.22"E

24°50’21.41"N, 67°25’14.81"E

24°46’58.44"N, 67°26’24.79"E

24°46’58.44"N 67°26’24.79"E

Source Type Wastewater Wastewater Wastewater Wastewater Wastewater Wastewater

Location Ghaghar Nullah At point of effluent discharge into PQA Drain

Ghaghar Nullah Within plant boundary wall

Near The Creek Near The Creek

Lab ID. E 04057 E 04058 E 04059 E 04060 E 04072 E 04071

Parameter Analytical Method

Unit Minimum Detection Limit

IFC NEQS

Sulfide US EPA 376.1 mg/l 0.5 1.0 – – – – – –

Chromium SMEW mg/l 0.100 – 1.0 – – – – – –

Copper US EPA 200.8 mg/l 0.005 – 1.0 – – – – 0.038 0.036

Lead US EPA 200.8 mg/l 0.005 – 0.5 – – – – – –

Mercury US EPA 200.8 mg/l 0.001 – 0.01 – – – – – –

Selenium US EPA 200.8 mg/l 0.005 – 0.5 – – – – 0.015 0.035

Nickel US EPA 200.8 mg/l 0.005 – 1.0 – – – – 0.052 0.048

Silver US EPA 200.8 mg/l 0.005 – 1.0 – – – – – –

Zinc SMEW mg/l 0.100 – 5.0 – – – – 0.300 0.500

Arsenic US EPA 200.8 mg/l 0.005 – 1.0 – – – – 0.143 0.142

Barium US EPA 200.8 mg/l 0.005 – 1.5 – – – – 0.044 0.036

Iron SMEW mg/l 0.100 – 8.0 – – – – – –

Manganese SMEW mg/l 0.100 – 1.5 – – – – – –

Boron US EPA 200.8 mg/l 0.001 – 6.0 – – – – – –

In the above table dash ( – ) means information not available or parameter was not analyzed



R4V03FBE: 02/19/14 5-17

PQA Drain Channel

The 3 m wide and 4 m deep rectangular Reinforced Cement Concrete (RCC) open-

channel drain shown in Exhibit 5.13 extends, approximately, 1,410 m east of the

Complex and ends at the Ghaghar Nullah. The nullah then courses south, along the

eastern edge of the PQA for, approximately, 7 km before discharging into Gharo Creek

near the sea. The results from the analysis of water sample W4 indicate that the effluent

being discharged into the PQA drain by FFBL is compliant with both NEQS and IFC

limits.

Exhibit 5.16 contains photographs at various locations along the PQA drain. The Textile

Institute is located adjacent to it, without an outlet into the drain. However, it was found,

during the field survey that the effluent in the drain was pumped out by the institute to

water the green areas within the institute‘s boundary walls.

The PQA drain site was previously also visited on the 18th

of July, 2013, to collect water

samples. The results from the water sample, W2, taken from the PQA drain indicate

compliance with NEQS limits for all parameters. All parameters were within the

prescribed IFC limits.



R4V03FBE: 02/19/14 5-18

Exhibit 5.15: The PQA Drain at the Northeast Corner of the FFBL Complex


Hagler Bailly Pakistan Description of the Environment R4V03FBE: 02/19/14 5-19

Exhibit 5.16: Photographs of the PQA Drain Channel

Effluent discharge from FFBL into the drain. The PQA drain with FFBL plant in the background.

Effluent in the PQA drain. The end of the PQA drain channel with Ghaghar Nullah

in the background.

Groundwater

FFBL has previously investigated groundwater resources in the area in search of

perennial raw water sources for meeting the Complex‘s process and non-process water

requirements. There are no known groundwater sources in the Bin Qasim area. A soil

survey of the plant area confirmed that there is no groundwater to a depth of 40 meters.18

During a field survey conducted for a previous EIA project in the Bin Qasim area in

1998, some groundwater wells were found in the nearby villages, most of which were

dry. Field surveys conducted for this project indicated there were no sources of

groundwater in the settlements surveyed within the 5 km study area around the Complex.

Surface Water

In the vicinity of the project area, the main surface water channel is the Ghaghar Nullah19

which lies quite close to the fertilizer complex (see Exhibit 5.15) and flows into the

Gharo Creek, about 10 km from the fertilizer complex. The Ghaghar Nullah remains dry

for most of the year. It only flows for about two months during the monsoon season, i.e.,

from July to August. Along most of its length, the nullah is 8-10 feet deep and its bed is

15-18 feet wide.

18 Soil Investigation Factual Report, FJFC Fertilizer Complex, Bin Qasim; Keller Grundbau GmbH –

Pakistan. 19

The term ‗nullah‘ means water stream in the local language.



The results from the water samples, W1 and W3, taken from the nullah indicate

compliance with NEQS limits for all parameters. The Gharo Creek in the Arabian Sea

will be the final receiving body of only excess stormwater (during rain) and cooling

tower blowdown from the CPP Project.

5.1.5 Traffic

Traffic surveys were conducted between the 22nd

and 30th

of July, 2013, at four locations

along the following routes:

the route for transporting coal from KPT to FFBL;

the route for transporting coal from Port Qasim (PQ) to FFBL;

the route for transporting ash from FFBL to the ash disposal sites;

Exhibit 5.17 lists the geographical coordinates of the traffic survey locations and states

the different durations for which the surveys lasted. Exhibit 5.18 illustrates the traffic

survey locations and Exhibit 5.19 describes the classifications of the vehicles surveyed

and PCU values assigned to each vehicle.

The traffic counts took place under normal working conditions. It is noteworthy that all

of the traffic counts were conducted during the Islamic holy month of Ramadan when

working hours in Pakistan are shortened. The flow of traffic during the month, especially

in the late evening, coinciding with the night prayers, may not be reflective of the normal

traffic behavior during particular time periods of the day. However, it would still be

representative of the total volume of traffic flow which would stay the same during the

holy month.

Exhibit 5.17: Summary of Traffic Survey Details

Survey Point

Survey Location Northing Easting Date Time Duration (Hours)

T1 Main Landhi Industrial Area Road

24°50‘55.21"N 67°12‘37.60"E 26th Jul 2013 2100 to 2200

hours

T2 Salar Khan Jokio Road (Ash Disposal Site ‗Option 3‘)

24°48‘56.02"N 67°29‘36.75"E 22nd

Jul 2013 1030 to 1200 hours

T3 Sunset Boulevard, DHA 24°50‘90.64"N 67° 3‘59.41"E 30th Jul 2013 2300 to 0700

hours

T4 Main Landhi Industrial Area Road

24°50‘51.35"N 67°12‘43.21"E 29th Jul 2013 24 hours



R4V03FBE: 02/19/14 5-21

Exhibit 5.18: Location of the Traffic Survey Points



R4V03FBE: 02/19/14 5-22

Exhibit 5.19: Vehicle Classification

Class Types Included PCU

Cars Sedans, coupes, and station wagons primarily used for carrying passengers. Includes both privately owned cars and taxis

1

Pickups Two-axle, 4-wheeled vehicles, other than passenger cars 2

Bikes Two wheeled vehicles 0.5

Rickshaws A three-wheeled motorized cabin cycle with seating space for up to three passengers.

0.86

Buses Vehicles manufactured as traditional passenger-carrying buses with two axles and six wheels. Includes conventional buses as well as minibuses with seating capacity of 30 or more passengers

2

Trucks Vehicles on a single frame, having two to six axles , used for carrying goods (each axle type was separtely counted)

3

Tractor Tractors and tractor lorries 3

Other Three wheeled vehicles and animal drawn carts 0.5

Passenger Car Unit (PCU)

Passenger Car Equivalent (PCE) or Passenger Car Unit (PCU) is a metric unit used to

assess traffic-flow rate.20

PCU, is a measure of the relative space requirement of a vehicle

compared to that of a passenger car under a specified set of roadway, traffic and other

conditions. The value assigned to each of the classification of the vehicles may depend on

a number of factors such as:

dimensions, power, speed, acceleration and braking characteristics of the vehicle;

road characteristics such as geometrics including gradients, curves, access

controls, type of road: rural or urban, presence and the type of intersections;

transverse and longitudinal clearances between vehicles moving on road, which in

turn depends upon the speeds, driver characteristics and the classes of other

moving vehicles;

environmental and climatic conditions and;

Traffic control methods, speed limits, and barriers.

The PCU for different classes of vehicles are not defined universally, however, the values

used here are typical for Pakistani road conditions.

Main Landhi Industrial Area Road

Two traffic surveys were conducted on the Main Landhi Industrial Area Road at a

distance of 200 m from each other shown in Exhibit 5.20. The road is a dual-carriageway

with two lanes on each side. A 1-hour survey was conducted at T1 from 9.00 pm to

20 Ahuja, Amanpreet Singh (2004). Development of passenger car equivalents for freeway merging section



R4V03FBE: 02/19/14 5-23

10.00 pm for consolidating the results from a night-time noise survey conducted at the

same location.

A 24-hour traffic survey was conducted at T4, also on the Main Landhi Industrial Area

Road, to record the baseline traffic conditions along this road segment. The Main Landhi

Industrial Area Road is part of the route from KPT to FFBL which is open to trucks for

24 hours. A 24-hour traffic survey was, therefore, conducted on this route to obtain

baseline information on existing traffic in order to be able to assess the impact of

additional trucks carrying coal from KPT, along this route, to the FFBL complex.

Exhibit 5.20 and Exhibit 5.22 display the results from the traffic survey from locations

T1 and T4 respectively.



R4V03FBE: 02/19/14 5-24

Exhibit 5.20: Traffic Survey Locations T1 & T4 in Main Landhi Industrial Area Road and T3 in Sunset Boulevard, DHA Phase II.



R4V03FBE: 02/19/14 5-25

Exhibit 5.21: 1-Hour Traffic Count from 2100 – 2200 Hours at

Sampling Point T1- Main Landhi Industrial Area Road, on the 26th July 2013

Location Cars Pick-up Bikes Buses Trucks Rickshaws Others Total PCU Heavy-weight Traffic (%)

Sampling Point T1

From KPT 140 31 495 73 167 199 0 1105 1268 22

Towards KPT 89 45 488 43 105 163 0 933 964 16

Exhibit 5.22: Hourly Traffic Count for 24 Hours from 0900 hours at T4 – Main Landhi Industrial Area Road, on the 29th July 2013

Time Cars Pick-up Bikes Buses Trucks Auto -Rickshaws Total PCU Heavy-Weight Traffic (%)

From KPT to FFBL

0900 to 1000 296 82 580 81 159 100 1298 1475 18

1000 to 1100 240 123 575 107 190 133 1368 1672 22

1100 to 1200 233 168 491 91 190 165 1338 1708 21

1200 to 1300 261 133 575 111 210 158 1448 1802 22

1300 to 1400 283 149 576 144 238 190 1580 2034 24

1400 to 1500 255 176 555 150 233 193 1562 2049 25

1500 to 1600 279 169 693 194 189 216 1740 2104 22

1600 to 1700 261 201 603 134 218 199 1616 2058 22

1700 to 1800 200 182 502 157 184 188 1413 1843 24

1800 to 1900 181 132 451 119 137 166 1186 1462 22

1900 to 2000 52 30 264 51 108 102 607 758 26

2000 to 2100 76 55 340 71 109 134 785 940 23



R4V03FBE: 02/19/14 5-26


2100 to 2200 119 67 368 82 145 119 900 1138 25

2200 to 2300 69 58 366 43 43 114 693 681 12

2300 to 2400 95 44 436 38 130 97 840 950 20

2400 to 0100 42 22 229 12 142 54 501 697 31

0100 to 0200 29 10 90 5 87 31 252 392 37

0200 to 0300 8 11 52 0 61 13 145 250 42

0300 to 0400 6 9 49 0 24 15 103 133 23

0400 to 0500 4 8 27 2 59 4 104 218 59

0500 to 0600 32 22 65 18 63 23 223 353 36

0600 to 0700 116 36 242 107 69 38 608 763 29

0700 to 0800 122 52 410 97 79 51 811 906 22

0800 to 0900 208 70 497 81 95 63 1014 1098 17

From FFBL to KPT

0900 to 1000 84 62 443 86 81 73 829 907 20

1000 to 1100 104 90 438 77 119 125 953 1122 21

1100 to 1200 129 128 564 71 126 162 1180 1326 17

1200 to 1300 177 110 787 86 161 219 1540 1634 16

1300 to 1400 164 160 648 83 167 150 1372 1604 18

1400 to 1500 205 132 666 119 158 154 1434 1646 19

1500 to 1600 203 158 755 130 180 169 1595 1842 19

1600 to 1700 325 162 917 142 175 184 1905 2075 17

1700 to 1800 224 120 719 162 209 200 1634 1947 23



R4V03FBE: 02/19/14 5-27


1800 to 1900 157 149 246 168 153 113 986 1470 33

1900 to 2000 41 56 208 40 92 84 521 685 25

2000 to 2100 132 77 332 85 89 96 811 972 21

2100 to 2200 75 71 252 73 71 144 686 826 21

2200 to 2300 36 36 360 21 83 124 660 686 16

2300 to 2400 44 43 291 19 105 81 583 698 21

2400 to 0100 18 27 140 10 33 43 271 298 16

0100 to 0200 18 8 48 1 24 19 118 148 21

0200 to 0300 10 2 35 1 21 13 82 108 27

0300 to 0400 6 22 42 0 19 7 96 134 20

0400 to 0500 11 9 28 7 33 9 97 164 41

0500 to 0600 18 44 76 45 36 41 260 377 31

0600 to 0700 41 61 247 74 51 60 534 639 23

0700 to 0800 43 78 418 102 95 86 822 971 24

0800 to 0900 67 47 499 83 82 68 846 881 20



R4V03FBE: 02/19/14 5-28

Salar Khan Jokio Road

A 1.5 hour traffic survey was conducted approximately 10 km east of the FFBL plant, at

the junction where the Salar Khan Jokio Road exits the National Highway (N5) towards

the north as shown in Exhibit 5.23.

The Salar Khan Jokio Road leads to the Ash Disposal Site,‘Option 3‘ and is also used by

inhabitants of a village located, approximately, 4 km north of the N5 and at a distance of

about 2 km from the ash disposal site. It is a single lane black top road shown in

Exhibit 5.24.

While taking soil samples and surveying the ash disposal site for ecological resources,

residents of the nearby village were asked about the existing traffic situation on the Salar

Khan Jokio Road; peak traffic times on it and the frequency of trucks traversing the road.

According to them, other than community traffic, the road is also used by heavy vehicles,

mostly sand laden trucks carrying excavated sand from nearby fields. However, the size

of the community traffic, mostly in the form of motorbikes, and the number of trucks

traversing the road are both low and do not impede each other‘s flow.

Based on the initial information from the client on ash disposal activities, it is estimated

that the number of trucks carrying ash from the Complex to ‗Option 3‘ will not lead to a

significant increase in the existing frequency and number of trucks already traversing the

Salar Khan Jokio Road road. Therefore, only a 1.5 hour traffic survey was conducted at

T2 from 10.30am to 12.00pm, corresponding with the peak traffic times This was done

merely to confirm the existing low flow and frequency of traffic on the road. Exhibit

5.25 shows the results of the 1.5 hour traffic count.



R4V03FBE: 02/19/14 5-29

Exhibit 5.23: Traffic Survey T2 at Salar Khan Jokio Road and N5 near Ash Disposal Site ‗Option 3‘



R4V03FBE: 02/19/14 5-30

Exhibit 5.24: A Truck on the Single-lane, Blacktop, Salar Khan Jokio Road

.

Exhibit 5.25: 1.5-Hour Traffic Count from 1000 – 1130 hours at

Sampling Point T2- Salar Khan Jokio Road.

Location Cars Pick-up Bikes Buses Trucks Total PCU Heavy-weight Traffic (%)

Sampling Point T2

From ‗Option 3‘ to Thatta 0 6 40 0 6 52 50 12

From Thatta to ‗Option 3‘ 0 6 44 0 3 53 43 6

From ‗Option 3‘ to Karachi 0 3 0 0 1 4 9 25

From Karachi to ‗Option 3‘ 0 2 1 0 0 3 4.5 0

Sunset Boulevard, DHA Phase 2

An 8-hour traffic survey was conducted at the Sunset Boulevard, a dual-carriageway with

3 lanes on each side passing through the center of Defense Housing Authority (DHA)

Phase II, an affluent residential area. T3, shown in Exhibit 5.20, is located on that part of

the route from KPT to FFBL which is restricted for use by trucks, except, between the

hours of 11.00pm to 7.00am. A night-time survey was, therefore, conducted between the

same hours to ascertain the baseline night-time traffic passing through the residential

area. Coal trucks from KPT will make their way towards FFBL from 11.00pm onwards

and contribute to the existing night-time traffic; hence, the need for determining the

existing baseline traffic situation to assess the impact from Project related traffic

activities through the area. The results of the traffic survey are given in Exhibit 5.26.



R4V03FBE: 02/19/14 5-31

Exhibit 5.26: Night-Time Hourly Traffic Count for 8 Hours from 2300 to 0700

at T3 – Sunset Boulevard, on the 30th

July 2013.

Time Cars Pick-up Bikes Buses Trucks Auto -Rickshaws Total PCU Heavy-Weight Traffic

From KPT to FFBL

2300 to 2400 535 222 775 63 465 159 2219 3024 24

2400 to 0100 393 93 665 29 212 111 1503 1701 16

0100 to 0200 293 54 480 8 141 95 1071 1162 14

0200 to 0300 146 22 309 1 53 46 577 545 9

0300 to 0400 109 24 247 1 67 39 487 517 14

0400 to 0500 32 9 44 7 93 8 193 372 52

0500 to 0600 69 31 96 46 62 10 314 466 34

0600 to 0700 70 28 143 71 81 25 418 604 36

From FFBL to KPT

2300 to 2400 339 55 382 16 341 166 1299 1838 27

2400 to 0100 266 39 202 7 180 99 793 1084 24

0100 to 0200 171 26 127 0 94 64 482 624 20

0200 to 0300 95 23 54 0 87 43 302 466 29

0300 to 0400 50 14 46 0 112 17 239 452 47

0400 to 0500 40 12 49 1 167 12 281 602 60

0500 to 0600 36 27 91 21 129 11 315 574 48

0600 to 0700 57 33 273 59 90 19 531 664 28



R4V03FBE: 02/19/14 5-32

5.1.6 Noise Survey

Two noise surveys were conducted at two dense residential areas along the coal transport

route from KPT to FFBL. The first noise survey, N1, was conducted on the 25th

of July,

2013, on the Main Landhi Area Industrial Road, while the 2nd

survey, N2, was conducted

on the 26th

of July, 2013 on the Sunset Boulevard. A third noise survey, N3, was carried

out for one hour at the same location as N1 on the 26th

of July, 2013. The purpose of N3

was to serve as a check for consistency in the measurements recorded by the sound meter.

Exhibit 5.27 lists the geographical coordinates of the noise survey locations and states

the duration for which the surveys lasted. Exhibit 5.28 displays the noise survey

locations on a map.

The equipment used for recording noise measurements was the Cirrus Optimus Red

Sound Level Meter (G061412, CR:1720) and the measurements were expressed in

Decibels (dB) and recorded using A-Weighting frequency weighting (dBA).21

Exhibit 5.27: Summary of Noise Survey Locations and Durations

Survey Point

Survey Location Northing Easting Date Time Duration (Hours)

N1 Main Landhi Industrial Area Road

24°50‘51.56"N 67°12‘43.21"E 25th

July 2013 2300 to 0700 hours

N2 Sunset Boulevard, DHA Phase II

24°50‘9.64"N 67° 3‘59.41"E 26nd

July 2013 2300 to 0700 hours

N3 Main Landhi Industrial Area Road

24°50‘51.56"N 67°12‘43.21"E 26th

July 2013 2100 to 2200 hours

21 The most common weighting that is used in noise measurement is A-Weighting. This effectively cuts off

the lower and higher frequencies that the average person cannot hear. [http://www.noisemeters.co.uk/help/faq/frequency-weighting]

http://www.noisemeters.co.uk/help/faq/frequency-weighting



R4V03FBE: 02/19/14 5-33

Exhibit 5.28: Location of the Noise Survey Points



R4V03FBE: 02/19/14 5-34

Main Landhi Industrial Area Road

A noise survey at N1 was carried out on the 1st-floor terrace of a 2-floor residential

apartment building on the Main Landhi Industrial Area Road with shops on the ground

floor (Exhibit 5.29). As described in Section 5.1.5, this road segment along the coal

transportation route from KPT to FFBL, is open to trucks for 24-hour traffic. However,

the coal trucks moving out of KPT would first have to traverse through a road segment,

along the same route, where trucks are only allowed on the road from 11.00 pm to 7 am.

Hence, coal trucks leaving KPT for FFBL will only start their journey at 11.00 pm which

implies that the effect of noise on the residents living along the Main Landhi Industrial

Area Road from the trucks carrying coal to the Project will be felt between 11.00pm and

7am. Therefore, noise survey N1, which lasted for nine hours, was carried out between

10:52pm up to 7:52am. Exhibit 5.28 illustrates the ‗24-hour‘ and ‗11pm-7am‘ truck

traffic road corridors along the Route.

Sunset Boulevard, DHA Phase II

A noise survey at N2 was carried out on the 1st-floor terrace of a house on the Sunset

Boulevard which passes through DHA Phase II (Exhibit 5.29). This road segment along

the coal transportation route from KPT to plantsite is open to trucks only between 11pm

and 7am. Coal trucks moving out of KPT have to traverse through this road segment first

before reaching the segment which is open to truck traffic for 24 hours for the rest of the

route to the Complex.

Noise generated from traffic activity related to the transport of coal from KPT to the

Complex will have an impact on the residents living along the ‗11pm-to-7am‘ road

segment during the night. Therefore, noise survey N2, which lasted for nine hours, was

carried out between 11:14pm up to 7:26am, in a house on the Sunset Boulevard, to obtain

baseline noise level measurements from traffic flow on the road at night.

Exhibit 5.30 to Exhibit 5.32 provide a summary of the results.



R4V03FBE: 02/19/14 5-35

Exhibit 5.29: Noise Survey at N1 – Main Landhi Industrial Area Road, and N2 – Sunset

Boulevard, Defence Phase 2.

At N1 with the balcony, where the noise meter was placed, in the background.

1st floor apartment balcony, at N1, where the noise meter was placed.

Noise meter in the balcony at night. N2, Sunset Boulevard from KPT.

Balcony where the noise meter was placed at N2. The noise meter, at N2, on the balcony at night.



R4V03FBE: 02/19/14 5-36

Exhibit 5.30: Summary of the Noise Survey

Noise Location N1 (Main Landhi Industrial Area Road)

N2 (Sunset Boulevard, DHA Phase I).

Date 7/25/2013 7/26/2013

Start time 10:51:53 PM 11:13:58 PM

End time 7:51:53 AM 7:29:13 AM

Duration 9 hours 08:16:23

LAeq1

69.1 dB 68.7 dB

LAFMax2

98.1 dB 92.7 dB

LAF103

71.1 dB 71.8 dB

LAF90 55.2 dB 58.7 dB

Notes:

1. LAeq is the A-weighted equivalent continuous sound pressure level. It is the constant noise level which, under a given situation and time period, contains the same acoustic energy as the actual time-varying noise level. It may be seen as an approximate mean level of the fluctuating sound.

2. The maximum level with A-weighted frequency response and Fast time constant.

3. LAFn: The A-weighted, n-percent exceeded level is the sound pressure level exceeded for n percent of the time, measured with a Fast time constant.

Exhibit 5.31: Chart Displaying LAeq and LAF Sound Measurements at

Noise Survey Location N1



R4V03FBE: 02/19/14 5-37

Exhibit 5.32: Chart Displaying LAeq and LAF Sound Measurements at

Noise Survey Location N2

5.2 Ecological Baseline

An ecological survey was conducted at the Project site and vicinity from the 20th

to the

25th

of July, 2013, during the Southwest Monsoon Period (June – September). The

objective of the study was to establish a terrestrial and marine baseline of the Project site

and vicinity. In addition to the field survey, reviews of available literature, and,

interviews with members of the local communities were carried out to gain information

about the biodiversity of the Study Area.

5.2.1 Scope

The specific objectives of the ecological baseline study were as follows:

A review of the available literature on the biodiversity of the Project site and

vicinity

Qualitative assessment of terrestrial ecological resources including vegetation,

mammals, reptiles, and birds

Qualitative assessment of marine ecological habitats

Documentation of populations and distribution of marine organisms.

Reports of wildlife sightings in the Study Area and vicinity by the resident

communities.

Identification of key species and determination if there is any potential critical

habitat and ecosystem services in the Project facility and surroundings.

5.2.2 Sampling Plan and Methodology

Seven sampling locations were selected to determine the baseline ecological conditions in

the Study Area during the South West Monsoon Period. Five sampling locations were

located in terrestrial habitats; one was located in the vicinity of Ghaghar Nullah, a

seasonal water body where the PQA drain discharges effluents; and, one sampling point

was located in marine habitat in Gharo Creek.



R4V03FBE: 02/19/14 5-38

The co-ordinates of the sampling points are given in Exhibit 5.33 and a map showing the

ecological sampling locations is given in Exhibit 5.34.

Exhibit 5.33: Coordinates of Ecological Sampling Locations

Sampling ID Latitude Longitude Habitat Type

E-1 24°49‘42.54"N 67°24‘26.85"E Plain in industrial area

E-2 24°49‘21.87"N 67°25‘02.44"E Plain in industrial area

E-3 24°50‘08.34"N 67°26‘23.18"E

Vicinity of seasonal water body (Ghaghar

Nullah)

E-4 24°47‘02.24"N 67°26‘54.37"E Creek

E-5 24°48‘51.16"N 67°21‘45.21"E Plain in ash disposal area





R4V03FBE: 02/19/14 5-39

Exhibit 5.34: Map of Ecological Sampling Locations in Project area and Vicinity



R4V03FBE: 02/19/14 5-40

Terrestrial Ecological Resources

An outline of the methodology used to sample the terrestrial ecological resource is given

below.

Vegetation: The area was sampled by the quadrate method, taking 3 quadrates of 10m x

10m at each sampling site. Abundant vegetation species observed in the quadrates were

noted. Plants collected were identified following the nomenclature from Flora of Pakistan

(Nasir and Ali 1972-199422, Ali and Qaiser, 1995-to date23).

Mammals: Line transects for mammals of 200 m by 20 m were placed at each sampling

location to record all animals or to have their signs detected. All the animals that were

sighted, or their signs detected (foot marks, droppings, dens), were recorded. The

specimens were identified with the help of the most recent keys available in literature

(Roberts 1997)24; and the GPS coordinates of the location was documented. Anecdotal

information regarding specific mammals was collected from the local people and relevant

literature was also consulted.

Reptiles: Line transects of 200 m by 20 m were placed at each sampling location and

reptiles were surveyed by active searching during the day. The sampling sites were

actively searched for all types of reptiles along the line transects. Active searching was

also carried out in sampling areas with a focus on suitable microhabitats. The specimens

were identified with the help of the most recent keys available in literature (Khan,

2006)25.

Birds: Line transects of 200 m by 20 m were placed at each sampling location to record

all birds observed. Transects were started as early as possible in the morning and in late

afternoon and covered all possible habitats. The coordinates of the starting point were

recorded. The birds were identified using the most recent keys available in literature

(Grimmett 2008)26.

Marine Ecological Resources

An outline of the methodology used to sample the marine ecological resources is given

below.

Only one sampling point, E-4 was located in marine habitat. To provide spatial coverage

and achieve reliability, three stations were sampled within this marine sampling point.

These stations were randomly selected to represent high, intertidal and low water

locations. The co-ordinates of these stations and the types of surveys undertaken are

listed in Exhibit 5.35 and a map of the three stations at Sampling Point E-4 is shown in

Exhibit 5.36.

22

S. I. and Nasir. 1972-1994. Flora of Pakistan Fascicles. Islamabad 23

Ali, S. I. and Qaiser, M. 1995 to date. Flora of Pakistan Fascicles. Karachi 24

Roberts, T.J. 1997. The Mammals of Pakistan. Oxford University Press Karachi. 525 pp

25

Muhammad Sharif Khan. 2006. Amphibians and Reptiles of Pakistan. Krieger Publishing Company,

Malabar, Florida, pp. 311. 26

Grimmett, R., Roberts, T., and Inskipp, T. 2008. Birds of Pakistan, Yale University Press.



R4V03FBE: 02/19/14 5-41

A linear diagonal transect sampling methodology was followed. A hand held GPS was

used to mark the location of each station sampled. Estimates of relative epipelagic species

abundance at each station were enumerated for faunal densities.

The ecological survey was conducted at low tide (0.8m) in the exposed tidal mudflats.

The sampling was carried out within an area of approximately 5 km. The habitat

components with the highest likelihood of being affected by the project were examined.

These included:

Mangrove habitat,

Mudflats habitats, surface benthic invertebrates and burrowing animal forms,

Pelagic fish community,

Marine mammals, turtles, and Endangered Species.

Exhibit 5.35: Description of Sampling Stations at Sampling Point E4

Station No.

Date Local Time

Substrate Type

Position Lat. Long

Sampling Location

Tidal Height

m

Type of Survey

E-4a. 24/07/13 1044 hrs Fine to coarse sand

N 24, 47,29.4

E 67,26, 21.8

High water tidal mark

0.8 Low. Ebb tide

Coastal habitat survey.

E-4b. 24/07/13 1100 hrs Muddy cum silty

N 24,46,52.1

E 67,26,22.3

Intertidal zone

0.8 m Epipelagic habitat survey.

E-4c. 24/07/13 1245 hrs Muddy cum silty

N 24, 46,00.8

E 67,26, 23.4

Low tidal zone

>0.8 m Flow tide

Epipelagic habitat and mangroves survey.



R4V03FBE: 02/19/14 5-42

Exhibit 5.36: Map showing Sampling Stations at Sampling Point E-4



R4V03FBE: 02/19/14 5-43

5.2.3 Results and Discussions

This section summarizes the results and discussions of the July 2013 ecological survey as

well as information gathered from literature sources and interviews with local community

members.

Mangrove habitat

The Project is located near Port Qasim which is part of the Indus Delta. The Indus Delta

supports the seventh largest mangrove forest system in the world (WWF-P)27. In the

Indus Delta mangrove ecosystem, eight species of mangroves have been reported out of

70 species known to occur in the tropical forests of the world. The Avicennia marina is

the dominant species of the mangroves in the Indus Delta. All other species are rare and

have disappeared from most part of the Delta due to adverse environmental/ecological

conditions28.

Out of 70 mangrove species worldwide 11 species (16 percent) have been placed on the

IUCN Red List29.

During the July 2013 survey, most of the mangrove plants observed was at Sampling

Point E-4. The most abundant mangrove species observed was Avicennia marina that

grows on the tidal mudflats having high organic matter. The mangroves density was

sparse and the plants grew intermittently in patches. Most of the plants were stunted,

most probably grazed down by domestic camels (Exhibit 5.37) and consisted largely of

juvenile plants. The height of the individual Avicennia plants was observed to be less

than1.0 m.

Exhibit 5.37: Mangrove Vegetation at Low Tide, and Domestic Camels Feeding

in the Study Area

Avicennia marina Domesticated camels feeding in the survey area

27

World Wide Fund for Nature- Pakistan, official website available at www.panda.org 28

Altaf A. Memon (May 14–19, 2005). "Devastation of the Indus River Delta". World Water & Environmental Resources Congress 2005. Anchorage, Alaska: World Wildlife Fund.

29 IUCN. 2009. IUCN Red List of Threatened Species (ver. 2009.2). Available at: www.iucnredlist.org.

http://en.wikipedia.org/wiki/World_Wildlife_Fund

http://www.iucnredlist.org/details/biblio/161547/www.iucnredlist.org



R4V03FBE: 02/19/14 5-44

Mudflats Habitats, Surface and Burrowing Animal Forms

Coastal areas and the intertidal region is a complex area where the division between land

and sea is unclear. The mudflat habitat was observed at Sampling Point E-4. Coastal

intertidal areas have a diverse range of communities that inhabit sandy shores, mudflats,

and mangrove. The epifaunal communities‘ observed in the surveyed area are

characteristic of very fine sediments from muddy to clayey. During the July 2013 survey,

the faunal communities observed in the mud flats at low tide were dominated by Uca crab

(fiddler Crab) and Boleophthalmus spp. (mud skippers) assemblages (Exhibit 5.38 and

Exhibit 5.39)

Exhibit 5.38: Male and Female Uca Spp (fiddler Crab)

Exhibit 5.39: Borrowing habitat of Boleophthalmus (mud skipper) spp

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

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

animals left behind and exposed by the receding tide.

Species Distribution Pattern

Three stations were sampled at Sampling Point E-4 during the July 2013 survey. The

Chi-Square Goodness of fit test was used to determine the species distribution pattern.

This test is based on frequency of occurrence and used in determining how well the data



R4V03FBE: 02/19/14 5-45

obtained from an experiment matches the expected data. It helps ensure the experimental

results are statistically significant and have not been caused by chance events.

The results of species distribution pattern at this site show that between high and low

high water mark Uca (fiddler Crab) and Boleophthalmus (mud skipper) dominated the

fauna. Both species showed an aggregated distribution pattern behavior. While the pea

crab, Scylla serrata (mud crabs) and Polycheat (Annelid worms) showed random

occurrences. (Exhibit 5.40).

Exhibit 5.40: Species Distribution Pattern of the Marine Invertebrate Taxa,

Surveys Conducted in July 2013.

Species Variance Mean Chi-sq d.f. Probability Aggregation

Uca spp (fiddler Crab) 136.3333 22.3333 12.209 2 0.0024 Aggregated

Boleophthalmus (mud skipper) 49 8 12.25 2 0.0023 Aggregated

Pea Crab 1.3333 0.6667 4 2 0.1328 Random

Scylla serrata (mud crabs) 4 2 4 2 0.1328 Random

Polycheat (Annelid worms) 2.3333 1.3333 3.5 2 0.1714 Random

Note:

Variance: Measure of how far a set of numbers is spread out

Mean: Average of numbers

Chi-sq: The chi-squared distribution (also chi-square or χ²-distribution) with k degrees of freedom is the distribution of a sum of the squares of k independent standard normal random variables.

d.f: Degree of Freedom.

Probability: Probability of chance occurrence of a given X² for an experiment with d degrees of freedom

Species Diversity Index

Species Diversity includes both species richness (number of species) and evenness

(relative abundance of the different species). Communities with a large number of species

that are evenly distributed are the most diverse and communities with few species that are

dominated by one species are the least diverse. Shannon Weiner Biodiversity Index, H

was calculated for the three samples collected from each station at Sampling Point E-4.

The Shannon-Weaver index H measures overall biodiversity. H is maximized when all

species have the same number of animals. The results are given in Exhibit 5.41.

The H max biodiversity values are generally low, ranging from 0.118 to 0.699. One of

the reasons for low diversity is that the entire Port Qasim area in the vicinity of the

Project is generally unstable and disturbed. Hence low diversity in such places is

expected. The Evenness Value J‘ increases from high water mark (station E-4a) towards

low water mark (station E-4c).



R4V03FBE: 02/19/14 5-46

Exhibit 5.41: Shannon Weiner Biodiversity Index at Sampling Point E-4

Index Station E-4a Station E-4b Station E-4c

Shannon H‘ Log Base 10. 0.118 0.475 0.431

Shannon Hmax Log Base 10. 0.301 0.699 0.602

Shannon J‘ 0.391 0.679 0.716

Pelagic Fish Community

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

wander among the mangroves at high tide (Bianchi, 1985)30. Subsistence fishing takes

place in the vicinity of the Port Qasim area during ebb and flow tides (Exhibit 5.42). The

local fisher folk use small gill set nets across small tidal creeks to trap between 2-10 kg of

fish in a day, mostly mullets, Boi (Mugil cephalus) The local fishermen are also engaged

in catching undersize juveniles of fish that is converted into trash fish, swimming crabs

(Portunus pelagicus) and juvenile shrimps (Metapenaeus spp) from the area. None of the

fish species observed or reported off the coast of Port Qasim area are listed as Critically

Endangered or Endangered in the IUCN Red list 2013.

Exhibit 5.42: Local fisherman netting fish, coastal fish Mugil cephalus (Boi)

Local fisherman netting fish at high tide in PQA Coastal fish Mugil cephalus (Boi) commonly used

as food by the local community

Marine Mammals and Turtles

Dolphins have been sighted in the Indus deltaic region and in the Port Qasim area.

However, the survey team did not observe any dolphins in the area during the survey.

There is no published information available with regards to the number of Cetaceans that

visit the Port Qasim area.

30

Bianchi, G. 1985. Field guide to the commercial marine and brackish-water species of Pakistan. FAO species identification sheets for fishery purposes. FAO, Rome, Italy.



R4V03FBE: 02/19/14 5-47

During the July 2013 survey, the team did not find any turtles, turtle remnants or turtle

tracks on the muddy shores in the Study Area. No turtle nest was observed. Turtles are

known to prefer sandy substrates instead of muddy substrates.

Vegetation

Other than Sampling Point E-4, most of the Study Area is located beyond tidal influence.

It is composed of mostly dry plain land, some seasonal water bodies and supports

characteristic xerophytic population. During the field survey a total of seven terrestrial

plant species were observed. These included Prosopis juliflora, Euphorbia caducifolia,

Calotropis procera, Capparis decidua, Typha elephantina and phragmites sp. The most

abundant among these were Prosopis juliflora, Euphorbia caducifolia, Calotropis

procera.

Mammals

During the survey, signs and scats of two carnivorous large mammal species - Jackal

Canis aureus and Fox Vulpes vulpes were commonly observed. Jackal Canis aureus is a

very adaptable animal and is included in Appendix III of the CITES Species List31 and

listed as Near Threatened in Pakistan‘s Mammals National Red List 200632. Signs of

Jackal Canis aureus were seen at Sampling Point E-5, E-6 and E-7. A footprint of the

Jackal seen at Sampling Point E-6 is given in Exhibit 5.43

Fox Vulpes vulpes is placed in Appendix III of the CITES list and listed as Near

Threatened in the Pakistan‘s Mammals National Red List 2006. Signs of Fox Vulpes

vulpes were seen at sampling point E-5, E-6 and E-7.

Occasional sightings of wolf, hyena and wild boars were reported by locals though signs

of these mammals were not observed during the July 2013 survey. Small mammals such

as rodents, hares, squirrels are also reported from the Study Area.

Exhibit 5.43: Signs of Jackal at Sampling Point E-6

31

UNEP-WCMC. 20 August 2013. UNEP-WCMC Species Database: CITES-Listed Species 32

Status and Red List of Pakistan Mammals. 2006. Biodiversity Programme IUCN Pakistan



R4V03FBE: 02/19/14 5-48

Avi fauna

Both water and land birds are found in the Study Area. Most of these birds are omnivores

while others scavenge on marine crabs and dead fish.

During the survey, a total of nine bird species were seen. Little Cormorant Phalacrocorax

niger, Grey Heron Ardea cinerea, Indian Pond Heron Ardeola grayii Great Egret

Casmerodius albus and Little Egret Egretta garzetta were seen around the coastal area

and wetlands at Sampling points E-3 and E-4. The Common Myna Acridotheres tristis,

Indian Robin Saxicoloides fulicatus and House Sparrow Passer domesticus were seen at

Sampling points E-5 and E-6 in barren plain while House crow Corvus splendens was

seen at Sampling points E-1 and E-2 near residential areas.

Information about the endemic and migratory birds of Indus Delta is given below.

Endemic Birds of Indus Delta

The mangroves of the Indus Delta provide abundant food and shelter to a number of

endemic species of birds. The common birds are Oystercatcher Haematopus ostralegus,

Lesser Sand Plover Charadrius mongolus, Greater Sand Plover Charadrius leschenaultii,

Grey Plover Pluvialis squatarola, Golden Plover Pluvialis apricaria, Little Ringed

Plover Charadrius dubius, Kentish Plover Charadrius alexandrinus, Sanderling Calidris

alba, Dunlin Calidris alpina, Curlew Numenius arquata , Whimbrel Numenius phaeopus,

Marsh Sandpiper Tringa stagnatilis and Common Sandpiper Actitis hypoleucos.

Breeding activities of a number of endemic birds have been reported in the coastal

wetlands of the Delta particularly Little Tern Sterna albifrons, Common Tern Sterna

hirundo, Gullbilled Tern Gelochelidon nilotica, Yellow legged Gull Larus michahellis,

Lesser Black backed Gull Larus fuscus and Great Black headed Gull Ichthyaetus

ichthyaetus.

Among these birds, only Common Curlew Numenius arquata is listed as Near

Threatened in IUCN Red List.

Migratory Birds of Indus Delta

Pakistan gets a large number of guest birds from Europe, Central Asian States and India

every year. These birds that originally reside in the northern states spend winters in

various wetlands and deserts of Pakistan from the high Himalayas to coastal mangroves

and mud flats in the Indus delta. After the winter season, they go back to their native

habitats.

This famous route from Siberia to various destinations in Pakistan over Karakorum,

Hindu Kush, and Suleiman Ranges along Indus River down to the delta is known as

International Migratory Bird Route Number 4. It is also called as the Green Route or

more commonly Indus Flyway, one of the important migratory routes in the Central

Asian - Indian Flyway 33

(Exhibit 5.44). The birds start on this route in November.

February is the peak time and by March they start flying back home. These periods may

33

Convention on the Conservation of Migratory Species. 1 February 2006. Central Asian Flyway Action Plan for the Conservation of Migratory Waterbirds and their Habitats. New Delhi, 10-12 June 2005: UNEP/CMS Secretariat.

http://en.wikipedia.org/wiki/Charadrius


http://en.wikipedia.org/wiki/Pluvialis

http://en.wikipedia.org/wiki/Pluvialis



http://en.wikipedia.org/wiki/Calidris

http://en.wikipedia.org/wiki/Calidrid

http://en.wikipedia.org/wiki/Curlew


http://en.wikipedia.org/wiki/Tringa

http://en.wikipedia.org/wiki/Actitis

http://en.wikipedia.org/wiki/Sterna

http://en.wikipedia.org/wiki/Sterna

http://en.wikipedia.org/wiki/Larus

http://en.wikipedia.org/wiki/Larus

http://en.wikipedia.org/wiki/Ichthyaetus


http://global.wetlands.org/Portals/0/external%20docs/Annex4_CAF_Action_Plan.pdf

http://global.wetlands.org/Portals/0/external%20docs/Annex4_CAF_Action_Plan.pdf

http://en.wikipedia.org/wiki/UNEP

http://en.wikipedia.org/wiki/Convention_on_Migratory_Species



R4V03FBE: 02/19/14 5-49

vary depending upon weather conditions in Siberia and/or Pakistan. As per an estimate

based on regular counts at different Pakistani wetlands, between 700,000 and 1,200,000

birds arrive in Pakistan through Indus Flyway every year.34

Some of these birds stay in

the lakes but majority migrate to coastal areas.

The common migratory waterfowl of the lakes in the Indus Delta include a variety of

ducks including Dunlin Calidris alpina, Redshank Tringa totanus, Coot Fulica atra,

White Pelicans Pelecanus onocrotalus, Flamingoes Phoenicopterus minor and Spoonbills

Platalea leucorodia. The Indus Delta also provides refuge for the rare species of birds

such as Painted Stork Mycteria leucocephala , White Stork Ciconia ciconia, Greater Knot

Calidris tenuirostris , Crane Grus grus, Ruddy Shelduck (Surkhab) Tadorna ferruginea,

Greyleg Geese Anser anser, Common Shelduck Tadorna tadorma and Marbled teal

Marmaronetta angustirostris.

Among these birds, Flamingoes Phoenicopterus minor and Painted Stork Mycteria

leucocephala are listed as Near Threatened while Greater Knot Calidris tenuirostris and

Marbled Teal Marmaronetta angustirostris are listed as Vulnerable in IUCN Red List.

Exhibit 5.44: Asian Migratory Bird Flyways

Source: http://alaska.fws.gov/media/avian_influenza/ak-flyway2.gif U.S. Fish and Wildlife Service/Alaska] |Author=U.S. Fish and Wildlife Service |Date=2008

34

Pakistan Wetlands Programme. 2012. Migratory Birds Census Report.


http://en.wikipedia.org/wiki/Tringa

http://en.wikipedia.org/wiki/Fulica

http://en.wikipedia.org/wiki/Pelican

http://en.wikipedia.org/wiki/Phoenicopterus

http://en.wikipedia.org/wiki/Spoonbill

http://en.wikipedia.org/wiki/Mycteria

http://en.wikipedia.org/wiki/Ciconia


http://en.wikipedia.org/wiki/Grus_(bird)

http://en.wikipedia.org/wiki/Shelduck

http://en.wikipedia.org/wiki/Anser_(genus)

http://en.wikipedia.org/wiki/Shelduck

http://en.wikipedia.org/wiki/Phoenicopterus

http://en.wikipedia.org/wiki/Mycteria




R4V03FBE: 02/19/14 5-50

Birds of Korangi/Phitti Creek system

The Port Qasim Areas is part of the Korangi/Phitti Creek system. A total of 52 bird

species have been reported from this creek system that belong to 30 genera and

12 families (Hasan 1996, 2006)35 (Exhibit 5.45).

Exhibit 5.45: Diversity of Bird Fauna at Korangi/Phitti Creek System

No. Family Genera Species Population Status

Abundant Common Less Common

1. Phalacrocoracidae 1 2 2

2. Pelecanidae 1 1 1

3. Ardeidae 4 7 4 3

4. Phoenicopteridae 1 1 1

5. Accipitridae 3 4 3 1

6. Charadriidae 7 18 1 9 8

7. Recurvistridae 2 2 - 2

8. Laridae 5 11 5 6

9. Alecedinidae 3 3 3

10. Meriopidae 1 1 1

11. Motacillidae 1 1 1

12. Corvidae 1 1 1

30 52 2 26 24

Table Source: Hasan (1996, 2006)

Of these birds, three are included in the IUCN Red List 2013 and listed as Near

Threatened. These are Painted Stork Mycteria ieucocephala, Black Tailed Godwit

Limosa limosa, and Eurasian Curlew Numenius arquata.

Reptiles

A low abundance and diversity of the reptiles species was observed in the Study Area.

Most of the reptiles observed were seen in the plains and near residential areas. During

the survey, a total of two reptile species were commonly observed in the Study Area.

These included Short-toed Sand Swimmer Ophiomorus brevipes and Sind Gecko

Crossobamon orientalis that were observed at Sampling Point E-1, E-4 and E-7.

35

Hasan, A., 1996. Biodiversity of bird fauna in mangrove areas of Sindh. In: Proc.UNESCO Workshop on Coastal Aquaculture (Q.B.Kazmi, ed.). Marine Reference Collection and Resource Centre, Univ. Karachi:. 21-26.

Hasan, A., S. I. Ahmad, 2006. Some Observations on Birds and Marine Mammals of Karachi Coast Rec. Zool. Surv. Pakistan, 17: 15 – 20

http://en.wikipedia.org/w/index.php?title=Ophiomorus_brevipes&action=edit&redlink=1

http://en.wikipedia.org/wiki/Crossobamon_orientalis



R4V03FBE: 02/19/14 5-51

5.2.4 Conclusions

1. The construction of the CPP site will take place within the boundaries of the

existing FFBL complex site which is located in a dedicated industrial area of Port

Qasim. Land disturbance as well as dust and noise generated during this

construction have little impact on the terrestrial fauna and avi-fauna owing of

presence and operation of existing fertilizer complex. Moreover, no mammal of

conservation importance has been reported from the area, even though the area is

visited by some migratory bird species, no Endangered or Critically Endangered

(in the IUCN Red List 2013) bird species have been reported. In any case, since

the CPP project will be constructed and operated with the existing FFBL

complex, no impact from Project construction and operation on, both, birds and

terrestrial ecological resources of the area is expected .

2. During operation effluents from the CPP project will mainly involve cooling

tower blowdown and stormwater. Both will be reused for horticulture, dust

suppression and for use on ash as wetting agent. Under normal operating

conditions water will be recovered and filtered and used for dust suppression at

various locations, floor washing, as well as fire mitigation at coal yard pile.

Sanitary effluents during construction and operation phases will be disposed of

through the existing septic tanks in the soakage pits. The CPP project is not a

chemical plant. Chemicals will be mainly used at cooling tower and in the Boiler

Feed Water. These chemicals are environmentally friendly and therefore it can be

concluded that during normal operation there will be no chemical effluent

discharged from the Project. However, in order to cater for spillage, protection

will be considered around the said processes to collect them in pits prior to

dumping them in chemical sewer basin via pump / pipes. The quantity of spill is

expected to be very small. Oil spill and recovery will be considered in the design

where there is a potential for oil spill. However, the quantum of the same is very

small and it will be recovered and dispose off as per existing practice in vogue.

3. Taking these points into account there is no danger expected to any marine life in

the vicinity of the Project site.

5.3 Socioeconomic Environment

The socioeconomic baseline study for the CPP Project examines the socioeconomic

setting of the communities located within 5 km of the FFBL fertilizer plant .

A socioeconomic survey was undertaken by HBP‘s social team from the 23rd

of July to

the 1st of August, 2013, with the objective of understanding the socioeconomic setting of

the communities that may potentially be affected by the Project activities. This baseline

information will be used in the EIA process to predict the socioeconomic impacts of the

Project. The process followed for collecting the baseline information and the key findings

of the field visit are documented in this section.

5.3.1 Scoping

The scoping phase of the EIA involved determining the issues to be addressed during the

EIA; the information to be collected, and the analysis required to assess the



R4V03FBE: 02/19/14 5-52

environmental impacts of the Project. The scoping phase benefits from the EIA team‘s

experience with similar projects and an understanding of the Project setting developed

during a scoping visit, which, for the CPP Project was undertaken on the 19th

and 20th

of

June, 2013. Through the scoping exercise, the following steps were completed:

Identification of the potential socioeconomic impacts of the Project;

Determining the area of influence against each potential impact;

Identifying the baseline information required to evaluate the potential impact.

The results of the scoping exercise are summarized in Exhibit 5.46.

Exhibit 5.46: Scoping Exercise for the EIA‘s Socioeconomic Component

Project activity: Development at the site and operations of the CPP

Potential Impact Area of Influence Information requirements

Generation of employment opportunities during Project construction and operations

Noise and vibrations from construction activity, resulting in disturbance and nuisance for nearby communities

Deterioration of air quality affecting health of nearby communities

Changes to local ecology and biodiversity due to the Project affecting existing use of resources

Positive impact on country‘s balance of payments (BoP) due to restoration of full production capacity and resulting lowered dependence on fertilizer imports

The intensity of the impacts on the biophysical environment is expected to reduce with increasing distance from the CPP site which implies that the human population located closer to the CPP site will be more affected.

Employment generation will benefit the nearby communities and the benefits may extend to a wider level, at the provincial or national levels

Positive impact on BoP will extend to national level

For communities residing near the CPP site information on existing:

Livelihoods and employment status

Health conditions and access to facilities

Skills assessment (literacy and occupational skills)

Physical and social infrastructure

Security conditions

At the provincial level, information on:

Economy and general socioeconomic profile

At the national level, information on:

Balance of payments

Changes to land affecting existing and potential land uses

Changes to air quality due to dust emissions during ash disposal affecting health of nearby communities

The site for ash disposal and its immediate surroundings

For the each ash disposal site option and its immediate surroundings, information on:

Existing land use

Potential land uses

Health conditions and access to facilities of communities in immediate surroundings



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Project activity: Development at the site and operations of the CPP

Potential Impact Area of Influence Information requirements

Noise and vibrations from the Project traffic resulting in disturbances at nighttime for the roadside inhabitants

The segment of the transport corridor Road segment from KPT to Qayyumabad, where Project traffic will pass at night time only

For the roadside inhabitants along the segment from KPT to Qayyumabad:

Nature, timing and frequency of disturbances or issues due to the passage of heavy traffic vehicles

Based on the scoping exercise, the socioeconomic study area (the ―Study Area‖) was

defined to include the following areas:

Area within 5 km of the CPP site, referred to as CPP Site Surroundings;

Area within 500 meters of the site options for ash disposal, referred to as the Ash

Disposal Sites;

Road segment from KPT to Qayyumabad36

Exhibit 5.47 shows the Project Setting which highlights the CPP Site Surroundings and

the coal transport routes from Karachi Port Trust (KPT) to Port Qasim (PA) to the FFBL

complex and also shows the ash disposal options..

36 The coal transport route from KPT to FFBL consists of a ‗11pm-to-7am‘ road segment from KPT to

Qayyumabad and a ‗24-hour‘ road segment for the rest of the way through Landhi and Korangi industrial areas to FFBL (see Section 5.1.5 on Traffic). Truck traffic on the former road segment is

allowed only between the hours from 11.00pm to 7.00am, while it is allowed for 24 hours in the latter. The former road segment traverses through designated residential areas while the latter traverses through industrial areas. Traffic-related issues during the night along the ‗11pm-to-7am‘ road segment were examined to understand the incremental impact from Project traffic on the residential areas along this segment.



R4V03FBE: 02/19/14 5-54

Exhibit 5.47: Project Setting



R4V03FBE: 02/19/14 5-55

5.3.2 Socioeconomic Baseline Survey

A survey was conducted in July, 2013, to collect baseline information on the

socioeconomic conditions prevailing in the Study Area. The survey lasted for 9 days.

Details of the survey are outlined below.

Methods of Data Collection

Information on the socioeconomic conditions prevailing within the Study Area was

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

The information was obtained from key informants: literate people, knowledgeable of the

socioeconomic conditions of their communities. Data collection for settlement surveys

was carried out using standardized questionnaires which is given in Appendix B. The

responses were recorded on the questionnaires by the social specialist from HBP‘s

socioeconomic team.

The main objective of the socioeconomic baseline Settlement Survey was to document

the existing socioeconomic conditions of the communities including demography,

livelihoods and access to social services. Principal areas covered in the village

questionnaire are listed below:

Demographic variables included (i) population, (ii) size of household,

Socioeconomic variables included (i) literacy and access to educational facilities,

(ii) access to health services, (iii) water supply and (iv) occupations.

The list of surveyed settlements along with their coordinates and the dates of the survey

are shown in Exhibit 5.48, whereas the locations of the surveyed settlements are shown

in Exhibit 5.49.

Exhibit 5.48: List of Surveyed Settlements

Date Location Coordinates

Jul 23, 2013 Soomar Jokiho 24 52 09.2 N 67 22 35.7E

Jul 24, 2013 Railway Colony 24 51 03.9 N 67 24 57.9 E

Jul 24, 2013 Haji Ibrahim Goth 24 50 33.1 N 67 25 59.6 E

Jul 25, 2013 Natho Tando Khoso 24 50 49.0 N 67 25 40.0 E

Jul 25, 2013 Haji Jhangi Khan 24 51 03.9 N 67 25 44.0 E

Jul 26, 2013 Haji Khan Zohrani 24 51 03.3 N 67 25 38.7 E

Jul 26, 2013 Humar Khan 24 51 28.3 N 67 25 46.3 E

Jul 27, 2013 Mir Khan Baloch 24 51 11.8 N 67 26 39.8 E

Jul 27, 2013 Haji Ghulam Muhammad 24 51 11.8 N 64 26 39.8 E

Jul 28, 2013 Ameen Muhammad Baloch 24 49 24.4 N 67 26 22.7 E

Jul 28, 2013 Pir Bux Goth 24 51 56.03 N 67 25 57.06 E

Jul 28, 2013 Muhammad Qasim Baloch 24 50 11.3 N 67 26 24.0 E

Jul 29, 2013 Morand Khan Qaserani Baloch 24 51 30.1 N 67 23 02.2 E

Jul 30, 2013 Allah Dino (Ash disposal site–Option 4) 24 48 04.0 N 67 28 42.5 E



R4V03FBE: 02/19/14 5-56

Exhibit 5.49: Location of Surveyed Settlements



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Survey Team

The survey team comprised of three members: a socioeconomic specialist responsible for

collecting settlement level data; a senior female sociologist, responsible for conducting

public consultations and collecting information from female community members; and,

one Sindhi-speaking field assistant.

5.3.3 FFBL Site Surroundings

Socioeconomic details of the communities located in the CPP Site Surroundings is

presented below:

Demography

During the socioeconomic survey, 13 settlements were surveyed to assess the

socioeconomic conditions of the 5 km Study Area around the proposed CPP site within

FFBL complex. The total population of the surveyed settlements was estimated to be

around 20,400. The largest settlement in the Study Area is Haji Ghulam Muhammad,

with an estimated population of 4,700 individuals, whereas Pir Bux Goth is the smallest

settlement with an estimated population of 65 persons. Exhibit 5.50 lists the number of

households and population of the surveyed settlements.

Exhibit 5.50: Demographic Profile of the CPP Site Surroundings

Settlement Population No. of Households

Soomar Jokiho, 1,100 150

Railway Colony 1,800 292

Haji Ibrahim Goth 2,300 350

Natho Tando Khoso 1,900 270

Haji Jhangi Khan 4,000 500

Haji Khan Zohrani 2,000 250

Humar Khan 1,000 100

Mir Khan Baloch 120 120

Haji Ghulam Muhammad 4,700 950

Ameen Muhammad Baloch 125 25

Pir Bux Goth 65 13

Muhammad Qasim Baloch 420 70

Morand Khan Qaserani Baloch 700 100

Total 20,230 3,085

Household Size

A household may either be a single person or a multi-person household. Household

members may be related or unrelated and essentially include people who make common

provisions for food and other essentials of living and have no usual place of residence



R4V03FBE: 02/19/14 5-58

elsewhere. The average size of the household in the surveyed settlement was 6.8 persons.

The maximum and minimum household sizes, recorded in the surveyed population were

10 and 5, respectively. The population residing in the area is largely rural and semi-urban

Religion and Ethnicity

Out of the total estimated population in the Study Area, 99.8% are Muslims. The other

0.2% of the population comprising of Hindus and Christians were reported mainly in Haji

Jhangi Khan Settlement, located in the northeast of the CPP site.

The ethnic makeup of the population within the Study Area comprises, mainly, of the

Kalmati caste, followed by Baloch, Khosa and Zoharani.

The main languages spoken in the area are Sindhi and Urdu.

Occupational Profile

Employment has a direct impact on poverty, income distribution and economic

development. There are certain issues inherent to employment such as literacy and skill

level. An unskilled and uneducated workforce is unable to compete in the global market

and contribute to economic development of the country.

Results from the settlements survey show that labor work was the main occupation in the

area. This is mainly due to low literacy levels because of which the labor-force residing

in the area are largely unskilled. Up to five percent of the employed were government

employees and an equal proportion is employed in the private sector, mainly the nearby

industries, where they work as peons, telephone operators and security guards.

Unemployment and underemployment are common issues reported in the area. There is

high competition for the daily-labor opportunities in the nearby industrial zone, as labor

supply exceeds labor demand. During the survey, it was reported that most laborers are

out of work for half the time in a year. The rate of daily wage labor is around Rs. 250 to

400 per day. Labor work includes work as masons, whitewashing, bagging and gardeners.

Physical Infrastructure

The condition of infrastructure in the surveyed settlements is poor. None of the surveyed

settlements in the Study Area reported having police stations, police check-posts and

natural gas facilities.

Housing and Other Structures

Over 62% of the living structures in the villages surveyed for the socioeconomic baseline

were of masonry construction, while the remaining were of adobe construction. Pictures

showing the living structures in the Study Area are shown in .



R4V03FBE: 02/19/14 5-59

Exhibit 5.51: Housing Structures in the Study Area

Masonry Construction Houses in the Study Area Adobe Construction Houses in the Study Area

The main market in the area is located in Ghaghar Phattak. The market contains general

stores, grocer shops, food-stores, and, mechanics and other service shops, while some

small shops for basic supplies exist in other settlements in the Study Area.

Exhibit 5.52: View of Shops in the Study Area

Shops at Haji Ghulam Muhammad Shops at Railway Colony

Every settlement in the Study Area had at least one mosque. The mosques were of

masonry construction, consisting of a single large prayer room or hall. The male

population of a settlement congregates for prayers.



R4V03FBE: 02/19/14 5-60

Exhibit 5.53: View of Mosques in the Study Area

Mosque at Haji Ibrahim Mosque at Mir Khan Baloch

Roads and Transport

Seven of the surveyed villages are connected by blacktop roads, whereas the remaining

settlements are connected by unsealed road. Regular transport facilities to the inhabitants

of the Study Area were in the form of taxis and buses. The inhabitants can easily access

the public transport from the national highway.

Power Supply

Electricity was available in nine of the thirteen surveyed settlements, supplied through

the K-ELECTRIC grid. Findings of the socioeconomic baseline survey show that fuel

wood is generally used for heating and cooking in settlement houses, whereas battery-

operated torches are used for lighting. This wood is usually collected from surrounding

areas. Mesquite bushes locally known as keekar, growing in the nearby lands, are the

main source of fuel wood. These are used in combination with larger logs which are

purchased from Ghaghar Phattak market or sellers roaming within the community. The

logs are available at a price of 150 to 300 per mund (mund is a local unit that equals 40

kg). LPG, being an expensive fuel alternative, is rarely used. LPG cylinders are available

in the Gulshan-e-Hadeed or Ghaghar Phattak markets.

Water Supply

Water supply is one of the major problems faced by inhabitants living in the Study Area.

Most of the underground water is brackish and saline. Up to 57% of the surveyed

settlements have access to potable water supplied and managed by the Karachi

Development Authority (KDA) through pipelines, while the rest of the settlements

purchase water from private tankers. The price of water per tanker varies between PKR

400 to 1,200, depending on the size of the tanker. One tanker meets six to eight days of

water requirements of an average household. FFBL has also established a reverse

osmosis (RO) plant in Natho Tando Khoso, which supplies water mainly to the Natho

Tando Khoso community and nearby residents.. Pictures showing the water supply and

storage sources in the Study Area are presented in .



R4V03FBE: 02/19/14 5-61

Exhibit 5.54: Water Supply and Storage Sources in the Study Area

Water Tank in Mir Khan Baloch Goth Reverse Osmosis (RO) Plant in Natho Tando Khoso

Water Supply from Private Tankers

Social Infrastructure

Improved socioeconomic conditions tie in with higher education levels and good health

of the people. An educated and skilled labor-force is more productive and contributes to

economic growth. Health is the basic right of every human and improved nutrition and

healthcare also contribute to bolstering the productivity of the human capital.

Education

Education facilities in the Study Area are provided by primary, middle and secondary

schools run by the provincial education department. Primary schools were reported in

80%, middle schools in 5% and high schools in only 7% of the surveyed settlements. A

primary school was also functioning under the Sindh Education Foundation37, located at

Natho Tando Khoso settlement.

Most of the schools were coeducational. FFBL has also established a girl‘s elementary

school in Haji Jhangi Khan, where education up to class eight is provided to girls.

37

The Sindh Education Foundation (SEF) was established in 1992 as a semi-autonomous organization to undertake educational initiatives in the disadvantaged areas of Sindh. SEF provides communities with direct access to educational facilities by opening schools through its various endeavors.



R4V03FBE: 02/19/14 5-62

Literacy rate for both males and females was reported at 36%. The literate people have

mostly attained education up to primary (5th grade) and matriculate levels (10th grade).

Pictures showing the education institutions in the Study Area are presented in

Exhibit 5.55: Education Institutions in the Study Area

Government Primary School at Mir Khan Baloch Government Boys Secondary School at Haji Ghulam

Muhammad

Health

Of the surveyed villages, it was reported that only one village, Haji Ghulam Muhammad,

had a hospital with 3 male doctors and 2 lady doctors, whereas, a dispensary is

functioning in Railway Colony with a visiting lady doctor. FFBL has also established a

clinic in Haji Jhangi Khan, which is operated by the Human Development Foundation

(HDF). 38The hospital and clinic at Gulshan-e-Hadeed are the main health facilities

located in the area. These facilities are, on average, located at a distance of 3 to 5 km

from the settlements.

The most common ailments reported were respiratory issues, cough and flu, followed by

Hepatitis C and eye problems among men and women.

Malaria and diarrhea were common among children with the lack of sanitation being the

main cause of diseases.

Crime and Security Conditions

There were almost no reported cases of conflicts, feuds, thefts, land disputes or other

serious crimes with the exception of some incidents of snatching and robbery which

occurred in the recent past in Railway Colony. The elders of the community are usually

approached to resolve all disputes and conflicts. The formal mechanisms, such as, police

are only approached if the elders are unable to resolve an issue.

38

Human Development Foundation (HDF) Pakistan was registered in 1999 as an independent organization in an effort to better deliver program services. HDF Pakistan is primarily responsible for program delivery but also forms partnerships with other organizations including international agencies like World Food Program and UNDP.



R4V03FBE: 02/19/14 5-63

5.3.4 Ash Disposal Sites

FFBL has thus far identified four site options for ash disposal. The ash disposal site

option at Pakistan Steel Mills (PSM) was visited first. Field visits to sites option 3 and

options 4 were undertaken by the field-survey team as these sites were identified prior to

the conclusion of the social team‘s field visit on 1st August, 2013. Site option 2 has been

identified more recently. The information presented for this site in this section is based on

observations of the HBP ecology team and information drawn from satellite imagery.

Ash disposal site options are shown in Exhibit 5.56.



R4V03FBE: 02/19/14 5-64

Exhibit 5.56: Ash Disposal Site Options



R4V03FBE: 02/19/14 5-65

Ash Disposal Site - Option 1: The site ‗Option 1‘ is a scrap and slag disposal area

owned by PSM outside of PSM plant limit. It is approximately 285 acres in size and

divided into more than 30 plots currently being used for storage and disposal of slag,

scrap and old refractory bricks. It is connected through Gate 9 of the PSM plant which

has access to external transportation for 3rd

party contractors.

The scrap yard is equipped with a security check-post and is connected by road to the

National Highway through the main PSM road.

Ash Disposal Site - Option 2: this site is located 6 km from the FFBL Complex, towards

southeast of the complex. The site is at a distance of 300 meters from national highway

(N5). The land is mostly barren and covered with mesquite bushes with very few housing

structures located at the northwestern edge of the site (Exhibit 5.57).

Exhibit 5.57: Photographs of Ash Disposal Site - Option 2

Ash Disposal Site

Ash Disposal Site - Option 3: This site is located towards the east of FFBL Complex, at

a distance of 11.5 km from the Complex. The area towards the north and east of the site is

all farmland, in which seasonal crops are cultivated (Exhibit 5.58). Some poultry farms

are located towards the northeast and west of the site.



R4V03FBE: 02/19/14 5-66


Ash Disposal Site

Agricultural Fields near the Ash Disposal Site Poultry Farms near Ash Disposal Site

Ash Disposal Site - Option 4: this site is located approximately 10 km from the FFBL

Complex, towards its east. It is towards the south of Option 3. The site is at a distance of

1 km from the National Highway (N5). Some community-owned agricultural fields are

located on the eastern edge of the site that fall within 500 m of it. Sand is also being

excavated from this site for construction purposes (see Exhibit 5.59). This site is no

longer being considered as an option for ash disposal by FFBL.

Within the 500 m radius of the Ash Disposal Site Option 4, there was only one

settlement, namely, Allah Dino, which is located towards southeast of CPP site. The

Allah Dino settlement comprised of a few scattered houses. The average household size

was about 7 people with an estimated population of 210 people.

The population of the settlement was entirely Muslim and belongs to the Kalmati ethnic

group. The main language spoken in the village was Sindhi.



R4V03FBE: 02/19/14 5-67


Ash Disposal Site

Agricultural Fields near Ash Disposal Site Settlement near Ash Disposal Site

Ash Disposal Site - Option 5: K-ELECTRIC is planning to convert its Bin Qasim

Thermal Power Station-I Unit No.3 and 4 to coal based boilers. They have planned to

utilize adjacent land (Option 5 in Exhibit 5.56) for reclaiming land by utilizing ash

generated during the operation of coal boilers. FFBL will approach K-ELECTRIC to

utilize the same land for FFBL CPP Project ash disposal.

5.3.5 Transport Corridor

After the completion of Pakistan International Bulk Terminal (PIBT) at PQ, coal will be

transported from PQ to Project site by road. The transportation requirement is estimated

at 300,000 – 500,000 tons of coal per year. However, until the PIBT becomes

operational coal will be delivered to the Project site via road from KPT.

The route that will be utilized for transportation of imported coal from KPT to the FFBL

site is approximately 55 km long and runs along the Moulvi Tamizuddin Road, Khayaban

e Roomi, Sunset Boulevard, Landhi Industrial Area, Korangi Industrial Area and internal

PQA roads. The road is a four-lane blacktop road, which is presently open for use to both

heavy and light traffic vehicles.



R4V03FBE: 02/19/14 5-68

FFBL to Qayyumabad Segment

The segment from FFBL to Qayyumabad is a four lane blacktop road with a length of

about 43 km which is presently open for use to both heavy and light traffic vehicles for

24 hours. According to the findings of the transport route survey, the road is in good

condition for most parts but there are some broken patches and inconsistent road surfaces.

Land Use Pattern

The land use pattern along the transport route varies between industrial, commercial and

residential areas. The land around the route from FFBL to the National Highway (N5), is

mostly barren. On the N5, up to 10 km, most of the land is barren with some settlements

in the beginning, followed by some housing societies, industries, colonies, shops and flats

located on either side of the road. From N-5 the segment passes through YB Chowrangi

Flyover and connects with the Main Korangi Industrial road, which is a densely

populated area comprising mostly of flats and shops.

The Main Landhi Industrial Area Road is a part of the route from KPT to FFBL which is

open to trucks for 24 hours.

Qayyumabad to KPT Segment

It is a four-lane road throughout its length of about 12 km. According to the findings of

the transport route survey, the road is in good condition. The segment of the route is open

to heavy traffic vehicles only between 11 pm and 7 am.

Land Use Pattern

On either side of the segment from Qayyumabad to KPT, the land is used for offices,

markets and residential purpose. This pattern continues up till the Sunset Boulevard,

which is about 1.5 km from Qayyumabad in the direction of KPT. The Sunset Boulevard

is a dual-carriageway with three lanes on each side passing through the center of Defense

Housing Authority (DHA) Phase II, an affluent residential area of the transport segment.

The route from the Sunset Boulevard to Khayaban e Roomi is surrounded by large

private houses on both sides. On either side of Khayaban e Roomi up to the Mai Kolachi

bypass the land is used for commercial activities with some residential houses. From the

Mai Kolachi bypass to Moulvi Tamizuddin road the area surrounding the road is sparsely

populated. In the last segment going from Moulvi Tamizuddin road to KPT, the land on

the right-side of the road is used by KPT, whereas, some shops and small houses are

located on the left.

Sensitive Receptors

During the transport corridor survey, sensitive receptors - those that can be potentially

affected by project-related traffic - were also identified. Only mosques and madrassahs

(religious seminaries) were found and interviewed along the transport corridor during the

survey. No other sensitive receptors such as shrines, graveyards, educational or health

facilities were found along the transport route.

To understand the nature of disturbances generated at nighttime due to the passage of

heavy traffic along the 11pm-to-7am road segment, interviews were conducted with the



R4V03FBE: 02/19/14 5-69

roadside inhabitants. The nature of disturbances is understood to change with the type of

building occupied by the inhabitant. To cover this aspect, interviews were conducted with

inhabitants of different types of structures, such as apartments and, large and small

houses. Mosques and madrassah (religious seminaries) were also interviewed since these

facilities are generally open for use at nighttime. No other facilities that are open for use

at nighttime were identified along the route. Locations along the transport corridor where

interviews were conducted are listed in Exhibit 5.60, whereas, locations along the

transport corridor where interviews were conducted are shown in Exhibit 5.61.

Most of the respondents reported that they had adjusted to the disturbances caused by the

traffic. Types of disturbances and issues reported include:

Vibrations generated from the passage of large trailers;

Traffic blockages in the early hours near Qayyumabad;

Noise generated from the pressure horns of heavy traffic.

Exhibit 5.60: List of Interviewed Locations

Location Coordinates

Timberland Area 24 49 53.6 N 66 58 59.7 E

Ghat Bandar 24 50 15.5 N 66 59 12.8 E

Railway Colony 24 50 44.8 N 66 59 46.4 E

Main Korangi Road 24 5 08.3 N 67 4 09.4 E

DHA Mor Phase II 24 50 11.2 N 67 04 02.7 E

Punjab Colony 24 49 44.6 N 67 02 55.7 E

Gizri 24 49 41.1 N 67 02 42.7 E

Clifton, Block 9 24 49 39.7 N 67 02 24.6 E

Boat Basin 24 49 37.9 N 67 01 47.6 E

Lalazar 24 50 40.4 N 66 59 57.6 E

Clifton, Phase 7 24 49 38.7 N 67 01 20.2 E

Bath Island 24 49 39.6 N 67 01 55.3 E

Punjab Chorangi 24 49 41.3 N 67 02 20.2 E

Naee Basti 24 49 43.0 N 67 02 38.6 E

Punjab Colony 24 49 45.7 N 67 02 57.7 E



Exhibit 5.61: Interview Locations along the Coal Transport Corridor from FFBL to KPT


Hagler Bailly Pakistan Stakeholder Consultations

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6. Stakeholder Consultations

As part of the EIA process, community stakeholder consultations were undertaken by the

HBP team, in conjunction with FFBL, from 23rd

July to 1st August, 2013. This section

summarizes the legal framework and the details of the process adopted for the

consultations during the field visit. Towards the end of the section, a summary of the

outcomes of the consultation meetings is also presented.

For a project, its stakeholders include groups and individuals that can take affect or can

affect the outcome of a project.39 The objectives of undertaking stakeholder

consultations during the course of the EIA for the CPP project were to;

Gather data and information on concerns of the stakeholders about their

socioeconomic and biophysical environment, as well as about the dependence on

their environment;

Ensure involvement of the stakeholders in the project planning and EIA

processes;

Seek input from the stakeholders on the planned project activities to increase

positive project outcomes and avoid or effectively mitigate negative project

impacts.

The views, interests and concerns of stakeholders were taken into account on the

following aspects of the Project:

Planning, design and implementation of the Project;

The assessment of the potential impacts of the Project and the identification of

appropriate mitigation measures;

The decisions by the regulatory authorities on whether to approve the project and

determination of corresponding conditions of approval.

6.1 National Regulations and International Standards for Stakeholder Consultations

The Project EIA will comply with relevant national legislation and will be conducted in

accordance with recognized international standards, such as those of International

Finance Corporation (IFC). The key stipulations of the national regulations and

international guidelines are given below.

39 This definition for Stakeholders is consistent with the definition adopted by the World Bank Group. See Stakeholder

Engagement: A Good Practice Handbook for Companies Doing Business in Emerging Markets, International Finance

Corporation, 2007.



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6.1.1 Pakistan Environmental Law

Public consultation is mandated under the Pakistan environmental law. The Federal

Agency, under Regulation 6 of the IEE-EIA Regulations 2000,40 has issued a set of

guidelines of general applicability and sectoral guidelines indicating specific assessment

requirements. This includes Guidelines for Public Consultation, 1997 (the ‗Guidelines‘).

Key extracts that represent the underlying theme of the Guidelines are given below:

Objectives of consultations: ―To inform stakeholders about the proposed project,

to provide an opportunity for those otherwise unrepresented to present their views

and values, providing better transparency and accountability in decision making,

creating a sense of ownership with the stakeholders‖;

Stakeholders: ―people who may be directly or indirectly affected by a proposal

will clearly be the focus of public involvement. Those who are directly affected

may be project beneficiaries, those likely to be adversely affected, or other

stakeholders. The identification of those indirectly affected is more difficult, and

to some extent it will be a subjective judgment. For this reason it is good practice

to have a very wide definition of who should be involved and to include any

person or group who thinks that they have an interest. Sometimes it may be

necessary to consult with a representative from a particular interest group. In such

cases the choice of representative should be left to the group itself. Consultation

should include not only those likely to be affected, positively or negatively, by the

outcome of a proposal, but should also include those who can affect the outcome

of a proposal.‖

Mechanism for consultations: ―provide sufficient relevant information in a form

that is easily understood by non-experts (without being simplistic or insulting),

allow sufficient time for stakeholders to read, discuss, consider the information

and its implications and to present their views, responses should be provided to

issues and problems raised or comments made by stakeholders, selection of

venues and timings of events should encourage maximum attendance‖;

Timing and frequency: ―Ideally, the public involvement program should

commence at the screening stage of a proposal and continue throughout the EIA

process.‖

Consultation tools: some specific consultation tools outlined in the Guidelines

that can be used for conducting consultations include; focus group meetings,

needs assessment, semi-structured interviews; village meetings and workshops.

Other important considerations: ―The development of a public involvement

program would typically involve consideration of the following issues; objectives

of the proposal and the study; identification of stakeholders; identification of

appropriate techniques to consult with the stakeholders; identification of

approaches to ensure feedback to involved stakeholders; and mechanisms to

ensure stakeholders‘ consideration are taken into account‖.

40 Review of Initial Environmental Examination and Environmental Impact Assessment Regulations, 2000



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6.1.2 International Standards

International guidelines, such as the Performance Standards by International Finance

Corporation and World Bank policies for environmental assessment, layout the objective

and approach for stakeholder consultations. Consultations are required for all

development initiatives that lead to environmental and social impacts.

Some of the main principles laid out for consultations include: 41,42,43,44

Stakeholder identification: Stakeholders include individuals and/or groups that

can be affected by or are interested in the development initiative. Consultations

should engage all types stakeholders, which can include potentially affected

communities, local government authorities, NGOs, academia and other civil

society bodies;

Selection of consultation techniques: Sufficient information should be shared

with the stakeholders in a timely and effective manner, with consideration for

stakeholder interests, linguistic and educational backgrounds, and socio-cultural

setting;

Arrangements for consultations: Venue and timing for consultation meetings

should be chosen in a manner that encourages maximum participation on behalf

of stakeholders;

Stages of consultation: Consultations should be conducted during the early cycle

of project development (scoping stage), so that the results and outcomes of the

consultations can contribute to the design process. Following this, stakeholders

should be provided feedback before finalization of the project‘s environmental

design (feedback stage) on how their concerns, raised at the scoping stage, were

addressed through suitable mitigation or design changes;

Stakeholder feedback and use of results: The views of stakeholders should be

documented and then analyzed for use in more effective decision-making.

6.1.3 Good Practice Principles

The good practice principles that were adhered to during the consultations are listed

below:

Cultural sensitivity: this requires understanding and appreciation of the social

institutions, values, and culture of the communities in the project area and respect

for the historical, cultural, environmental, political and social backgrounds of the

communities which are affected by a proposal;

41 Performance Standard 1, January 2012, International Finance Corporation.

42 Meaningful Consultations in Environmental Assessment, September 1998. This note was prepared by Shelton H. Davis and Nightingale Rukuba–Ngaiza based on the World Bank's Operational Directive 4.01 on Environmental Assessments.

43 Stakeholder Engagement: A Good Practice Handbook for Companies Doing Business in Emerging Markets, May 2007, International Finance Corporation.

44 Operational Directive OD 4.20, September 1991, The World Bank Operational Manual, The World Bank.



R4V03FBE: 02/19/14 6-4

Interactive approach: consultation should not be limited to one–way

dissemination of information. Stakeholder comments should feed into the EIA

process and proposed project design;

Open, transparent and informative: People who are affected by the Project and

are interested in participating should have access to relevant information, in a

simple and understandable format;

Inclusive and equitable: Ensure that all stakeholder groups are represented,

including less represented groups such as women, children, elderly and poor

people;

Appropriateness and flexibility: Consultation methodologies must be appropriate

to the specific phase of the EIA process and the stakeholder groups identified. The

consultation should also be adjusted according to the resources available;

Capacity building: Capacity building should be a part of consultation interaction

wherever appropriate and practicable.

6.2 Stakeholder Identification and Analysis

As stated earlier, stakeholders are defined as groups and individuals that can take affect

or can affect the outcome of a project. Stakeholders that can be affected by the Project

activities (first part of the definition of stakeholders) were identified through an exercise

undertaken at the scoping phase of the EIA summarized in Exhibit 5.46, and include all

groups and individuals that fall within the Study Area.

Groups and individuals that hold interest in the Project and can influence the Project

outcome (latter part of the definition of stakeholders) include:

Government and regulatory authorities directly or indirectly connected to or

overseeing, the activities of the Project;

Non–governmental organizations working in areas that can be affected by the

Project;

Academia that can be interested in transfer of skill and knowledge aspect of the

Project;

Based on the above, a list of stakeholders was drawn and provided in Exhibit 6.1. Given

the varying roles and educational backgrounds, stakeholders were divided into the

following target groups:

Institutional stakeholders;

Communities.

The stakeholders were identified on the basis of the most recent information and

understanding of the Project and its surrounding environment. Stakeholder identification

is a dynamic process as both stakeholders and their interests can change over the life of

the Project.



R4V03FBE: 02/19/14 6-5

Exhibit 6.1: Project Stakeholders

Community

1. All communities located within the 5 km (Study Area) of the CPP site

2. Communities located within 500 m of ash disposal sites

3. Roadside residents along the coal transport corridor segment from KPT to Qayyumabad

Institutional

1. All industries and offices located within 5 km of the CPP site

2. World Wildlife Fund

3. International Union for Conservation of Nature

4. Defence Housing Authority

6.3 Consultation Methodology

The methodology adopted for consultations was in line with the legal framework adopted

for the Project EIA. It is summarized below:

6.3.1 Consultation Material

The main document for distribution to stakeholders during the consultations was the

Background Information Document (BID). The BID contained information on the Project

and the EIA process. The BID for the Project is included as Appendix C. The

consultation material was made available to the stakeholders in Urdu and English, to suit

their language preference.

6.3.2 Community Consultation Mechanism

To ensure maximum stakeholder participation, the consultation meetings were scheduled

after discussions with stakeholders and invitations were extended in advance. A local

field assistant was sent to extend invitations to the communities a day in advance of the

meetings. Separate consultation sessions were arranged for the community women. The

community consultations were conducted with the community members within their

settlements to encourage and facilitate their participation. The list of communities

consulted along with the geographical coordinates and dates when the consultations took

place are shown in Exhibit 6.2. Communities where stakeholder consultations were

conducted are shown on a map in Exhibit 6.3. Photographic records of the consultations

with the men from the communities are presented in Exhibit 6.4, whereas, photographs

of consultations with the women of the community are not presented in consideration of

local customs and traditions. The meetings progressed in the following manner:

An overview of the Project and EIA process was provided to the community

representatives. The main point of the BID was read out to them in Sindhi and

Urdu;

Members of the communities were given the opportunity to raise queries or

concerns regarding the Project. Queries were responded to and concerns were

documented;

FFBL‘s intention to continue consultations through the life of the Project was

outlined.



R4V03FBE: 02/19/14 6-6

Exhibit 6.2: List of Communities Consulted

Date Location Coordinates

Jul 23, 2013 Soomar Jokiho, 24 52 09.2 N 67 22 35.7 E

Jul 24, 2013 Railway Colony 24 51 03.9 N 67 24 57.9 E

Jul 24, 2013 Haji Ibrahim Goth 24 50 33.1 N 67 25 59.6 E

Jul 25, 2013 Natho Tando Khoso 24 50 49.0 N 67 25 40.0 E

Jul 25, 2013 Haji Jhangi Khan 24 51 03.9 N 67 25 44.0 E

Jul 26, 2013 Haji Khan Zohrani 24 51 03.3 N 67 25 38.7 E

Jul 26, 2013 Humar Khan 24 51 28.3 N 67 25 46.3 E

Jul 27, 2013 Mir Khan Baloch 24 51 11.8 N 67 26 39.8 E

Jul 28, 2013 Ameen Muhammad Baloch 24 49 24.4 N 67 26 22.7 E

Jul 28, 2013 Pir Bux Goth 24 51 56.03 N 67 25 57.06 E

Jul 28, 2013 Muhammad Qasim Baloch 24 50 11.3 N 67 26 24.0 E

Jul 29, 2013 Morand Khan Qaserani Baloch 24 51 30.1 N 67 23 02.2 E

Jul 30, 2013 Allah Dino (Ash disposal site–South) 24 48 04.0 N 67 28 42.5 E



R4V03FBE: 02/19/14 6-7

Exhibit 6.3: Locations of Community Stakeholder Consultations



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Exhibit 6.4: Photographs of the Community Consultations

Community Consultation at Railway Colony Community Consultation at Haji Khan Zohrani

Community Consultation at Haji Jhangi Khan Community Consultation at Morand Khan Qaserani

Community Consultation at Humar Khan Community Consultation at Mir Khan Baloch

6.3.3 Institutional Consultation Mechanism

Letters to inform the institutional and industrial stakeholders about the objective of the

consultation process and to set up meetings with them were dispatched in the last week of

July, 2013. The BID was enclosed with the letters containing information on the Project

for the stakeholders. The list of the institutional stakeholders is provided in Exhibit 6.5.



R4V03FBE: 02/19/14 6-9

Exhibit 6.5: List of Institutional Stakeholders

Institutions Invited Date Consulted Venue

Textile Institute of Pakistan Aug 19, 2013 Arabian Sea Country Club

Lotte Pakistan Limited Aug 19, 2013 Arabian Sea Country Club

Arabian Sea Country Club Aug 19, 2013 Arabian Sea Country Club

Northwest Mineral Aug 19, 2013 Arabian Sea Country Club

Kausar Ghee Mill Aug 19, 2013 Arabian Sea Country Club

Peki Cakes Aug 19, 2013 Arabian Sea Country Club

Exide Sulfuric acid plant Aug 19, 2013 Arabian Sea Country Club

Worldwide Fund for Nature (WWF) Aug 20, 2013 WWF Office

International Union for Conservation of Nature (IUCN)

Aug 20, 2013 IUCN Office

Defense Housing Authority (DHA) Aug 20, 2013 DHA Office, Phase II

Wali Oil Mills Ltd

Invitations sent in the last week of July 2013 but stakeholder did not attend consultation session

Geolinks Incineration Plant

Linde Group Limited

Rasul Floor Mills

Port Qasim Authority (PQA)

A combined consultation meeting with the industries, located within 5 km of the CPP site

was scheduled on the 19th

of August, 2013 at the Arabian Sea Country Club, and,

separate consultation sessions were conducted with the rest of the institutional

stakeholders, at their offices, on the 20th

of August, 2013. The locations of the

institutional stakeholder are mapped Exhibit 6.6 Photographic records of the

institutional consultations are presented in Exhibit 6.7.

The combined consultation meeting with industries progressed in the following manner:

HBP provided a brief presentation comprising of an overview of the project

description and EIA process that was undertaken for the Project. The presentation

also included information on the structure of the EIA report to further facilitate

understanding of the EIA process;

Stakeholders were given the opportunity to raise queries or concerns regarding the

Project. Queries were responded to and concerns were documented;


outlined.



R4V03FBE: 02/19/14 6-10

Individual consultation sessions with the rest of the institutional stakeholders

progressed in the following manner:

Stakeholders were provided an overview of the Project description;

The EIA process that will be undertaken for the Project was briefly described and

the structure of the EIA report was presented to facilitate understanding of the

process;

Stakeholders were given the opportunity to raise queries or concerns regarding the

Project. Queries were responded to and concerns were documented;


outlined.



R4V03FBE: 02/19/14 6-11

Exhibit 6.6: Map of Institutional Stakeholder Locations



R4V03FBE: 02/19/14 6-12

Exhibit 6.7: Photographs of the Institutional Consultations

Consultation Session with Industrial Representatives at Arabian Sea Golf Club

6.3.4 Documentation and Reporting

The HBP team recorded all discussions during the meetings. An attendance record was

also maintained presented as Appendix D and series of photographs were taken.

6.4 Summary of Concerns

Exhibit 6.8 contains a summary of the concerns expressed by the stakeholders and the

relevant measures FFBL will take to address them. Exhibit 6.9 contains the detailed log

of the concerns emerging from both the community and institutional stakeholder

consultations.



R4V03FBE: 02/19/14 6-13

Exhibit 6.8: Summary of Concerns and Relevant Measures

Comments/Issues raised Relevant Measures

Air Quality

The impact of emissions from FFBL new project to be mitigated or minimized.

The Project will be equipped with latest technology and equipment to ensure full compliance with national and international environmental standards on emission limits.

Releasing of gases from the FFBL CPP plant may cause breathing problems in the area.

The new Project will be equipped with latest technology and equipment to ensure compliance with national and international environmental standards on emission limits. It will not contribute to breathing issues.

Agriculture fields have been ruined due the emissions from industries.

There are no agricultural fields close to the FFBL plant. The existing plant operations do not affect the agricultural fields located in settlements at a distance from the plant-site. The emissions and effluents from the CPP project are not going to impact the agricultural fields. All effluents and emissions will be within the NEQS limits and IFC guidelines.

Air emissions from the industries have affected agricultural fields .

FFBL emission from existing plants are within NEQS limits and composition do not affect agriculture fields.

The inhabitants of the village facing numerous diseases such as respiratory illnesses and eyes problems due to the emissions from surrounding industries and cement plants.

FFBL emission from existing plants are within NEQS limits. Moreover, new project will demonstrate the same.

Moreover the FFBL CPP project will be equipped with the latest technology to ensure compliance with national and international standards

The emissions from industrial activity, in particular a local cement plant, is contaminating the vegetation that serves as livestock feed, which is adversely affecting the health of the livestock

FFBL emission from existing plants are within NEQS limits.


The negative impact of emissions from FFBL should be mitigated or minimized.

FFBL emission from existing plants are within NEQS limits.




R4V03FBE: 02/19/14 6-14


How is FFBL going to control emissions so that the industries in the surrounding areas would not be adversely affected by contamination of ash and other gaseous emissions.

FFBL will be complying with National Environmental Quality Standards (NEQS) but also complying with the more stringent international standards such as those of World Bank Guidelines. There will be a proper emission monitoring program to monitor gaseous emissions from the plant. FFBL are in the process of receiving a recommendation for stack height design which will be based on air dispersion modeling.

Moreover, numerous environmental control and mitigation measures are undertaken by FFBL such as use of CFB boiler technology to ensure SOx capture within boiler and low NOx generation thanks to low furnace temperature, use of good quality coal, provision of dust suppression system, emission monitoring & control, etc

While there was no problem in the summers, during the winter the wind direction changes and is such that Lotte Chemicals is affected from the emissions from FFBL. They would like that information regarding air dispersion modeling and the resulting recommendation for stack height is shared with them so they can know how much they willbe affected.

HBP is working on air dispersion modeling based on which a design recommendation would be given for stack height. Their desire for taking a look at the recommendations from the modeling exercise has been noted and the client may share the results with them.

With regards to the fabric filters, whether there was a procedure in place for FFBL to shut down part or all of their operations in case the de-dusters malfunctioned and stopped working.

The de-dusters (bag house filters) have multiple chambers working at a time and if any one of those malfunctioned, the particular chamber could be stopped without stopping the entire de-duster..

In early 2002 the students living there suffered from excess gaseous emission into the air from nearby industries (either FFBL or acid plant) for a few days. Although such an incident had not taken place since, he harbored the fear that something of the same sort may happen again, specifically from NOx and SOx, with the new plant since wind direction blows air from FFBL in their direction. TIP also wanted to know the Air dispersion modeling done by HBP and the results of that.

HBP were looking into air dispersion modeling to come up with a safe stack height design which will keep the Textile Institute safe from its emissions. FFBL‘s emissions will be well below IFC standards to begin with. The initial design they were considering for the stack height is 70 to 80m.



R4V03FBE: 02/19/14 6-15


We are really concerned about the fly ash and in general wanted information about the stack height and results from air dispersion modeling.

HBP were looking into air dispersion modeling to come up with a safe stack height design. FFBL‘s emissions will be well below IFC standards to begin with. The initial design they were considering for the stack height is 70 to 80 m.

Moreover, Client has already considered strict environmental control measures by installation of Sorbent injection in boilers, bag house filters installation, etc

During the three ~ four months in the year the wind blows into the opposite direction (NE to SW) and during this time emissions from FFBL may be blown towards the city.

First the location is too far away from the City, therefore no impact foreseen. FFBL has already considered strictest environmental control measures by installation of Sorbent injection in boilers to SOx, bag house filters on each CFB boiler flue gas to control dust and low combustion temperature to limit the NOx, Emission Monitoring System on each boiler flue gas duct to stack, etc to ensure FFBL‘s emissions well below national and World Bank guidelines.

Moreover, HBP were looking into air dispersion modeling to come up with a stack height design to ensure adequate dispersions for area within diameter of 5 Kms.

Ash Production and Disposal

Due to ash and environmental pollution the trees will be damaged.

The new project will be equipped with the latest technology to minimize the negative impact of emissions. FFBL will also ensure compliance with national and international standards.

We are concerned about the fly ash and want to know whether the amounts of ash particles in the air would spread and settle on the surrounding industries contaminating them especially those dealing with food items like Bake Parlor.

The fabric filters in the de-dusting process filters the fly ash out of the flue gases. This process is more than 99.9% efficient in the removal of fly ash and particular matter /dust. In-addition, dispersion modeling is being carried out for the same.

Moreover, numerous environmental control and mitigation measures are undertaken by FFBL such as use of CFB boiler technology to ensure SOx capture within boiler and low NOx generation thanks to low furnace temperature, use of good quality coal, provision of dust suppression system, emission monitoring & control, etc



R4V03FBE: 02/19/14 6-16


Would the bottom ash be wet or dry? FFBL is still looking into the details for this. Use of blow down water from cooling tower to be used for sprinkling on dry ash (to moist the ash) prior to loading to dumping trucks .

What is the percentage of ash that would be produced? Ash produced would be around 4 to 12%, but it depends heavily on the ash content in coal feed and burning efficiency.

The ash disposal sites would be an area of concern for WWF since ash is an artificial environment and reptiles such as lizards and snakes suffer. He was also concerned that the ash had the potential of contaminating groundwater. The ash should be used as building material or in cement manufacturing instead of disposing it off in ash disposal sites.

HBP has already reviewed the sites after considering all these matter. Moreover, number of options for utilization also considered.

Coal-Type

Why FFBL was importing coal and not utilizing coal from Thar?

Quality of Thar coal is an issue owing to remote location and presence of high moisture. However, provision of use of local coal along with the imported coal is considered. Coal from Baluchistan / Sindh (of better quality) may also be used in certain percentage after considering sulfur and moisture aspects.

What the mercury content in the coal would be and what was being done to handle it?

Concern noted.

FFBL CPP project will be equipped with the latest technology to ensure compliance with national and international standards. Moreover, coal selection to consider this matter also.

We also want to know the sulfur content of the coal and whether there would be additional effluents discharged from the Project?

The sulfur content in the imported coal will be approximately 0.2-1.5%.

We want to know about the type of coal that would be used? This will be thermal grade coal. In the international market it is also referred to as ‗Steam Grade‘ coal.

Why was local coal with a higher sulfur content not being FFBL had to look into various parameters when choosing a



R4V03FBE: 02/19/14 6-17


considered given FFBL was using state of the art technology.

specific type of coal. It particularly had to consider the efficiency with which the coal would burn.

Fauji Group is already working on Fauji Oil Terminal and Distribution Company Limited (FOTCO), which will be importing LNG. Why FFBL is converting to coal

Natural gas more costlier while coal will be a good choice to replace existing Natural gas, even LNG is started to come.

Coal Transport

Why FFBL is not using Pakistan Steel Mill coal jetty? It would be the best option for coal even for FFBL who will benefit from a reduction of transport costs. After that he also strongly suggested that FFBL uses Pakistan Bulk International Terminal Limited (PBIT).

The PBIT/PQ or PIBT would become the primary transport route for importing coal once it would be completed.

Initially, the quality of storing and packing coals in the trucks is of a high standard but with time it reduces.

Client to ensure good transportation to avoid any spill as it is financial matter also.

FFBL should use Pakistan Steel Mill Jetty for importing coal and taking it to the FFBL Complex.

The PBIT at PQ would become the primary transport route for importing coal once it would be completed. PSM jetty is dedicated for PS.

A concern was raised about coal spilling from trucks and leachates contaminating groundwater at the coal yard site within the FFBL Complex.

Concern noted, contractors engaged to be instructed to ensure proper covering along the route of transportation to prevent any spillage which is also loss of costly material.

Consultations If the stakeholder session would be the only one or will other opportunities for information sharing be provided to them?

Although there will only be one such stakeholder consultation session of this kind, the stakeholders could get in touch with HBP or the client at any point in the Project.

Effluent Discharge

What would be the quantity and composition of effluent discharges and FFBL‘s effluent treatment methodology?

The quantity of effluent from CPP project will be very little and will consist of mainly stormwater (only during rain) and partly cooling tower blow down. It is to be noted that cooling tower blow down will be used for ash conditioning, horticulture, etc. There will be no chemical and oily streams during normal operations, however there will be no flow during normal operations however spill retention and recovery arrangement is being considered while sanitary effluent will be routed to septic tank and then to soakage pit as per practice in vogue.



R4V03FBE: 02/19/14 6-18


The area was principally a fishing ground before PQ was built. Since then the ecosystem and ecological resources in the area have undergone depletion and degradation.

CPP project will be installed within existing FFBL complex which will have control measures to prevent environmental issue. Moreover, the proposed project is far away from sea.

The mercury content in the fish had become high along with other heavy metals such as cadmium, arsenic, lead etc.

FFBL CPP project will be equipped with the latest technology to ensure compliance with national and international standards

Below the Port Qasim Industrial Estate area there are three layers of water: the subsurface water, aquifer and ground water. The leachates from FFBL‘s coal yard could be carried all the way into the groundwater during heavy monsoon rains. These heavy metal leachates from the ground water had the potential to reach the sea.

Water from proposed CPP project coal yard will be recovered and then stored, filtered and re-utilized i.e. water recovery management has been considered.

Reed Beds in the Ghaghar Nullah as mitigation against the effluents discharged there by FFBL.

The effluents from CPP project will be mainly storm (during rain) and cooling water blow down (during normal operation), both will be environmental friendly and utilized at CPP plant however some quantity will be disposed off especially during rain.

Electricity Production

With regards to FFBL‘s plans to export power to the National Grid theyiquired if FFBL had considered selling it to the industries in the Port Qasim Industrial Estate.

FFBL is putting extra margins in boilers and auxiliaries for power export through a 50 Hz steam turbine generator with complete accessories to the National grid. Due to the way the electricity distribution system was set up, they could not sell electricity directly to anyone. They can only sell it to local electricity company (k-Electric).

Is FFBL planning to install an electricity grid within the plant?

An electricity hook up arrangement with the grid would be set up within the plant.

Quality Assurance At times, the industries claim they are importing coal of some specific type while in reality they import cheaper coal which is extremely damaging to the environment. There should be transparency and a check on the coal that was being brought in by FFBL.

It has already been ensured. It also helps avoid damage to costly equipment like coal boilers.

Resettlement Whenever a company starts a project in the area, they move the local residing communities to another location.

It was clearly explained that FFBL plan to install new coal power plant on an empty space situated within the existing



R4V03FBE: 02/19/14 6-19


The inhabitants do not want to resettle. fertilizer complex. Therefore, no resettlement is required.

Traffic Impact The primary concern for DHA is additional congestion on the road from FFBL‘s coal truck traffic.

The quantity of coal required for CPP project is relatively small as compared quantity already being imported/transported to Pakistan moreover dedicated jetty is expected at PQ (PBIT) and same will be preference for transportation of coal to site. Therefore, this issue of congestion may be relieved by that time.

Traffic Impact The four bottlenecks within the Cantonment Board area where the congestion impacts will be felt the most are: submarine chowk, sundial chowk, sunset boulevard and , Ittehad-Korangi Junction. The solution for avoiding these would be to build flyovers over these four chokepoints. As a mitigation measure, FFBL along with all the industries in the Port Qasim Industrial Estate and other industrial sites which use these roads, chip-in with the construction costs of the flyovers along with DHA.

The quantity of coal required for CPP project is relatively small as compared quantity already being transported moreover dedicated jetty is expected at PQ (PBIT) and same will be preference for transportation of coal to site. Therefore, this issue of congestion may be relieved by that time.

Transport What would be the frequency of transport of limestone for the desulphurization process? It would add to the congestion of the internal Port Qasim roads which are already showing some signs of congestion and traffic.

The impact on roads from it will be very less as their consumption is small compared to other users in the country. The transport of both raw materials, coal & limestone, will not be on a regular basis but twice or thrice in a year when the ship comes in and coal is transported from the port to the coal yard within FFBL. Coal consumption by FFBL would be around 1000-1500 tonnes/day. Trucks will be covered with tarpaulin & will be damped as a mitigation measure prior to transport. And generally, since coal was their main fuel and valuable too, it will be in FFBL own interest to ensure that none is lost due to spillage en route.

Transport The poor handling of the limestone transport would mean a lot of spillage on the roads. Currently whenever sulfur was being transported in the area there was, at times, a lot of spillage. The spill would get blown up by wind which goes into their manufacturing systems and creates problems for them. The same applied for the transport of coal and at

Same as above



R4V03FBE: 02/19/14 6-20


present there were issues related to spillage in the area from trucks carrying materials for other industries which was adversely affecting them already.


Hagler Bailly Pakistan Stakeholder Consultations R4V03FBE: 02/19/14 6-21

Exhibit 6.9: Detailed Log of the Consultations

Date Meeting Venue Stakeholder Comments/ Issue raised by

Comments/Issues raised

Jul 23, 2013 Otaq of Village Soomar Jhokio (Men) Hajjan Soomro Employment opportunities to the local villagers.

Jul 23, 2013 Otaq of Village Soomar Jhokio (Men) Hajjan Soomro/ Habibullah Jokhio

The inhabitants are facing respiratory problems from the filtration of iron slag (or iron ore) by Pakistan Steel Mills, with the filtrate dumped near the village. Daily about 15 trucks of iron slag are dumped near the village.

Jul 23, 2013 Otaq of Village Soomar Jhokio (Men) Habibullah Jokhio As the settlement is located near the national highway, the villagers have to face dust and noise pollution generated from traffic.

Jul 23, 2013 Otaq of Village Soomar Jhokio (Men) Muhammad Siddique

The inhabitants would be happy, if some arrangement can be made for the provision of a primary school.

Jul 23, 2013 Residence of Ms Saeeda Johkio

Soomar Jhokio (Women)

Saeeda Johkio Unemployment is very common in the village.



Wheeda J Johkio Gas and electricity facilities to be provided to local communities.



Saeeda Johkio Whenever a company starts a project in the area, they move the local residing communities to another location. The inhabitants do not want to resettle.



Zainab Johkio No health and education facilities are available to local communities.

Jul 24, 2013 Hotel of Village Railway Colony (Men)

Abdul Sattar The impact of emissions from FFBL new project to be mitigated.


Abdul Sattar / Shameer Ahmed

There is no gas facility in the colony. SSGC has collected the fee for the supply of gas but no gas connection has been provided as yet. Someone to facilitate the villagers in obtaining access to basic facility of the gas connection.






Abdul Sattar Industries give authority to contractors to hire laborers. Contractors mismanage the local laborers and often hire non-locals as laborers. This practice should be discouraged and the contractors should be made accountable for their actions


Qambar Ali Due to nearby local cement operation, air quality of the colony is not good especially in winter (Dec to Feb).


Qambar Ali Due to the explosions conducted by nearby local cement, cracks have appeared in our flats. The frequency of explosions is once a week and 15-20 explosions per day.


Abdul Sattar The inhabitants would be grateful, if some arrangement can be made for the provision of a Reverse Osmoses (RO) system as the water quality supplied by KWSB is not good. There is no water quality monitoring system.


Abdul Malik In hiring process, contractor should not be involved as he deducts commission every month from the referred person.

Jul 24, 2013 Residence of Ghani Bux

Railway Colony (Women)

Shehnaz Khaskhali

The people of the village applied for jobs in company but no response received so far. Employment for local population should be considered by the nearby industries.

Jul 24, 2013 Residence of Ghani Bux

Railway Colony (Women)

Shabeera Burrio The basic facilities such as natural gas, electricity, health and education to the village.

Jul 24, 2013 Hotel of Village Haji Ibrahim Goth (Men)

Muhammmad Baloch

FFBL has provided health and Reverse osmoses (RO) facilities to Haji Jhangi Khan and Goth Nathan located at Ghaghar Phattak. We are also a part of Ghaghar Phattak and similar facilities to be provided to us.

Jul 24, 2013 Residence of Sultan Ahmed

Haji Ibrahim Goth (Women)

Sugran Ahmed/ Maryum Azeem

Natural gas, electricity and health facilities to the village to be provided.

Jul 25, 2013 Otaq of Abdul Wahid

Haji Jhangi Khan (Men)

Zamir Ali For the drinking water, Reverse Osmoses (RO) system should be installed in the villager.



Muhammad Ameen

BHU in the village is without doctor and medicines. People face many problems due to lack of medicines.







Ijaz Ahmed FFBL has established a clinic in the village but due to lack of medicines in the clinic people face numerous hardships. The clinic does not have the maternity facility. The said facilities to be provided.



Ijaz Ahmed Due to local cement operation, air quality gets ruined when the wind directions changes especially in winter (Dec to Feb).



Muhammad Ameen

Port Qasim Authority has laid channel to discharge effluents up to Textile Institute of Pakistan. It should be further expended to Arabian sea, so the effluent can be discharge in the sea.



Abdul Wahid FFBL with the help of Human Development Foundation (HDF) has initiated some projects in the village such as elementary school and health clinic. These projects should be monitored regularly.

Jul 25, 2013 Residence of Ghulam Shabir

Haji Jhangi Khan (Women)

Jamila Ali There should be a vocational or technical training center, which should provide trainings to the local community to enable them to work effectively.



Yasmeen Shabir Due occupying land by the factories deforestation has been increased and there is scarcity of fuel wood, therefore the community has to purchase fuel wood which causes more poverty to the community.



Jamila Ali Schools are available in the village but due to absence and lack of interest of teachers, those schools are not functioning effectively and standard of education is poor.



Sanam Manzoor Employment opportunities should be provided to the local people.

Jul 25, 2013 Residence of Mozzan

Naatho Tindo Khoso (Men)

Riaz Contractors looking for workers, hire people for jobs from outside their area. Employment opportunities should be provided to nearby communities.

Jul 25, 2013 Residence of Mozzan

Naatho Tindo Khoso (Men)

Abdul Qayyum/ Mozzan

The inhabitants would be grateful, if some arrangement can be made for the provision of health facility as similar provided to Haji Jhangi Khan village. We are also a part of Ghaghar Phattak and similar facilities to be provided to us by FFBL.

Jul 25, 2013 Residence of Naatho Tindo Khoso Mumtaz Mustafa The community is affected by smoke and bad odor generated by the





Mustafa (Women) industries.

Jul 25, 2013 Residence of Mustafa

Naatho Tindo Khoso (Women)

Zaheera Sajjad The inhabitants of the village apply for jobs in the nearby industries but the employment opportunities are not provided to them.

Jul 25, 2013 Residence of Mustafa

Naatho Tindo Khoso (Women)

Naseem Khatoon There should be a vocational training center for women in order to enable them to participate as effective individual of the society.

Jul 26, 2013 Residence of Haji Khan Zohrani

Haji Khan Zohrani (Men)

Muhammad Azam The people employed in the industries are getting very low wages. The minimum monthly salary should be set according to the government policy.

Jul 26, 2013 Residence of Haji Khan Zohrani

Haji Khan Zohrani (Men)

Khadim Hussain The clinic, established by FFBL in Haji Jhangi Khan. The clinic does not have the maternity facility. The said facilities to be looked into.

Jul 26, 2013 Residence of Gulam Hussain

Haji Khan Zohrani (Women)

Sanam Gulam The community is living below poverty line due to unemployment by factories.

Jul 26, 2013 Residence of Gulam Hussain

Haji Khan Zohrani (Women)

Haseena Ali/ Gindul Khan

High school for girls and drinking water should be provided

Jul 26, 2013 Residence of Muhammad Bux

Humar Khan (Women)

Asha Achar/ Barki Murad

Neither any teacher nor furniture is available in the school. Also, there is no teacher for education in the community.


Humar Khan (Women)

Barki Murad/ Kazbano

Drinking water for the villagers to be provided.


Humar Khan (Women)

Asha Achar Contractor system for employment of community members in the industries should be abolished and employment should be made in the industries directly.


Humar Khan (Women)

Barki Murad Bad odor and smoke causes nausea and vomiting.

Jul 27, 2013 Otaq of Village Mir Khan Baloch (Men)

Muhammad Ameen

Air emissions from industries are affecting agricultural productivity. This issue should be investigated and the causes should be mitigated.

Jul 27, 2013 Otaq of Village Mir Khan Baloch Gulzar Ahmed Agriculture fields have been affected due the emissions from nearby





(Men) /Muhammad Ameen

industries.

Jul 27, 2013 Residence of Bashir

Mir Khan Baloch (Women)

Bhagul Ameen Natural gas and electricity is not provided to the village.

Jul 27, 2013 Residence of Bashir

Mir Khan Baloch (Women)

Saleemat Ameen The village has one school, but due to absence of teacher, the school is not effectively working.


Haji Ghulam Muhammad Goth (Women)

Malhi Hepatitis C and other stomach diseases are common in the community.



Zarina Ramzan The community members were displaced due to the establishment of industries, but not a single employment is provided to the community members in the industries.



Najma Sudheer/ Janat Khatoon

A dispensary for the community to be provided .

Jul 28, 2013 Road side of the village

Ameen Muhammad Baloch (Men)

Muhammad Yousaf Baloch

Gas and water pipelines are crossing from the village but we are deprived from these facilities.

Jul 28, 2013 Residence of Muhammad Yusuf

Ameen Muhammad Baloch (Women)

Bachai There is no electricity, water and Sui gas in the community.

Jul 28, 2013 Residence of Muhammad Yusuf

Ameen Muhammad Baloch (Women)

Bhagul Hassan Health facility should be provided to the community

Jul 28, 2013 Otaq of the village

Pir Bux Goth (Men) Lal Khan Air emissions from the industries have ruined the agricultural fields of the village.


Pir Bux Goth (Men) Allah Bachayo The inhabitants of the village facing numerous diseases such as respiratory and eyes problems due to the emissions from FFBL and Dewan cement.

Jul 28, 2013 Otaq of the Pir Bux Goth (Men) Lal Khan The emissions from industrial activity, in particular local cement, is





village contaminating the vegetation that serves as livestock feed, which is adversely affecting the health of the livestock

Jul 28, 2013 Residence of Pir Bux

Pir Bux Goth (Women)

Rab Dini The emissions from industrial activity, in particular is contaminating the vegetation that serves as livestock feed, which is adversely affecting the health of the livestock



Soomri The community does not have any educational or health facility.



Soomri Drinking water is not available in community and water is purchased through water tankers and one water tanker costs about Rs.1200/-. The company should provide drinking water facility for the community.



Soomri The affected people of the Port Qasim area did not receive any compensation from PQA as yet.


Morand Khan Qaiserani (Men)

Muhammad Hanif Morand Khan Qasireni village is the affected community of the Port Qasim area and but we did not receive any compensation from PQA as yet



Pir Bux Qaserani Facilities are provided to other villages those are not affected due to their influence in government.



Pir Bux Qaserani We have filed a case against PQA for employment in 2009 but still waiting for the decision.



Pir Bux Qaserani Employment opportunities should be provided to the affected people.



Pir Bux Qaserani FFBL should facilitate the villagers in obtaining access to basic facility of education.



Ayaz Ahmed Qasierani

The village has the facility of primary and middle schools. There are so many educated people in the village. The teachers should be appointed from the village. The already appointed teachers are from outside the village and they are neither regular nor competent.


Morand Khan Qaiserani (Women)

Zarina Emissions from the nearby industries have caused eye diseases in the community.







Chagli Pir Bux The community has been displaced by Port Qasim Authorities, but alternate land provided for residence of the community is not suitable for their residence. Therefore suitable alternate land should be provided to community for residence.



Sughra Qadeer Drinking water should be provided to them.



Bakhtawar There is school in the community but the teachers are less in number as against the number of students and there is no female teacher for girls. Also, the furniture is not adequate for the students.

Aug 19, 2013 Albatross Hall, Arabian Sea Golf and Country Club

DGM Materials Management, Bake Parlor

Faisal Abubakar We are concerned about the fly ash and want to know whether the amounts of ash particles in the air would spread and settle on the surrounding industries contaminating them especially those dealing with food items like Bake Parlor.



Faisal Abubakar How is FFBL going to control emissions so that the industries in the surrounding areas would not be adversely affected by contamination of ash and other gaseous emissions.



Faisal Abubakar Why FFBL was importing coal and not utilizing coal from Thar?


Lotte Chemical Pakistan

Shabbir K. Hussain, HSE & Business Development Manager

If the stakeholder session would be the only one or will other opportunities for information sharing be provided to them?



Shabbir K. Hussain, HSE & Business

While there was no problem in the summers, during the winter the wind direction changes and is such that Lotte Chemicals is affected from the emissions from FFBL. They would like that information regarding air





Development Manager

dispersion modeling and the resulting recommendation for stack height is shared with them so they can know how much they willbe affected.




What the mercury content in the coal would be and what was being done to handle it?




With regards to the fabric filters, whether there was a procedure in place for FFBL to shut down part or all of their operations in case the de-dusters malfunctioned and stopped working.




What would be the frequency of transport of limestone for the desulphurization process? It would add to the congestion of the internal Port Qasim roads which are already showing some signs of congestion and traffic.




The poor handling of the limestone transport would mean a lot of spillage on the roads. Currently whenever sulfur was being transported in the area there was, at times, a lot of spillage. The spill would get blown up by wind which goes into their manufacturing systems and creates problems for them. The same applied for the transport of coal and at present there were issues related to spillage in the area from trucks carrying materials for other industries which was adversely affecting them already.




Would the bottom ash be wet or dry?

Aug 19, 2013 Albatross Hall, Arabian Sea Golf


Shabbir K. Hussain, HSE &

We also want to know the sulfur content of the coal and whether there would be additional effluents discharged from the Project?





and Country Club Business Development Manager


Exide Sulfuric acid plant

Tariq Jawaid, Plant Manager

We want to know about the type of coal that would be used?


Exide Sulfuric acid plant

Tariq Jawaid, Plant Manager

What is the percentage of ash that would be produced?


Textile Institute of Pakistan (TIP)

Mohsin Raza, Manager Administration

In early 2002 the students living there suffered from gaseous emission into the air from nearby industries for a few days. Although such an incident had not taken place since, he harbored the fear that something of the same sort may happen again, specifically from NOx and SOx, with the new plant since wind direction blows air from FFBL in their direction. TIP also wanted to know the air dispersion modeling done by HBP and the results of that.


The information about all the air emissions coming out from the FFBL site should be shared with TIP.


Peki Cakes Fahim Afzal, Quality Assurance Manager

Why was local coal with a higher sulfur content not being considered.


Kausar Ghee Mills Bilal Ahmed, Project Director

With regards to FFBL‘s plans to export power to the National Grid they iquired if FFBL had considered selling it to the industries in the Port Qasim Industrial Estate.


Kausar Ghee Mills Bilal Ahmed, Project Director

Is FFBL planning to install an electricity grid within the plant?

Aug 19, 2013 Albatross Hall, Arabian Sea Golf

Kausar Ghee Mills Hamid Ali Mir, Director

We are really concerned about the fly ash and in general wanted information about the stack height and results from air dispersion modeling.





and Country Club

Aug 20, 2013 IUCN Office International Union for the Conservation of Nature (IUCN)

Syed Kamran Haider Naqvi, Urban Specialist

What would be the quantity and composition of effluent discharges and FFBL‘s effluent treatment methodology?



Fauji Group is already working on Fauji Oil Terminal and Distribution Company Limited (FOTCO), which will be importing LNG. Why FFBL is converting to coal


Tahir Qureshi, Senior Advisor Coastal Ecosystem and Marine

The area was principally a fishing ground before PQ was built. Since then the ecosystem and ecological resources in the area have undergone depletion and degradation.



The mercury content in the fish had become high along with other heavy metals such as cadmium, arsenic, lead etc.



Below the Port Qasim Industrial Estate area there are three layers of water: the subsurface water, aquifer and ground water. The leachates from FFBL‘s coal yard could be carried all the way into the groundwater during heavy monsoon rains. These heavy metal leachates from the ground water had the potential to reach the sea.



There was no endangered species in the region around the Project site that he was aware of.



Mangroves should be planted as a mitigation measure for effluent discharge into the sea.







Reed Beds in the Ghaghar Nullah as mitigation against the effluents discharged there by FFBL.

Aug 20, 2013 Office of Defense Housing Authority (DHA)

Defense Housing Authority (DHA)

Lt Col (R) Syed Ali Amjad, Director Special Projects

The primary concern for DHA is additional congestion on the road from FFBL‘s coal truck traffic.




The four bottlenecks within the Cantonment Board area where the congestion impacts will be felt the most are: submarine chowk, sundial chowk, sunset boulevard and , Ittehad-Korangi Junction. The solution for avoiding these would be to build flyovers over these four chokepoints. As a mitigation measure, FFBL along with all the industries in the Port Qasim Industrial Estate and other industrial sites which use these roads, chip-in with the construction costs of the flyovers along with DHA.




Why FFBL is not using Pakistan Steel Mill coal jetty? It would be the best option for coal even for FFBL who will benefit from a reduction of transport costs. After that he also strongly suggested that FFBL uses Pakistan Bulk International Terminal Limited (PBIT).




Initially, the quality of storing and packing coals in the trucks is of a high standard but with time it reduces.

Aug 20, 2013 Office of WWF Office of World Wild Fund (WWF)

Muhammad Moazzam Khan, Technical Advisor, Marine Fisheries

FFBL should use Pakistan Steel Mill Jetty for importing coal and taking it to the FFBL Complex.



A concern was raised about coal spilling from trucks and leachates contaminating groundwater at the coal yard site within the FFBL Complex.


Muhammad Moazzam Khan,

The ash disposal sites would be an area of concern for WWF since ash is an artificial environment and reptiles such as lizards and snakes suffer. He was





Technical Advisor, Marine Fisheries

also concerned that the ash had the potential of contaminating groundwater. The ash should be used as building material or in cement manufacturing instead of disposing it off in ash disposal sites.



At times, the industries claim they are importing coal of some specific type while in reality they import cheaper coal which is extremely damaging to the environment. There should be transparency and a check on the coal that was being brought in by the Project.



During the three ~ four months in the year the wind blows into the opposite direction (NE to SW) and during this time emissions may be blown towards the city.


Hagler Bailly Pakistan Environmental Screening

R4V03FBE: 02/19/14 7-1

7. Environmental Screening

A development project can have adverse as well as beneficial environmental impacts.

The extent of the impacts depends on the nature and magnitude of the proposed activities,

and the type and sensitivity of the host environment. The depth of the environmental

assessment to be carried out for the proposed project also depends on these factors. A

detailed environmental assessment, usually called an environmental impact assessment

(EIA), needs to be carried out if the project has one or more of the following attributes:

direct pollutant discharges that are large enough to cause degradation of air, water

or soil;

large-scale physical disturbance of the site and/or its surroundings;

extraction, consumption, and/or conversion of substantial amounts of forest and

other natural resources;

measurable modification of the prevalent hydrological cycle;

hazardous material in more than incidental quantities; and

involuntary displacement of people and other significant social impacts.45

An integral part of the environmental assessment is the identification of those impacts

that are potentially significant and, thus, merit an in-depth assessment. In this way,

impacts that are not significant and need not be addressed in detail are screened out.

Having described the details of the Project; existing environmental conditions at the

FFBL plant site; and, the results of stakeholder consultations earlier in the report, this

section contains the screening process for the environmental impacts from the proposed

CPP project.

7.1 Screening Methodology

The environmental screening process is conducted using a systematic approach to assess

all possible impacts of the various phases of the proposed project. Quite a few alternative

techniques are used for this purpose; each having its specific advantages and

disadvantages. For the CPP project, the matrix methodology has been employed, which is

the most widely used technique.

Matrices are particularly useful for environmental assessments, as they reflect the fact

that impacts result from the interaction of development activities and the environment. It

is a simple but effective method, and covers all possible environmental parameters and all

of the proposed project activities. The matrix is formed by listing environmental

parameters along one axis, and project activities along the other. The magnitude and

significance of the impact of a proposed activity on a particular environmental element is

indicated in the corresponding cell using a convenient scale. This approach facilitates the

45 Environmental Assessment Sourcebook – Update, The World Bank, April 1993



R4V03FBE: 02/19/14 7-2

linking of specific project activities with specific types of impacts, and is particularly

useful for identifying significant impacts.

7.2 Development of Screening Matrix

The screening matrix for the proposed Project has been developed considering the project

activities discussed in Section 4 and evaluating their possible impacts on the

environmental parameters discussed in Section 5 and Section 6. The development

procedure is outlined below.

Objective: To evaluate the likely impacts of the proposed Project and the

associated facilities on the environment and identify issues that are potentially

significant and merit in-depth assessment and thus screen out issues that are

unimportant or irrelevant.

Participants: The environmental assessment team of HBP

Methodology: Group discussion on every aspect of the development plan and their

impacts on environmental parameters.

Preparation: Initial site visit, preliminary interview of community representatives,

and review of background information provided by FFBL.

The screening matrix thus developed is shown in Exhibit 7.1. The main issues that were

identified are:

1. Impacts of liquid effluents generated by the CPP project on the water resources

2. Impact of gaseous and dust emissions from the CPP project on the ambient air

quality

Since these parameters have been identified as having potentially significant impacts,

they are discussed in separate sections of this report.

For some other issues, it was concluded that the impacts were not significant enough to

merit in-depth assessments. These include:

1. Soil, topography, land use and drainage pattern

2. Ash Disposal

3. Increased noise levels generated by the plant operation

3. Biological resources. Impact of the increased vehicular traffic due to coal

transport for the project

4. Impact of the increased vehicular traffic due to ash disposal for the project

These issues are briefly discussed below.

7.3 Summary of Project Impacts

The potential impacts of the Project on the surrounding environmental and

socioeconomic environments from the gaseous emissions and effluents are expected to

reduce with the increased distance from the Project facilities. Therefore, a study area of

five kilometers (the ―Study Area‖) around the site was delineated, to assess the baseline



R4V03FBE: 02/19/14 7-3

conditions in the areas likely to be affected by the Project due to its proximity to the

Project site (see Section 9).

Fugitive dust emissions was the major impact considered out of the development and

operation of the ash disposal sites. The dust emissions, if any, from the ash disposal sites

will be fugitive in nature and maximum when the wind velocities are likely to be high.

The dust emissions are likely to be confined to the place of generation only. Generally

large dust particles (greater than about 30μm), that make up the greatest proportion of

dust emitted from construction activities and stockpiles will largely deposit within 100m

of sources. Dust particles in the size range 10 – 30 μm are typically likely to travel 200m

to 500m. Smaller particles than these are not produced in significant amounts from

construction activities. Fly ash particles are generally spherical in shape and range in size

from 0.5 µm to 300 µm.46 The potential for significant dust nuisance and therefore, the

demarcated Study Area for the ash disposal sites is 500 m from the edges of the ash

disposal sites.

The traffic routes for coal transport from the ports to the FFBL plant site, and from the

Complex to the ash disposal sites were categorized as the following:

the route for transporting coal from KPT to FFBL;

the route for transporting coal from Port Qasim (PQ) to FFBL;

the route for transporting ash from FFBL to the ash disposal sites;

Coal Transport from Ports to FFBL Plant

The 13 km long route from PQ to the Complex, traverses through the Eastern industrial

zone of PQA on internal roads. PQA is an industrial site built solely for industries, and

related processes and activities including industrial traffic. This route was excluded from

a baseline assessment for traffic conditions since there are no sensitive receptors along

the route which would be affected by noise, dust or congestion from increased traffic on

the route due to the Project.

The route for coal transport from KPT to the Complex, is made up of parts where

industrial traffic, which includes all types of trucks, is allowed for 24 hours (road

segment ―24-hours‖); and parts, where heavy traffic is allowed only between 11 pm and

7 am (road segment ―11pm-to-7am‖). Residential areas along both sections of this route

were identified as being prone to noise and traffic impacts.

Ash Disposal Route from FFBL Plant to the Ash Disposal Sites

The route from the Complex to the ash disposal sites would be affected, primarily, by the

additional traffic from the transport of ash from the Plant to these sites. The presence of

jeepable tracks near sensitive receptors leading up to the sites would potentially result in

dust being thrown up by the movement of the trucks.

However, since FFBL will receive coal shipments from Port Qasim which is within the

designated industrial complex and will dispose ash in low-lying barren lands or in

46 Snellings, R.; Mertens G., Elsen J. (2012). "Supplementary cementitious materials". Reviews in

Mineralogy and Geochemistry 74: 211–278.



R4V03FBE: 02/19/14 7-4

designated K-Electric / Pakistan Steel Mills slag yard or an area close to the Plant, with

no sensitive receptors located between or around them both, impacts of additional traffic

are not expected to be considerable. This will be discussed further in Section 9.



R4V03FBE: 02/19/14 7-5

Exhibit 7.1: Environmental Screening Matrix

Environmental Parameters

Air Q

ualit

y

Gro

undw

ate

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Qualit

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uan

tity

Surf

ace W

ate

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Qualit

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ua

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Veg

eta

tio

n

Wild

life

Nois

e a

nd

Vib

ration

Land

form

Land

Use

Road T

raffic

Em

plo

ym

ent

Relo

ca

tio

n

Mig

ratio

n R

ate

Access to

Tra

nsport

Access to

Serv

ices

Safe

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f

Surr

oun

din

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Pop

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Fem

ale

Mob

ility

Cultura

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Resourc

es

Project Activities

Project Design & Location

Plant Location – 0 –1 – – – – – –1 +2 – – – – – – –

Ash Disposal Site Location –1 –1 –1 –1 0 0 –1 –1 –2 – – – – – –1 – –

Construction Phase

Site Preparation –1 – – – 0 – – – –1 +1 – – – – 0 – –

Transportation of Equipment, Material, Staff –1 – 0 – 0 –1 0 – –1 0 – – – – 0 – –

Civil Works 0 – 0 – – –1 0 – –1 +2 – – – – 0 – –

Installation Works –1 – 0 – – –1 0 – –1 +2 – – – – 0 – –

Waste Disposal 0 –1 –1 0 0 – – – –1 – – – – – 0 – –

Operation Phase

Plant Operations –2 - –2 0 0 –2 – – – +2 – – – – 0 – –

Power Generation –1 0 0 – 0 –1 – – – +1 – – – – – – –

Coal Transport –1 – – – – –1 – – –2 +2 – – – – –1 – –

Ash Disposal Transport –1 – – – –1 –1 – 0 –1 +1 – – – – –1 – –

Waste Disposal –1 –1 –1 –1 –1 – – – – – – – – – 0 – –

Legend: -2 : Major adverse impact -1 : Minor adverse impact 0 : Negligible impact, if any

+2 : Major favorable impact +1 : Minor favorable impact - : No impact, whatsoever


Hagler Bailly Pakistan Analysis of Alternatives

R4V03FBE: 02/19/14 8-1

8. Analysis of Alternatives

This section considers the alternatives available to FFBL in pursuing the development of

different aspects of the CPP Project. The alternatives analyzed look into available project

options for meeting FFBL‘s economic objectives for adding new coal-based boilers to the

existing fertilizer plant; along with discussing different components of the Project

including the selected boiler technology, and, pollution-controlling technologies. The

type of coal selected for the new boiler and the ports the coal will be transported from;

along with different traffic routes for coal transport and the alternatives available for ash

disposal are also discussed.

The different facets of the Project that were looked into for an analysis of alternatives is

as follows:

No project alternative

Site selection for CPP

Selection of coal-type

Transportation of coal to Project Site

Boiler technology

Particulate matter emission controls

SO2 treatment options

NOx treatment options

Ash handling and disposal

8.1 No Project Alternative

The objective of the CPP Project, in installing two coal-based CFB boilers at the existing

FFBL complex (the ‗Complex‘), is to reduce the existing fertilizer plant‘s dependency on

natural gas for fuel owing to severe shortage of gas in the country. The shortage has

resulted in the curtailment of fertilizer production in the Complex and affected the

reliability and safety of existing process units due to frequent load fluctuations and,

shutdowns and start-ups. By using coal to generate power for the Complex as well as for

export to the national grid, the supply of natural gas will be left for use only as feedstock

in the fertilizer manufacturing process.


fertilizer production, but industrial output across the country, impacting other fertilizer



R4V03FBE: 02/19/14 8-2

industries as well. Four fertilizer plants receiving natural gas from Sui Northern Gas

Pipelines Limited (SNGPL) faced more than 300 days of gas curtailment in 2012.47

In 2010, FFBL shut down its urea production plant due to shortage of natural gas while

production of di-ammonium phosphate (DAP) decreased by half. The plant has an

allocation of 85 million cubic feet per day (mmscfd) of gas from Sui Southern Gas

Company Limited (SSGCL). However, in 2010, this figure saw a drop to 40 mmscfd.48 In

July 2012, the FFBL urea plant shut down again for a month due to low gas pressure

from SSGCL.49

The scale of the adverse economic impact on natural gas–based industries from gas

shortages in Pakistan can be judged from the fact that in the first quarter of the year 2012,

all SNGPL-based plants, as well as SSGCL-based FFBL faced revenue losses of up to

53%, compared with the first quarter of 2011. These plants generated Rs 8.16 billion in

revenues in the first quarter of 2012, compared to Rs17.29 billion rupees the year before.

In 2012, these plants lost profitability by 125%, and incurred collective losses of Rs1.076

billion, whereas the same plants had earned profits of Rs4.3 billion in the corresponding

period of 2011.50


Granular Urea. It makes up for 45% of the demand for DAP and 13% for Urea in the

domestic market.51 The quantity of fertilizer products produced by FFBL has already

been adversely affected by the shortage of natural gas in the country and with the

demand-supply gap for gas in the country only widening in the foreseeable future, FFBL

will suffer further until and unless new gas reserves are made operational and added to

the country‘s supply system. Until then, if FFBL continues with the existing natural gas-

based plant, it will continue suffering a decline in production.


in a shortfall of urea and DAP production in the country as a whole. This would place an


the shortfall in the country. The price of urea would rise as a result, affecting agricultural

production resulting in an inflationary pressure on basic food commodities. Agricultural

exports would also become more expensive and, thus, less competitive in the


47 Staff Report. (2013, April 25). Gas shortage to fertilizer sector may cost $450m to exchequer. Retrieved

September 11, 2013, from Pakistan Today: ttp://www.pakistantoday.com.pk/2013/04/25/news/profit/gas-shortage-to-fertilizer-sector-may-cost-450m-to-exchequer/

48 Nasir, M. (2010, December 29). Gas shortage: Fauji Fertiliser Bin Qasim urea plant shuts down. Retrieved September 11, 2013, from The Express Tribune: http://tribune.com.pk/story/96212/gas-shortage-fauji-fertiliser-bin-qasim-urea-plant-shuts-down

49 Staff Report. (2013, July 25). FFC shut due to low gas pressure. Retrieved September 11, 2013, from The Nation:http://www.nation.com.pk/pakistan-news-newspaper-daily-english-online/business/25-Jul-2012/ffc-shut-due-to-low-gas-pressure

50 Staff Report. (2013, April 25). Gas shortage to fertilizer sector may cost $450m to exchequer. Retrieved September 11, 2013, from Pakistan Today: ttp://www.pakistantoday.com.pk/2013/04/25/news/profit/gas-shortage-to-fertilizer-sector-may-cost-450m-to-exchequer/



http://tribune.com.pk/story/96212/gas-shortage-fauji-fertiliser-bin-qasim-urea-plant-shuts-down

http://tribune.com.pk/story/96212/gas-shortage-fauji-fertiliser-bin-qasim-urea-plant-shuts-down



R4V03FBE: 02/19/14 8-3

Therefore, in order to ensure competitiveness in the fertilizer business, it is strategically a

good decision for FFBL to switch to an alternative fuel source for producing steam and

powering the Complex. Use of coal-based Circulating Fluidized Bed (CFB) boilers would

leave FFBL with sufficient natural gas for feedstock to maintain production until more

gas reserves are made operational and added to the supply side. A ‗no alternative‘ option

will result in increasing financial loss to the company due to reduced fertilizer

production. The resulting increase in import of fertilizers in the country would add heavy

financial burden to the country‘s economy.

8.2 Site Selection for CPP

The CPP project will be located in an empty area within the existing FFBL plant site. The

site is located in PQ and situated in a designated industrial zone (Section 4).

Environmentally and economically, locating the CPP project within the existing plant site

is the most suitable option. All other facilities such as the coal storage and coal handling

facilities will also be located within the existing complex.

8.3 Selection of Coal-type for the Project

As discussed in Section 8.1, the prevailing shortage of natural gas in Pakistan and the

resulting loss in production to FFBL has been the major impetus for the introduction of

two coal-based boilers to the existing plant. Current production of coal in Pakistan is 3.5

million tonnes/year, of which 39% is in Balochistan, 18% in Punjab, and 32% in Sindh.

Production is confined to small deposits scattered throughout the country, and fulfills

about 45% of the demand for coal in the country which exceeds 7.5 million tonnes/year.

52 The production is mainly utilized in the brick kiln and the cement industry. The quality

of coal produced in the country is highly variable53

, with sulfur content ranging from 3%

to 5%, and ash content ranging from 5% to 20%. Coal from the existing mines alone

cannot be considered for utilization at FFBL‘s fertilizer plant in view of limited

availability and poor quality with a high level of variation. However, it can be used in

conjunction with imported coal to modify the overall quality to match design

requirements for fuel for the CFB boilers.

Local coal can be supplied from the Thar lignite deposits located in western Sind.

Potential reserves of Thar lignite are estimated at 182 billion tonnes. A comparison of the

quality of Thar lignite with that of the imported bituminous coal is summarized in

Exhibit 8.1. Mining in Thar, however, has yet to be developed.

Exhibit 8.2 presents the properties of sub-bituminous coal from Australia, Indonesia, and

South Africa. Properties of Thar coal are also provided for reference. Indonesian and

South African coal has been selected for the CPP project due to the relatively cheaper

cost, shorter transportation distance and options of low sulfur varieties. An estimate made

in 2010 shows that Indonesia has over 100 billion tons of coal inferred reserves, with

over 20 billion tons proven reserves. Indonesian coal is, by large, sub-bituminous, with

low ash, low sulfur, high volatilities and average Gross Calorific Value. Most large coal

52 Pakistan Energy Yearbook, 2011, Ministry of Petroleum & Natural Resources, Hydrocarbon

Development Institute of Pakistan

53 Pakistan Coal Power Generation Potential, Private Power Infrastructure Board, June 2004.



R4V03FBE: 02/19/14 8-4

mines in Indonesia have an established logistics network between the mines and the sea

port. One of the deciding factors for Indonesian coal import is the distance from the

source to the ports in Pakistan, which will reduce the transport cost significantly. The

ports available in Karachi for the import of coal will be discussed in Section 8.4.

Exhibit 8.1: A Comparison of the Quality of Thar Lignite with

Imported Bituminous Coal

Imported Lignite Thar Lignite

Heating Value (GCV), kcal/kg 5,491-6,133 3,153

Moisture 8-19% 48%

Ash 4-16% 7.8%

Sulfur 0.4-4% 1.0%

Exhibit 8.2: Comparisons of Coal Properties

Coal Properties Sub-bituminous Coal Lignite Coal

Australia Indonesia South Africa Thar

Moisture (ar %) 4-16 4-26 8.5 45-50

Coal Ash Content (ar. %) 4-16 3.0-22.0 15-62 14-15

Volatile Matter (ar %) 18-32 18-38 22-25 21-29

Sulfur Content (ar %) 0.4-0.9 0.2-0.94 0.6-0.9 0.2-2.7

Coal Net Calorific Value (kcal/kg) 4,000-6,900 3,105-6,900 5,900-6,200 2,500-3,700

8.4 Transportation of Coal to Project Site

The different ports available to FFBL for the import of coal are:

Karachi Port, which is at a geodesic distance of 45 km from the FFBL plant site,

and;

Port Qasim, which is at a geodesic distance of 12 km from the plant.

Karachi Port

Karachi Port (KP) was commissioned in 1973 as the capacity at Karachi Port Trust (KPT)

was not sufficient to handle the growing cargo volumes, and the option of expanding it

was limited due to densely populated areas encircling it. KP has 30 dry cargo berths and

3 liquid cargo berths for petroleum and non-petroleum products, and is presently

handling about 12 million tons/year of dry cargo, in addition to 14 million tons of

petroleum products. KPT has two container terminals.



R4V03FBE: 02/19/14 8-5

Port Qasim

Port Qasim was commissioned in 1973 as the capacity at KP was not sufficient to handle

the growing cargo volumes, and the options for expansion were limited as the port is

encircled by densely populated areas. PQ is located at a distance of about 35 km east of

Karachi, and presently handles about 26 million tons of cargo annually, and is accessible

through a 45 km long channel suitable for 11 meter draught vessel. The iron ore and coal

Berth at PQ is a specialized berth originally designed for handling of raw material

imports of Pakistan Steel Mills. The design capacity of the berth stands as 3.03 million

tons per annum.

A 4.25 km long conveyor belt transports coal from the berth to Junction-13, within the

confines of the PSM, from where it is diverted to the coal yard through Junction-2 by two

conveyors, each equipped with two Russian-made universal machines utilized as either

stackers or re-claimers. The PSM coal yard has a capacity of 320,000 MT. The ownership

and operational control of the PSM berth is with PQA and it is intended for use

exclusively by PSM.

PSM has shown interest in sharing the berth with FFBL on a commercial basis, provided

FFBL installs the required unloading and storage infrastructure, which includes extending

the conveyor belt system to adjacent land belonging to PSM and beyond their coal yard at

Junction 2.

Another coal handling facility at PQ currently under development is the Pakistan

International Bulk Terminal (PIBT). This facility will provide mechanized material

handling from ship unloading to conveyance of the material to a storage yard. According

to PBIT, the mechanized handling facilities will allow for a 40,000 – 60,000 MT ship to

be unloaded in 24 hours as compared to 72 hours at KPT. The expected date of

commencement of operations by the PIBT is December 2015.

From both an environmental and economic point of view, the short distance of 13 km

from PQ to the FFBL site, through a designated industrial zone, on internal PQA roads,

makes PQ the most suitable port for the import of coal by FFBL. Using PIBT‘s

specialized coal handling facilities, once in operation, will be the most economically

feasible choice for FFBL in the long-run for coal handling at the port.

Port Selected for Offloading of Imported Coal for the Project

Although PQ will be the port of choice for FFBL once PIBT becomes operational, until

then, it will be more feasible for the former to receive coal shipments at KP.

Road Options for Transporting Coal to Project Site

After completion of PIBT at PQ, coal will be transported from PQ to Project site by road.

Transportation requirement is estimated at 330,000 – 500,000 tons per year of coal. Cost

of coal transportation by road from Karachi Port using commercially available trucking

services is comparably higher than transporting it from PQ. However, till the completion

of PIBT at PQ, coal will be delivered to the Project site via road from KP.

There are three feasible road options for trucks carrying coal from KPT and PBQ to the

plant site: Exhibit 8.3 summarizes all three options in the form of a table and Exhibit 8.4



R4V03FBE: 02/19/14 8-6

illustrates the three road options for transporting coal from the two ports to the FFBL

plant.

RD-1 - the ‗Northern Bypass Route‘ :

KPT – Northern Bypass (N25) – M10 – FFBL Plant

RD-2 - the ‗Inter-City Road Route‘ :

KPT - Main Kolachi Bypass - Khyaban e Roomi - Sunset Boulevard -

Korangi Road - Main Korangi Industrial Road - National Highway (N5) -

FFBL Plant

RD-2 – ‗Internal PQA Route‘ :

PBQ – Internal PQA Road – FFBL Plant

RD-1 is the longest route, approximately 103 km from KPT to the plant but it bypasses

the city avoiding congestion and traffic. This is one of the preferred routes used by

vehicles transporting materials from KP to PQA.

RD-2 is, approximately, 49 km from KP to the plant, however, it is connected to the

National Highway (N25) through roads out of the port that go through densely built-up

residential areas.

RD-3 is only 13 km long. Coal being transported from PQ to the plant will pass through

internal PQA roads. Among all transport options, this route is both, environmentally and

economically the best option for FFBL for coal transportation.

Exhibit 8.3: Route Options

Route No.

Description Route Sections Length (approx)

Road Routes

RD-1 The Northern Route via N-25 following M-10 and N-5 through PQ Road to FFBL

Karachi to Sher Shah [N-25]

N-25 to M-10

M-10 to M-9

M-9 to Eastern Bypass (N-5)

Eastern Bypass to Port Qasim Road

103 km

RD-2 Inter-City Road Route via Sunset Boulevard and N5 to PQ road to FFBL

KPT to Main Kolachi Bypass

Main Kolachi Bypass to Khyaban e Roomi

Khyaban e Roomi to Sunset Boulevard

Sunset Boulevard to Korangi Road

Korangi Road to Main Korangi Industrial Road

Main Korangi Industrial Road to National Highway (N-5)

N-5 to PQ Road

PQ Road to FFBL Plant

49 km

RD-3 The shortest route to transport coal from Port Bin Qasim using PQ Road to FFBL

Port Bin Qasim to FFBL via Port Qasim road 13 km



R4V03FBE: 02/19/14 8-7

Exhibit 8.4: CPP Project Setting illustrating Coal Transport Route Options from the Ports to FFBL Plant



R4V03FBE: 02/19/14 8-8

8.5 Boiler Technology

Boiler technologies that can be considered for the Project are:

Various advanced pulverized coal (PC) combustion technologies (subcritical,

supercritical, ultra supercritical)

Fluidized bed combustion (FBC) technologies (atmospheric, circulating and

pressurized).

8.5.1 Pulverized Coal-based Boilers

Pulverized Coal (PC) fired stations have been in use more than 60 years and, in terms of

overall numbers and generating capacity, they dominate the global market. Pulverized

fuel (PF) based plant is in widespread use throughout the world, in both the developed

and developing nations. PF firing technology has emerged as an environmentally

acceptable technology for burning a wide range of solid fuels to generate steam and

electric power. Plants with PF boilers are available up to a current maximum capacity of

1,300MW.

Over the years, many advances have been made with pulverized fuel technology,

including environmentally focused measures to minimize emissions of SOx, NOx and

particulates, as well as application of advanced steam cycles that allow for greater plant

efficiency. Globally, PF plant is characterized by overall thermal efficiencies of up to

roughly 36% (Lower Heating Value [LHV] basis), whereas plants with higher steam

temperatures and pressures can attain up to some 45%. As further developments take

place in the metallurgy of critical components of boiler and turbine that are exposed to

high pressure and high temperature steam, it is expected that efficiencies of 50% to 55%

will ultimately be achieved.

It has to be noted however, that the increase in efficiency of the generating plant is due to

the combination of the boiler and steam turbine working at higher pressures and

temperatures. As far as the steam generation is concerned, the efficiency of the boiler per

say does not vary much as steam pressures and temperatures are increased.

Firing System

Controlling parameters in the PF combustion process are time, temperature and

turbulence. In a PF boiler, furnace temperature shall be about 1,300 to 1,500°C and fuel

residence time is about 2 to 5 seconds. The most popular system for firing pulverized coal

is the use of tangential firing and opposing firing shown in Exhibit 8.5.



R4V03FBE: 02/19/14 8-9

Exhibit 8.5: Type of PF Firing System

Type of Firing Tangential firing Wall/Opposing firing

Description Four burners corner to corner to create a fire ball at the center of the furnace.

Typically the combustion is staged, with the first stage combustion taking place from the burners to the centre of the furnace. The partially combusted material mixes in the flow upwards; there overfire air ports encourage complete combustion by supply air for the second stage of combustion.

Schematic diagram

Classification of PF Coal Power Plants

Pulverized coal power plants are broken down into three categories; subcritical

pulverized coal plants, supercritical pulverized coal plants, and ultra-supercritical

pulverized coal plants. The classifications are mainly based on the live steam parameters

and reheat steam temperature. Some of the well-known classifications are presented in

Exhibit 8.6.

Exhibit 8.6: Classification of Pulverized Coal plants

Category Unit Subcritical Supercritical Ultra supercritical

Year <1990 1990 2000-

Live steam pressure Bar 165 >221 >300

Live steam temperature °C 540 540-560 >600

Reheat steam temperature °C 540 560 >600

Single Reheat Yes Yes No

Double Reheat No No Yes

Power Plant Generating Efficiency % ~38 ~41 ~46+

Source: Henderson, 2003; Smeers et al., 2001.



R4V03FBE: 02/19/14 8-10

Advantages of PF Combustion

The following are the advantages of the PF combustion technology:

Fuel Flexibility - PF boiler has the ability to burn varying quality of coals and all

ranks of coal from anthracitic to lignite, and it permits combination of firing (i.e.,

it can use coal, oil and gas). Because of these advantages, there is widespread use

of pulverized coal furnaces.

High Combustion Efficiency - Since the coal is being burnt in pulverized form, the

rate of burning and the amount of excess air required are optimized resulting in

better combustion efficiency than the other types of boilers.

Sustainability to load variations - Boilers are known to have higher thermal

inertia than any equipment in a power station. In such case, the rate of reaction

with respect to load variation is the most essential. A PF boiler has the flexibility

to sustain load variations in very short periods than any other type of boiler. This

will increase the operational flexibility for the plant operator.

Maintenance problems - Pulverized fuel boilers are less outage prone when

compared with other types of boilers such as Fluidized Bed Combustion. Erosion

of economizer and pressure parts are less, and hence the outages are less.

However, there is a need to be vigilant and maintain the grinding elements of the

pulverizers.

Provenness and Reliability - Pulverized fuel fired boilers are reliable and proven

worldwide since 1918, when Milwaukee Electric Railway and Light company,

later Wisconsin Electric, conducted tests in the use of pulverized coal in 1918.

Plants with PF boilers are available up to a maximum capacity of 1,300MW.

tangential firing technology.

8.5.2 Circulating Fluidized Bed Combustion

Fluidized bed combustion (FBC) power plants use the same steam cycle as conventional

PF plant. They raise steam via a different combustion technology. The possibility of

applying fluidized bed combustion technology for the generation of electricity from coal

first attracted worldwide interest in the 1960´s. This was especially because it promised

to be a cost effective alternative to PF plants, while at the same time allowing sulfur

capture without use of add-on scrubbers. Moreover, the technology is suitable for high

ash, variable quality, high moisture and high sulfur fuels.

FBC is a method of burning coal in a bed of heated particles suspended in a gas flow. An

evenly distributed air or gas supply is passed upward through a finely divided bed of

solid particles such as sand supported on a fine mesh; the particles are undisturbed at low

velocity. As air velocity is gradually increased, a stage is reached when the individual

particles are suspended in the air stream and the bed is called ―fluidized‖.

Classification of FBC

FBC falls into three main categories which is atmospheric fluidized bed combustion

(AFBC), pressurized fluidized bed combustion (PFBC), and advanced pressurized

fluidized bed combustion (APFBC).



R4V03FBE: 02/19/14 8-11

Atmospheric fluidized-bed combustion (AFBC) technology is commercially available in

subcritical pressure with a size limit of about 350 MW. FBC is commercially available as

bubbling fluidized bed combustion (BFBC) or circulating fluidized bed (CFB)

combustion version. CFB technology has emerged as an environmentally acceptable

technology for burning a wide range of solid fuels to generate steam and electric power.

In PFBC type, a compressor supplies the forced draft (FD) air and the combustor in a

pressure vessel. In PFB plant, the boiler combustion occurs under pressure. The pressure

is typically 6 to 16 times higher than atmosphere pressure. The heat release rate in the

bed is proportional to the bed pressure and hence a deep bed is used to extract large

amounts of heat. This improves the combustion efficiency and sulfur dioxide absorption

in the bed.

APFBC, a technology that will not be commercially available for at least 10 years, will

utilize high temperature gas turbines and have cycle efficiency of above 50% by fuel

gasification. The bed also operates at a higher temperature which improves efficiency at

expense of higher NOx emission.

Advantages of FBC

The following are few of the advantages of FBC:

Fuel Flexibility - The relatively low furnace temperatures are below the ash

softening temperature for nearly all fuels. As a result, the furnace design is

independent of ash characteristics which allow a given furnace to handle a wide

range of fuels.

Low SO2 Emissions - Limestone is an effective sulfur sorbent in the temperature

range of (815 – 925°C). SO2 removal efficiency of 95% and higher has been

demonstrated along with good sorbent utilization.

Low NOx Emissions - Low furnace temperature plus staging of air feed to the

furnace produce very low NOX emissions.

Combustion Efficiency - The long solids residence time in the furnace resulting

from the collection/recirculation of solids via the cyclone, plus the vigorous

solids/gas contact in the furnace caused by the fluidization airflow, result in better

combustion efficiency, even with difficult-to-burn fuels.

8.5.3 Proposed Technology for Boiler Combustion

Exhibit 8.7 presents a comparison of various types of pulverized coal combustion and

fluidized bed combustion technologies. The selected coal combustion technology for the

proposed CPP project is the sub-critical, atmospheric CFB boiler. The main reason for

selecting CFB boiler is fuel flexibility, low SO2 and NOx emissions and its combustion

efficiency.

CFB has several advantages compared to Pulverized Fuel (PF) especially because it

promises to be a cost effective alternative to PF plants while at the same time allowing

sulfur capture without the use of add-on scrubbers. Moreover, the technology is suitable

for high ash, variable quality, high moisture and high sulfur fuels.



R4V03FBE: 02/19/14 8-12

CFB combustion uses the same thermodynamic cycle as a PF system. Thus, its power

generation efficiency is in the same range as PF, but with a lower capital cost. This is due

to its‘ ability to effectively control gaseous emission without the need to install additional

SOx treatment system. In addition, CFB combustion has significantly lower power

consumption compared to PF system. Therefore, the selected combustion technology is

the best available technology for the proposed Project.

Exhibit 8.7: Technical and Economic Status of Coal Combustion Technologies

Criteria Pulverised Coal-based Combustion Fluidized Bed Combustion

Subcritical Supercritical CFBC PFBC

Status Commercial Commercial Commercial Demonstrated

Complexity Low Medium Medium Medium

Usage Base/medium load Base/medium load Base/medium load Base/medium load

Fuel range All coals, Co-firing with selected biomass

All coals, Co-firing with selected biomass

All coals, residuals, biomass

All coals

Operational flexibility

Medium – performance limited at low load

Medium – performance limited at low load

Medium –potentially similar to PF but not yet proven.

Medium –potentially similar to PF but not yet proven.

Unit size < 1000 MW 400 – 1,000 MW ≤460 MW ≤360 MW

Environmental performance

Requires ESP or baghouse for Particulate Matter Control, FGD for SOx Emission Control. NOx reduction mainly achievable via burner design and configuration

Requires ESP or baghouse for Particulate Matter Control, FGD for SOx Emission Control. NOx reduction mainly achievable via burner design and configuration

Requires baghouse or ESP for Particulate Matter Control.

SOx Emission controlled by in furnace limestone injection. NOx reduction mainly achievable via low temperature combustion

Requires ESP or baghouse for Particulate Matter Control.

SOx Emission controlled by in furnace limestone injection. NOx reduction mainly achievable via low temperature combustion

Availability Proven to be excellent

Proven to be good Proven to be good Limited experience

8.6 Particulate Matter Emission Controls

Particulate matter treatment technologies are electrostatic precipitators (ESP), fabric

filters, cyclones and wet scrubbers. Exhibit 8.8 presents a comparison among the

technologies in terms of efficiencies, advantages and disadvantages.



R4V03FBE: 02/19/14 8-13

Exhibit 8.8: Particulate matter control technologies

Control Technology Description Control Efficiency Advantages Disadvantages

Electrostatic precipitator (ESP)

ESP is applicable to a variety of coal combustion sources and the negatively charged dry precipitator is most commonly used.

The high-voltage fields to apply large electrical charges to particles moving through the field. The charged particles move toward an oppositely charged collection surface, where they accumulate. The accumulated particles are than removed by rapper and collected at ESP hopper.

>99 % High collection efficiency of 99% or greater at relatively low energy consumption.

Low pressure drop.

Continuous operation with minimum maintenance.

Relatively low operation costs.

Operation capability at high temperature (up to 700 °C) and high pressure (up to 10 atm)

Capability to handle relatively large gas flow rates. (up to 50,000 m

3/min)

High capital cost

High sensitivity to fluctuations in gas stream (flow rates, temperature, particulate and gas composition, and particulate loadings)

Difficulties with the collection of particles with extremely high or low resistivity.

- High space requirement for installation

- Highly trained maintenance personnel required.

Fabric filters or bag houses

ESP is widely applied to combustion sources since 1970s. It consist of a number of filtering elements (bags) along the bag cleaning system contained in a main shell structure incorporating dust hopper. The particle-laden gas stream pass through the tightly woven fabric and the particulates are collected on one side of fabric. Filtered gas passes through the bags and is exhausted from the unit.

When cleaning is necessary, dampers are used to isolate a compartment of bags from the inlet gas flow. Then, some of the filtered gas passes in the reverse direction in order to remove some of the dust cake. The gas used for reverse air cleaning is re-filtered and released.

99.9% Very high collection efficiency (99.9%).

Relative insensitivity to gas stream fluctuations and large changes in inlet dust loadings (for continuously cleaned filters).

Recirculation of filter outlet air.

Dry recovery of collected material for subsequent processing and disposal.

No corrosion problems.

Simple maintenance, flammable dust collection in the absence of high voltage

Various configurations and dimensions of filter collectors

Relatively simple operation

Requirement of costly refractory mineral or metallic fabric at temperatures in excess of 290 °C.

Need for fabric treatment to remove collected dust and reduce seepage of certain dusts.

Relatively high maintenance requirements

Shortened fabric life at elevated temperatures and in the presence of acid or alkaline particulate.

Respiratory protection requirement for fabric replacement.

Medium pressure-drop.



R4V03FBE: 02/19/14 8-14

Control Technology Description Control Efficiency Advantages Disadvantages

Wet scrubber Wet scrubbers including venture and flooded disc scrubbers, tray or tower units, turbulent contact absorbers or high pressure impingement scrubbers are applicable particulate matter and SOx control on coal-based combustion sources. The system requires substantial amounts of water and chemicals for neutralizing. Water is injected into the flue gas stream at the venture throat to form droplets. Fly ash particles impact with the droplets forming a wet by-product which then generally requires disposal.

95-99% Relatively small space requirement.

Ability to collect gases, as well as ―sticky‖ particulates.

Ability to handle high-temperature, high-humidity gas streams

Low capital cost (if wastewater treatment system is not required)

High collection efficiency of fine particulates (95-99%).

Potential water disposal/effluent treatment problem.

Corrosion problems (more severe than with dry systems).

Potentially objectionable steam plume opacity or droplet entrainment

Potentially high pressure drop.

Potential problem of solid buildup at the wet-dry interface

Relatively high maintenance costs

Cyclone or multi-cyclone

A cyclone is a cylindrical vessel which can be installed singly, in series or groups as in a multi-cyclone collector. The flue gas enters the vessel tangentially and sets up a rotary motion whirling in a circular or conical path. The particles are hit against the walls by centrifugal force of the flue gas motion where they impinge and eventually settle into hoppers.

Cyclones is referred as mechanical collectors and are often used as a pre-collector upstream of an ESP, fabric filter or wet scrubber so that these devices can specified for lower particle loadings to reduce capital and operating costs.

90-95% Low capital cost.

Relative simplicity and few maintenance problems.

Relatively low operating pressure drop.

Temperature and pressure limitations imposed only by the materials of construction used

Dry collection and disposal.

Relatively small space requirements

Relatively low overall particulate collection efficiencies especially for particulate sizes below 10 micron (PM10).

Inability to handle sticky materials.



R4V03FBE: 02/19/14 8-15

Particulate matter treatment technologies that can meet the environmental control

requirements are fabric filters and electrostatic precipitators (ESP).

Fabric Filters: The major advantages of fabric filter dust collectors over electrostatic

precipitators are: lower initial cost, modular construction (permits on‐line maintenance),

no high voltage requirements, simplicity, wide economical capacity range, and a high

collection efficiency (99 percent plus) that is not appreciably affected by such variables

as inlet grain loading, particle size distribution, turndown, or fuel constituents. Major

disadvantages include: the fabric filter‘s sensitivity to flue gas temperature which must be

controlled for maximum bag life and preventing bag blinding (clogging). Operation with

flue gas temperatures below the dew point will blind the bag house filters within a short

operating period and shorten fabric filter life. Operation above the temperature limits of

the fabric filter will result in fabric failure. Finally, fabric filters call for an increased

operating load on the Induced draft fan due to the higher resistance for gas flow through

the bag house.

Electrostatic Precipitators: The major advantages of the electrostatic precipitator stem

from their smaller physical size as compared to fabric filters. They also operate under a

wide range of temperature applications allowing them to tolerate, not only, temperature

excursions outside the normal operating range, but also a low pressure drop with resulting

low energy consumption, and dry continuous disposal of collected dust. A properly

designed and operated precipitator can perform in a reasonably high collection efficiency

range. Limitations include the following:

electrostatic precipitators are normally more process sensitive than fabric filters

and require tighter control of boiler and collector operating conditions and fuel

selection;

low sulfur coal, selected for reduced sulfur dioxide emissions, normally produces

a high resistivity ash;

the electrical charge retention ability of high resistivity ash makes it difficult to

remove from the collecting plates thereby causing excessive ash buildup and

electrical arcing resulting in erratic currents and reduced power to the fields which

in turn reduces the collecting ability of the unit and results in unburned carbon in

the fly ash which reduces resistivity;

initial cost is usually higher for an electrostatic precipitator versus a fabric filter of

the same design performance.

Proposed Technology for Particulate Matter Emission Control

Fly ash collection from coal‐Based boilers has been the most common use of electrostatic

precipitators. However, these units are not as well suited to upstream acid gas (HCl, SOx,

NOx, and toxics) treatment systems as are bag houses. For this reason, bag houses are

becoming the preferred method in order to comply with increasingly stringent air

emissions requirements and are selected for the CPP project.

When coal will be fed into the combustion zone of the CFB boiler selected by FFBL for

the CPP project, it is heated up by hot inert materials in the combustion chamber. After

the coal heats up, it expands, cracks and breaks into smaller pieces and the temperature of



R4V03FBE: 02/19/14 8-16

the air and inert materials will eventually increase up to 800~900°C. As the coal breaks

and becomes smaller, combustion flue gas will carry these fine particles, including fine

coal and inert materials, towards the cyclone.

In the cyclone, the heavier particles separate from the gas and fall to the hopper of the

cyclone. The heavier particles are then recycled back to the boiler combustion chamber

for recirculation.

Inert materials consisting of fly ash, sand, and limestone, and other by-products of the

combustion process will be circulating inside the combustor and separator. When the

inert material reaches certain particle size, it will be separated out from the cyclone. The

exhaust hot flue gas from cyclone will carry the fine particle flows through a rear

horizontal convection pass/heat recovery area. The superheaters and reheaters will be

located in the convection pass together with economizers. The flue gas shall flow through

the superheater, re-heater, low temperature superheater, economizer and air pre-heater.

Fine particles will be captured by the Fabric Fiber filters and transported to dry fly ash

silos. The clean flue gas shall then be drawn by the induced draft (ID) fans and exhaust

through chimney and released into environment.

8.7 SO2 Treatment Options

Several techniques are used to reduce SO2 emissions from coal combustion. Flue gas

desulfurization (FGD) systems are in current operation on several lignite-fired utility

boilers. Post combustion FGD techniques can remove SO2 formed during combustion by

using an alkaline reagent to absorb SO2 in the flue gas. Flue gases can be treated using

wet, dry, or semi-dry desulfurization processes of either the throwaway type (in which all

waste streams are discarded) or the recovery/regenerable type (in which the SO2

absorbent is regenerated and reused).

Wet FGD is the most commonly applied techniques for SOx emission reduction.

Wet systems generally use alkali slurries as the SO2 absorbent medium and can be

designed to remove greater than 90% of the incoming SO2. The effectiveness of

these devices depends not only on control device design but also on operating

variables. Lime or limestone scrubbers, sodium scrubbers, and dual alkali

scrubbers are among the commercially proven wet FGD systems. These are

favored because their availability and relatively low cost. Although wet scrubbers

can also be utilized in particulate removal, they are most effective when coupled

with ESP or filters. Wet scrubbers consist of a spray tower or absorber where flue

gas is sprayed with calcium-based water slurry.

Dry FGD/ Spray Drying: Dry scrubbers are an alternative application for SO2

removal. Dry FGD require the use of efficient particulate control device such as

ESP or fabric filter. Instead of saturating the flue gas, dry FGD uses little or no

moisture and thus eliminates the need for dewatering. Lime is mixed in slurry

with about 20% solids; the slurry is atomized and injected into the boiler flue gas.

The SO2 reacts with the alkali solution or slurry to form liquid-phase salts. The

slurry is dried by the latent heat of the flue gas to about 1% free moisture. The

dried alkali continues to react with SO2 in the flue gas to form sulfite and sulfate

salts. The spray dryer solids are entrained in the flue gas and carried out of the



R4V03FBE: 02/19/14 8-17

dryer to a particulate control device such as an ESP or baghouse. The absorber

construction material is usually carbon steel making lower capital cost. However,

the necessary use of lime in the process will increase the operational costs.

Besides than, dry FGD‘s efficiency is slightly lower than wet FGD (70-90% wt.).

Dry FGD have been proven with low-sulfur coal in the United States and

elsewhere, but their applicability for use with high-sulfur coals has not been

widely demonstrated.

Furnace Injection: A dry sorbent is injected into the upper part of the furnace to

react with the SO2 in the flue gas. The finely grinded sorbent is distributed quickly

and evenly over the entire cross section in the upper part of the furnace. In PF

system, the combustion temperature at furnace is range between 750-1,250 °C.

Commercially available limestone or hydrated lime is used as sorbent. Removal

efficiency can be obtained up to 50%. Limestone may also be injected into the

furnace, typically in an FBC, to react with SO2 and form calcium sulfate. The

CPP project has made use of CFB technology which utilizes limestone injected

into the furnace where it cleans the SO2.

Duct Injection: In duct injection, the sorbent is evenly distributed in the flue gas

duct after the pre-heater where the temperature is about 150 °C. At the same time,

the flue gas is humidified with water if necessary. Reaction with the SO2 in the

flue gas occurs in the ductwork and the by-product is captured in a downstream

filter. Removal efficiency is greater compared to furnace injection systems. An

80% SO2 removal efficiency has been reported in actual commercial installations.

Proposed Technology for SO2 Treatment

In the proposed CFB boiler technology chosen for the CPP project, limestone is injected

into the furnace. The injected limestone reacts with the sulfur released from the fuel to

capture the SO2 and form CaSO4. The reaction requires that there is always an excess

amount of limestone present. The required amount of excess limestone is dependent on a

number of factors such as the amount of sulfur in the fuel, the temperature of the bed, the

cyclone efficiency, and the physical and chemical characteristics of the limestone.

Provisions are made for primary and secondary air supply to the furnace. The primary air

is supplied through the lower wind box to the fluidizing grid and provides the initial

fluidization air flow. The secondary air provides a staged combustion effect to ensure

high combustion efficiencies and to minimize NOx production.

8.8 NOx Treatment Options

NOx control technologies mainly fall under two categories: primary control technologies

and secondary control technologies. Primary control technologies reduce the amount of

NOx produced in the primary combustion zone. In contrast, secondary control

technologies reduce the NOx present in the flue gas away from the primary combustion

zone. Some of the secondary control technologies actually use a second stage of

combustion, such as reburning. Exhibit 8.9 summarizes available NOx control

technologies.



R4V03FBE: 02/19/14 8-18

Exhibit 8.9: NOx Control Options for Coal-Based Boilers

Control Technique Description of technique Applicable boiler designs

NOx reduction potential

Commercial availability R&D status

Comments

Combustion Modifications

Load reduction Reduction of coal and air. Stokers Minimal Available Applicable to stokers that can reduce load without increasing excess air; may cause reduction in boiler efficiency; NOx reduction varies with percent load reduction.

Operational modifications (BOOS, LEA, BF, or combination)

Rearrangement of air or fuel in the main combustion zone.

Pulverized coal boilers (some designs); Stokers (LEA only)

10-20 Available Must have sufficient operational flexibility to achieve NOx reduction potential without sacrificing boiler performance.

Overfire Air Injection of air above main combustion zone

Pulverized coal boilers and stokers

20-30 Available Must have sufficient furnace height above top row of burners in order to retrofit this technology to existing boilers.

Low NOx Burners (LNB)

New burner designs controlling airfuel mixing

Pulverized coal boilers

35-55 Available Available in new boiler designs and can be retrofit in existing boilers.

LNB with OFA Combination of new burner designs and injection of air above main combustion zone


40-60 Available Available in new boiler designs and can be retrofit in existing boilers with sufficient furnace height above top row of burners.

Reburn Injection of reburn fuel and completion air above main combustion zone

Pulverized coal boilers, cyclone furnaces

50-60 Commercially available but not widely demonstrated

Reburn fuel can be natural gas, fuel oil, or pulverized coal. Must have sufficient furnace height to retrofit this technology to existing boilers.



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Control Technique Description of technique Applicable boiler designs

NOx reduction potential

Commercial availability R&D status

Comments

Post-Combustion Modifications

SNCR Injection of NH3 or urea in the convective pass

Pulverized coal boilers, cyclone furnaces, stokers, and fluidized bed boilers

30-60 Commercially available but not widely demonstrated

Applicable to new boilers or as a retrofit technology; must have sufficient residence time at correct temperature (1,750E±90 EF); elaborate reagent injection system; possible load restrictions on boiler; and possible air preheater fouling by ammonium bisulfate

Selective Catalytic reduction (SCR)

Injection of NH3 in combination with catalyst material

Pulverized coal boilers, cyclone furnaces

75-85 Commercially offered, but not yet demonstrated

Applicable to new boilers or as a retrofit technology provided there is sufficient space; hot-side SCR best on low-sulfur fuel and low fly ash applications; cold-side SCR can be used on high-sulfur/high-ash applications if equipped with an upstream FGD system.

LNB with SNCR Combination of new burner designs and injection of NH3 or urea


50-80 Commercially offered, but not widely demonstrated as a combined technology

Same as LNB and SNCR alone.

LNB with OFA and SCR

Combination of new burner design, injection of air above combustion zone, and injection of NH3 or urea


85-95 Commercially offered, but not widely demonstrated as a combined technology

Same as LNB, OFA, and SCR alone.



R4V03FBE: 02/19/14 8-20

As discussed in Section 8.5.2, the CFB boiler technology recommended for the Project

makes use of a low furnace temperature along with staging of air feed to the furnace

which produces very low NOX emissions. Secondary air will be introduced in the CFB

boiler by secondary air nozzles to ensure solid circulation and a supply of uniform air

distribution in the upper region of the furnace which helps control excess oxygen and

reduce NOx emissions.

8.9 Ash Handling and Disposal

Coal combustion residuals generated from the boiler technology proposed for the CPP

project include the following with low concentrations of arsenic, selenium, lead, and

mercury:

At the furnace bottom, as bottom ash or bed ash (about 20 to 30% of the total

volume of ash produced);

At the bottom of the air heater hoppers, as fly ash (about 0 to 5%), and;

At the fabric filters, as fly ash (about 70 to 80%).

The collected ash is a mixture of fuel ash, unburned carbon residues and – with the

addition of limestone into the bed - calcium sulfate and unreacted lime. Exhibit 4.11 lists

the estimated daily and annual quantities of fly ash and bottom ash expected to be

produced by the CPP project.

An important design requirement for the fly ash and bottom ash handling systems is to

have minimal impact on the existing FFBL site in terms of space requirements, water

usage and power consumption. Truck removal of fly ash and bottom ash is a reasonable

approach, given the lack of space at FFBL for ash storage and the strong incentive to

minimize water usage and treatment.

8.9.1 Ash Recycling Options

After collection at ash silos, coal ash will be impounded in a landfill in one of the ash

disposal options discussed in the section above. The most suitable alternative, however, is

to reuse the ash as raw materials in other industrial processes. This section discusses the

various avenues available for recycling ash.

Fly ash is a product of burning finely ground coal in a boiler. It is removed from the plant

exhaust gases primarily by electrostatic precipitators or baghouses and secondarily by

scrubber systems. Physically, fly ash is a very fine, powdery material, composed mostly

of silica. Fly ash is a pozzolan, a siliceous material which in the presence of water will

react with calcium hydroxide at ordinary temperatures to produce cementitious

compounds. Because of its spherical shape and pozzolanic properties, fly ash is useful in

cement and concrete applications. The spherical shape and particle size distribution of fly

ash also make it good mineral filler in hot mix asphalt applications and improve the

fluidity of flowable fill and grout when it is used for those applications.

Fly ash applications include its use as a:

Raw material in concrete products and grout

Feed stock in the production of cement



R4V03FBE: 02/19/14 8-21

Fill material for structural applications and embankments

Ingredient in waste stabilization and/or solidification

Ingredient in soil modification and/or stabilization

Component of flowable fill

Component in road bases, sub-bases, and pavement

Mineral filler in asphalt

Bottom ash is agglomerated ash particles, formed in pulverized coal furnaces that are too

large to be carried in the flue gases and impinge on the furnace walls or fall through open

grates to an ash hopper at the bottom of the furnace. Physically, bottom ash is typically

grey to black in color, is quite angular, and has a porous surface structure. Bottom ash is

coarse, with grain sizes spanning from fine sand to fine gravel. Bottom ash can be used as

a replacement for aggregate and is usually sufficiently well-graded in size to avoid the

need for blending with other fine aggregates to meet gradation requirements. The porous

surface structure of bottom ash particles make this material less durable than

conventional aggregates and better suited for use in base course and shoulder mixtures or

in cold mix applications in road construction, as opposed to wearing surface mixtures.

This porous surface structure also makes this material lighter than conventional aggregate

and useful in lightweight concrete applications.

Bottom ash applications include its use as a:

Filler material for structural applications and embankments

Aggregate in road bases, sub-bases, and pavement

Feed stock in the production of cement

Aggregate in lightweight concrete products

Recycling of ash will be the preferred option for ash disposal. A review of the utilization

of fly ash produced in the coal powered plants in India54 shows that on an average the

utilization of fly ash produced by the coal based power plants is over 50%, with a number

of plants achieving 100% utilization. There are a number of potential users of ash

produced by the project in the vicinity of FFBL. These include cement plants which are

located at a distance of 50-100 km from the plant mainly on the main highway M-9

linking Hyderabad to Karachi (Exhibit 8.11). Production of cement concrete blocks

where bottom ash can be used as an aggregate is also common and widespread in the

Karachi area. As the ash recycling applications and market are not developed in Pakistan,

FFBL management will consult with cement factories and other construction industries to

explore the options for recycling their ash. Recognizing that the recycling of ash in this

manner will develop over time, an ash disposal area will be developed to store ash as

discussed in Section 8.9.2.

54 Report on Fly Ash Generation at Coal/Lignite Based Thermal Power Stations and its Utilization in the

Country for the Year 2010-11, Central Electricity Authority, New Delhi, December 2011



R4V03FBE: 02/19/14 8-22

Exhibit 8.10: Estimated Daily and Yearly Quantities of Fly Ash and Bottom Ash

Produced by the CPP Project


Normal Load


BMCR


Normal Load


BMCR Load

Trips per Week @ 25-ton Trucks

Normal / BMCR

Fly ash 75.75 133.44 25,000 45,000 21 / 38

Bottom ash 33.33 67.20 11,000 22,176 14 / 19

Total 110.0 204.0 36,000 67,176 35 / 57

8.9.2 Ash Disposal Site Options

Among all the ash disposal sites considered by FFBL, the three options that are

environmentally and commercially viable are:

Option 1: The slag disposal area owned by PSM outside of PSM plant limit.

Option 2: Barren land located 6 km southeast from the FFBL Complex.

Option 5: K-Electric‘s land-reclamation project in the PQA.

Both Option 1 and Option 5 are, however, future projects and may not be available for

ash disposal by the time the Project will become operational. Therefore, the best option

for ash disposal available at the moment is Option 2. Option 2 is a barren and empty

land which was previously used for sand excavation and is located outside the designated

industrial area of the PQA. It lies 6 km southeast of the FFBL Complex at a distance of

300 m from the national highway (N5). Section 9 considers the environmental impacts of

ash disposal at this site and proposes mitigation measures.

In the future, if and when the ash disposal options at PSM and K-Electric become

available, the latter will be the best option on account that it is a developed site

designated for ash-disposal by K-Electric. FFBL may utilize this option for disposing ash

in K-Electric‘s land reclamation project.

K-Electric is planning to convert its Bin Qasim Thermal Power Station-I Unit No.3 and 4

to coal based boilers. They have planned to utilize adjacent land (Option 5 in Exhibit

5.56) for reclaiming land by utilizing ash generated during the operation of coal boilers.

FFBL will approach K-Electric to utilize the same land for FFBL‘s CPP Project ash

disposal.

The ash disposal site options are discussed in Section 8.9.1. Ash disposal site options

considered by FFBL are shown in Exhibit 5.56.

FFBL is also looking to provide the ash to local cement and concrete brick manufacturing

plants and other industries where the ash may be utilized.



R4V03FBE: 02/19/14 8-23

Exhibit 8.11: Location of Cement Plant Accessible to FFBL



R4V03FBE: 02/19/14 8-24

Exhibit 8.12: Ash Disposal Site Options



R4V03FBE: 02/19/14 8-25

Ash Disposal Site - Option 1: The site ‗Option 1‘ is a scrap and slag disposal area

owned by PSM outside of PSM plant limit. It is approximately 285 acres in size and

divided into more than 30 plots currently being used for storage and disposal of slag,

scrap and old refractory bricks. It is connected through Gate 9 of the PSM plant which

has access to external transportation for 3rd

party contractors.

The scrap yard is equipped with a security check-post and is connected by road to the

National Highway through the main PSM road.

Ash Disposal Site - Option 2: It is approximately 51 acres in size and located 6 km from

the FFBL Complex, towards southeast of the complex. The site is at a distance of 300 m

from national highway (N5).The land is mostly barren and covered with mesquite bushes

with very few housing structures located at the northwestern edge of the site (Exhibit

5.57).


Potential Ashdisposal site in barren land previously used for sand excavation

Ash Disposal Site – Option 3: This site is located towards the east of FFBL Complex, at

a distance of 11.5 km from the Complex. The area towards the north and east of the site is

all farmland, in which seasonal crops are cultivated (Exhibit 5.58). Some poultry farms

are located towards the northeast and west of the site.

Exhibit 8.14: Photographs of Ash Disposal Site – Option 3

Potential Ash Disposal Site



R4V03FBE: 02/19/14 8-26

Agricultural Fields near the Ash Disposal Site Poultry Farms near Ash Disposal Site

Ash Disposal Site - Option 4: this site is located approximately 10 km from the FFBL

Complex, towards its east. It is towards the south of Option 3. The site is at a distance of

1 km from the National Highway (N5). Some community-owned agricultural fields are

located on the eastern edge of the site that fall within 500 m of it. Sand is also being

excavated from this site for construction purposes (see Exhibit 5.59). This site is no

longer being considered as an option for ash disposal by FFBL.


Potential Ash Disposal Site

Agricultural Fields near Ash Disposal Site Settlement near Ash Disposal Site

Ash Disposal Site - Option 5: K-ELECTRIC is planning to convert its Bin Qasim

Thermal Power Station-I Unit No.3 and 4 to coal based boilers. They have planned to



R4V03FBE: 02/19/14 8-27

utilize adjacent land (Option 5 in Exhibit 5.56) for reclaiming land by utilizing ash

generated during the operation of coal boilers. FFBL will approach K-ELECTRIC to

utilize the same land for FFBL CPP Project ash disposal.

Proposed Ash Disposal Site

The following factors were considered in selection of the location for the ash disposal

site.

The site should be close to FFBL plant for economic as well as management

reasons.

The economic value of the land should be low in terms of both the current and

potential uses.

There should be minimal adverse environmental impact, if any, both in the short

and long run.

All five options being considered by FFBL as their potential ash disposal sites are located

close to the plant site with good access routes. Option 3 is located on land close to a

village settlement. Part of it is being used for agriculture with groundwater as a source for

irrigation. Locating the ash disposal site here will require strict controls and regular

monitoring by FFBL to ensure there is no spillage of ash en route to the site; excavation

of soil and dumping of ash does not contaminate nearby agricultural fields; rainwater is

kept from seeping into the ash disposal site and seeping out and contaminating the ground

water resources in the vicinity; and, the transportation of the ash to the site does not

generate traffic which congests the narrow village roads in the vicinity of the ash disposal

site. For these reasons, Option 3 is not deemed a suitable location for an ash disposal site.

Option 4 is not being considered by FFBL any more, however, it too shares the similar

concerns as Option 3 on account of the close proximity of village settlements and

agricultural fields to the proposed location for an ash disposal site.

Option 1 at the PSM scrap and slag yard is a suitable option for FFBL‘s ash disposal site,

however, it is not likely to be available by the time the Project becomes operational. Not

only is the proposed area a designated industrial disposal area for PSM‘s slag, there are

no sensitive receptors, ecological habitats, agricultural fields, settlements, and ground

water resources in the vicinity. Ash disposal at this site will require minimum

management and controls compared to all other options. Option 5, K-ELECTRIC‘s land

reclamation project, similarly, is a future-project unlikely to be available when the Plant

becomes operational.

Option 2 is a barren land with excavated areas already present on account of sand

excavated for use by nearby industries. There are no settlements or ecological habitats in

the near vicinity of the site and there are no signs of agricultural lands either. This makes

for a good option for an ash disposal site; however, FFBL will also need to carefully

manage the commercial contract and conditions for use of land with the land owners.

FFBL must also check with the owners of adjacent land for any upcoming development

plans which may result in the shutting down of FFBL‘s ash disposal site. Section 9

considers the environmental impacts of ash disposal at this site and proposes mitigation

measures.


Hagler Bailly Pakistan Project Impacts and Mitigation

R4V03FBE: 02/19/14 9-1

9. Project Impacts and Mitigation

This section discusses the potential environmental and social impacts of the proposed

CPP project (the ―Project‖). It predicts the magnitude of the impacts, assesses their

significance, identifies mitigation measures to minimize adverse impacts, and evaluates

the residual impacts, if any, of the Project.

An audit of the existing FFBL plant operations was conducted in July 2013 according to

which all of the existing emissions and effluents discharged by FFBL are complaint with

NEQS limits. The industrial processes related to the production of steam from two new

Circulating Fluidized Bed (CFB) boilers in the proposed Project, once operational, will

not add any new types of wastewater streams to the existing ones; nor, will new mediums

of effluent discharge be required. New environmental impacts will be in the form of NOx

and SOx emissions from burning coal; fugitive dust emissions from handling coal and ash

at the coal yard and ash disposal site respectively; and, from traffic congestion and noise

from the transport of coal from the ports to the FFBL plant site (the ―Complex‖).

9.1 Impact Assessment Methodology

The potential environmental and social impact of a development activity is identified on

the basis of concerns raised by stakeholders, technical guidelines, and the professional

opinions of the project team.

Once potential impacts have been identified, the assessment of each impact follows these

steps:

1. Definition of the criteria for determining significance

2. The consequence of the proposed activity is evaluated by comparing it against

recognized ‗significance criteria‘. The criteria are of the following types:

a. Institutional recognition—laws, standards, government policies, or plans

b. Technical recognition—guidelines, scientific or technical knowledge, or

judgment of recognized resource persons

c. Public recognition—social or cultural values or opinion of a segment of the

public, especially the community directly affected by the Project

d. Professional interpretation of the evaluator.

3. Prediction of the magnitude of potential impacts

4. This step refers to the description, quantitatively (where possible) or

qualitatively, of the anticipated impacts of the proposed Project. This may be

achieved through the use of models or comparison with other similar activities.

5. Identification of mitigation measures

6. If it is determined that the predicted impact is significant when compared to

the criteria for determining significance, suitable mitigation measures are



R4V03FBE: 02/19/14 9-2

identified. There is a range of mitigation measures that can be applied to reduce

impacts. Broadly, these measures can be classified into following categories:

a. Avoiding the impact altogether by completely discarding a proposed activity

or parts of an activity; for example, by using CFC–free equipment to avoid

impact on the ozone layer.

b. Minimizing impacts by limiting the degree or magnitude of the activity, for

example, minimizing dust emissions by reducing vehicular traffic.

c. Rectifying the impact by repairing, rehabilitating, or restoring the affected

environment;

d. Compensating for the impact by replacing or providing substitute resources or

environments.

7. Evaluation of the residual impact

8. Incorporation of the suggested mitigation measures reduces the adverse

impact of the Project and brings it within acceptable limits. This step refers to the

identification of the anticipated remaining impacts after mitigation measures have

been applied, i.e., the residual impacts.

9. Identification of monitoring requirements

10. The last step in the assessment process is the identification of minimum

monitoring requirements. The scope and frequency of the monitoring required

depends on the residual impacts identified. The purpose of monitoring is to

confirm that the impact is within the predicted limits and to provide timely

information if unacceptable impact is taking place.

9.2 Identification of Potential Environmental Impacts

This section identifies and assesses the potential environmental and social impacts of the

proposed installation of the Project within the existing Complex. Each potential impact is

then categorized based on Exhibit 9.1, according to anticipated risk to the environment

due to the Project activity to identify the potentially significant issues.

Risk is defined qualitatively in terms of consequence and probability. Consequence is

defined in terms of magnitude, duration, and spatial scale. Thus, the three categories used

in the following exhibit to identify risk are defined as follows:

H—Definite impact, major deterioration and/or long–term impact and/or large

footprint

M—Possible impact, moderate deterioration and/or medium–term impact and/or

intermediate footprint

L—Unlikely (or low likelihood) impact, minor deterioration and/or short–term

impact and/or small footprint

The significant issues are then further discussed in the following sections.



R4V03FBE: 02/19/14 9-3

Exhibit 9.1: Screening of Environmental and Social Impacts of the Proposed Activities

Project Activity Impacts Risk Discussion

Construction Phase

Transportation of equipment during construction

Road transportation resullting in:

Increased traffic noise

Increased vehicular emission

Congestion on road

Increased exposure of community to traffic hazard

L All traffic will remain within the PQA, a designated industrial zone, without any direct contact with neighbouring communities. Storage area will be set up within the existing plant, minimizing frequency of equipment being transported to the plant.

Land Acquisition Acquisition of land from private owners can potentially affect the livelihood

L The Project is being built within the existing FFBL plant premises where sufficient land is already available, therefore, no additional land is being acquired for it. For ash disposal, there are five options including PSM slag yard and a barren land without any future plans of development on it.

Establishment of a construction camp

Waste generation, emission, effluents, and land use L The camp will be located within the existing FFBL plant which is located within an industrial zone with no sensitive receptors or open surface channels in the vicinity. All necessary precautions for effluents and emission will be considered.

Storage of equipment and materials for construction

Improper storage can result in spillage and leakages leading to

Contamination of soil

Contamination of the ground water

L No hazardous materials will be used in the equipment and materials that will be installed.

Disposal of the old equiment and construction debris

Solid waste generation with potential of

Soil contamination

L Hazardous materials are not expected in the equipment and materials that will be removed.

General construction activity

Injuries to the workers or loss of life in case of accidents M Systems and procedures for occupational health and safety and plant housekeeping developed for the existing plant will be applicable to the proposed Project as well. Strict compliance will be ensured.



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Spillage and leakage leading to

Contamination of soil

Contamination of the ground water

L The CPP project is located within the existing FFBL plant which is located within an industrial zone with no sensitive receptors or open surface channels in the vicinity.

Typical construction related impacts such as :

Accidents from unmanaged and unsafe use of machinery/equipment/electrical installations

Noise and vibration

Increase in dust

Social and cultural issues.

Injuries during dismantling.

Health effects to the workers

Social tensions created from work force hiring

L Systems and procedures for occupational health and safety and plant housekeeping developed for the existing plant will be applicable to the proposed Project as well. Strict compliance will be ensured. Original equipment manufacturer‘s (OEM) recommended instructions will be implemented and ensured.

Security guards and construction workers will be provided adequate training for safety and emergency response.

Transmission Lines Lightening / induced current / EMF L Transmission lines to be designed in a way which ensures electric and magnetic fields will be minimized, while meeting the voltage and load requirements.

Transmission lines will be built with a grounded shield wire at the top of poles in order to mitigate the impact of lightning.

Induced current / magentic fields will be prevented by grounding the metal objects near the transmission lines.

Operation Phase

Gaseous emission Emission of SOX, NOx, PM10, and other pollutants resulting in increased health expenses and affecting deprived segments of the local populace.

M Mitigation measures such as installation of fabric filters at flue gas emission points in the new CFB boilers have been incorporated in the design for control and prevention of particulate matter. Sulfur will be removed by limestone which, in a CFB boiler, is added to the furnace combustion process inside the boilers. NOx generation will be well within the limits as set by National and International Standards and also due to selection of CFB boiler which operates at lower furnance temperature and thushas low NOx generation.



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Coal handling at the coal yard

Emission of dust particulates from coal handling activities at the coal yard. Leachates from rainwater and dust–suppression water system runoffs.

L Dry and windy conditions will aid the dispersion of dust particles from the coal yard however water based sprinklers system is included in the design to control dust supression and fire–fighting. Dust particles may settle on flat surfaces in the existing plant and sorrounding industries. Since there is no ground water resources in the vicinity of the FFBL site, therefore, risk of water contamination is negligibe. Moreover, all water from coal yard will be recovered through a dedicated decantation basin for re–use. In addition, other mitigation measures such as sheiding (wind barrier) or shedding will be considered.

Ash disposal Emission of dust particulates from ash handling activities at the ash disposal site. Leachates from rainwater runoffs contaminating water supplies.

L There are five options for ash disposal.

The option # 1 (PSM land) there are no sensitive receptors, nor any water resourcesl at this location. However, due to ongoing privitization process, the option is not currently available.

Option 2 ~4 are flat or low-lying barren lands along National highway towards Dhabeji or within PQA industrial area. Necessary mitigation to be carried out (land to be covered after filling with soil; etc)

Option 5 (K-Electric proposed ash disposal site for new Coal power plant). In this option, the ash will be utilized for land filling and for reclamation near K-Electric Bin Qasim power plant.

The best option is the K-Electric‘s land– reclamation site followed by flat low-lying barren land to be acquired by FFBL.

Effluent discharge Discharge of effluent L Existing effluent is in compliance with NEQS. There will be limited additional effluent from the CPP project.

Main effluent will be cooling water blowdown (will be within NEQS limits) from the Project which will be used for bottom and fly ash conditioning while the remaining blowdown water will be disposed off into PQA‘s drain channel. No chemical nor oily effluent will be gnenerated during normal operation and their use will be also restricted. Despite this, spill control and recovery will be considered where chemicals and oil are used.



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Electrical installations, operation and maintenance

Unsafe condition L OEM operational and maintenace instructions will be implemented and enforced.

The power transformer, being oil containing equipment, will have fencing around it, with a concrete wall and fitted within sump of sufficient size to capture all oil in case of leakage.

The grid station‘s protection and operational controls will be well maintained to switch off the faulty equipment to avoid impacts of accident.

The safe guards and operational personals will be provided adequate training for the safety / emergency responses.



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9.3 Construction Phase

Construction activities have different types of construction impacts. Some of these relate

to activities at the construction site where as others relate to the setting up and operation

of the construction crew camp. Typical issues include:

Site clearance leading to dust emission

Erosion and sedimentation

Air quality impact from operation of construction machinery

Noise and vibration

Waste management

Off–site impacts such as those related to borrow pits

Effluent from construction camp

Safety

Cultural impact

Many of the construction impacts are temporary and end with the completion of the

construction activity. However, poor management can result in damage to the

environment during activities. To avoid adverse impacts from the construction activities

on the environment, the following measures are proposed:

The construction contractor will develop a specific construction management plan

(CMP) based on the CMP included in the Environmental Management Plan in

Appendix E.

The CMP will clearly identify all areas that will be utilized during construction

for various purposes. For example, on a plot plan of the construction site the

following will be shown:

Areas used for camp / site office

Storage areas for raw material and equipment

Waste yard

Location of any potentially hazardous material such as oil

Parking area

Loading and unloading of material

Septic tanks

Other key mitigation measures to be adopted are as follows:

New equipment will be stored in properly demarcated and identified areas

Separate storage of each item will be adopted and each area will be marked

either on floor or cordoned off by tapes



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Lifting equipment (cranes) used for the equipment will follow the prescribed

safety specification.

Proper illumination to be provided

Material Safety Data Sheet (MSDS) for chemicals, if any, will accompany the

consignment. A copy of the MSDS will be available near the storage area at

all times.

Appropriate PPE will be provided to the workers and it will be ensured that

the PPE are used.

The staff will be provided with training in use of PPE.

Proper scaffolding platforms will be provided for all work areas located more

than 1 m above floor level.

First Aid facilities and fire protection devices will be placed in areas where

work activities will be performed.

Ear protection will be used if the noise level is above 85 dB(A)

All confined spaces55

will be identified

The temperature of the confined space will be in the human tolerance range

Artificial and intrinsically safe lighting will be provided in the confined

spaces

If there is a risk of gases or fumes in the confined space the provisions for

ventilation will be made.

9.3.1 Drainage and Stormwater Run–off

The stormwater runoff from construction sites can carry solids and oil. Any risk may be

eliminated by taking measures to avoid potential spills and taking immediate remedial

measures in case of accidental spillage of oil.

The area of the plant site is a designated industrial zone with small and large industries

located in its surroundings. There are no natural drain courses or open–surface water

bodies in the area close to the site. The construction site is within the existing fertilizer

complex and surrounded by walls and it is unlikely that the construction work at the plant

will measurably affect the drainage pattern of the area.

Camp Effluent

The staff and labor camps for the construction and operation of the new CPP plant will be

a source of wastewater generated from the toilets, washrooms, and the kitchen, etc. All

55 ―Confined space" means a space that:

(1) Is large enough and so configured that an employee can bodily enter and perform assigned work; and

(2) Has limited or restricted means for entry or exit (for example, tanks, vessels, silos, storage bins, hoppers, vaults, and pits are spaces that may have limited means of entry); and

(3) Is not designed for continuous employee occupancy.



R4V03FBE: 02/19/14 9-9

sanitary effluent will, however, be routed to existing septic tanks and soakage pits or

existing restrooms will be utilized where possible.

9.3.2 Disposal of Waste

The construction activities will generate considerable amount of waste. A detailed

inventory of the waste will be prepared. The waste will include metals (mainly iron and

copper), concrete, wood, cotton, plastic, packing materials, electronic, and insulation

material. Several types of hazards are associated with the wastes. For example:

Sharp edges in metals

Tripping hazards if material is left in the pathways

Soil contamination from leaking oil from equipment

Slipping hazard from oil on floors

Potentially toxic content

Respiratory disorders

A comprehensive waste management plan will be instituted during which re–use

opportunities for waste generated from the plant during routine operation and

maintenance will be actively investigated. Used oil and other waste identified, if any, will

be stored in separate designated and contained facility.

As a standard practice all metal (mainly iron and copper) or wooden parts generated as

waste during the rehabilitation project will be recycled or stored in dedicated existing

scrap yard for auction.

9.3.3 Soil and Water Impact

Possible sources of soil and water impacts include:

Spills during refueling, discharges during vehicle and equipment maintenance,

traffic accidents, handling of chemicals and leakages from equipment and

vehicles often result in contamination of soil during construction;

Runoff after a storm from the plant site or the construction site may contain oil

that may pollute the surrounding lands. Earthwork may also alter the drainage

pattern and affect the stormwater flow and result in possible flooding of sections

of surrounding land;

Various types of wastes such as packing waste; metal scrap, and excess materials,

uprooted vegetation, and excess soil will be generated during the construction

phase. Besides being an eyesore, the waste can be a health hazard and pollute

waterways, if disposed improperly.

9.3.4 Contamination Prevention

In the absence of national or domestic regulations and an effective waste management

system, waste disposal can potentially become a serious environmental issue. To avoid



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any potential issue, the project proponent will have to impose adequate internal controls.

The proposed controls are discussed in the following section.

According to the IFC PS 4 guidelines, the client will prevent or minimize the potential for

community exposure to hazardous materials that may be released by the project and in

addition, the client will exercise commercially reasonable efforts to control the safety of

deliveries of raw materials and of transportation and disposal of wastes.

The following control measures are proposed to mitigate the impact on soil and sea water

to meet the requirements of the IFC PS 3 Pollution Prevention and Abatement, PS 4

Resource Efficiency and Pollution Prevention, and MARPOL conventions for

Community Health, Safety and Security:

Spill prevention trays will be provided and used at refueling locations

On–site maintenance of construction vehicles and equipment to be carried out at

designated places within existing Complex

Regular inspections will be carried out to detect leakages from construction

vehicles and equipment

Vehicles and/or equipment with leakage will not be used until repaired

Fuels, lubricants, and chemicals will be stored in covered bunded areas, underlain

with impervious lining

Appropriate spill control arrangements, including shovels, plastic bags and

absorbent materials, will be available near fuel and oil storage areas

Measures will be taken to minimize soil contamination. Contaminated soil will be

immediately collected to minimize the volume of contaminated soil. Heavily

contaminated soil will be segregated from the rest of the soil. Various final

disposal options for contaminated soil are available. These include incineration at

facilities in Karachi, disposal through licensed hazardous waste contractors,

encapsulation at site, and bioremediation at site or off–site location. Appropriate

disposal method will be employed, however, until an acceptable method is found

the contaminated soil will be stored at the site in secure containers.

Through contouring and installation of embankments, where necessary, it will be

ensured that stormwater from the surrounding areas does not enter the

construction site and pass to the sea water

All unpaved exposed areas of the plant will be compacted to minimize water

erosion

All areas containing potentially hazardous materials will be hydrologically

isolated from the remaining site.

Soil banks from ditching operations will not be placed where they might impair

natural drainage

Channel runoff will be provided, where necessary, to avoid flooding



R4V03FBE: 02/20/14 9-11

No untreated effluents will be released to the environment

Liquid waste will be collected and treated using the existing water treatment plant

in the Complex to comply with NEQS and the IFC guidelines for Nitrogenous and

Ammonia fertilizer plants before releasing to the environment

Good practice measures will be followed while handling coal at PQA and Karachi

Port (KP) while transferring from ships.

Implementation of the proposed mitigation measures is not likely to leave any long–term

residual impact on the soil. However, insignificant amounts of hydrocarbons may be left

in the soil due to minor spills, where remedial measures are not possible.

The treated water discharged will contain contaminants. However, their concentration

will be below the NEQS limits.

Even after implementation of the control measures, it is possible that some littering may

take place. Periodic monitoring and cleanup will be undertaken to minimize the residual

impact.

Solid waste generated during plant construction, operation, maintenance activities, office

works, and housekeeping will be accumulated in a scrap yard and auctioned to

government authorized contractors having NOCs for recycling and dumping the waste at

government approved sites for safe disposal as per practice in vogue.

Impact Characterization

Phase: Construction and Operation

Magnitude Duration Scale Consequence Probability Significance +/– Confidence

Initial Impact Major Long term

Inter–mediate

Medium Possible High – High

Residual Impact

Major Long term

Inter–mediate

Minot Possible Low – High

9.4 Operation Phase

The industrial processes of the CPP project related to the production of steam from the

boilers, once operational, will not add new wastewater streams to the existing ones; nor,

will new streams of effluent discharge be required.

New environmental impacts will result from NOx and SOx emissions from burning coal;

fugitive dust emissions from handling coal and ash at the coal yard and ash disposal site

respectively; and, traffic congestion and noise from the transport of coal from the ports to

the Complex.

9.4.1 Impacts on Water Resources


FFBL fertilizer complex generate a variety of wastewater streams as stated in

Section 3.2.8. Out of these, cooling water blow–down, effluents from the

demineralization plant and stormwater effluents are discharged into the PQA drain



R4V03FBE: 02/19/14 9-12

outside FFBL‘s battery limits. The CPP project will result in an addition in the volume of

the cooling water blow–down generated from existing plant operations. However, the

blowdown will also be utilized for ash conditioning and thus, effluent generation will be

further curtailed. Moreover, the blowdown water shall also be utilized for horticulture

purposes thereby reducing discharge of blowdown as effluent to the fullest.

PQA has planned the installation of an industrial sewage treatment plant which will treat

the waste generated by the industries in the PQA to further reduce the pollutant levels in

the effluent. The treated effluent will ultimately discharge into the sea though a dedicated

drain. Presently the effluent is discharged into the PQA drain flows into the Ghaghar

Nullah, a natural rain water course, from where the effluents end up in the sea. Although

the effluent in the PQA drain also includes effluent from other industries, FFBL

recognizes that it is industrial effluent which can be a potential hazard for the community,

particularly the livestock. FFBL will collaborate with PQA to prevent access of the

people of the surrounding communities to the Ghaghar Nullah by putting up warning

signs and initiating an awareness campaign.

Wastewater Discharge into the Ghaghar Nullah

A list of wastewater sources, quantities, types of wastewater treatment, and receiving

water bodies for different plant operating conditions from the existing FFBL plant is

provided in Exhibit 3.5 and Exhibit 3.6. The three wastewater streams from the existing

plant operations that are being discharged into the PQA drain – which ultimately

discharges into the Ghaghar Nullah – are from the:

Cooling water blow–down, at a rate of 2,200 m3/day;

Demineralization wastewater (after neutralization), at a rate of 216 m3/day, and;

Stormwater runoff.

In the existing Complex, the designed discharge of cooling tower blowdown was

7,776 m3/day. However, due to water conservation measures such as increasing cooling

water cycles in the existing cooling tower and use of blowdown water for horticulture

purposes, the existing blowdown discharge rate into the PQA drain is around

2,200 m3/day.

Without adding a new wastewater stream, the CPP project will generate about 70 m3/hr

only or 1,680 m3/day, of cooling tower blowdown which will, partly, be used for ash

conditioning as well as for horticulture. Therefore, the net effect from the blowdown

water from the CPP project will be an additional 1,200 m3/day to the existing cooling

water blowdown. Therefore, coupled with the demin wastewater, a total of 3,616 m3/day

of effluent will be discharged into the PQA drain once the Project becomes operational.

The results from the audit have already shown that the quality of the treated wastewater

being discharged into the PQA drain complies with NEQS standards. Section 5.1.4

discusses the results of water samples taken from the point where the FFBL effluent

leaves the plant boundary wall and shows the results to be complaint with both NEQS

and IFC Guidelines.

The additional volume of cooling water blow–down added by the CPP project to the

existing wastewater stream is not expected to be very large and thus, will be effectively



R4V03FBE: 02/19/14 9-13

managed by the existing wastewater treatment systems in the Complex. Therefore, there

is no significant impact expected to surrounding water resources from the new CPP

project.

The Ghaghar Nullah – where the PQA drain finally discharges effluents from FFBL –

remains dry for 6 to 9 months of the year. Peak flows have been witnessed during the

monsoon season.

Treated wastewater from the existing fertilizer complex will meet the NEQS for liquid

effluents, as discussed above. Parameters, such as, chemical oxygen demand (COD),

dissolved solids, phosphates, and heavy metals, will be well within the allowed limits for

liquid effluents when they are discharged into the PQA drain before eventually flowing

into the Ghaghar Nullah. It will be further diluted when mixed with the rainwater in the

nullah during the monsoon season. The level of suspended solids is exceptionally high in

rivers, lakes and canal water in the rainy season. However, the Ghaghar Nullah is not a

permanent source of surface or fresh water for settlements located downstream and this

water is not used for drinking. Therefore, a slight increment of suspended solids in the

Ghaghar Nullah during the monsoon season will not have any adverse environmental

impact.

Impacts during Other Seasons

The Ghaghar Nullah does not receive significant amounts of rainfall for the rest of the

year. The continuous discharge of effluents into the nullah will mean that there will be a

year–round flow from the nullah going into the Gharo Creek near the sea. Since the

quantum of the flows will be well within the capacity of the nullah, no significant erosion

of the nullah boundaries or dispersion of effluent into the surrounding areas is expected.

As the wastewater quality will be well within both the NEQS and IFC limits, it will not

have a negative impact on the environment.

The Ghaghar Nullah is not generally used as a source of drinking water by inhabitants of

neighboring settlements; however, it is regularly used as a grazing area for their

livestock. Therefore, the PQA should arrange for a closed drain through the battery limits

of the PQA right down to the sea, instead of letting it flow into the Ghaghar Nullah where

residents from surrounding settlements and their livestock can come into contact with the

discharge. However, in its absence, FFBL, being a user of the PQA drain and PQA itself

will put up sign boards along the PQA drain and Ghaghar Nullah warning people from

using the water. PQA is currently liaising with other government agencies to initiate

construction of a closed drain-channel up to the sea creek as the number of industries in

the area is on the rise.

The CPP project is not a chemical process plant; it will, therefore, not generate any

chemical effluent or oil effluent owing to small use of oil.

Wastewater Discharge into Evaporation Pond

Discharges from the chemical sewer are currently sent to the evaporation pond after

neutralization. The process will remain the same when the CPP project becomes

operational. The total area of the evaporation pond is 22 acres (91,242 m2).



R4V03FBE: 02/19/14 9-14

Since there will be no effluent discharge from the evaporation pond, there will be no

effect whatsoever on the surface water resources from it.

A clay layer at the base of evaporation pond greatly reduces water infiltration below land

occupied by the Complex. Furthermore, as discussed in Section 5.1.4, there are no

significant groundwater resources in the Bin Qasim area. Therefore, any change in

groundwater quality, if at all, will not be significant. During normal operation of CPP,

there will be no effluent going to evaporation pond.

Impact of Water Consumed by the Project

The operational water requirements for the CPP project will be met by the existing water

supply system of the Complex. The existing supply is met by a 7.0 MGD RCC lined

carbon steel water line dedicated for use by FFBL, as well as from a PQA water reservoir

which supplies (4.5 MGD). The existing makeup water needs of the fertilizer complex

are estimated to be 1,270 m3/h and are not expected to rise from the CPP project.

Since the existing FFBL water supply system has already been established specifically

for meeting the water requirements of FFBL‘s existing complex— which will stay the

same with the CPP project— there will be no adverse impact on the water resources of

the area or the community.

Mitigation Measures

Based upon the above analyses, the following mitigation measures will be adopted:

1. Effluents being discharged by FFBL into the PQA drain will meet both the NEQS

and IFC limits. The incremental impact from the CPP project on water in the PQA

drain and Ghaghar Nullah will be quite small (mainly from cooling tower

blowdown during normal operation and stormwater especially during rain) and is

unlikely to have significant impacts on creek ecology downstream.

Despite the incremental impact of effluent from CPP, the overall combined

effluent (existing fertilizer complex and from CPP) will remain within the

designed flow rate of the existing complex. However, to further reduce the above

impact, FFBL intends to utilize as much of the treated effluents as required for

their dust suppression systems installed in the coal yard and other coal handling

facilities within the plant. Some of the wastewater in the existing fertilizer

complex (cooling tower blowdown) is already being utilized for watering

plantations within the plant. The wastewater quality is suitable for irrigation

purposes.

2. Although the possibility of using wastewater from the PQA drain channel /

Ghaghar Nullah by locals for meeting drinking water needs is remote, however,

warning sign boards in Sindhi, Urdu and English will be placed at regular

intervals along the PQA drain / Ghaghar Nullah. Furthermore, areas downstream

of the discharge point will be monitored periodically. The Port Qasim authorities

should look into extending the existing drain south, within the limits of the PQA,

directly into the sea thereby reducing the risk of using this water if any by nearby

settlements.



R4V03FBE: 02/19/14 9-15

9.4.2 Impacts on Air Quality

The main mode of air pollution from a thermal power plant is point emission—emissions

from the boiler and the combustion of fuel (such as coal) results in the emission of

various types of pollutants from the plant stack. The main pollutants are particulate

matter, oxides of nitrogen (NOx), and sulfur dioxide (SO2). To ensure protection of

human health, standards and limits have been prescribed by national regulatory

authorities on the maximum acceptable concentration of these pollutants in the ambient

air. The impact of the proposed project was assessed using US EPA approved ambient air

quality model in order to ensure compliance with the ambient air quality standards and

guidelines.

Objectives of Air Quality Impact Assessment

Specific objectives of the air quality impact assessment were:

1. Predict the impact of the proposed Project on the ambient air quality of the

surrounding area

2. Assess the predicted air quality against the applicable standards and guidelines

3. Identify the mitigations measures, if any, that are required to ensure compliance

with the applicable standards and guidelines

4. Identify the optimum height of the emission stacks

Applicable Standards

The primary pollutants of concern are particulate matter, oxides of nitrogen (NOx), and

sulfur dioxide (SO2). The NEQS for ambient air quality applicable to the project are

shown in Exhibit 9.2.

Exhibit 9.2: NEQS for Ambient Air Quality for the Pollutant of Concern

Pollutants Time–weighted Average Concentration in Ambient Air

Sulfur Dioxide (SO2) Annual Average* 80 μg/m3


Oxide of Nitrogen as (NO) Annual Average* 40 μg/m3


Oxide of Nitrogen as (NO2) Annual Average* 40 μg/m3


Respirable particulate Matter. PM10 Annual Average* 120 μg/m3


Particulate Matter. PM2.5 Annual Average* 15 μg/m3


1 hour 15 μg/m3




R4V03FBE: 02/19/14 9-16


Air Quality Model

To predict the increment of the pollutants in the ambient air due to the power plant the

United States Environmental Protection Agency‘s regulatory model AERMOD was used.

The modeling area was defined as 16 km × 16 km with the FFBL in the center. The size

of the area was defined considering the following points in the pre–run of model:

Distance from the center of FFBL at which the pollutants concentrations become

negligible

Location and distance of other sources of emissions, if any.

Location and distance of receptors

Pre–processed hourly meteorological data for the meteorological station at Karachi for

the year 2011 was purchased and used in the model.

Modeling Scenarios and Inputs Parameters

Emissions from the fertilizer plant were estimated for two scenarios as follows:

1. Existing Scenario—Total 10 stacks were assumed to be functioning in the

Existing Scenario using natural gas as fuel for the utility gas turbines (HRSG and

Auxiliary Boilers). Exhibit 9.3 lists the stacks under the Existing Scenario.

Exhibit 9.3: Stack Identification for Existing Scenario


DAP DAP Plant Stack DX–531

Urea

Granulator Scrubbers UX–670

Coolers Scrubbers UX–670

4 kg/cm2 Absorber UX–331

Low–Pressure Absorber UX–331

Ammonia

Waste Heat Recovery Boiler V–405

Reformer Furnace Stack F–101

Fired Heater Stack F–1003

Utility Gas Turbine HRSG SX–601

Auxiliary Boiler SX–601

2. CPP Scenario after conversion on coal—Total 9 stacks were assumed to be

functioning. Utility gas turbine stacks will not operate in this scenario. However,

one stack using coal as fuel will operate instead. Therefore, CPP boiler stack

using sub–bituminous coal was assumed to be operational under CPP Scenario.



R4V03FBE: 02/19/14 9-17

For all the scenarios, common inputs for modeling are shown in Exhibit 9.4. Input values

which are different in each scenario are shown in Exhibit 9.5.

Exhibit 9.4: Common Model Inputs for Stack under All Scenarios

Parameter Unit Stacks

Stack ID DX–531 UX–670 V–405 F–101 F–1003 UX–331

Stack Serial 1A 2B 5E 6F 7G 9U

Location, x UTM 340116 340161 340254 340244 340153 340205

Location, y UTM 2747796 2747830 2747609 2747711 2747706 2747822

Location, z m 36 36 35 34 34 35

Stack Height m 63.81 62.30 20.00 36.00 30.18 60.00

Temperature K 330.15 314.78 443.15 498.15 643.15 321.23

Velocity m/s 9.95 20.44 23.83 12.50 13.50 0.04

Diameter m 3.30 3.00 2.50 2.10 0.94 4.00

Exhibit 9.5: Scenario Based Model Inputs for Stacks

Parameter UUnit Existing Scenario CPP Scenario

Stack ID SX–601 CX–xxx

Stack Serial 3C4D 8H

Location, x UTM 340272 340287

Location, y UTM 2747935 2747414

Location, z m 34 32

Stack Height m 73.50 70.00

Temperature K 492.47 422.15

Velocity m/s 10.39 18.00

Diameter m 6.10 3.00

Exhibit 4.10 presents pollutant flow rates assumed in the model for Existing Scenario

and CPP Scenario. The pollutants flow rates were calculated from the emissions data

provided by FFBL.

Exhibit 9.6: Pollutant Flow Rates Assumed for Modeling

Pollutant Unit Common to both Scenarios Existing Scenario

CPP Scenario

Stack ID DX–531 UX–670 F–101 SX–601 CX–xxx

NOx g/s – – 8.09 0.01 60.36

SOx g/s – – – – 126.06

PM₁₀ g/s 6.97 3.24 – – 4.44

PM2.5 g/s 2.32 1.08 – – 1.48

Note: Stacks that are not mentioned above have zero values for all pollutants



R4V03FBE: 02/19/14 9-18

Background Pollutant Levels

The ambient air quality was measured for the area in the vicinity of the FFBL. The

results are shown in Exhibit 5.11. The background level defined as the contribution of

emission sources in the area other than the emissions contributed by FFBL, but this

cannot be measured as it is not possible to completely shut down the fertilizer plant for

such measurement. However, a conservative estimate was developed by a simulating air

quality with the FFBL fertilizer plant running on natural gas (Existing Scenario) using the

United States Environmental Protection Agency‘s regulatory model AERMOD. By

subtracting the Existing Scenario values from the ambient air measurements, background

levels were determined as shown below.

Background Levels of PM2.5 in Pakistan

It has been argued that dust levels in Pakistan are naturally high due to dry conditions.56

A source apportionment study carried out in Lahore57 indicated that 68-89% of PM10 in

ambient air is from re-suspended soil and dust. The re-suspended solid includes natural

dust and dust from traffic movement. Similar results have been reported from

neighboring India where environmental conditions are similar.58 In the project area both

these sources are likely to contribute.

Estimate for Background PM2.5 and Comparison with Standards and Guidelines

The estimated annual background level of 63 µg/m3 for PM2.5 is considerably above the

NEQS 24-hr (98th Percentile) limit of 35 µg/m3, and above the Annual Average limit of

15 µg/m3. A review of the NEQS for PM2.5 and the regional practice indicates that:

The NEQS 1-hr limit for PM2.5 is inconsistent with the annual limit. The limit for

1-hr (15 µg/m3) is the same as the annual limit. This is contrary to the practice

world-wide where the limits for longer time frame are always lower than that of a

shorter time frame to allow for variations over time.59 Similarly, the NEQS 1-hr

limit of 15 µg/m3 for PM2.5 is inconsistent with the 24 hour limit of 35 µg/m

3.

The ambient air quality standards of other countries in the region are reflective of

the high PM2.5 levels in the ambient air. The annual limits for PM2.5 in India and

Sri Lanka are 40 µg/m3 and 25 µg/m

3 respectively. Similarly, the 24-hr limits for

PM2.5 in these countries are 60 and 50 µg/m3 respectively. Given the high natural

56 See for example, JICA Report. http://www.environment.gov.pk/pub-pdf/3city-inv.pdf (Date Accessed:

August 20, 2013)

57 Zhang. Y., et al. 2008. Daily Variations in Sources of Carbonaceous Aerosol in Lahore, Pakistan during a High Pollution Spring Episode.. Vol. 8, No. 2, pp. 130-146. http://www.aaqr.org/VOL8_No2_June2008/2_AAQR-07-09-OA-0042_130-146.pdf (Date Accessed: August 20, 2013)

58 T. Pachauri, et al. in Aerosol and Air Quality Research, 13: 977–991, 2013 have reported that PM2.5 levels in Agra is 308 and 91 µg/m

3 for traffic and rural sampling sites respectively. After subtracting the

organic and elemental carbon (contributed by biomass burning and vehicular emission), the background level in rural area is still 38 µg/m

3.

59 Higher pollutant concentrations are permitted for shorter intervals only and prolonged stress to receptors over a longer period of time is avoided by prescribing a lower limit for an extended period of time. The average for a longer period cannot also mathematically be higher than the maximum figures for the shorter intervals.

http://www.environment.gov.pk/pub-pdf/3city-inv.pdf



R4V03FBE: 02/19/14 9-19

background particulate levels in Pakistan where environmental conditions are

somewhat similar to those in India and the current level of controls on industrial

and vehicular emissions, it is unlikely that compliance with the NEQS annual

limit of 15 µg/m3 for the PM2.5 can be achieved in any part of Sindh in the near

future.

The FFBL will formally approach the Environmental Protection Agency of the

Government of Sindh to review the PM2.5 limits in the NEQS and to rationalize

them, and the subject is presently under discussion. The Environment Department

has already indicated willingness to undertake a review of the PM2.5 limits in view

of the evidence and discussion presented recently in another EIA.

Results

The predicted increments in pollutant levels are presented in Exhibit 9.7.

Exhibit 9.7: Predicted Increment to the Pollutant Levels

Pollutant Averaging Time Increase in Concentration (µg/m³)

Existing Scenario CPP Scenario

SO₂ 24–hr (98th Percentile) – 70.24

Annual – 22.70

NO₂ 24–hr (98th Percentile) 18.8 33.63

Annual 6.8 11.83

PM₁₀ 24–hr (98th Percentile) 20.06 20.41

Annual 7.62 8.03

PM2.5 1–hr (Highest) 22.6 22.6

24–hr (98th Percentile) 6.68 6.79

Annual 2.54 2.67

The contours for annual concentrations under Existing Scenario are shown in Exhibit 9.8

to Exhibit 9.10.



R4V03FBE: 02/19/14 9-20

Exhibit 9.8: Predicted Increment to the Annual NOX Levels (µg/Nm3)



R4V03FBE: 02/19/14 9-21

Exhibit 9.9: Predicted Increment to the Annual PM10 Levels (µg/Nm3)



R4V03FBE: 02/19/14 9-22

Exhibit 9.10: Predicted Increment to the Annual PM2.5 Levels (µg/Nm3)

The contours for annual concentrations under CPP Scenario are presented in Exhibit 9.11

to Exhibit 9.14.



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Exhibit 9.11: Predicted Increment to the Annual SOx Levels (µg/Nm3)



R4V03FBE: 02/19/14 9-24

Exhibit 9.12: Predicted Increment to the Annual NOx Levels (µg/Nm3)



R4V03FBE: 02/19/14 9-25

Exhibit 9.13: Predicted Increment to the Annual PM10 Levels (µg/Nm3)



R4V03FBE: 02/19/14 9-26

Exhibit 9.14: Predicted Increment to the Annual PM2.5 Levels (µg/Nm3)



R4V03FBE: 02/20/14 9-27

To assess the total impact of plant on the air quality in surrounding environment,

background levels were added to the incremental pollutant levels predicted by the Model.

Exhibit 9.15 shows the comparison of results with the NEQS.

Exhibit 9.15: Predicted Pollutant Concentrations

Pollutant Background Concentration

Levels (µg/m³)

Averaging Time

Incremental Concentration Level

(µg/m³)

NEQS (µg/m³)

Predicted Concentration Level

(µg/m³)

Existing Scenario

CPP Scenario

Existing Scenario

CPP Scenario

SO₂ 22.8 24–hr (98th Percentile)

– 70.24 120 22.8 93.04

Annual – 22.70 80 22.8 45.5

NO₂ 13.4 24–hr (98th Percentile)

18.8 33.63 80 32.2 47.03

Annual 6.8 11.83 40 20.2 25.23

PM₁₀ 97.3 24–hr (98th Percentile)

20.06 20.41 150 117.4 117.7

Annual 7.62 8.03 120 104.9 105.3

PM2.5 62.7 1–hr (Max.) 22.6 22.6 15 85.3 85.3

24–hr (98th Percentile)

6.68 6.79 35 69.4 69.5

Annual 2.54 2.67 15 65.2 65.4

The results of the air dispersion modeling indicate that SO2, NO2, and PM10

concentrations in the air with the CPP in operation will be compliant with national












PM2.5 limits in view of the evidence and discussion presented recently in another EIA60.

60 Hagler Bailly Pakistan. Environmental Impact Assessment: Jamshoro Power Generation Project.

Islamabad: HBP, 2013.



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9.4.3 Air Quality Impacts from Coal–Handling at the FFBL Coal Yard

The predominant discharge from the proposed coal yard will be particulate matter. Small

quantities of engine exhaust emissions will be generated from the mobile equipment used

on the site. The emissions from the engines are considered to be relatively minor and are

expected to be well dispersed prior to reaching sensitive receptors. The dust that will be

discharged from the coal stockpile in the coal yard will be comprised of a wide variety of

size fractions. The larger deposited dust is material generally greater than 50μm in

diameter. It poses a nuisance potential due to soiling of surfaces and can cause irritation

to eyes and nose. Because it is relatively large in size, deposited particulate usually falls

out of the air within a short distance of the source and usually within 100m. There are no

sensitive receptors within a 100 m radius of the FFBL complex.

The finer materials, commonly referred to as Total Suspended Particulate or TSP, and

generally less than 20 μm, can travel large distances downwind. While these pose the

greatest potential health effect, the major source of the finer particulates in the

atmosphere is combustion processes which have been discussed in the air quality section.

The particulate generated from processes such as those involved in a coal yard are likely

to be predominantly made up of larger size fractions (greater than 10μm).

The major factors that influence dust emissions from surfaces are:61

Wind speed across the surface – the critical wind speed for pickup of dust from

surfaces is 5 m/s; above 10 m/s pickup increases rapidly.

The percentage of fine particles in the material on the surface.

Moisture content of the material on the surface.

The area of exposed surface.

Disturbances such as traffic, excavation, loading and unloading of materials.

The height of the source above the surrounding ground level.

Dust emissions from material handling and storage can be significant if not controlled.

However, if standard dust control techniques are used the emissions can be reduced

significantly. The smaller the particle size of the material on the surface of a road or an

exposed surface, the more easily the particles are able to be picked up and entrained in

the wind. Moisture binds particles together preventing them from being disturbed by

wind or vehicle movements. Each coal type and grade has a unique moisture content

above which dust emissions are substantially reduced. FFBL will ensure that the moisture

content of the coal is maintained as required throughout the coal handling process from

the point it arrives at the ports, to its injection into the boilers, to minimize dust

emissions.

CPP‘s coal–handling operations will have dust-suppression systems spraying water on

the coal at the ports and prior to unloading at plant-site and being exposed to the sun and

wind in order to cater for some evaporation and seepage.

61 Beca Pty Ltd (Beca). (2010). L&M Coal Ltd Assessment of Environmental Effects of Discharges to Air

from Proposed Coal Stockpiles. Greymouth, New Zealand: West Coast Regional Council.



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Sources of Particulates and Proposed Mitigation Methods

The activities that will take place at FFBL‘s coal storage yard for the CPP project, that

may generate discharge to air are:

Construction

Vehicle movements on unpaved surfaces

Wind generated dust from dry exposed surfaces such as stockpiles and yard areas.

Loading and unloading of materials

Stockpiling.

The methods proposed to mitigate the potential sources of particulate emissions are

summarized below:

Construction

During the excavation of the site designated for the coal yard, stripping of soil from the

surface and the formation of bunds and roads have the potential to generate significant

quantities of dust if the processes are not carefully controlled. To control dust from these

activities during the preparation of the coal yard FFBL will use the following mitigation

methods:

Keep exposed surface areas to a minimum and vegetate exposed areas as soon as

practical.

Restrict potentially dusty activities such as the stripping and spreading of topsoil

on days when conditions are dry and winds are strong and blowing towards

sensitive receptors.

However, since the climate and weather conditions in the CPP project site will be

dry and windy on most days, dust from the construction of the coal yard has the

potential to generate a lot of dust. FFBL will, therefore, ensure the availability of

large quantities of water as a dust suppressant to keep unvegetated surfaces and

roads damp.

Yard Areas and Roads

Vehicle traffic on access roads and vehicle traffic around the stockpile all have the

potential to be significant sources of dust. Dust from yard areas and roads will be

controlled primarily by limiting the amount of fine particles exposed to the wind and,

keeping surfaces damp.

On areas of the yard and roads that are crossed by vehicles any coal deposited onto the

surface can be ground into small particles which are particularly susceptible to pick up by

the wind. FFBL will control this dust by removing the buildup of fine material on a

regular basis and replacing the surface of the area with coarser grade material.

Yard areas disturbed, and roads used frequently will be watered regularly. It is also

recommended that FFBL controls vehicle speeds in the vicinity of the coal stockpile.



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Limiting the speed of vehicles reduces the turbulent wake behind moving vehicles and

reduces the amount of material picked up and entrained by the wind.

The coal stockpile area will be designed to minimize haul distances between the stockpile

and the boiler loading area and the number of vehicle movements. Bunds will be built

strategically to shelter the yard area from the wind, providing a significant barrier to dust

being carried beyond the boundary wall of the Complex.

In summary the following dust mitigation methods will be adopted:

Coal stockpile to be inside bund area,

Vehicle speeds to be controlled in the vicinity of the stockpile,

Road and yard surfaces to be cleaned or kept damp when required,

Internal haul roads and yard areas to be maintained by removal of fine material

and the laying of fresh gravel.

Travel distances be minimized by using conveyors to load coal onto the stockpiles

and by locating the stockpile in close proximity to the boilers.

Loading and Unloading of Materials

Coal falling onto a stockpile and at conveyor transfer points is a potential source of dust

as is wind picking up fine dry particles of coal from the surface of the conveyors. Coal

falling off conveyors due to blockages and dropping from return belts can result in a

buildup of coal under conveyors. This material can become a source of dust if not

removed.

Transfer points to the yard conveyor will be covered, however, some parts, such as the

transfer point between the yard conveyor and the stacker may not be able to be covered

due to the design of the equipment. Dust suppression systems will be installed in those

parts.

Elevated stacker conveyors will be provided with covers or windshields to shelter the

coal from the wind and reduce dust potential. The coal will be damp when it is loaded

onto the stockpile and water will be available to dampen the coal plume falling onto the

stockpile to reduce dust formation. This will be required especially when thermal coal is

being stockpiled given the high percentage of fine material in the coal. However,

ensuring relatively high moisture content of the coal being carried by trucks to the yard

will reduce this risk.

Conveyor belts will be fitted with belt scrapers to remove coal build up on the return

belts. Coal dropping onto the ground as a result of spillages will be regularly removed.

Coal being reclaimed from the stockpile for use in the boilers will also lead to possible

spillage. Such loading areas will be cleared of any spilled coal regularly and bunds

surrounding the stockpile area will shelter the load out activities from the wind and water

used to dampen surfaces. These mitigation methods will reduce the potential for dust

generated from these activities leaving the site.

To control dust from the loading and unloading of coal the following methods will be

adopted:



R4V03FBE: 02/19/14 9-31

A conveyor and travelling stacker be used to transfer material to the stockpiles,

Water will be used to dampen any dust produced from the coal falling onto the

stockpiles,

Transfer points on the yard conveyors will be covered,

The elevated stacker conveyor will be provided with wind shields or covers,

Conveyors will be fitted with belt scrapers,

Coal deposits under the conveyors and at the truck unloading area will be

regularly removed,

Bunds will be strategically located around points of frequent handling of coal at

the stockpile to shelter the loading and unloading activities from the wind.

Dust Control System for CPP Project

Dust control is achieved by dust suppression and extraction system. Dust suppression is

achieved by two methods; Plain Water Dust Suppression System and Dry Fog Type Dust

Suppression System. Design and construction features of Dust control system shall be

generally in conformity with the recommendation of ―American Conference of

Governmental Industrial Hygienists‖ or applicable international standards.

Type of dust suppression system to be provided at various locations shall be as

given below:

Around the Coal unloading station – Plain water dust suppression.

Crusher receipt and discharge points – dry fog type dust suppression

For all transfer points – Dry fog type dust suppression system

For stock pile – Plain water type dust suppression system with swiveling nozzles.

Boom belt discharge of stacker / reclaimer – Dry fog type dust suppression

system

Dry fog type dust suppression system:–

Spray head minimum pressure at inlet (dry fog) shall be provided by the

Contractor for water and air.

Dust extraction System shall be provided at following locations:

For Bunker floor

For crusher house

At the outlet of the dust extraction system, the dust concentration shall be well below as per International standard applicable for working areas

Coal Stockpiles

Wind blowing across the stockpile and vehicle movements disturbing the surface of the

stockpile has the potential to generate dust. The amount of dust generated from surfaces



R4V03FBE: 02/19/14 9-32

such as stockpiles is dependent on the wind speed across the surface and the proportion

of fine material on the surface of the pile exposed to the wind. Inactive stockpiles develop

a crusty surface that effectively minimizes dust emissions.

The principal means of controlling dust from stockpiles is the use of water as a dust

suppressant and minimizing the disturbance of the surface with vehicles. The coal will

have inherently high moisture content when it is loaded onto the stockpile. Moisture loss

from evaporation will reduce the surface moisture content quickly and increase the dust

potential if it is not replaced.

Considering the dry and windy conditions for the bulk of the year at the PQA industrial

area, FFBL will install a dust-suppression watering system to maintain the moisture

content of the stockpile surfaces all year around.

Monitoring

If the mitigation measures proposed above are set in place, there is no significant risk to

the environment outside of the Complex boundary. However, considering occupational

health and safety standards for FFBL workers and those working in industries in the

vicinity of the fertilizer complex, dust from the coal yard has a high potential for causing

respiratory ailments. The high winds, along with the hot and dry climate for most of the

year in PQA will constantly contribute to dust generation and emission from the coal

handling activities at the coal yard.

FFBL will therefore install a monitoring system in place to regulate all the dust

suppression systems and monitor TPM samples at different locations within the plant site

to check dust levels are in control (Appendix E: Environmental Management Plan).

9.4.4 Ash Disposal and Management

The annual ash produced from the Project will range between 36,000 tons/year for

normal boiler load and 67,000 tons/year during maximum boiler load (Section 4.12).

Options for disposal of fly ash and prospects for sale to the cement industry are discussed

in Section 8.

The available land at ash disposal site Option 2 is 51 acres. The depth of the ash pond

will be around 3.5 m to avoid ash dust formation from the wind. A 3.5 m deep ash

disposal site in the available area will last 28 years under normal boiler load and 15 years

under maximum boiler load. The following practices will be followed for the

construction and operation of the ash disposal site.

The area will be demarcated

Quantity and quality of ash will be monitored regularly

Of-site disposal i.e., selling to cement and construction industry will be

considered

The dry and wet ash will be handled separately

Fugitive emissions will be controlled by sprinkling



R4V03FBE: 02/19/14 9-33

For ease of operation, the ash disposal area will be divided into smaller plots of

20m X 20m. This enables the ponds to be filled properly, and in case of future

reclamation, the process will be easier.

The options of ash utilization including the ash–based products include:

Brick/Block/Tiles Manufacturing

Cement Manufacturing

Roads and Embankment Construction

Structural Fill for Reclaiming Low Lying Areas

Mine–Filling

Agriculture, Forestry and Waste–land Development

Part Replacement of Cement in Mortar, Concrete and Ready Mix Concrete

Hydraulic Structure (Roller Compacted Concrete)

Ash Dyke Raising

Building Components – Mortar, Concrete,

Concrete Hollow Blocks, Aerated Concrete Blocks etc.





Component in road bases, sub–bases, and pavement


Other Medium and High Value Added Products (Ceramic Tiles, Wood, Paints)

Pavement Blocks, Light Weight Aggregate, Extraction of Alumina, Cenospheres,

etc.

The following strategy will be adopted to ensure full fly ash utilization in brick and

cement block manufacturing: During the first three years a study will be undertaken to

ascertain the market for utilization of fly as in cement and other industry. Subsequently,

FFBL will seek to enter into formal contract with the cement unit(s) to sell the fly ash. In

the case of an agreement, the life of the ash disposal site at Option 2 will be extended

well beyond the existing design.

9.4.5 Port Impacts

Imported coal for the CPP project will arrive at Port Qasim (PQ) which is located at a

distance of 13 km from FFBL through internal PQA roads. Traffic from the transport of

coal will not impact any sensitive receptors as the port, FFBL Complex and the roads

connecting the two, all lie within the PQA which is a designated industrial zone. The

Pakistan International Bulk Terminal (PIBT) is being constructed at PQ which will easily

be able to handle CPP‘s annual supply of imported coal from 300,000 to 500,000 tons.



R4V03FBE: 02/19/14 9-34

9.5 Ecological Impacts

Section 5.2.4 (Conclusions of Ecology Baseline) outlines the areas of concern and

Project activities that may have a possible negative impact on the ecological resources.

The Project is located in an industrial area where the natural habitat is highly disturbed.

No terrestrial floral or faunal species listed as Endangered or Critically Endangered in the

IUCN Red list 2012 has been reported from the Project site or vicinity. Moreover, there is

no critical habitat located in or near the vicinity of the Project site. The ash disposal sites

will be designated low-lying flat and barren land. The natural habitat there, too, is highly

disturbed with no critical habitats in the area. Therefore, Project construction and

operation, and ash disposal during project operation is not expected to have any

significant impact on unmodified habitats or terrestrial ecological resources due to habitat

loss and disturbance. The only impact on the ecology and biodiversity of the Project site

and vicinity is likely to come from the waste generated during Project construction and

operation.

9.5.1 Waste from Project Construction and Operations

The liquid effluent presently discharged from the Project is NEQS compliant. The treated

stormwater from existing complex is discharged into the Port Qasim Authority's (PQA)

drain channel which ultimately discharges the effluent into the Ghaghar Nullah. The

nullah discharges into a creek near the Arabian Sea. The volume of these effluents will

increase slightly when the CPP Project becomes operational mainly on account of

stormwater from rainfall. Despite the increase, the overall volume of effluent from the

CPP and existing plant processes will remain below the designed effluent volume for the

existing complex. There will be no change in the pollutant concentrations in the liquid

effluent from the cooling tower blowdown and stormwater discharged in to the PQA

drain. Since the use of chemicals and oil will be limited to a small area in the plant, these

will not be discharged into the drain. Moreover, no untreated liquid effluent will be

discharged there. Therefore, the impact of the effluent negatively impacting marine life is

unlikely. Nevertheless, it is recommended that all measures outlined in the Waste

Management Plan for Project construction and operation be implemented to ensure

minimal pollution.

The five options shared by the client, under consideration for ash disposal sites are all

located inside the industrial area as well as in vicinity of the Complex where the habitat is

already disturbed and therefore not expected to significantly impact terrestrial ecological

resources. However, leakage from the prospective ash disposal sites due to seepage into

the creek water, negatively impacting marine biodiversity. This can be prevented by

covering and lining the ash disposal sites as recommended in Section 9.4.4 and regular

monitoring to be ensured.

Gaseous discharges from coal burning particularly SOx, NOX and particulates may have

negative health effects on the flora and fauna, particularly the birds62 found near the

Project site and vicinity. However, the Circulating Fluidized Bed (CFB) boiler planned

for use in the Project helps reduce NOx while the addition of limestone helps remove

62 S. Llacuna et al, January 1993, Effects of air pollution on passerine birds and small mammals, Archives

of Environmental Contamination and Toxicology, Volume 24, Issue 1, pp 59–66

http://link.springer.com/search?facet-author=%22S.+Llacuna%22

http://link.springer.com/journal/244

http://link.springer.com/journal/244

http://link.springer.com/journal/244/24/1/page/1



R4V03FBE: 02/19/14 9-35

sulfur oxides inside the furnace. Fabric filters in the dedusters also filter out fly ash

(Particulate Matter) in the flue gases. Therefore, the impact of gaseous emissions

negative impacts in the Project site and vicinity is not expected to be significant.

Nevertheless, monitoring of gaseous emissions as well as coal and ash dust is

recommended to ensure that they remain within the limits prescribed by NEQS after the

CPP project becomes operational.

Good practice measures recommended are as follows:

Refer to waste management measures outlined in the Waste Management Plan,

Monitoring of liquid effluents from Project to ensure they meet the NEQS

Standards,

Monitoring of gaseous emissions including coal and ash dust,

Monitoring ash disposal sites.

Strict implementation of safe operating procedures/plans as per OEM guidelines /

instructions during construction, operation and maintenance.

Implementation of quality, health, safety and environmental controls for the new

Project as in vogue in the existing fertilizer complex.

Impact Characterization

The impact of the waste generated from project activities including effluents discharged in to the stream, gaseous emissions and ash disposal are summarized in the table below.

Impact EC1: Project activities resulting in discharge of waste materials negatively affecting flora and fauna


Initial Impact Minor Medium term

Inter–mediate

Low Possible Low – High

Residual Impact

Minor Medium term

Inter–mediate

Low Possible Low – High

9.6 Socioeconomic Impacts

The Project activities will result in a positive impact on the existing socioeconomic

environment of the area covered in the socioeconomic study. The study area (the ―CPP

Site Surroundings‖) is located within a 5 km radius with the Complex at the center. The

positive socioeconomic impacts of the Project include:

Positive impact to Pakistan‘s economy due to restoration of production capacity;

Generation of employment opportunities during Project construction and

operations.

These are further discussed below.

9.6.1 Positive Economic Impact of CPP Project

Natural gas curtailments to FFBL have led to a reduction in the plant‘s production of

fertilizer. Pakistan has had to meet the shortfall in domestic production through fertilizer

imports which are more expensive. In FY2012, every ton of imported urea cost Rs.



R4V03FBE: 02/19/14 9-36

10,000 more to the purchaser (urea constitutes up to 71% of Pakistan‘s fertilizer

imports).63

Associated businesses also take a direct hit as a result. The government has to

pay subsidies to bring the price of imported urea at par with the price of urea produced in

the country.

The proposed CPP project will curtail dependency on natural gas to some extent and will

restore FFBL‘s fertilizer production to a higher–than–present level. This will provide

respite to the economy from expensive fertilizer imports and will also ensure economic

returns to FFBL as well as the national economy. The generation of power by FFBL

through the Project will also help alleviate, to some extent, power crisis in the country. It

will also result in indirect benefits in the form of incomes generated by secondary

businesses supplying goods and services to FFBL and induced benefits generated from

the income spent by the direct and indirect employees of FFBL on national goods and

services.

Impact SC1: Positive economic impact due to restoration of full production capacity


Initial Impact

Medium Long Large High Possible High + High

9.6.2 Employment Opportunities

The Project will create additional job opportunities for unskilled, semi–skilled and skilled

laborers in construction, erection, operation, and maintenance phases. The proposed

project is being implemented to replace the existing natural gas–based steam and power

facilities; however other utilities will remain in operation such as raw water, cooling

water, demineralized and boiler feed water, compressed air system, etc. Therefore,

induction of new employees will go side–by–side retention of existing FFBL manpower

while the overall plant administration management will also stay the same.

The construction phase will generate temporary employment, approximately, 700 to 900

people, for a period of two years with demand expected to peak to about 1200 people.

Project operation will generate long–term employment. A Project workforce of up to 125

people including skilled and semi–skilled laborers is anticipated in the operation phase.

About 15 to 25% of the total workforce for the operation phase will be relocated from the

existing FFBL team. Semi–skilled manpower from nearby communities will be utilized

where they meet the required criteria. Around 15 to 20 un–skilled personnel will also be

hired for solid–waste handling.

Sourcing of local goods and services will also be prioritized wherever feasible. This will

create business opportunities and strengthen linkages between the national, regional, and

local economy.

In an area that is suffering from underemployment and low wage employment, the

Project‘s direct and indirect employment opportunities represent a positive development

63 In FY2012, domestic urea was priced at Rs 1,731 per 50 kg and imported urea (FoB price) was US$

470 per ton. Source: National Fertilizer Review.



R4V03FBE: 02/19/14 9-37

for beneficiaries and their families who will see an increase in incomes and reduction in

poverty.

Impact SC2: Generation of employment opportunities during Project construction and operations


Initial Impact

Minor Medium Small Low Possible Low + High

FFBL will take these concerns into account and adopt measures to address the concerns

of the local community. FFBL will ensure that equal employment opportunities are given

to the locals where they meet the requirements. FFBL is already providing educational

and health facilities to surrounding communities as part of its corporate social

responsibility (CSR) activities. These activities also include provision of water-supply to

some areas. It will add training programs for the inhabitants to equip them with relevant

skills for potential employment at the Complex or other industries in PQA.

9.6.3 Traffic Impacts

During the construction phase, the construction site, complete with workers‘ camp and

equipment storage areas will be located within the walls of the existing FFBL complex.

Therefore, there will be no adverse impacts from traffic to people in the CPP Site

Surroundings during the construction phase of the Project.

During the operational phase, the CPP project will receive its supply of limestone from a

local quarry, imported coal from PQ, and ash will be disposed in the vicinity of the

Complex. As discussed in Section 9.4.4 and Section 9.4.5, the port is located within PQA

area while the ash disposal sites are also located within the same vicinity. Hence, there

will be no adverse impacts from traffic to people in the CPP Site Surroundings during the

operational phase of the Project.


Hagler Bailly Pakistan Conclusion

R4V03FBE: 02/19/14 10-1

10. Conclusion

The proposed CPP project entails the construction of a new coal power plant with coal-

based boilers and steam turbine generators (STGs) to replace existing natural gas-based

boilers and gas turbines.

The findings of the study indicate that the CPP project will have positive impacts on the

socioeconomic environment through direct and in-direct employment generation; and,

increased business opportunities. The continuation of existing fertilizer plant operation

using coal-based power will be beneficial to the company through stability of production,

and, to the country as a whole through the reduction in dependence on dwindling natural

gas supply as fuel and stability of the agricultural sector of the economy through

consistent supply of fertilizers at affordable rates. It will also help alleviate, to some

extent, the ongoing power crisis in the country.

Among the potential negative impacts of the Project, the main concern is the possible

deterioration of air quality around the CPP project area. However, FFBL has undertaken

a number of design measures to ensure that gaseous emissions from the Project are in line

and well within the levels prescribed by NEQS and IFC guidelines.

The results of the air dispersion modeling in Section 9.4.2 indicate that SO2, NO2, and

PM10 concentrations in the air with the CPP in operation will be compliant with national












PM2.5 limits in view of the evidence and discussion presented recently in another EIA.

The existing fertilizer manufacturing processes at the FFBL complex generate a variety

of wastewater streams as stated in Section 3.2.8. There are two disposal options for the

plant effluents. All potentially hazardous effluents produced during abnormal plant

operations are directed to an evaporation pond. Effluents produced during normal

operations such as cooling water blow-down, effluents from the demineralization plant

and stormwater are discharged into the PQA drain outside FFBL‘s battery limits. The

effluents discharged into the PQA drain are within the limits prescribed by NEQS.

The effluent generated by the CPP project will also comprise of:

10-2

Cooling water blow–down, and;

Stormwater runoff.

While there will be a net addition in the combined volume of effluents produced by the existing complex and the CPP project, this volume will still be below the designed effluent volume for the existing complex.

In view of the above and assuming effective implementation of the mitigation measures and monitoring requirements as outlined in the Environmental Management Plan (EMP) (Appendix E), it can be concluded that the proposed CPP project—with 2 × 250 t/h Circulating Fluidized Boilers, 3 × 16 MWe Steam Turbine Generators (based on 60 Hz), a STG for power export up to 70 MW, along with auxiliaries to be installed within the existing FFBL complex—will comply with all the Pakistan regulatory requirements including NEQS and IFC guidelines with the exception of ambient air quality standards PM2.5. It has been recognized that national standards for ambient air quality will require revision. This issue has been discussed with the Sindh Environmental Protection Agency and they have expressed willingness to review the standards.


Hagler Bailly Pakistan Appendix A

R4V03FBE: 02/19/14 A-1

Appendix A: National Environmental Quality Standards and International Finance Corporation Guidelines

A.1 National Environmental Quality Standards

Exhibit A.1: NEQS for Municipal and Liquid Industrial Effluents

(mg/l, unless otherwise defined)

No. Parameter Standards

Into Inland Waters

Into Sewage Treatment

1

Into Sea2)

1. Temperature increase3 =<3°C =<3°C =<3°C

2. pH value 6 to 9 6 to 9 6 to 9

3. Five-day bio-chemical oxygen demand (BOD)5 at 20°C

4

80 250 805

4. Chemical oxygen demand (COD)1 150 400 400

5. Total suspended solids (TSS) 200 400 200

6. Total dissolved solids (TDS) 3,500 3,500 3,500

7. Grease and oil 10 10 10

8. Phenolic compounds (as phenol) 0.1 0.3 0.3

9. Chlorides (as Cl') 1,000 1,000 SC6

10. Fluorides (as F') 10 10 10

11. Cyanide total (as CN') 1.0 1.0 1.0

12. Anionic detergents (as MBAS)7 20 20 20

13. Sulfates (SO4) 600 1,000 SC6

14. Sulfides (s') 1.0 1.0 1.0

15. Ammonia (NH3) 40 40 40

16. Pesticides8 0.15 0.15 0.15

17. Cadmium9 0.1 0.1 0.1

18. Chromium (trivalent and hexavalent)9 1.0 1.0 1.0

19. Copper9 1.0 1.0 1.0

20. Lead9 0.5 0.5 0.5

21. Mercury9 0.01 0.01 0.01

22. Selenium9 0.5 0.5 0.5



R4V03FBE: 02/19/14 A-2

No. Parameter Standards

Into Inland Waters

Into Sewage Treatment

1

Into Sea2)

23. Nickel9 1.0 1.0 1.0

24. Silver9 1.0 1.0 1.0

25. Total toxic metals 2.0 2.0 2.0

26. Zinc 5.0 5.0 5.0

27. Arsenic9 1.0 1.0 1.0

28. Barium9 1.5 1.5 1.5

29. Iron 8.0 8.0 8.0

30. Manganese 1.5 1.5 1.5

31. Boron9 6.0 6.0 6.0

32. Chlorine 1.0 1.0 1.0

Explanations:

1. Applicable only when and where sewage treatment is operational and BOD = 80 mg/l is achieved by the sewage treatment system.

2. Provided discharge is not at shore and not within 10 miles of mangrove or other important estuaries.

3. The effluent should not result in temperature increase of more than 3oC at the edge of the zone where initial mixing and dilution take place in the receiving body. In case zone is not define, use 100 m from the point of discharge

4. Assuming minimum dilution 1:10 discharge, lower ratio would attract progressively stringent standards to be determined by the Federal Environmental Protection Agency. By 1:10 dilution means, for example that for each one cubic meter of treated effluent, the recipient water body should have 10 cubic meter of water for dilution of this effluent.

5. The value for industry is 200 mg/l

6. Discharge concentration at or below sea concentration (SC)

7. Methylene Blue Active substances assuming surfactant as biodegradable

8. Pesticides include herbicides, fungicides, and insecticides

9. Subject to total toxic metals discharge should not exceed level given at S. No. 25

Notes:

1. Dilution of liquid effluents to bring them to the NEQS limiting values is not permissible through fresh water mixing with the effluent before discharging into the environment.

2. The concentration of pollutants in water being used will be subtracted from the effluent for calculating the NEQS limits.



R4V03FBE: 02/19/14 A-3

Exhibit A.2: National Environmental Quality Standards for Gaseous Emissions

No. Parameter Source of Emission Standards

1. Smoke Smoke opacity not to exceed 40% or 2 on Ringlemann Scale or equivalent smoke number

2. Particulate matter1 (a) Boilers and furnaces:

i) Oil-fired 300

ii) Coal-fired 500

iii) Cement kilns 300

(b) Grinding, crushing, clinker coolers and related processes, metallurgical processes, converters, blast furnaces and cupolas

500

3. Hydrogen chloride Any 400

4. Chlorine Any 150

5. Hydrogen fluoride Any 150

6. Hydrogen sulfide Any 10

7. Sulfur oxides2, 3

Sulfuric acid/sulfonic acid plants 5,000

Other plants except power plants operating on oil and coal

1,700

8. Carbon monoxide Any 800

9. Lead Any 50

10. Mercury Any 10

11. Cadmium Any 20

12. Arsenic Any 20

13. Copper Any 50

14. Antimony Any 20

15. Zinc Any 200

16. Oxides of nitrogen

3

Nitric acid manufacturing unit 3,000

Gas-fired 400

Oil-fired 600

Coal-fired 1,200

1. Based on the assumption that the size of the particulate is 10 micron or more.

2. Based on 1 per cent sulfur content in fuel oil. Higher content of sulfur will cause standards to be pro-rated.

3. In respect of emissions of sulfur dioxide and nitrogen oxides, the power plants operating on oil and coal as fuel shall in addition to National Environmental Quality Standards (NEQS) above, comply with the standards stated in Exhibit A.3 and Exhibit A.4.



R4V03FBE: 02/19/14 A-4

Exhibit A.3: Sulfur Dioxide Standards for Power Plants Operating on Oil and Coal

Sulfur Dioxide Background Levels (µg/m3) Standards

Criterion I Criterion II

Background Air Quality (SO2 basis)

Annual Average

Maximum 24-Hour Interval

Max. SO2 Emissions (TPD)

Max. Allowable 1-Year Average Ground Level Increment to Ambient (µg/m

3)

Unpolluted < 50 < 200 500 50

Moderately polluted1

Low 50 200 500 50

High 100 400 100 10

Very polluted2 > 100 > 400 100 10

1. For intermediate values between 50 and 100 g/m3 linear interpretation should be used.

2. No project with sulfur dioxide emissions will be recommended.

Exhibit A.4: Nitrogen Oxides Standards for Power Plants Operating on Oil and Coal

Annual arithmetic mean of ambient air concentrations of nitrogen oxides (expressed as NO2) should not exceed

100 g/m3 (0.05 ppm)

Maximum emission levels for stationary source discharges, before mixing with the atmosphere: For fuel fired steam generators

Liquid fossil fuel 130 ng/J of heat input

Solid fossil fuel 300 ng/J of heat input

Lignite fossil fuel 260 ng/J of heat input

Exhibit A.5: National Environmental Quality Standards for Motor Vehicle

Exhaust and Noise

No. Parameter Standards (Maximum Permissible Limit)

Measuring Method

1. Smoke 40% or 2 on the Ringelmann Scale during engine acceleration mode.

To compared with Ringlemann chart at a distance of 6 meters or more.

2. Carbon Monoxide

Emission Standards:

New Vehicles Used Vehicles

4.5% 6% Under idling conditions: Nondispersive infrared detection through gas analyzer.

3. Noise 85 db (A) Sound-meter at 7.5 meters from the source.



R4V03FBE: 02/19/14 A-5

Exhibit A.6: National Environmental Quality Standards for Ambient Air


Concentration in Ambient Air Method of Measurement

Effective from 1st July 2010

Effective from 1st January 2013


Annual Average* 80 μg/m3 80 μg/m

3 -Ultra Violet

Fluorescence method

24 hours** 120 μg/m3 120 μg/m

3

Oxide of Nitrogen as (NO)


3 -Gas Phase

Chemiluminescence 24 hours** 40 μg/m

3 40 μg/m

3

Oxide of Nitrogen as (NO2)


3 -Gas Phase

Chemiluminescence 24 hours** 40 μg/m

3 80 μg/m

3

O3 1 hour 180 μg/m3 130 μg/m

3 -Non dispersive UV

absorption method

Suspended Particulate Matter (SPM)


3 -High Volume

Sampling, (Average flow rate not less than 1.1 m

3/min)

24 hours** 550 μg/m3 500 μg/m

3

Respirable particulate Matter. PM 10


3 -β Ray Absorption

method 24 hours** 250 μg/m

3 150 μg/m

3

Respirable Particulate Matter. PM 2.5


3 -β Ray Absorption

method 24 hours** 40 μg/m

3 35 μg/m

3

1 hour 25 μg/m3 15 μg/m

3

Lead (Pb) Annual Average* 1.5 μg/m3 1 μg/m

3 ASS Method after

sampling using EPM 2000 or equivalent Filter paper

24 hours** 2 μg/m3 1.5 μg/m

3

Carbon Monoxide (CO)

8 hours** 5 mg/m3 5 mg/m

3 Non Dispersive

Infra Red (NDIR) method

1 hour 10 mg/m3 10 mg/m

3





R4V03FBE: 02/19/14 A-6

Exhibit A.7: National Environmental Quality Standards for Noise

No. Category of Area/Zone Effective from Ist July, 2010 Effective from Ist July, 2012

Limit in dB(A) Leq*

Day time Night time Day time Night time

1. Residential are (A) 65 50 55 45

2. Commercial are (B) 70 60 65 55

3. Industrial area (C) 80 75 75 65

4. Silence zone (D) 55 45 50 45

Note:

1. Day time hours: 6 .00 am to 10.00 pm

2. Night Time hours: 10.00 pm to 6.00 am

3. Silence zone: Zones which are declared as such by the competent authority. An area comprising not less than 100 meters around hospitals, educational institutions and courts and courts.

4. Mixed categories of areas may be declared as one of the four above-mentioned categories by the competent authority.

5. dB(A) Leq: time weighted average of the level of sound in decibels on scale A which is relatable to human hearing.



R4V03FBE: 02/19/14 A-7

Exhibit A.8: National Environmental Quality Standards for Drinking Water

Properties/ Parameters Standard Values For Pakistan

Who Guidelines Remarks

Bacterial

All water intended for drinking (e.Coli or Thermo tolerant Coliform bacteria)

Must not be detectable in any 100 ml sample


Most Asian countries also follow WHO standards

Treated water entering the distribution system (E.Coli or thermo tolerant coliform and total coliform bacteria)




Treated water in the distribution system (E.coli or thermo tolerant coliform and total coliform bacteria)

Must not be detectable in any 100 ml sample In case of large supplies, where sufficient samples are examined, must not be present in 95% of the samples taken throughout any 12-month period.

Must not be detectable in any 100 ml sample In case of large supplies, where sufficient samples are examined, must not be present in 95% of the samples taken throughout any 12-month period.


Physical

Colour ≤15 TCU ≤15 TCU

Taste Non objectionable/Accept able

Non objectionable/Accept able

Odour Non objectionable/Accept able

Non objectionable/Accept able

Turbidity < 5 NTU < 5 NTU

Total hardness as CaCO3

< 500 mg/l –

TDS < 1000 < 1000

pH 6.5 – 8.5 6.5 – 8.5

Chemical

Essential Inorganic mg/Litre mg/Litre

Aluminium (Al) mg/1 <0.2 0.2

Antimony (Sb) <0.005 (P) 0.02

Arsenic (As) < 0.05 (P) 0.01 Standard for Pakistan similar to most Asian developing countries

Barium (Ba) 0.7 0.7



R4V03FBE: 02/19/14 A-8



Boron (B) 0.3 0.3

Cadmium (Cd) 0.01 0.003 Standard for Pakistan similar to most Asian developing countries

Chloride (Cl) <250 250

Chromium (Cr) <0.05 0.05

Copper (Cu) 2 2

Toxic Inorganic mg/Litre mg/Litre

Cyanide (CN) <0.05 0.07 Standard for Pakistan similar to Asian developing countries

Fluoride (F)* <1.5 1.5

Lead (Pb) <0.05 0.01 Standard for Pakistan similar to most Asian developing countries

Manganese (Mn) < 0.5 0.5

Mercury (Hg) <0.001 0.001

Nickel (Ni) <0.02 0.02

Nitrate (NO3)* <50 50

Nitrite (NO2)* <3 (P) 3

Selenium (Se) 0.01(P) 0.01

Residual chlorine 0.2-0.5 at consumer end 0.5-1.5 at source

–

Zinc (Zn) 5.0 3 Standard for Pakistan similar to most Asian developing countries

* indicates priority health related inorganic constituents which need regular monitoring.

Organic

Pesticides mg/L PSQCA No. 4639-2004, Page No. 4 Table No. 3 Serial No. 20- 58 may be consulted.***

Annex II



R4V03FBE: 02/19/14 A-9



Phenolic compounds (as Phenols) mg/L

< 0.002

Polynuclear aromatic hydrocarbons (as PAH) g/L

0.01

( By GC/MS method)

Radioactive

Alpha Emitters bq/L or pCi

0.1 0.1

Beta emitters 1 1

*** PSQCA: Pakistan Standards Quality Control Authority.

Proviso:

The existing drinking water treatment infrastructure is not adequate to comply with WHO guidelines. The arsenic concentrations in South Punjab and in some parts of Sindh have been found high then Revised WHO guidelines. It will take some time to control arsenic through treatment process. Lead concentration in the proposed standards is higher than WHO Guidelines. As the piping system for supply of drinking water in urban centres are generally old and will take significant resources and time to get them replaced. In the recent past, lead was completely phased out from petroleum products to cut down lead entering into environment. These steps will enable to achieve WHO Guidelines for Arsenic, Lead, Cadmium and Zinc. However, for the bottled water, WHO limits for Arsenic, Lead, Cadmium and Zinc will be applicable and PSQCA Standards for all the remaining parameters.



R4V03FBE: 02/19/14 A-10

A.2 International Finance Corporation Guidelines

See following pages

Environmental, Health, and Safety Guidelines GENERAL EHS GUIDELINES: ENVIRONMENTAL

AIR EMISSIONS AND AMBIENT AIR QUALITY

APRIL 30, 2007 3

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1.0 Environmental 1.1 Air Emissions and Ambient Air Quality

Applicability and Approach ...............................................3 Ambient Air Quality ..........................................................4

General Approach....................................................4 Projects Located in Degraded Airsheds or Ecologically Sensitive Areas........................................................5

Point Sources ..................................................................5 Stack Height.............................................................5 Small Combustion Facilities Emissions Guidelines ....6

Fugitive Sources ..............................................................8 Volatile Organic Compounds (VOCs) ........................8 Particulate Matter (PM).............................................8 Ozone Depleting Substances (ODS) .........................9

Mobile Sources – Land-based ..........................................9 Greenhouse Gases (GHGs) .............................................9 Monitoring......................................................................10

Monitoring of Small Combustion Plants Emissions...11

Applicability and Approach This guideline applies to facilities or projects that generate

emissions to air at any stage of the project life-cycle. It

complements the industry-specific emissions guidance presented

in the Industry Sector Environmental, Health, and Safety (EHS)

Guidelines by providing information about common techniques for

emissions management that may be applied to a range of industry

sectors. This guideline provides an approach to the management

of significant sources of emissions, including specific guidance for

assessment and monitoring of impacts. It is also intended to

provide additional information on approaches to emissions

management in projects located in areas of poor air quality, where

it may be necessary to establish project-specific emissions

standards.

Emissions of air pollutants can occur from a wide variety of

activities during the construction, operation, and decommissioning

phases of a project. These activities can be categorized based on

the spatial characteristic of the source including point sources,

fugitive sources, and mobile sources and, further, by process,

such as combustion, materials storage, or other industry sector-

specific processes.

Where possible, facilities and projects should avoid, minimize, and

control adverse impacts to human health, safety, and the

environment from emissions to air. Where this is not possible, the

generation and release of emissions of any type should be

managed through a combination of:

• Energy use efficiency

• Process modification

• Selection of fuels or other materials, the processing of which

may result in less polluting emissions

• Application of emissions control techniques

The selected prevention and control techniques may include one

or more methods of treatment depending on:

• Regulatory requirements

• Significance of the source

• Location of the emitting facility relative to other sources

• Location of sensitive receptors

• Existing ambient air quality, and potential for degradation of

the airshed from a proposed project

• Technical feasibility and cost effectiveness of the available

options for prevention, control, and release of emissions

Cfrankel

General EHS Guidelines [Complete version] at: www.ifc.org/ifcext/enviro.nsf/Content/EnvironmentalGuidelines



APRIL 30, 2007 4

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Ambient Air Quality

General Approach Projects with significant5,6 sources of air emissions, and potential

for significant impacts to ambient air quality, should prevent or

minimize impacts by ensuring that:

• Emissions do not result in pollutant concentrations that reach

or exceed relevant ambient quality guidelines and standards9

by applying national legislated standards, or in their absence,

the current WHO Air Quality Guidelines10 (see Table 1.1.1),

or other internationally recognized sources11;

• Emissions do not contribute a significant portion to the

attainment of relevant ambient air quality guidelines or

standards. As a general rule, this Guideline suggests 25

percent of the applicable air quality standards to allow

5 Significant sources of point and fugitive emissions are considered to be general sources which, for example, can contribute a net emissions increase of one or more of the following pollutants within a given airshed: PM10: 50 tons per year (tpy); NOx: 500 tpy; SO2: 500 tpy; or as established through national legislation; and combustion sources with an equivalent heat input of 50 MWth or greater. The significance of emissions of inorganic and organic pollutants should be established on a project-specific basis taking into account toxic and other properties of the pollutant. 6 United States Environmental Protection Agency, Prevention of Significant Deterioration of Air Quality, 40 CFR Ch. 1 Part 52.21. Other references for establishing significant emissions include the European Commission. 2000. “Guidance Document for EPER implementation.” http://ec.europa.eu/environment/ippc/eper/index.htm ; and Australian Government. 2004. “National Pollutant Inventory Guide.” http://www.npi.gov.au/handbooks/pubs/npiguide.pdf 7 World Health Organization (WHO). Air Quality Guidelines Global Update, 2005. PM 24-hour value is the 99th percentile. 8 Interim targets are provided in recognition of the need for a staged approach to achieving the recommended guidelines. 9 Ambient air quality standards are ambient air quality levels established and published through national legislative and regulatory processes, and ambient quality guidelines refer to ambient quality levels primarily developed through clinical, toxicological, and epidemiological evidence (such as those published by the World Health Organization). 10 Available at World Health Organization (WHO). http://www.who.int/en 11 For example the United States National Ambient Air Quality Standards (NAAQS) (http://www.epa.gov/air/criteria.html) and the relevant European Council Directives (Council Directive 1999/30/EC of 22 April 1999 / Council Directive 2002/3/EC of February 12 2002).

additional, future sustainable development in the same

airshed. 12

At facility level, impacts should be estimated through qualitative or

quantitative assessments by the use of baseline air quality

assessments and atmospheric dispersion models to assess

potential ground level concentrations. Local atmospheric, climatic,

and air quality data should be applied when modeling dispersion,

protection against atmospheric downwash, wakes, or eddy effects

of the source, nearby13 structures, and terrain features. The

dispersion model applied should be internationally recognized, or

comparable. Examples of acceptable emission estimation and

dispersion modeling approaches for point and fugitive sources are

12 US EPA Prevention of Significant Deterioration Increments Limits applicable to non-degraded airsheds.

Table 1.1.1: WHO Ambient Air Quality Guidelines7,8

Averaging Period

Guideline value in µg/m3

Sulfur dioxide (SO2) 24-hour

10 minute

125 (Interim target-1) 50 (Interim target-2)

20 (guideline) 500 (guideline)

Nitrogen dioxide (NO2) 1-year 1-hour

40 (guideline) 200 (guideline)

Particulate Matter PM10

1-year

24-hour

70 (Interim target-1) 50 (Interim target-2) 30 (Interim target-3)

20 (guideline)


50 (guideline) Particulate Matter PM2.5

1-year

24-hour


10 (guideline)

75 (Interim target-1) 50 (Interim target-2)

37.5 (Interim target-3) 25 (guideline)

Ozone 8-hour daily maximum

160 (Interim target-1) 100 (guideline)



APRIL 30, 2007 5

WORLD BANK GROUP

included in Annex 1.1.1. These approaches include screening

models for single source evaluations (SCREEN3 or AIRSCREEN),

as well as more complex and refined models (AERMOD OR

ADMS). Model selection is dependent on the complexity and geo-

morphology of the project site (e.g. mountainous terrain, urban or

rural area).

Projects Located in Degraded Airsheds or Ecologically Sensitive Areas Facilities or projects located within poor quality airsheds14, and

within or next to areas established as ecologically sensitive (e.g.

national parks), should ensure that any increase in pollution levels

is as small as feasible, and amounts to a fraction of the applicable

short-term and annual average air quality guidelines or standards

as established in the project-specific environmental assessment.

Suitable mitigation measures may also include the relocation of

significant sources of emissions outside the airshed in question,

use of cleaner fuels or technologies, application of comprehensive

pollution control measures, offset activities at installations

controlled by the project sponsor or other facilities within the same

airshed, and buy-down of emissions within the same airshed.

Specific provisions for minimizing emissions and their impacts in

poor air quality or ecologically sensitive airsheds should be

established on a project-by-project or industry-specific basis.

Offset provisions outside the immediate control of the project

sponsor or buy-downs should be monitored and enforced by the

local agency responsible for granting and monitoring emission

permits. Such provisions should be in place prior to final

commissioning of the facility / project.

13 “Nearby” generally considers an area within a radius of up to 20 times the stack height. 14 An airshed should be considered as having poor air quality if nationally legislated air quality standards or WHO Air Quality Guidelines are exceeded significantly.

Point Sources Point sources are discrete, stationary, identifiable sources of

emissions that release pollutants to the atmosphere. They are

typically located in manufacturing or production plants. Within a

given point source, there may be several individual ‘emission

points’ that comprise the point source.15

Point sources are characterized by the release of air pollutants

typically associated with the combustion of fossil fuels, such as

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

(CO), and particulate matter (PM), as well as other air pollutants

including certain volatile organic compounds (VOCs) and metals

that may also be associated with a wide range of industrial

activities.

Emissions from point sources should be avoided and controlled

according to good international industry practice (GIIP) applicable

to the relevant industry sector, depending on ambient conditions,

through the combined application of process modifications and

emissions controls, examples of which are provided in Annex

1.1.2. Additional recommendations regarding stack height and

emissions from small combustion facilities are provided below.

Stack Height The stack height for all point sources of emissions, whether

‘significant’ or not, should be designed according to GIIP (see

Annex 1.1.3) to avoid excessive ground level concentrations due

to downwash, wakes, and eddy effects, and to ensure reasonable

diffusion to minimize impacts. For projects where there are

multiple sources of emissions, stack heights should be established

with due consideration to emissions from all other project sources,

both point and fugitive. Non-significant sources of emissions,

15 Emission points refer to a specific stack, vent, or other discrete point of pollution release. This term should not be confused with point source, which is a regulatory distinction from area and mobile sources. The characterization of point sources into multiple emissions points is useful for allowing more detailed reporting of emissions information.



APRIL 30, 2007 6

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including small combustion sources,16 should also use GIIP in

stack design.

Small Combustion Facilities Emissions Guidelines Small combustion processes are systems designed to deliver

electrical or mechanical power, steam, heat, or any combination of

these, regardless of the fuel type, with a total, rated heat input

capacity of between three Megawatt thermal (MWth) and 50

MWth.

The emissions guidelines in Table 1.1.2 are applicable to small

combustion process installations operating more than 500 hours

per year, and those with an annual capacity utilization of more

than 30 percent. Plants firing a mixture of fuels should compare

emissions performance with these guidelines based on the sum of

the relative contribution of each applied fuel17. Lower emission

values may apply if the proposed facility is located in an

ecologically sensitive airshed, or airshed with poor air quality, in

order to address potential cumulative impacts from the installation

of more than one small combustion plant as part of a distributed

generation project.

16 Small combustion sources are those with a total rated heat input capacity of 50MWth or less. 17 The contribution of a fuel is the percentage of heat input (LHV) provided by this fuel multiplied by its limit value.



APRIL 30, 2007 7

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Table 1.1.2 - Small Combustion Facilities Emissions Guidelines (3MWth – 50MWth) – (in mg/Nm3 or as indicated) Combustion Technology /

Fuel Particulate Matter (PM) Sulfur Dioxide (SO2) Nitrogen Oxides (NOx) Dry Gas, Excess O2 Content (%)

Engine

Gas N/A N/A 200 (Spark Ignition)

400 (Dual Fuel) 1,600 (Compression Ignition)

15

Liquid

50 or up to 100 if justified by project specific considerations (e.g. Economic feasibility of using lower ash content fuel, or adding secondary treatment to meet 50, and available environmental capacity of the site)

1.5 percent Sulfur or up to 3.0 percent Sulfur if justified by project specific considerations (e.g. Economic feasibility of using lower S content fuel, or adding secondary treatment to meet levels of using 1.5 percent Sulfur, and available environmental capacity of the site)

If bore size diameter [mm] < 400: 1460 (or up to 1,600 if justified to maintain high energy efficiency.) If bore size diameter [mm] > or = 400: 1,850

15

Turbine Natural Gas =3MWth to < 15MWth N/A N/A 42 ppm (Electric generation)

100 ppm (Mechanical drive) 15

Natural Gas =15MWth to < 50MWth N/A N/A 25 ppm 15

Fuels other than Natural Gas =3MWth to < 15MWth N/A

0.5 percent Sulfur or lower percent Sulfur (e.g. 0.2 percent Sulfur) if commercially available without significant excess fuel cost

96 ppm (Electric generation) 150 ppm (Mechanical drive) 15

Fuels other than Natural Gas =15MWth to < 50MWth N/A 0.5% S or lower % S (0.2%S) if commercially

available without significant excess fuel cost 74 ppm 15

Boiler

Gas N/A N/A 320 3

Liquid 50 or up to 150 if justified by environmental assessment

2000 460 3

Solid 50 or up to 150 if justified by environmental assessment

2000 650 6

Notes: -N/A/ - no emissions guideline; Higher performance levels than these in the Table should be applicable to facilities located in urban / industrial areas with degraded airsheds or close to ecologically sensitive areas where more stringent emissions controls may be needed.; MWth is heat input on HHV basis; Solid fuels include biomass; Nm3 is at one atmosphere pressure, 0°C.; MWth category is to apply to the entire facility consisting of multiple units that are reasonably considered to be emitted from a common stack except for NOx and PM limits for turbines and boilers. Guidelines values apply to facilities operating more than 500 hours per year with an annual capacity utilization factor of more than 30 percent.



APRIL 30, 2007 8

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Fugitive Sources Fugitive source air emissions refer to emissions that are

distributed spatially over a wide area and not confined to a specific

discharge point. They originate in operations where exhausts are

not captured and passed through a stack. Fugitive emissions have

the potential for much greater ground-level impacts per unit than

stationary source emissions, since they are discharged and

dispersed close to the ground. The two main types of fugitive

emissions are Volatile Organic Compounds (VOCs) and

particulate matter (PM). Other contaminants (NOx, SO2 and CO)

are mainly associated with combustion processes, as described

above. Projects with potentially significant fugitive sources of

emissions should establish the need for ambient quality

assessment and monitoring practices.

Open burning of solid wastes, whether hazardous or non-

hazardous, is not considered good practice and should be

avoided, as the generation of polluting emissions from this type of

source cannot be controlled effectively.

Volatile Organic Compounds (VOCs) The most common sources of fugitive VOC emissions are

associated with industrial activities that produce, store, and use

VOC-containing liquids or gases where the material is under

pressure, exposed to a lower vapor pressure, or displaced from an

enclosed space. Typical sources include equipment leaks, open

vats and mixing tanks, storage tanks, unit operations in

wastewater treatment systems, and accidental releases.

Equipment leaks include valves, fittings, and elbows which are

subject to leaks under pressure. The recommended prevention

and control techniques for VOC emissions associated with

equipment leaks include:

• Equipment modifications, examples of which are presented in

Annex 1.1.4;

• Implementing a leak detection and repair (LDAR) program

that controls fugitive emissions by regularly monitoring to

detect leaks, and implementing repairs within a predefined

time period.18

For VOC emissions associated with handling of chemicals in open

vats and mixing processes, the recommended prevention and

control techniques include:

• Substitution of less volatile substances, such as aqueous

solvents;

• Collection of vapors through air extractors and subsequent

treatment of gas stream by removing VOCs with control

devices such as condensers or activated carbon absorption;

• Collection of vapors through air extractors and subsequent

treatment with destructive control devices such as:

o Catalytic Incinerators: Used to reduce VOCs from

process exhaust gases exiting paint spray booths,

ovens, and other process operations

o Thermal Incinerators: Used to control VOC levels in a

gas stream by passing the stream through a combustion

chamber where the VOCs are burned in air at

temperatures between 700º C to 1,300º C

o Enclosed Oxidizing Flares: Used to convert VOCs into

CO2 and H2O by way of direct combustion

• Use of floating roofs on storage tanks to reduce the

opportunity for volatilization by eliminating the headspace

present in conventional storage tanks.

Particulate Matter (PM) The most common pollutant involved in fugitive emissions is dust

or particulate matter (PM). This is released during certain

operations, such as transport and open storage of solid materials,

and from exposed soil surfaces, including unpaved roads.

18 For more information, see Leak Detection and Repair Program (LDAR), at: http://www.ldar.net



APRIL 30, 2007 9

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Recommended prevention and control of these emissions sources

include:

• Use of dust control methods, such as covers, water

suppression, or increased moisture content for open

materials storage piles, or controls, including air extraction

and treatment through a baghouse or cyclone for material

handling sources, such as conveyors and bins;

• Use of water suppression for control of loose materials on

paved or unpaved road surfaces. Oil and oil by-products is

not a recommended method to control road dust. Examples

of additional control options for unpaved roads include those

summarized in Annex 1.1.5.

Ozone Depleting Substances (ODS) Several chemicals are classified as ozone depleting substances

(ODSs) and are scheduled for phase-out under the Montreal

Protocol on Substances that Deplete the Ozone Layer.19 No new

systems or processes should be installed using CFCs, halons,

1,1,1-trichloroethane, carbon tetrachloride, methyl bromide or

HBFCs. HCFCs should only be considered as interim / bridging

alternatives as determined by the host country commitments and

regulations.20

Mobile Sources – Land-based Similar to other combustion processes, emissions from vehicles

include CO, NOx, SO2, PM and VOCs. Emissions from on-road

and off-road vehicles should comply with national or regional

19 Examples include: chlorofluorocarbons (CFCs); halons; 1,1,1-trichloroethane (methyl chloroform); carbon tetrachloride; hydrochlorofluorocarbons (HCFCs); hydrobromofluorocarbons (HBFCs); and methyl bromide. They are currently used in a variety of applications including: domestic, commercial, and process refrigeration (CFCs and HCFCs); domestic, commercial, and motor vehicle air conditioning (CFCs and HCFCs); for manufacturing foam products (CFCs); for solvent cleaning applications (CFCs, HCFCs, methyl chloroform, and carbon tetrachloride); as aerosol propellants (CFCs); in fire protection systems (halons and HBFCs); and as crop fumigants (methyl bromide). 20 Additional information is available through the Montreal Protocol Secretariat web site available at: http://ozone.unep.org/

programs. In the absence of these, the following approach should

be considered:

• Regardless of the size or type of vehicle, fleet owners /

operators should implement the manufacturer recommended

engine maintenance programs;

• Drivers should be instructed on the benefits of driving

practices that reduce both the risk of accidents and fuel

consumption, including measured acceleration and driving

within safe speed limits;

• Operators with fleets of 120 or more units of heavy duty

vehicles (buses and trucks), or 540 or more light duty

vehicles21 (cars and light trucks) within an airshed should

consider additional ways to reduce potential impacts

including:

o Replacing older vehicles with newer, more fuel efficient

alternatives

o Converting high-use vehicles to cleaner fuels, where

feasible

o Installing and maintaining emissions control devices,

such as catalytic converters

o Implementing a regular vehicle maintenance and repair

program

Greenhouse Gases (GHGs) Sectors that may have potentially significant emissions of

greenhouse gases (GHGs)22 include energy, transport, heavy

industry (e.g. cement production, iron / steel manufacturing,

aluminum smelting, petrochemical industries, petroleum refining,

fertilizer manufacturing), agriculture, forestry and waste

management. GHGs may be generated from direct emissions

21 The selected fleet size thresholds are assumed to represent potentially significant sources of emissions based on individual vehicles traveling 100,000 km / yr using average emission factors. 22 The six greenhouse gases that form part of the Kyoto Protocol to the United Nations Framework Convention on Climate Change include carbon dioxide (C02); methane (CH4); nitrous oxide (N2O); hydrofluorocarbons (HFCs); perfluorocarbons (PFCs); and sulfur hexafluoride (SF 6).



APRIL 30, 2007 10

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from facilities within the physical project boundary and indirect

emissions associated with the off-site production of power used by

the project.

Recommendations for reduction and control of greenhouse gases

include:

• Carbon financing;23

• Enhancement of energy efficiency (see section on

‘Energy Conservation’);

• Protection and enhancement of sinks and reservoirs of

greenhouse gases;

• Promotion of sustainable forms of agriculture and

forestry;

• Promotion, development and increased use of

renewable forms of energy;

• Carbon capture and storage technologies;24

• Limitation and / or reduction of methane emissions

through recovery and use in waste management, as well

as in the production, transport and distribution of energy

(coal, oil, and gas).

Monitoring Emissions and air quality monitoring programs provide information

that can be used to assess the effectiveness of emissions

management strategies. A systematic planning process is

recommended to ensure that the data collected are adequate for

their intended purposes (and to avoid collecting unnecessary

data). This process, sometimes referred to as a data quality

objectives process, defines the purpose of collecting the data, the

23 Carbon financing as a carbon emissions reduction strategy may include the host government-endorsed Clean Development Mechanism or Joint Implementation of the United Nations Framework Convention on Climate Change. 24 Carbon dioxide capture and storage (CCS) is a process consisting of the separation of CO2 from industrial and energy-related sources; transport to a storage location; and long-term isolation from the atmosphere, for example in geological formations, in the ocean, or in mineral carbonates (reaction of CO2 with metal oxides in silicate minerals to produce stable carbonates). It is the object of intensive research worldwide (Intergovernmental Panel on Climate Change (IPCC), Special Report, Carbon Dioxide Capture and Storage (2006).

decisions to be made based on the data and the consequences of

making an incorrect decision, the time and geographic

boundaries, and the quality of data needed to make a correct

decision.25 The air quality monitoring program should consider

the following elements:

• Monitoring parameters: The monitoring parameters selected

should reflect the pollutants of concern associated with

project processes. For combustion processes, indicator

parameters typically include the quality of inputs, such as the

sulfur content of fuel.

• Baseline calculations: Before a project is developed, baseline

air quality monitoring at and in the vicinity of the site should

be undertaken to assess background levels of key pollutants,

in order to differentiate between existing ambient conditions

and project-related impacts.

• Monitoring type and frequency: Data on emissions and

ambient air quality generated through the monitoring program

should be representative of the emissions discharged by the

project over time. Examples of time-dependent variations in

the manufacturing process include batch process

manufacturing and seasonal process variations. Emissions

from highly variable processes may need to be sampled

more frequently or through composite methods. Emissions

monitoring frequency and duration may also range from

continuous for some combustion process operating

parameters or inputs (e.g. the quality of fuel) to less frequent,

monthly, quarterly or yearly stack tests.

• Monitoring locations: Ambient air quality monitoring may

consists of off-site or fence line monitoring either by the

project sponsor, the competent government agency, or by

collaboration between both. The location of ambient air

25 See, for example, United States Environmental Protection Agency, Guidance on Systematic Planning Using the Data Quality Objectives Process EPA QA/G-4, EPA/240/B-06/001 February 2006.



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quality monitoring stations should be established based on

the results of scientific methods and mathematical models to

estimate potential impact to the receiving airshed from an

emissions source taking into consideration such aspects as

the location of potentially affected communities and

prevailing wind directions.

• Sampling and analysis methods: Monitoring programs should

apply national or international methods for sample collection

and analysis, such as those published by the International

Organization for Standardization,26 the European Committee

for Standardization,27 or the U.S. Environmental Protection

Agency.28 Sampling should be conducted by, or under, the

supervision of trained individuals. Analysis should be

conducted by entities permitted or certified for this purpose.

Sampling and analysis Quality Assurance / Quality Control

(QA/QC) plans should be applied and documented to ensure

that data quality is adequate for the intended data use (e.g.,

method detection limits are below levels of concern).

Monitoring reports should include QA/QC documentation.

Monitoring of Small Combustion Plants Emissions • Additional recommended monitoring approaches for boilers:

Boilers with capacities between =3 MWth and < 20 MWth:

o Annual Stack Emission Testing: SO2, NOx and PM. For

gaseous fuel-fired boilers, only NOx. SO2 can be

calculated based on fuel quality certification if no SO2

control equipment is used.

26 An on-line catalogue of ISO standards relating to the environment, health protection, and safety is available at: http://www.iso.org/iso/en/CatalogueListPage.CatalogueList?ICS1=13&ICS2=&ICS3=&scopelist=

27 An on-line catalogue of European Standards is available at: http://www.cen.eu/catweb/cwen.htm .

28 The National Environmental Methods Index provides a searchable clearinghouse of U.S. methods and procedures for both regulatory and non-regulatory monitoring purposes for water, sediment, air and tissues, and is available at http://www.nemi.gov/.

o If Annual Stack Emission Testing demonstrates results

consistently and significantly better than the required

levels, frequency of Annual Stack Emission Testing can

be reduced from annual to every two or three years.

o Emission Monitoring: None

Boilers with capacities between =20 MWth and < 50 MWth

o Annual Stack Emission Testing: SO2, NOx and PM. For

gaseous fuel-fired boilers, only NOx. SO2 can be

calculated based on fuel quality certification (if no SO2

control equipment is used)

o Emission Monitoring: SO2. Plants with SO2 control

equipment: Continuous. NOx: Continuous monitoring of

either NOx emissions or indicative NOx emissions using

combustion parameters. PM: Continuous monitoring of

either PM emissions, opacity, or indicative PM

emissions using combustion parameters / visual

monitoring.

• Additional recommended monitoring approaches for

turbines:

o Annual Stack Emission Testing: NOx and SO2 (NOx

only for gaseous fuel-fired turbines).

o If Annual Stack Emission Testing results show

constantly (3 consecutive years) and significantly (e.g.

less than 75 percent) better than the required levels,

frequency of Annual Stack Emission Testing can be

reduced from annual to every two or three years.

o Emission Monitoring: NOx: Continuous monitoring of


combustion parameters.SO2: Continuous monitoring if

SO2 control equipment is used.

• Additional recommended monitoring approaches for

engines:

o Annual Stack Emission Testing: NOx ,SO2 and PM (NOx

only for gaseous fuel-fired diesel engines).



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o If Annual Stack Emission Testing results show

constantly (3 consecutive years) and significantly (e.g.

less than 75 percent) better than the required levels,

frequency of Annual Stack Emission Testing can be

reduced from annual to every two or three years.

o Emission Monitoring: NOx: Continuous monitoring of


combustion parameters. SO2: Continuous monitoring if

SO2 control equipment is used. PM: Continuous

monitoring of either PM emissions or indicative PM

emissions using operating parameters.



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Annex 1.1.1 – Air Emissions Estimation and Dispersion

Modeling Methods

The following is a partial list of documents to aid in the estimation

of air emissions from various processes and air dispersion

models:

Australian Emission Estimation Technique Manuals

http://www.npi.gov.au/handbooks/

Atmospheric Emission Inventory Guidebook, UN / ECE / EMEP

and the European Environment Agency

http://www.aeat.co.uk/netcen/airqual/TFEI/unece.htm

Emission factors and emission estimation methods, US EPA

Office of Air Quality Planning & Standards

http://www.epa.gov/ttn/chief

Guidelines on Air Quality Models (Revised), US Environmental

Protection Agency (EPA), 2005

http://www.epa.gov/scram001/guidance/guide/appw_05.pdf

Frequently Asked Questions, Air Quality Modeling and

Assessment Unit (AQMAU), UK Environment Agency

http://www.environment-

agency.gov.uk/subjects/airquality/236092/?version=1&lang=_e

OECD Database on Use and Release of Industrial Chemicals

http://www.olis.oecd.org/ehs/urchem.nsf/



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Annex 1.1.2 – Illustrative Point Source Air Emissions Prevention and Control Technologies

Principal Sources and Issues General Prevention / Process Modification Approach

Control Options Reduction Efficiency (%)

Gas Condition

Comments

Particulate Matter (PM)

Fabric Filters 99 - 99.7% Dry gas, temp <400F

Applicability depends on flue gas properties including temperature, chemical properties, abrasion and load. Typical air to cloth ratio range of 2.0 to 3.5 cfm/ft2

Achievable outlet concentrations of 23 mg/Nm3

Electrostatic Precipitator (ESP)

97 – 99% Varies depending of particle type

Precondition gas to remove large particles. Efficiency dependent on resistivity of particle. Achievable outlet concentration of 23 mg/Nm3

Cyclone 74 – 95% None Most efficient for large particles. Achievable outlet concentrations of 30 - 40 mg/Nm3

Main sources are the combustion of fossil fuels and numerous manufacturing processes that collect PM through air extraction and ventilation systems. Volcanoes, ocean spray, forest fires and blowing dust (most prevalent in dry and semiarid climates) contribute to background levels.

Fuel switching (e.g. selection of lower sulfur fuels) or reducing the amount of fine particulates added to a process.

Wet Scrubber 93 – 95% None Wet sludge may be a disposal problem depending on local infrastructure. Achievable outlet concentrations of 30 - 40 mg/Nm3


Fuel Switching >90% Alternate fuels may include low sulfur coal, light diesel or natural gas with consequent reduction in particulate emissions related to sulfur in the fuel. Fuel cleaning or beneficiation of fuels prior to combustion is another viable option but may have economic consequences.

Sorbent Injection 30% - 70% Calcium or lime is injected into the flue gas and the SO2 is adsorbed onto the sorbent

Dry Flue Gas Desulfurization

70%-90% Can be regenerable or throwaway.

Mainly produced by the combustion of fuels such as oil and coal and as a by-product from some chemical production or wastewater treatment processes.

Control system selection is heavily dependent on the inlet concentration. For SO2 concentrations in excess of 10%, the stream is passed through an acid plant not only to lower the SO2 emissions but also to generate high grade sulfur for sale. Levels below 10% are not rich enough for this process and should therefore utilize absorption or ‘scrubbing,’ where SO2 molecules are captured into a liquid phase or adsorption, where SO2 molecules are captured on the surface of a solid adsorbent.

Wet Flue Gas Desulfurization

>90% Produces gypsum as a by-product



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Annex 1.1.2: Illustrative Point Source Air Emissions Prevention and Control Technologies (continued)

Oxides of Nitrogen (NOx) Percent Reduction by Fuel Type Comments

Combustion modification (Illustrative of boilers)

Coal Oil Gas

Low-excess-air firing 10–30 10–30 10–30

Staged Combustion 20–50 20–50 20–50

Flue Gas Recirculation N/A 20–50 20–50

Water/Steam Injection N/A 10–50 N/A.

Low-NOx Burners 30–40 30–40 30–40

These modifications are capable of reducing NOx emissions by 50 to 95%. The method of combustion control used depends on the

type of boiler and the method of firing fuel.

Flue Gas Treatment Coal Oil Gas

Selective Catalytic Reduction (SCR) 60–90 60–90 60–90

Associated with combustion of fuel. May occur in several forms of nitrogen oxide; namely nitric oxide (NO), nitrogen dioxide (NO2) and nitrous oxide (N2O), which is also a

greenhouse gas. The term NOx serves as a composite between NO and NO2 and emissions are usually

reported as NOx. Here the NO is multiplied by the ratio of molecular weights of NO2 to NO and added to the NO2 emissions.

Means of reducing NOx emissions are based on the modification of operating conditions such as minimizing the resident time at peak temperatures, reducing the peak temperatures by increasing heat transfer rates or minimizing the availability of oxygen.

Selective Non-Catalytic Reduction (SNCR)

N/A 30–70 30–70

Flue gas treatment is more effective in reducing NOx emissions than are combustion controls. Techniques can be classified as

SCR, SNCR, and adsorption. SCR involves the injection of ammonia as a reducing agent to convert NOx to nitrogen in the presence of a catalyst in a converter upstream of the air heater.

Generally, some ammonia slips through and is part of the emissions. SNCR also involves the injection of ammonia or urea

based products without the presence of a catalyst.

Note: Compiled by IFC based on inputs from technical experts.



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Annex 1.1.3 - Good International Industry Practice (GIIP)

Stack Height

(Based on United States 40 CFR, part 51.100 (ii)).

HG = H + 1.5L; where

HG = GEP stack height measured from the ground level

elevation at the base of the stack

H = Height of nearby structure(s) above the base of the

stack.

L = Lesser dimension, height (h) or width (w), of nearby

structures

“Nearby structures” = Structures within/touching a radius

of 5L but less than 800 m.

Annex 1.1.4 - Examples of VOC Emissions Controls

29 Seal-less equipment can be a large source of emissions in the event of equipment failure. 30 Actual efficiency of a closed-vent system depends on percentage of vapors collected and efficiency of control device to which the vapors are routed. 31 Control efficiency of closed vent-systems installed on a pressure relief device may be lower than other closed-vent systems.

Equipment Type Modification

Approximate Control

Efficiency (%)

Seal-less design 10029

Closed-vent system 9030 Pumps

Dual mechanical seal with barrier fluid maintained at a higher pressure than the pumped fluid

100

Closed-vent system 90

Compressors Dual mechanical seal with barrier fluid maintained at a higher pressure than the compressed gas

100

Closed-vent system Variable31 Pressure Relief Devices

Rupture disk assembly 100

Valves Seal-less design 100

Connectors Weld together 100

Open-ended Lines Blind, cap, plug, or second valve 100

Sampling Connections Closed-loop sampling 100

Note: Examples of technologies are provided for illustrative purposes. The availability and applicability of any particular technology will vary depending on manufacturer specifications.

Stack

1.5*LHG

hH

Pro

ject

ed w

idth

(w)

Maximum 5*L



APRIL 30, 2007 17

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Annex 1.1.5 - Fugitive PM Emissions Controls

Control Type Control Efficiency

Chemical Stabilization 0% - 98%

Hygroscopic salts Bitumens/adhesives

60% - 96%

Surfactants 0% - 68%

Wet Suppression – Watering 12% - 98%

Speed Reduction 0% - 80%

Traffic Reduction Not quantified

Paving (Asphalt / Concrete) 85% - 99%

Covering with Gravel, Slag, or "Road Carpet"

30% - 50%

Vacuum Sweeping 0% - 58%

Water Flushing/Broom Sweeping 0% - 96%

Environmental, Health, and Safety (EHS) Guidelines GENERAL EHS GUIDELINES: ENVIRONMENTAL

WASTEWATER AND AMBIENT WATER QUALITY

APRIL 30, 2007 25

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1.3 Wastewater and Ambient Water Quality

Applicability and Approach......................................25 General Liquid Effluent Quality .......................................26

Discharge to Surface Water....................................26 Discharge to Sanitary Sewer Systems.....................26 Land Application of Treated Effluent........................27 Septic Systems ......................................................27

Wastewater Management...............................................27 Industrial Wastewater .............................................27 Sanitary Wastewater ..............................................29 Emissions from Wastewater Treatment Operations .30 Residuals from Wastewater Treatment Operations..30 Occupational Health and Safety Issues in Wastewater Treatment Operations.............................................30

Monitoring......................................................................30

Applicability and Approach This guideline applies to projects that have either direct or indirect

discharge of process wastewater, wastewater from utility

operations or stormwater to the environment. These guidelines

are also applicable to industrial discharges to sanitary sewers that

discharge to the environment without any treatment. Process

wastewater may include contaminated wastewater from utility

operations, stormwater, and sanitary sewage. It provides

information on common techniques for wastewater management,

water conservation, and reuse that can be applied to a wide range

of industry sectors. This guideline is meant to be complemented

by the industry-specific effluent guidelines presented in the

Industry Sector Environmental, Health, and Safety (EHS)

Guidelines. Projects with the potential to generate process

wastewater, sanitary (domestic) sewage, or stormwater should

incorporate the necessary precautions to avoid, minimize, and

control adverse impacts to human health, safety, or the

environment.

In the context of their overall ESHS management system, facilities

should:

• Understand the quality, quantity, frequency and sources of

liquid effluents in its installations. This includes knowledge

about the locations, routes and integrity of internal drainage

systems and discharge points

• Plan and implement the segregation of liquid effluents

principally along industrial, utility, sanitary, and stormwater

categories, in order to limit the volume of water requiring

specialized treatment. Characteristics of individual streams

may also be used for source segregation.

• Identify opportunities to prevent or reduce wastewater

pollution through such measures as recycle/reuse within their

facility, input substitution, or process modification (e.g.

change of technology or operating conditions/modes).

• Assess compliance of their wastewater discharges with the

applicable: (i) discharge standard (if the wastewater is

discharged to a surface water or sewer), and (ii) water quality

standard for a specific reuse (e.g. if the wastewater is reused

for irrigation).

Additionally, the generation and discharge of wastewater of any

type should be managed through a combination of:

• Water use efficiency to reduce the amount of wastewater

generation

• Process modification, including waste minimization, and

reducing the use of hazardous materials to reduce the load of

pollutants requiring treatment

• If needed, application of wastewater treatment techniques to

further reduce the load of contaminants prior to discharge,

taking into consideration potential impacts of cross-media

transfer of contaminants during treatment (e.g., from water to

air or land)

Cfrankel

General EHS Guidelines [Complete version] at: www.ifc.org/ifcext/enviro.nsf/Content/EnvironmentalGuidelines



APRIL 30, 2007 26

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When wastewater treatment is required prior to discharge, the

level of treatment should be based on:

• Whether wastewater is being discharged to a sanitary sewer

system, or to surface waters

• National and local standards as reflected in permit

requirements and sewer system capacity to convey and treat

wastewater if discharge is to sanitary sewer

• Assimilative capacity of the receiving water for the load of

contaminant being discharged wastewater if discharge is to

surface water

• Intended use of the receiving water body (e.g. as a source of

drinking water, recreation, irrigation, navigation, or other)

• Presence of sensitive receptors (e.g., endangered species)

or habitats

• Good International Industry Practice (GIIP) for the relevant

industry sector

General Liquid Effluent Quality

Discharge to Surface Water Discharges of process wastewater, sanitary wastewater,

wastewater from utility operations or stormwater to surface water

should not result in contaminant concentrations in excess of local

ambient water quality criteria or, in the absence of local criteria,

other sources of ambient water quality.35 Receiving water use36

and assimilative capacity37, taking other sources of discharges to

35 An example is the US EPA National Recommended Water Quality Criteria http://www.epa.gov/waterscience/criteria/wqcriteria.html

36 Examples of receiving water uses as may be designated by local authorities include: drinking water (with some level of treatment), recreation, aquaculture, irrigation, general aquatic life, ornamental, and navigation. Examples of health-based guideline values for receiving waters include World Health Organization (WHO) guidelines for recreational use (http://www.who.int/water_sanitation_health/dwq/guidelines/en/index.html)

37 The assimilative capacity of the receiving water body depends on numerous factors including, but not limited to, the total volume of water, flow rate, flushing rate of the water body and the loading of pollutants from other effluent sources in

the receiving water into consideration, should also influence the

acceptable pollution loadings and effluent discharge quality.

Additional considerations that should be included in the setting of

project-specific performance levels for wastewater effluents

include:

• Process wastewater treatment standards consistent with

applicable Industry Sector EHS Guidelines. Projects for

which there are no industry-specific guidelines should

reference the effluent quality guidelines of an industry sector

with suitably analogous processes and effluents;

• Compliance with national or local standards for sanitary

wastewater discharges or, in their absence, the indicative

guideline values applicable to sanitary wastewater

discharges shown in Table 1.3.1 below ;

• Temperature of wastewater prior to discharge does not result

in an increase greater than 3°C of ambient temperature at

the edge of a scientifically established mixing zone which

takes into account ambient water quality, receiving water use

and assimilative capacity among other considerations.

Discharge to Sanitary Sewer Systems Discharges of industrial wastewater, sanitary wastewater,

wastewater from utility operations or stormwater into public or

private wastewater treatment systems should:

• Meet the pretreatment and monitoring requirements of the

sewer treatment system into which it discharges.

• Not interfere, directly or indirectly, with the operation and

maintenance of the collection and treatment systems, or

pose a risk to worker health and safety, or adversely impact

the area or region. A seasonally representative baseline assessment of ambient water quality may be required for use with established scientific methods and mathematical models to estimate potential impact to the receiving water from an effluent source.



APRIL 30, 2007 27

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characteristics of residuals from wastewater treatment

operations.

• Be discharged into municipal or centralized wastewater

treatment systems that have adequate capacity to meet local

regulatory requirements for treatment of wastewater

generated from the project. Pretreatment of wastewater to

meet regulatory requirements before discharge from the

project site is required if the municipal or centralized

wastewater treatment system receiving wastewater from the

project does not have adequate capacity to maintain

regulatory compliance.

Land Application of Treated Effluent The quality of treated process wastewater, wastewater from utility

operations or stormwater discharged on land, including wetlands,

should be established based on local regulatory requirements. .

Where land is used as part of the treatment system and the

ultimate receptor is surface water, water quality guidelines for

surface water discharges specific to the industry sector process

should apply.38 Potential impact on soil, groundwater, and surface

water, in the context of protection, conservation and long term

sustainability of water and land resources should be assessed

when land is used as part of any wastewater treatment system.

Septic Systems Septic systems are commonly used for treatment and disposal of

domestic sanitary sewage in areas with no sewerage collection

networks, Septic systems should only be used for treatment of

sanitary sewage, and unsuitable for industrial wastewater

treatment. When septic systems are the selected form of

wastewater disposal and treatment, they should be:

38 Additional guidance on water quality considerations for land application is available in the WHO Guidelines for the Safe Use of Wastewater, Excreta and Greywater. Volume 2: Wastewater Use in Agriculture http://www.who.int/water_sanitation_health/wastewater/gsuweg2/en/index.html

• Properly designed and installed in accordance with local

regulations and guidance to prevent any hazard to public

health or contamination of land, surface or groundwater.

• Well maintained to allow effective operation.

• Installed in areas with sufficient soil percolation for the design

wastewater loading rate.

• Installed in areas of stable soils that are nearly level, well

drained, and permeable, with enough separation between the

drain field and the groundwater table or other receiving

waters.

Wastewater Management Wastewater management includes water conservation,

wastewater treatment, stormwater management, and wastewater

and water quality monitoring.

Industrial Wastewater Industrial wastewater generated from industrial operations

includes process wastewater, wastewater from utility operations,,

runoff from process and materials staging areas, and

miscellaneous activities including wastewater from laboratories,

equipment maintenance shops, etc.. The pollutants in an industrial

wastewater may include acids or bases (exhibited as low or high

pH), soluble organic chemicals causing depletion of dissolved

oxygen, suspended solids, nutrients (phosphorus, nitrogen),

heavy metals (e.g. cadmium, chromium, copper, lead, mercury,

nickel, zinc), cyanide, toxic organic chemicals, oily materials, and

volatile materials. , as well as from thermal characteristics of the

discharge (e.g., elevated temperature). Transfer of pollutants to

another phase, such as air, soil, or the sub-surface, should be

minimized through process and engineering controls.

Process Wastewater – – Examples of treatment approaches

typically used in the treatment of industrial wastewater are

summarized in Annex 1.3.1. While the choice of treatment



APRIL 30, 2007 28

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technology is driven by wastewater characteristics, the actual

performance of this technology depends largely on the adequacy

of its design, equipment selection, as well as operation and

maintenance of its installed facilities. Adequate resources are

required for proper operation and maintenance of a treatment

facility, and performance is strongly dependent on the technical

ability and training of its operational staff. One or more treatment

technologies may be used to achieve the desired discharge

quality and to maintain consistent compliance with regulatory

requirements. The design and operation of the selected

wastewater treatment technologies should avoid uncontrolled air

emissions of volatile chemicals from wastewaters. Residuals from

industrial wastewater treatment operations should be disposed in

compliance with local regulatory requirements, in the absence of

which disposal has to be consistent with protection of public health

and safety, and conservation and long term sustainability of water

and land resources.

Wastewater from Utilities Operations - Utility operations such

as cooling towers and demineralization systems may result in high

rates of water consumption, as well as the potential release of

high temperature water containing high dissolved solids, residues

of biocides, residues of other cooling system anti-fouling agents,

etc. Recommended water management strategies for utility

operations include:

• Adoption of water conservation opportunities for facility

cooling systems as provided in the Water Conservation

section below;

• Use of heat recovery methods (also energy efficiency

improvements) or other cooling methods to reduce the

temperature of heated water prior to discharge to ensure the

discharge water temperature does not result in an increase

greater than 3°C of ambient temperature at the edge of a

scientifically established mixing zone which takes into

account ambient water quality, receiving water use, potential

receptors and assimilative capacity among other

considerations;

• Minimizing use of antifouling and corrosion inhibiting

chemicals by ensuring appropriate depth of water intake and

use of screens. Least hazardous alternatives should be used

with regards to toxicity, biodegradability, bioavailability, and

bioaccumulation potential. Dose applied should accord with

local regulatory requirements and manufacturer

recommendations;

• Testing for residual biocides and other pollutants of concern

should be conducted to determine the need for dose

adjustments or treatment of cooling water prior to discharge.

Stormwater Management - Stormwater includes any surface

runoff and flows resulting from precipitation, drainage or other

sources. Typically stormwater runoff contains suspended

sediments, metals, petroleum hydrocarbons, Polycyclic Aromatic

Hydrocarbons (PAHs), coliform, etc. Rapid runoff, even of

uncontaminated stormwater, also degrades the quality of the

receiving water by eroding stream beds and banks. In order to

reduce the need for stormwater treatment, the following principles

should be applied:

• Stormwater should be separated from process and sanitary

wastewater streams in order to reduce the volume of

wastewater to be treated prior to discharge

• Surface runoff from process areas or potential sources of

contamination should be prevented

• Where this approach is not practical, runoff from process and

storage areas should be segregated from potentially less

contaminated runoff

• Runoff from areas without potential sources of contamination

should be minimized (e.g. by minimizing the area of

impermeable surfaces) and the peak discharge rate should



APRIL 30, 2007 29

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be reduced (e.g. by using vegetated swales and retention

ponds);

• Where stormwater treatment is deemed necessary to protect

the quality of receiving water bodies, priority should be given

to managing and treating the first flush of stormwater runoff

where the majority of potential contaminants tend to be

present;

• When water quality criteria allow, stormwater should be

managed as a resource, either for groundwater recharge or

for meeting water needs at the facility;

• Oil water separators and grease traps should be installed

and maintained as appropriate at refueling facilities,

workshops, parking areas, fuel storage and containment

areas.

• Sludge from stormwater catchments or collection and

treatment systems may contain elevated levels of pollutants

and should be disposed in compliance with local regulatory

requirements, in the absence of which disposal has to be

consistent with protection of public health and safety, and

conservation and long term sustainability of water and land

resources.

Sanitary Wastewater Sanitary wastewater from industrial facilities may include effluents

from domestic sewage, food service, and laundry facilities serving

site employees. Miscellaneous wastewater from laboratories,

medical infirmaries, water softening etc. may also be discharged

to the sanitary wastewater treatment system. Recommended

sanitary wastewater management strategies include:

• Segregation of wastewater streams to ensure compatibility

with selected treatment option (e.g. septic system which can

only accept domestic sewage);

• Segregation and pretreatment of oil and grease containing

effluents (e.g. use of a grease trap) prior to discharge into

sewer systems;

• If sewage from the industrial facility is to be discharged to

surface water, treatment to meet national or local standards

for sanitary wastewater discharges or, in their absence, the

indicative guideline values applicable to sanitary wastewater

discharges shown in Table 1.3.1;

• If sewage from the industrial facility is to be discharged to

either a septic system, or where land is used as part of the

treatment system, treatment to meet applicable national or

local standards for sanitary wastewater discharges is

required.

• Sludge from sanitary wastewater treatment systems should

be disposed in compliance with local regulatory

requirements, in the absence of which disposal has to be

consistent with protection of public health and safety, and

conservation and long term sustainability of water and land

resources.



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Emissions from Wastewater Treatment Operations Air emissions from wastewater treatment operations may include

hydrogen sulfide, methane, ozone (in the case of ozone

disinfection), volatile organic compounds (e.g., chloroform

generated from chlorination activities and other volatile organic

compounds (VOCs) from industrial wastewater), gaseous or

volatile chemicals used for disinfection processes (e.g., chlorine

and ammonia), and bioaerosols. Odors from treatment facilities

can also be a nuisance to workers and the surrounding

community. Recommendations for the management of emissions

are presented in the Air Emissions and Ambient Air Quality

section of this document and in the EHS Guidelines for Water and

Sanitation.

Residuals from Wastewater Treatment Operations Sludge from a waste treatment plant needs to be evaluated on a

case-by-case basis to establish whether it constitutes a hazardous

or a non-hazardous waste and managed accordingly as described

in the Waste Management section of this document.

Occupational Health and Safety Issues in Wastewater Treatment Operations Wastewater treatment facility operators may be exposed to

physical, chemical, and biological hazards depending on the

design of the facilities and the types of wastewater effluents

managed. Examples of these hazards include the potential for

trips and falls into tanks, confined space entries for maintenance

operations, and inhalation of VOCs, bioaerosols, and methane,

contact with pathogens and vectors, and use of potentially

hazardous chemicals, including chlorine, sodium and calcium

hypochlorite, and ammonia. Detailed recommendations for the

management of occupational health and safety issues are

presented in the relevant section of this document. Additional

guidance specifically applicable to wastewater treatment systems

is provided in the EHS Guidelines for Water and Sanitation.

Monitoring A wastewater and water quality monitoring program with adequate

resources and management oversight should be developed and

implemented to meet the objective(s) of the monitoring program.

The wastewater and water quality monitoring program should

consider the following elements:

• Monitoring parameters: The parameters selected for

monitoring should be indicative of the pollutants of concern

from the process, and should include parameters that are

regulated under compliance requirements;

• Monitoring type and frequency: Wastewater monitoring

should take into consideration the discharge characteristics

from the process over time. Monitoring of discharges from

processes with batch manufacturing or seasonal process

variations should take into consideration of time-dependent

Table 1.3.1 Indicative Values for Treated Sanitary Sewage Dischargesa

Pollutants Units Guideline Value

pH pH 6 – 9

BOD mg/l 30

COD mg/l 125

Total nitrogen mg/l 10

Total phosphorus mg/l 2

Oil and grease mg/l 10

Total suspended solids mg/l 50

Total coliform bacteria MPNb / 100 ml 400a

Notes: a Not applicable to centralized, municipal, wastewater treatment systems which are included in EHS Guidelines for Water and Sanitation. b MPN = Most Probable Number



APRIL 30, 2007 31

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variations in discharges and, therefore, is more complex than

monitoring of continuous discharges. Effluents from highly

variable processes may need to be sampled more frequently

or through composite methods. Grab samples or, if

automated equipment permits, composite samples may offer

more insight on average concentrations of pollutants over a

24-hour period. Composite samplers may not be appropriate

where analytes of concern are short-lived (e.g., quickly

degraded or volatile).

• Monitoring locations: The monitoring location should be

selected with the objective of providing representative

monitoring data. Effluent sampling stations may be located

at the final discharge, as well as at strategic upstream points

prior to merging of different discharges. Process discharges

should not be diluted prior or after treatment with the

objective of meeting the discharge or ambient water quality

standards.

• Data quality: Monitoring programs should apply

internationally approved methods for sample collection,

preservation and analysis. Sampling should be conducted by

or under the supervision of trained individuals. Analysis

should be conducted by entities permitted or certified for this

purpose. Sampling and Analysis Quality Assurance/Quality

Control (QA/QC) plans should be prepared and,

implemented. QA/QC documentation should be included in

monitoring reports.



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Annex 1.3.1 - Examples of Industrial Wastewater Treatment Approaches

Pollutant/Parameter Control Options / Principle Common End of Pipe Control Technology

pH Chemical, Equalization Acid/Base addition, Flow equalization

Oil and Grease / TPH Phase separation Dissolved Air Floatation, oil water separator, grease trap

TSS - Settleable Settling, Size Exclusion Sedimentation basin, clarifier, centrifuge, screens

TSS - Non-Settleable Floatation, Filtration - traditional and tangential

Dissolved air floatation, Multimedia filter, sand filter, fabric filter, ultrafiltration, microfiltration

Hi - BOD (> 2 Kg/m3) Biological - Anaerobic Suspended growth, attached growth, hybrid

Lo - BOD (< 2 Kg/m3) Biological - Aerobic, Facultative Suspended growth, attached growth, hybrid

COD - Non-Biodegradable Oxidation, Adsorption, Size Exclusion

Chemical oxidation, Thermal oxidation, Activated Carbon, Membranes

Metals - Particulate and Soluble

Coagulation, flocculation, precipitation, size exclusion

Flash mix with settling, filtration - traditional and tangential

Inorganics / Non-metals Coagulation, flocculation, precipitation, size exclusion, Oxidation, Adsorption

Flash mix with settling, filtration - traditional and tangential, Chemical oxidation, Thermal oxidation, Activated Carbon, Reverse Osmosis, Evaporation

Organics - VOCs and SVOCs Biological - Aerobic, Anaerobic, Facultative; Adsorption, Oxidation

Biological : Suspended growth, attached growth, hybrid; Chemical oxidation, Thermal oxidation, Activated Carbon

Emissions – Odors and VOCs

Capture – Active or Passive; Biological; Adsorption, Oxidation

Biological : Attached growth; Chemical oxidation, Thermal oxidation, Activated Carbon

Nutrients Biological Nutrient Removal, Chemical, Physical, Adsorption

Aerobic/Anoxic biological treatment, chemical hydrolysis and air stripping, chlorination, ion exchange

Color Biological - Aerobic, Anaerobic, Facultative; Adsorption, Oxidation Biological Aerobic, Chemical oxidation, Activated Carbon

Temperature Evaporative Cooling Surface Aerators, Flow Equalization

TDS Concentration, Size Exclusion Evaporation, crystallization, Reverse Osmosis

Active Ingredients/Emerging Contaminants

Adsorption, Oxidation, Size Exclusion, Concentration

Chemical oxidation, Thermal oxidation, Activated Carbon, Ion Exchange, Reverse Osmosis, Evaporation, Crystallization

Radionuclides Adsorption,Size Exclusion, Concentration

Ion Exchange, Reverse Osmosis, Evaporation, Crystallization

Pathogens Disinfection, Sterilization Chlorine, Ozone, Peroxide, UV, Thermal

Toxicity Adsorption, Oxidation, Size Exclusion, Concentration

Chemical oxidation, Thermal oxidation, Activated Carbon, Evaporation, crystallization, Reverse Osmosis

Environmental, Health, and Safety Guidelines THERMAL POWER PLANTS

DECEMBER 19, 2008 1

WORLD BANK GROUP

Environmental, Health, and Safety Guidelines for Thermal Power Plants

Introduction

The Environmental, Health, and Safety (EHS) Guidelines are

technical reference documents with general and industry-specific

examples of Good International Industry Practice (GIIP)1. When

one or more members of the World Bank Group are involved in a

project, these EHS Guidelines are applied as required by their

respective policies and standards. These industry sector EHS

guidelines are designed to be used together with the General EHS Guidelines document, which provides guidance to users on

common EHS issues potentially applicable to all industry sectors.

For complex projects, use of multiple industry-sector guidelines

may be necessary. A complete list of industry-sector guidelines

can be found at:

www.ifc.org/ifcext/sustainability.nsf/Content/EnvironmentalGuideli

nes

The EHS Guidelines contain the performance levels and

measures that are generally considered to be achievable in new

facilities by existing technology at reasonable costs. Application

of the EHS Guidelines to existing facilities may involve the

establishment of site-specific targets, based on environmental

assessments and/or environmental audits as appropriate, with an

appropriate timetable for achieving them. The applicability of the

EHS Guidelines should be tailored to the hazards and risks

established for each project on the basis of the results of an

environmental assessment in which site-specific variables, such

as host country context, assimilative capacity of the environment,

and other project factors, are taken into account. The applicability

1 Defined as the exercise of professional skill, diligence, prudence and foresight that would be reasonably expected from skilled and experienced professionals engaged in the same type of undertaking under the same or similar circumstances globally. The circumstances that skilled and experienced professionals may find when evaluating the range of pollution prevention and control techniques available to a project may include, but are not limited to, varying levels of environmental degradation and environmental assimilative capacity as well as varying levels of financial and technical feasibility.

of specific technical recommendations should be based on the

professional opinion of qualified and experienced persons. When

host country regulations differ from the levels and measures

presented in the EHS Guidelines, projects are expected to

achieve whichever is more stringent. If less stringent levels or

measures than those provided in these EHS Guidelines are

appropriate, in view of specific project circumstances, a full and

detailed justification for any proposed alternatives is needed as

part of the site-specific environmental assessment. This

justification should demonstrate that the choice for any alternate

performance levels is protective of human health and the

environment.

Applicability

This document includes information relevant to combustion

processes fueled by gaseous, liquid and solid fossil fuels and

biomass and designed to deliver electrical or mechanical power,

steam, heat, or any combination of these, regardless of the fuel

type (except for solid waste which is covered under a separate

Guideline for Waste Management Facilities), with a total rated

heat input capacity above 50 Megawatt thermal input (MWth) on

Higher Heating Value (HHV) basis.2 It applies to boilers,

reciprocating engines, and combustion turbines in new and

existing facilities. Annex A contains a detailed description of

industry activities for this sector, and Annex B contains guidance

for Environmental Assessment (EA) of thermal power projects.

Emissions guidelines applicable to facilities with a total heat input

capacity of less than 50 MWth are presented in Section 1.1 of the

General EHS Guidelines. Depending on the characteristics of

the project and its associated activities (i.e., fuel sourcing and

evacuation of generated electricity), readers should also consult

2 Total capacity applicable to a facility with multiple units.

http://www.ifc.org/ifcext/sustainability.nsf/Content/EnvironmentalGuidelines

http://www.ifc.org/ifcext/sustainability.nsf/Content/EnvironmentalGuidelines


DECEMBER 19, 2008 2

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the EHS Guidelines for Mining and the EHS Guidelines for Electric

Power Transmission and Distribution.

Decisions to invest in this sector by one or more members of the

World Bank Group are made within the context of the World Bank

Group strategy on climate change.

This document is organized according to the following sections:

Section 1.0 – Industry Specific Impacts and Management Section 2.0 – Performance Indicators and Monitoring Section 3.0 – References and Additional Sources Annex A – General Description of Industry Activities Annex B – Environmental Assessment Guidance for Thermal Power Projects.

1.0 Industry-Specific Impacts and Management

The following section provides a summary of the most significant

EHS issues associated with thermal power plants, which occur

during the operational phase, along with recommendations for

their management.

As described in the introduction to the General EHS Guidelines,

the general approach to the management of EHS issues in

industrial development activities, including power plants, should

consider potential impacts as early as possible in the project

cycle, including the incorporation of EHS considerations into the

site selection and plant design processes in order to maximize the

range of options available to prevent and control potential

negative impacts.

Recommendations for the management of EHS issues common to

most large industrial and infrastructure facilities during the

construction and decommissioning phases are provided in the

General EHS Guidelines.

1.1 Environment

Environmental issues in thermal power plant projects primarily

include the following:

• Air emissions

• Energy efficiency and Greenhouse Gas emissions

• Water consumption and aquatic habitat alteration

• Effluents

• Solid wastes

• Hazardous materials and oil

• Noise

Air Emissions The primary emissions to air from the combustion of fossil fuels or

biomass are sulfur dioxide (SO2), nitrogen oxides (NOX),

particulate matter (PM), carbon monoxide (CO), and greenhouse

gases, such as carbon dioxide (CO2). Depending on the fuel type

and quality, mainly waste fuels or solid fuels, other substances

such as heavy metals (i.e., mercury, arsenic, cadmium, vanadium,

nickel, etc), halide compounds (including hydrogen fluoride),

unburned hydrocarbons and other volatile organic compounds

(VOCs) may be emitted in smaller quantities, but may have a

significant influence on the environment due to their toxicity and/or

persistence. Sulfur dioxide and nitrogen oxide are also implicated

in long-range and trans-boundary acid deposition.

The amount and nature of air emissions depends on factors such

as the fuel (e.g., coal, fuel oil, natural gas, or biomass), the type

and design of the combustion unit (e.g., reciprocating engines,

combustion turbines, or boilers), operating practices, emission

control measures (e.g., primary combustion control, secondary

flue gas treatment), and the overall system efficiency. For

example, gas-fired plants generally produce negligible quantities

of particulate matter and sulfur oxides, and levels of nitrogen

oxides are about 60% of those from plants using coal (without


DECEMBER 19, 2008 3

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emission reduction measures). Natural gas-fired plants also

release lower quantities of carbon dioxide, a greenhouse gas.

Some measures, such as choice of fuel and use of measures to

increase energy conversion efficiency, will reduce emissions of

multiple air pollutants, including CO2, per unit of energy

generation. Optimizing energy utilization efficiency of the

generation process depends on a variety of factors, including the

nature and quality of fuel, the type of combustion system, the

operating temperature of the combustion turbines, the operating

pressure and temperature of steam turbines, the local climate

conditions, the type of cooling system used, etc. Recommended

measures to prevent, minimize, and control air emissions include:

• Use of the cleanest fuel economically available (natural gas

is preferable to oil, which is preferable to coal) if that is

consistent with the overall energy and environmental policy

of the country or the region where the plant is proposed. For

most large power plants, fuel choice is often part of the

national energy policy, and fuels, combustion technology and

pollution control technology, which are all interrelated, should

be evaluated very carefully upstream of the project to

optimize the project’s environmental performance;

• When burning coal, giving preference to high-heat-content,

low-ash, and low-sulfur coal;

• Considering beneficiation to reduce ash content, especially

for high ash coal;3

• Selection of the best power generation technology for the fuel

chosen to balance the environmental and economic benefits.

The choice of technology and pollution control systems will

be based on the site-specific environmental assessment

(some examples include the use of higher energy-efficient

systems, such as combined cycle gas turbine system for

natural gas and oil-fired units, and supercritical, ultra-

supercritical or integrated coal gasification combined cycle

(IGCC) technology for coal-fired units);

• Designing stack heights according to Good International

Industry Practice (GIIP) to avoid excessive ground level

concentrations and minimize impacts, including acid

deposition;4

• Considering use of combined heat and power (CHP, or co-

generation) facilities. By making use of otherwise wasted

heat, CHP facilities can achieve thermal efficiencies of 70 –

90 percent, compared with 32 – 45 percent for conventional

thermal power plants.

• As stated in the General EHS Guidelines, emissions from a

single project should not contribute more than 25% of the

applicable ambient air quality standards to allow additional,

future sustainable development in the same airshed.5

Pollutant-specific control recommendations are provided below.

Sulfur Dioxide The range of options for the control of sulfur oxides varies

substantially because of large differences in the sulfur content of

different fuels and in control costs as described in Table 1. The

choice of technology depends on a benefit-cost analysis of the

environmental performance of different fuels, the cost of controls,

and the existence of a market for sulfur control by-products6.

Recommended measures to prevent, minimize, and control SO2

emissions include:

3 If sulfur is inorganically bound to the ash, this will also reduce sulfur content. 4 For specific guidance on calculating stack height see Annex 1.1.3 of the General EHS Guidelines. Raising stack height should not be used to allow more emissions. However, if the proposed emission rates result in significant incremental ambient air quality impacts to the attainment of the relevant ambient air quality standards, options to raise stack height and/or to further reduce emissions should be considered in the EA. Typical examples of GIIP stack heights are up to around 200m for large coal-fired power plants, up to around 80m for HFO-fueled diesel engine power plants, and up to 100m for gas-fired combined cycle gas turbine power plants. Final selection of the stack height will depend on the terrain of the surrounding areas, nearby buildings, meteorological conditions, predicted incremental impacts and the location of existing and future receptors. 5 For example, the US EPA Prevention of Significant Deterioration Increments Limits applicable to non-degraded airsheds provide the following: SO2 (91 μg/m3 for 2nd highest 24-hour, 20 μg/m3 for annual average), NO2 (20 μg/m3 for annual average), and PM10 (30 μg/m3 for 2nd highest 24-hour, and 17 μg/m3 for annual average).


DECEMBER 19, 2008 4

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• Use of fuels with a lower content of sulfur where

economically feasible;

• Use of lime (CaO) or limestone (CaCO3) in coal-fired fluidized

bed combustion boilers to have integrated desulfurization

which can achieve a removal efficiency of up to 80-90 %

through use of Fluidized Bed Combustion7, 8;

• Depending on the plant size, fuel quality, and potential for

significant emissions of SO2 , use of flue gas desulfurization

(FGD) for large boilers using coal or oil and for large

reciprocating engines . The optimal type of FGD system

(e.g., wet FGD using limestone with 85 to 98% removal

efficiency, dry FGD using lime with 70 to 94% removal

efficiency, seawater FGD with up to 90% removal efficiency)

depends on the capacity of the plant, fuel properties, site

conditions, and the cost and availability of reagent as well as

by-product disposal and utilization.9

Table 1 - Performance / Characteristics of FGDs Type of FGD

Characteristics Plant Capital Cost Increase

Wet FGD • Flue gas is saturated with water • Limestone (CaCO3) as reagent • Removal efficiency up to 98% • Use 1-1.5% of electricity generated • Most widely used • Distance to limestone source and

the limestone reactivity to be considered

• High water consumption • Need to treat wastewater • Gypsum as a saleable by-product

or waste

11-14%

Semi-Dry FGD

• Also called “Dry Scrubbing” – under controlled humidification.

• Lime (CaO) as reagent • Removal efficiency up to 94%

9-12%

6 Regenerative Flue Gas Desulfurization (FGD) options (either wet or semi-dray) may be considered under these conditions. 7 EC (2006). 8 The SO2 removal efficiency of FBC technologies depends on the sulfur and lime content of fuel, sorbent quantity, ratio, and quality. 9 The use of wet scrubbers, in addition to dust control equipment (e.g. ESP or Fabric Filter), has the advantage of also reducing emissions of HCl, HF, heavy metals, and further dust remaining after ESP or Fabric Filter. Because of higher costs, the wet scrubbing process is generally not used at plants with a capacity of less than 100 MWth (EC 2006).

• Can remove SO3 as well at higher removal rate than Wet FGD

• Use 0.5-1.0% of electricity generated, less than Wet FGD

• Lime is more expensive than limestone

• No wastewater • Waste – mixture of fly ash,

unreacted additive and CaSO3 Seawater FGD

• Removal efficiency up to 90% • Not practical for high S coal

(>1%S) • Impacts on marine environment

need to be carefully examined (e.g., reduction of pH, inputs of remaining heavy metals, fly ash, temperature, sulfate, dissolved oxygen, and chemical oxygen demand)

• Use 0.8-1.6% of electricity generated

• Simple process, no wastewater or solid waste,

7-10%

Sources: EC (2006) and World Bank Group.

Nitrogen Oxides Formation of nitrogen oxides can be controlled by modifying

operational and design parameters of the combustion process

(primary measures). Additional treatment of NOX from the flue

gas (secondary measures; see Table 2) may be required in some

cases depending on the ambient air quality objectives.

Recommended measures to prevent, minimize, and control NOX

emissions include:

• Use of low NOX burners with other combustion modifications,

such as low excess air (LEA) firing, for boiler plants.

Installation of additional NOX controls for boilers may be

necessary to meet emissions limits; a selective catalytic

reduction (SCR) system can be used for pulverized coal-

fired, oil-fired, and gas-fired boilers or a selective non-

catalytic reduction (SNCR) system for a fluidized-bed boiler;

• Use of dry low-NOX combustors for combustion turbines

burning natural gas;

• Use of water injection or SCR for combustion turbines and


DECEMBER 19, 2008 5

WORLD BANK GROUP

reciprocating engines burning liquid fuels;10

• Optimization of operational parameters for existing

reciprocating engines burning natural gas to reduce NOx

emissions;

• Use of lean-burn concept or SCR for new gas engines.

Table 2 - Performance / Characteristics of Secondary NOx Reduction Systems

Type Characteristics Plant Capital Cost Increase

SCR • NOx emission reduction rate of 80 – 95%

• Use 0.5% of electricity generated • Use ammonia or urea as reagent. • Ammonia slip increases with increasing

NH3/NOx ratio may cause a problem (e.g., too high ammonia in the fly ash). Larger catalyst volume / improving the mixing of NH3 and NOx in the flue gas may be needed to avoid this problem.

• Catalysts may contain heavy metals. Proper handling and disposal / recycle of spent catalysts is needed.

• Life of catalysts has been 6-10 years (coal-fired), 8-12 years (oil-fired) and more than 10 years (gas-fired).

4-9% (coal-fired boiler) 1-2% (gas-fired combined cycle gas turbine) 20-30% (reciprocating engines)

SNCR • NOx emission reduction rate of 30 – 50%

• Use 0.1-0.3% of electricity generated • Use ammonia or urea as reagent. • Cannot be used on gas turbines or gas

engines. • Operates without using catalysts.

1-2%

Source: EC (2006), World Bank Group

Particulate Matter Particulate matter11 is emitted from the combustion process,

especially from the use of heavy fuel oil, coal, and solid biomass.

The proven technologies for particulate removal in power plants

are fabric filters and electrostatic precipitators (ESPs), shown in

Table 3. The choice between a fabric filter and an ESP depends

on the fuel properties, type of FGD system if used for SO2 control,

10 Water injection may not be practical for industrial combustion turbines in all cases. Even if water is available, the facilities for water treatment and the operating and maintenance costs of water injection may be costly and may complicate the operation of a small combustion turbine.

and ambient air quality objectives. Particulate matter can also be

released during transfer and storage of coal and additives, such

as lime. Recommendations to prevent, minimize, and control

particulate matter emissions include:

• Installation of dust controls capable of over 99% removal

efficiency, such as ESPs or Fabric Filters (baghouses), for

coal-fired power plants. The advanced control for

particulates is a wet ESP, which further increases the

removal efficiency and also collects condensables (e.g.,

sulfuric acid mist) that are not effectively captured by an ESP

or a fabric filter;12

• Use of loading and unloading equipment that minimizes the

height of fuel drop to the stockpile to reduce the generation of

fugitive dust and installing of cyclone dust collectors;

• Use of water spray systems to reduce the formation of

fugitive dust from solid fuel storage in arid environments;

• Use of enclosed conveyors with well designed, extraction

and filtration equipment on conveyor transfer points to

prevent the emission of dust;

• For solid fuels of which fine fugitive dust could contain

vanadium, nickel and Polycyclic Aromatic Hydrocarbons

(PAHs) (e.g., in coal and petroleum coke), use of full

enclosure during transportation and covering stockpiles

where necessary;

• Design and operate transport systems to minimize the

generation and transport of dust on site;

• Storage of lime or limestone in silos with well designed,

extraction and filtration equipment;

• Use of wind fences in open storage of coal or use of

enclosed storage structures to minimize fugitive dust

11 Including all particle sizes (e.g. TSP, PM10, and PM2.5) 12 Flue gas conditioning (FGC) is a recommended approach to address the issue of low gas conductivity and lower ESP collection performance which occurs when ESPs are used to collect dust from very low sulfur fuels. One particular FGC design involves introduction of sulfur trioxide (SO3) gas into the flue gas upstream of the ESP, to increase the conductivity of the flue gas dramatically improve the ESP collection efficiency. There is typically no risk of increased SOx emissions as the SO3 is highly reactive and adheres to the dust.


DECEMBER 19, 2008 6

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emissions where necessary, applying special ventilation

systems in enclosed storage to avoid dust explosions (e.g.,

use of cyclone separators at coal transfer points).

See Annex 1.1.2 of the General EHS Guidelines for an additional

illustrative presentation of point source emissions prevention and

control technologies.

Table 3 – Performance / Characteristics of Dust Removal Systems

Type Performance / Characteristics ESP • Removal efficiency of >96.5% (<1 μm), >99.95%

(>10 μm) • 0.1-1.8% of electricity generated is used • It might not work on particulates with very high

electrical resistivity. In these cases, flue gas conditioning (FGC) may improve ESP performance.

• Can handle very large gas volume with low pressure drops

Fabric Filter • Removal efficiency of >99.6% (<1 μm), >99.95% (>10 μm). Removes smaller particles than ESPs.

• 0.2-3% of electricity generated is used • Filter life decreases as coal S content increases • Operating costs go up considerably as the fabric

filter becomes dense to remove more particles • If ash is particularly reactive, it can weaken the

fabric and eventually it disintegrates. Wet Scrubber • Removal efficiency of >98.5% (<1 μm), >99.9%

(>10 μm) • Up to 3% of electricity generated is used. • As a secondary effect, can remove and absorb

gaseous heavy metals • Wastewater needs to be treated

Sources: EC (2006) and World Bank Group.

Other Pollutants Depending on the fuel type and quality, other air pollutants may be

present in environmentally significant quantities requiring proper

consideration in the evaluation of potential impacts to ambient air

quality and in the design and implementation of management

actions and environmental controls. Examples of additional

pollutants include mercury in coal, vanadium in heavy fuel oil, and

other heavy metals present in waste fuels such as petroleum coke

(petcoke) and used lubricating oils13. Recommendations to

13 In these cases, the EA should address potential impacts to ambient air quality

prevent, minimize, and control emissions of other air pollutants

such as mercury in particular from thermal power plants include

the use of conventional secondary controls such as fabric filters or

ESPs operated in combination with FGD techniques, such as

limestone FGD, Dry Lime FGD, or sorbent injection.14 Additional

removal of metals such as mercury can be achieved in a high dust

SCR system along with powered activated carbon, bromine-

enhanced Powdered Activated Carbon (PAC) or other sorbents.

Since mercury emissions from thermal power plants pose

potentially significant local and transboundary impacts to

ecosystems and public health and safety through

bioaccumulation, particular consideration should be given to their

minimization in the environmental assessment and accordingly in

plant design.15

Emissions Offsets Facilities in degraded airsheds should minimize incremental

impacts by achieving emissions values outlined in Table 6. Where

these emissions values result nonetheless in excessive ambient

impacts relative to local regulatory standards (or in their absence,

other international recognized standards or guidelines, including

World Health Organization guidelines), the project should explore

and implement site-specific offsets that result in no net increase in

the total emissions of those pollutants (e.g., particulate matter,

sulfur dioxide, or nitrogen dioxide) that are responsible for the

degradation of the airshed. Offset provisions should be

implemented before the power plant comes fully on stream.

Suitable offset measures could include reductions in emissions of

particulate matter, sulfur dioxide, or nitrogen dioxide, as necessary

through (a) the installation of new or more effective controls at

other units within the same power plant or at other power plants in

for such heavy metals as mercury, nickel, vanadium, cadmium, lead, etc. 14 For Fabric Filters or Electrostatic Precipitators operated in combination with FGD techniques, an average removal rate of 75% or 90 % in the additional presence of SCR can be obtained (EC, 2006). 15 Although no major industrial country has formally adopted regulatory limits for mercury emissions from thermal power plants, such limitations where under consideration in the United States and European Union as of 2008. Future updates of these EHS Guidelines will reflect changes in the international state of


DECEMBER 19, 2008 7

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the same airshed, (b) the installation of new or more effective

controls at other large sources, such as district heating plants or

industrial plants, in the same airshed, or (c) investments in gas

distribution or district heating systems designed to substitute for

the use of coal for residential heating and other small boilers.

Wherever possible, the offset provisions should be implemented

within the framework of an overall air quality management strategy

designed to ensure that air quality in the airshed is brought into

compliance with ambient standards. The monitoring and

enforcement of ambient air quality in the airshed to ensure that

offset provisions are complied with would be the responsibility of

the local or national agency responsible for granting and

supervising environmental permits. Project sponsors who cannot

engage in the negotiations necessary to put together an offset

agreement (for example, due to the lack of the local or national air

quality management framework) should consider the option of

relying on an appropriate combination of using cleaner fuels, more

effective pollution controls, or reconsidering the selection of the

proposed project site. The overall objective is that the new

thermal power plants should not contribute to deterioration of the

already degraded airshed.

Energy Efficiency and GHG Emissions Carbon dioxide, one of the major greenhouse gases (GHGs)

under the UN Framework Convention on Climate Change, is

emitted from the combustion of fossil fuels. Recommendations to

avoid, minimize, and offset emissions of carbon dioxide from new

and existing thermal power plants include, among others:

• Use of less carbon intensive fossil fuels (i.e., less carbon

containing fuel per unit of calorific value -- gas is less than oil

and oil is less than coal) or co-firing with carbon neutral fuels

(i.e., biomass);

• Use of combined heat and power plants (CHP) where

feasible;

• Use of higher energy conversion efficiency technology of the

practice regarding mercury emissions prevention and control.

same fuel type / power plant size than that of the

country/region average. New facilities should be aimed to be

in top quartile of the country/region average of the same fuel

type and power plant size. Rehabilitation of existing facilities

must achieve significant improvements in efficiency. Typical

CO2 emissions performance of different fuels / technologies

are presented below in Table 4;

• Consider efficiency-relevant trade-offs between capital and

operating costs involved in the use of different technologies.

For example, supercritical plants may have a higher capital

cost than subcritical plants for the same capacity, but lower

operating costs. On the other hand, characteristics of

existing and future size of the grid may impose limitations in

plant size and hence technological choice. These tradeoffs

need to be fully examined in the EA;

• Use of high performance monitoring and process control

techniques, good design and maintenance of the combustion

system so that initially designed efficiency performance can

be maintained;

• Where feasible, arrangement of emissions offsets (including

the Kyoto Protocol’s flexible mechanisms and the voluntary

carbon market), including reforestation, afforestation, or

capture and storage of CO2 or other currently experimental

options16;

• Where feasible, include transmission and distribution loss

reduction and demand side measures. For example, an

investment in peak load management could reduce cycling

requirements of the generation facility thereby improving its

operating efficiency. The feasibility of these types of off-set

options may vary depending on whether the facility is part of

a vertically integrated utility or an independent power

producer;

• Consider fuel cycle emissions and off-site factors (e.g., fuel

16 The application of carbon capture and storage (CCS) from thermal power projects is still in experimental stages worldwide although consideration has started to be given to CCS-ready design. Several options are currently under evaluation including CO2 storage in coal seams or deep aquifers and oil reservoir injection for enhanced oil recovery.


DECEMBER 19, 2008 8

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supply, proximity to load centers, potential for off-site use of

waste heat, or use of nearby waste gases (blast furnace

gases or coal bed methane) as fuel. etc).

Table 4 - Typical CO2 Emissions Performance of New Thermal Power Plants

Fuel Efficiency CO2 (gCO2 / kWh – Gross)

Efficiency (% Net, HHV) Coal (*1, *2)

Ultra-Supercritical (*1): 37.6 – 42.7 Supercritical: 35.9-38.3 (*1) 39.1 (w/o CCS) (*2) 24.9 (with CCS) (*2) Subcritical: 33.1-35.9 (*1) 36.8 (w/o CCS) (*2) 24.9 (with CCS) (*2) IGCC: 39.2-41.8 (*1) 38.2–41.1 (w/o CCS) (*2) 31.7–32.5 (with CCS) (*2)

676-795

756-836

763 95

807-907

808 102

654-719

640 – 662 68 – 86

Gas (*2) Advanced CCGT (*2): 50.8 (w/o CCS) 43.7 (with CCS)

355 39

Efficiency (% Net, LHV) Coal (*3) 42 (Ultra-Supercritical)

40 (Supercritical) 30 – 38 (Subcritical) 46 (IGCC) 38 (IGCC+CCS)

811 851

896-1,050 760 134

Coal and Lignite (*4, *7)

(*4) 43-47 (Coal-PC) >41(Coal-FBC) 42-45 (Lignite-PC) >40 (Lignite-FBC)

(*6) 725-792 (Net) <831 (Net)

808-866 (Net) <909 (Net)

Gas (*4, *7)

(*4) 36–40 (Simple Cycle GT) 38-45 (Gas Engine) 40-42 (Boiler) 54-58 (CCGT)

(*6) 505-561 (Net) 531-449 (Net) 481-505 (Net) 348-374 (Net)

Oil (*4, *7)

(*4) 40 – 45 (HFO/LFO Reciprocating Engine)

(*6) 449-505 (Net)

Efficiency (% Gross, LHV) Coal (*5, *7)

(*5) 47 (Ultra-supercritical) 44 (Supercritical) 41-42 (Subcritical) 47-48 (IGCC)

(*6) 725 774

811-831 710-725

Oil (*5, *7)

(*5) 43 (Reciprocating Engine) 41 (Boiler)

(*6) 648 680

Gas (*5) (*5) 34 (Simple Cycle GT) 51 (CCGT)

(*6) 594 396

Source: (*1) US EPA 2006, (*2) US DOE/NETL 2007, (*3) World Bank, April 2006, (*4) European Commission 2006, (*5) World Bank Group, Sep 2006, (*6) World Bank Group estimates

Water Consumption and Aquatic Habitat Alteration Steam turbines used with boilers and heat recovery steam

generators(HRSG) used in combined cycle gas turbine units

require a cooling system to condense steam used to generate

electricity. Typical cooling systems used in thermal power plants

include: (i) once-through cooling system where sufficient cooling

water and receiving surface water are available; (ii) closed circuit

wet cooling system; and (iii) closed circuit dry cooling system

(e.g., air cooled condensers).

Combustion facilities using once-through cooling systems require

large quantities of water which are discharged back to receiving

surface water with elevated temperature. Water is also required

for boiler makeup, auxiliary station equipment, ash handling, and

FGD systems.17 The withdrawal of such large quantities of water

has the potential to compete with other important water uses such

as agricultural irrigation or drinking water sources. Withdrawal

and discharge with elevated temperature and chemical

contaminants such as biocides or other additives, if used, may

affect aquatic organisms, including phytoplankton, zooplankton,

fish, crustaceans, shellfish, and many other forms of aquatic life.

Aquatic organisms drawn into cooling water intake structures are

either impinged on components of the cooling water intake

structure or entrained in the cooling water system itself. In the

case of either impingement or entrainment, aquatic organisms

may be killed or subjected to significant harm. In some cases

(e.g., sea turtles), organisms are entrapped in the intake canals.

There may be special concerns about the potential impacts of

cooling water intake structures located in or near habitat areas

that support threatened, endangered, or other protected species

or where local fishery is active.

Conventional intake structures include traveling screens with

relative high through-screen velocities and no fish handling or

17 The availability of water and impact of water use may affect the choice of FGD


DECEMBER 19, 2008 9

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return system.18 Measures to prevent, minimize, and control

environmental impacts associated with water withdrawal should

be established based on the results of a project EA, considering

the availability and use of water resources locally and the

ecological characteristics of the project affected area.

Recommended management measures to prevent or control

impacts to water resources and aquatic habitats include19:

• Conserving water resources, particularly in areas with limited

water resources, by:

o Use of a closed-cycle, recirculating cooling water

system (e.g., natural or forced draft cooling tower), or

closed circuit dry cooling system (e.g., air cooled

condensers) if necessary to prevent unacceptable

adverse impacts. Cooling ponds or cooling towers are

the primary technologies for a recirculating cooling water

system. Once-through cooling water systems may be

acceptable if compatible with the hydrology and ecology

of the water source and the receiving water and may be

the preferred or feasible alternative for certain pollution

control technologies such as seawater scrubbers

o Use of dry scrubbers in situations where these controls

are also required or recycling of wastewater in coal-fired

plants for use as FGD makeup

o Use of air-cooled systems

• Reduction of maximum through-screen design intake velocity

to 0.5 ft/s;

• Reduction of intake flow to the following levels:

o For freshwater rivers or streams to a flow sufficient to

maintain resource use (i.e., irrigation and fisheries) as

well as biodiversity during annual mean low flow

conditions20

system used (i.e., wet vs. semi-dry). 18 The velocity generally considered suitable for the management of debris is 1 fps [0.30 m/s] with wide mesh screens; a standard mesh for power plants of 3/8 in (9.5 mm). 19 For additional information refer to Schimmoller (2004) and USEPA (2001). 20 Stream flow requirements may be based on mean annual flow or mean low flow. Regulatory requirements may be 5% or higher for mean annual flows and 10% to

o For lakes or reservoirs, intake flow must not disrupt the

thermal stratification or turnover pattern of the source

water

o For estuaries or tidal rivers, reduction of intake flow to

1% of the tidal excursion volume

• If there are threatened, endangered, or other protected

species or if there are fisheries within the hydraulic zone of

influence of the intake, reduction of impingement and

entrainment of fish and shellfish by the installation of

technologies such as barrier nets (seasonal or year-round),

fish handling and return systems, fine mesh screens,

wedgewire screens, and aquatic filter barrier systems.

Examples of operational measures to reduce impingement

and entrainment include seasonal shutdowns, if necessary,

or reductions in flow or continuous use of screens.

Designing the location of the intake structure in a different

direction or further out into the water body may also reduce

impingement and entrainment.

Effluents Effluents from thermal power plants include thermal discharges,

wastewater effluents, and sanitary wastewater.

Thermal Discharges As noted above, thermal power plants with steam-powered

generators and once-through cooling systems use significant

volume of water to cool and condense the steam for return to the

boiler. The heated water is normally discharged back to the

source water (i.e., river, lake, estuary, or the ocean) or the nearest

surface water body. In general, thermal discharge should be

designed to ensure that discharge water temperature does not

result in exceeding relevant ambient water quality temperature

standards outside a scientifically established mixing zone. The

mixing zone is typically defined as the zone where initial dilution of

a discharge takes place within which relevant water quality

25% for mean low flows. Their applicability should be verified on a site-specific


DECEMBER 19, 2008 10

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temperature standards are allowed to exceed and takes into

account cumulative impact of seasonal variations, ambient water

quality, receiving water use, potential receptors and assimilative

capacity among other considerations. Establishment of such a

mixing zone is project specific and may be established by local

regulatory agencies and confirmed or updated through the

project's environmental assessment process. Where no

regulatory standard exists, the acceptable ambient water

temperature change will be established through the environmental

assessment process. Thermal discharges should be designed to

prevent negative impacts to the receiving water taking into

account the following criteria:

• The elevated temperature areas because of thermal

discharge from the project should not impair the integrity of

the water body as a whole or endanger sensitive areas (such

as recreational areas, breeding grounds, or areas with

sensitive biota);

• There should be no lethality or significant impact to breeding

and feeding habits of organisms passing through the

elevated temperature areas;

• There should be no significant risk to human health or the

environment due to the elevated temperature or residual

levels of water treatment chemicals.

If a once-through cooling system is used for large projects (i.e., a

plant with > 1,200MWth steam generating capacity), impacts of

thermal discharges should be evaluated in the EA with a

mathematical or physical hydrodynamic plume model, which can

be a relatively effective method for evaluating a thermal discharge

to find the maximum discharge temperatures and flow rates that

would meet the environmental objectives of the receiving water.21

basis taking into consideration resource use and biodiversity requirements. 21 An example model is CORMIX (Cornell Mixing Zone Expert System) hydrodynamic mixing zone computer simulation, which has been developed by the U.S. Environmental Protection Agency. This model emphasizes predicting the site- and discharge-specific geometry and dilution characteristics to assess the environmental effects of a proposed discharge.

Recommendations to prevent, minimize, and control thermal

discharges include:

• Use of multi-port diffusers;

• Adjustment of the discharge temperature, flow, outfall

location, and outfall design to minimize impacts to acceptable

level (i.e., extend length of discharge channel before

reaching the surface water body for pre-cooling or change

location of discharge point to minimize the elevated

temperature areas);

• Use of a closed-cycle, recirculating cooling water system as

described above (e.g., natural or forced draft cooling tower),

or closed circuit dry cooling system (e.g., air cooled

condensers) if necessary to prevent unacceptable adverse

impacts. Cooling ponds or cooling towers are the primary

technologies for a recirculating cooling water system.

Liquid Waste The wastewater streams in a thermal power plant include cooling

tower blowdown; ash handling wastewater; wet FGD system

discharges; material storage runoff; metal cleaning wastewater;

and low-volume wastewater, such as air heater and precipitator

wash water, boiler blowdown, boiler chemical cleaning waste, floor

and yard drains and sumps, laboratory wastes, and backflush

from ion exchange boiler water purification units. All of these

wastewaters are usually present in plants burning coal or

biomass; some of these streams (e.g., ash handling wastewater)

may be present in reduced quantities or may not be present at all

in oil-fired or gas-fired power plants. The characteristics of the

wastewaters generated depend on the ways in which the water

has been used. Contamination arises from demineralizers;

lubricating and auxiliary fuel oils; trace contaminants in the fuel

(introduced through the ash-handling wastewater and wet FGD

system discharges); and chlorine, biocides, and other chemicals

used to manage the quality of water in cooling systems. Cooling

tower blowdown tends to be very high in total dissolved solids but

is generally classified as non-contact cooling water and, as such,



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is typically subject to limits for pH, residual chlorine, and toxic

chemicals that may be present in cooling tower additives

(including corrosion inhibiting chemicals containing chromium and

zinc whose use should be eliminated).

Recommended water treatment and wastewater conservation

methods are discussed in Sections 1.3 and 1.4, respectively, of

the General EHS Guidelines. In addition, recommended

measures to prevent, minimize, and control wastewater effluents

from thermal power plants include:

• Recycling of wastewater in coal-fired plants for use as FGD

makeup. This practice conserves water and reduces the

number of wastewater streams requiring treatment and

discharge22;

• In coal-fired power plants without FGD systems, treatment of

process wastewater in conventional physical-chemical

treatment systems for pH adjustment and removal of total

suspended solids (TSS), and oil / grease, at a minimum.

Depending on local regulations, these treatment systems can

also be used to remove most heavy metals to part-per-billion

(ppb) levels by chemical precipitation as either metal

hydroxide or metal organosulfide compounds;

• Collection of fly ash in dry form and bottom ash in drag chain

conveyor systems in new coal-fired power plants;

• Consider use of soot blowers or other dry methods to remove

fireside wastes from heat transfer surfaces so as to minimize

the frequency and amount of water used in fireside washes;

• Use of infiltration and runoff control measures such as

compacted soils, protective liners, and sedimentation

controls for runoff from coal piles;

• Spraying of coal piles with anionic detergents to inhibit

bacterial growth and minimize acidity of leachate;23

22 Suitable wastewater streams for reuse include gypsum wash water, which is a different wastewater stream than the FGD wastewater. In plants that produce marketable gypsum, the gypsum is rinsed to remove chloride and other undesirable trace elements. 23 If coal pile runoff will be used as makeup to the FGD system, anionic detergents

• Use of SOX removal systems that generate less wastewater,

if feasible; however, the environmental and cost

characteristics of both inputs and wastes should be assessed

on a case-by-case basis;

• Treatment of low-volume wastewater streams that are

typically collected in the boiler and turbine room sumps in

conventional oil-water separators before discharge;

• Treatment of acidic low-volume wastewater streams, such as

those associated with the regeneration of makeup

demineralizer and deep-bed condensate polishing systems,

by chemical neutralization in-situ before discharge;

• Pretreatment of cooling tower makeup water, installation of

automated bleed/feed controllers, and use of inert

construction materials to reduce chemical treatment

requirements for cooling towers;

• Elimination of metals such as chromium and zinc from

chemical additives used to control scaling and corrosion in

cooling towers;

• Use the minimum required quantities of chlorinated biocides

in place of brominated biocides or alternatively apply

intermittent shock dosing of chlorine as opposed to

continuous low level feed.

Sanitary Wastewater Sewage and other wastewater generated from washrooms, etc.

are similar to domestic wastewater. Impacts and management of

sanitary wastewater is addressed in Section 1.3 of the General EHS Guidelines.

Solid Wastes Coal-fired and biomass-fired thermal power plants generate the

greatest amount of solid wastes due to the relatively high

percentage of ash in the fuel.24 The large-volume coal

may increase or create foaming within the scrubber system. Therefore, use of anionic surfactants on coal piles should be evaluated on a case-by-case basis. 24 For example, a 500 MWe plant using coal with 2.5% sulfur (S), 16% ash, and 30,000 kilojoules per kilogram (kJ/kg) heat content will generate about 500 tons of



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combustion wastes (CCW) are fly ash, bottom ash, boiler slag,

and FGD sludge. Biomass contains less sulfur; therefore FGD

may not be necessary. Fluidized-bed combustion (FBC) boilers

generate fly ash and bottom ash, which is called bed ash. Fly ash

removed from exhaust gases makes up 60–85% of the coal ash

residue in pulverized-coal boilers and 20% in stoker boilers.

Bottom ash includes slag and particles that are coarser and

heavier than fly ash. Due to the presence of sorbent material,

FBC wastes have a higher content of calcium and sulfate and a

lower content of silica and alumina than conventional coal

combustion wastes. Low-volume solid wastes from coal-fired

thermal power plants and other plants include coal mill

rejects/pyrites, cooling tower sludge, wastewater treatment

sludge, and water treatment sludge.

Oil combustion wastes include fly ash and bottom ash and are

normally only generated in significant quantities when residual fuel

oil is burned in oil-fired steam electric boilers. Other technologies

(e.g., combustion turbines and diesel engines) and fuels (e.g.,

distillate oil) generate little or no solid wastes. Overall, oil

combustion wastes are generated in much smaller quantities than

the large-volume CCW discussed above. Gas-fired thermal power

plants generate essentially no solid waste because of the

negligible ash content, regardless of the combustion technology.

Metals are constituents of concern in both CCW and low-volume

solid wastes. For example, ash residues and the dust removed

from exhaust gases may contain significant levels of heavy metals

and some organic compounds, in addition to inert materials.

Ash residues are not typically classified as a hazardous waste due

to their inert nature.25 However, where ash residues are expected

to contain potentially significant levels of heavy metals,

radioactivity, or other potentially hazardous materials, they should

be tested at the start of plant operations to verify their

solid waste per day. 25 Some countries may categorize fly ash as hazardous due to the presence of arsenic or radioactivity, precluding its use as a construction material.

classification as hazardous or non-hazardous according to local

regulations or internationally recognized standards. Additional

information about the classification and management of

hazardous and non-hazardous wastes is presented in Section 1.6

of the General EHS Guidelines.

The high-volume CCWs wastes are typically managed in landfills

or surface impoundments or, increasingly, may be applied to a

variety of beneficial uses. Low-volume wastes are also managed

in landfills or surface impoundments, but are more frequently

managed in surface impoundments. Many coal-fired plants co-

manage large-volume and low-volume wastes.

Recommended measures to prevent, minimize, and control the

volume of solid wastes from thermal power plants include:

• Dry handling of the coal combustion wastes, in particular fly

ash. Dry handling methods do not involve surface

impoundments and, therefore, do not present the ecological

risks identified for impoundments (e.g., metal uptake by

wildlife);

• Recycling of CCWs in uses such as cement and other

concrete products, construction fills (including structural fill,

flowable fill, and road base), agricultural uses such as

calcium fertilizers (provided trace metals or other potentially

hazardous materials levels are within accepted thresholds),

waste management applications, mining applications,

construction materials (e.g., synthetic gypsum for

plasterboard), and incorporation into other products provided

the residues (such as trace metals and radioactivity) are not

considered hazardous. Ensuring consistent quality of fuels

and additives helps to ensure the CCWs can be recycled. If

beneficial reuse is not feasible, disposal of CCW in permitted

landfills with environmental controls such as run-on/run-off

controls, liners, leachate collection systems, ground-water

monitoring, closure controls, daily (or other operational)

cover, and fugitive dust controls is recommended;



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• Dry collection of bottom ash and fly ash from power plants

combusting heavy fuel oil if containing high levels of

economically valuable metals such as vanadium and recycle

for vanadium recovery (where economically viable) or

disposal in a permitted landfill with environmental controls;

• Management of ash disposal and reclamation so as to

minimize environmental impacts – especially the migration of

toxic metals, if present, to nearby surface and groundwater

bodies, in addition to the transport of suspended solids in

surface runoff due to seasonal precipitation and flooding. In

particular, construction, operation, and maintenance of

surface impoundments should be conducted in accordance

with internationally recognized standards.26, 27

• Reuse of sludge from treatment of waste waters from FGD

plants. This sludge may be re-used in the FGD plant due to

the calcium components. It can also be used as an additive

in coal-fired plant combustion to improve the ash melting

behavior

Hazardous Materials and Oil Hazardous materials stored and used at combustion facilities

include solid, liquid, and gaseous waste-based fuels; air, water,

and wastewater treatment chemicals; and equipment and facility

maintenance chemicals (e.g., paint certain types of lubricants, and

cleaners). Spill prevention and response guidance is addressed

in Sections 1.5 and 3.7 of the General EHS Guidelines.

In addition, recommended measures to prevent, minimize, and

control hazards associated with hazardous materials storage and

handling at thermal power plants include the use of double-walled,

underground pressurized tanks for storage of pure liquefied

ammonia (e.g., for use as reagent for SCR) in quantities over 100

26 See, for example, U.S. Department of Labor, Mine Safety and Health Administration regulations at 30 CFR §§ 77.214 - 77.216. 27 Additional detailed guidance applicable to the prevention and control of impacts to soil and water resources from non-hazardous and hazardous solid waste disposal is presented in the World Bank Group EHS Guidelines for Waste Management Facilities.

m3; tanks of lesser capacity should be manufactured using

annealing processes (EC 2006).

Noise Principal sources of noise in thermal power plants include the

turbine generators and auxiliaries; boilers and auxiliaries, such as

coal pulverizers; reciprocating engines; fans and ductwork;

pumps; compressors; condensers; precipitators, including rappers

and plate vibrators; piping and valves; motors; transformers;

circuit breakers; and cooling towers. Thermal power plants used

for base load operation may operate continually while smaller

plants may operate less frequently but still pose a significant

source of noise if located in urban areas.

Noise impacts, control measures, and recommended ambient

noise levels are presented in Section 1.7 of the General EHS Guidelines. Additional recommended measures to prevent,

minimize, and control noise from thermal power plants include:

• Siting new facilities with consideration of distances from the

noise sources to the receptors (e.g., residential receptors,

schools, hospitals, religious places) to the extent possible. If

the local land use is not controlled through zoning or is not

effectively enforced, examine whether residential receptors

could come outside the acquired plant boundary. In some

cases, it could be more cost effective to acquire additional

land as buffer zone than relying on technical noise control

measures, where possible;

• Use of noise control techniques such as: using acoustic

machine enclosures; selecting structures according to their

noise isolation effect to envelop the building; using mufflers

or silencers in intake and exhaust channels; using sound-

absorptive materials in walls and ceilings; using vibration

isolators and flexible connections (e.g., helical steel springs

and rubber elements); applying a carefully detailed design to

prevent possible noise leakage through openings or to

minimize pressure variations in piping;



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• Modification of the plant configuration or use of noise barriers

such as berms and vegetation to limit ambient noise at plant

property lines, especially where sensitive noise receptors

may be present.

Noise propagation models may be effective tools to help evaluate

noise management options such as alternative plant locations,

general arrangement of the plant and auxiliary equipment, building

enclosure design, and, together with the results of a baseline

noise assessment, expected compliance with the applicable

community noise requirements.

1.2 Occupational Health and Safety

Occupational health and safety risks and mitigation measures

during construction, operation, and decommissioning of thermal

power plants are similar to those at other large industrial facilities,

and are addressed in Section 2.0 of the General EHS Guidelines. In addition, the following health and safety impacts

are of particular concern during operation of thermal power plants:

• Non-ionizing radiation

• Heat

• Noise

• Confined spaces

• Electrical hazards

• Fire and explosion hazards

• Chemical hazards

• Dust

Non-ionizing radiation Combustion facility workers may have a higher exposure to

electric and magnetic fields (EMF) than the general public due to

working in proximity to electric power generators, equipment, and

connecting high-voltage transmission lines. Occupational EMF

exposure should be prevented or minimized through the

preparation and implementation of an EMF safety program

including the following components:

• Identification of potential exposure levels in the workplace,

including surveys of exposure levels in new projects and the

use of personal monitors during working activities;

• Training of workers in the identification of occupational EMF

levels and hazards;

• Establishment and identification of safety zones to

differentiate between work areas with expected elevated

EMF levels compared to those acceptable for public

exposure, limiting access to properly trained workers;

• Implementation of action plans to address potential or

confirmed exposure levels that exceed reference

occupational exposure levels developed by international

organizations such as the International Commission on Non-

Ionizing Radiation Protection (ICNIRP), the Institute of

Electrical and Electronics Engineers (IEEE).28 Personal

exposure monitoring equipment should be set to warn of

exposure levels that are below occupational exposure

reference levels (e.g., 50 percent). Action plans to address

occupational exposure may include limiting exposure time

through work rotation, increasing the distance between the

source and the worker, when feasible, or the use of shielding

materials.

Heat Occupational exposure to heat occurs during operation and

maintenance of combustion units, pipes, and related hot

equipment. Recommended prevention and control measures to

address heat exposure at thermal power plants include:

• Regular inspection and maintenance of pressure vessels and

piping;

• Provision of adequate ventilation in work areas to reduce

heat and humidity;

28 The ICNIRP exposure guidelines for Occupational Exposure are listed in Section 2.2 of this Guideline.



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• Reducing the time required for work in elevated temperature

environments and ensuring access to drinking water;

• Shielding surfaces where workers come in close contact with

hot equipment, including generating equipment, pipes etc;

• Use of warning signs near high temperature surfaces and

personal protective equipment (PPE) as appropriate,

including insulated gloves and shoes.

Noise Noise sources in combustion facilities include the turbine

generators and auxiliaries; boilers and auxiliaries, such as

pulverizers; diesel engines; fans and ductwork; pumps;

compressors; condensers; precipitators, including rappers and

plate vibrators; piping and valves; motors; transformers; circuit

breakers; and cooling towers. Recommendations for reducing

noise and vibration are discussed in Section 1.1, above. In

addition, recommendations to prevent, minimize, and control

occupational noise exposures in thermal power plants include:

• Provision of sound-insulated control rooms with noise levels

below 60 dBA29;

• Design of generators to meet applicable occupational noise

levels;

• Identify and mark high noise areas and require that personal

noise protecting gear is used all the time when working in

such high noise areas (typically areas with noise levels >85

dBA).

Confined Spaces Specific areas for confined space entry may include coal ash

containers, turbines, condensers, and cooling water towers

29 Depending on the type and size of the thermal power plants, distance between control room and the noise emitting sources differs. CSA Z107.58 provides design guidelines for control rooms as 60 dBA. Large thermal power plants using steam boilers or combustion turbines tend to be quieter than 60 dBA. Reciprocating engine manufacturers recommend 65 to 70 dBA instead of 60 dBA (Euromot Position as of 9 May 2008). This guideline recommends 60 dBA as GIIP, with an understanding that up to 65 dBA can be accepted for reciprocating engine power plants if 60 dBA is economically difficult to achieve.

(during maintenance activities). Recommend confined space

entry procedures are discussed in Section 2.8 of the General EHS Guidelines.

Electrical Hazards Energized equipment and power lines can pose electrical hazards

for workers at thermal power plants. Recommended measures to

prevent, minimize, and control electrical hazards at thermal power

plants include:

• Consider installation of hazard warning lights inside electrical

equipment enclosures to warn of inadvertent energization;

• Use of voltage sensors prior to and during workers' entrance

into enclosures containing electrical components;

• Deactivation and proper grounding of live power equipment

and distribution lines according to applicable legislation and

guidelines whenever possible before work is performed on or

proximal to them;

• Provision of specialized electrical safety training to those

workers working with or around exposed components of

electric circuits. This training should include, but not be

limited to, training in basic electrical theory, proper safe work

procedures, hazard awareness and identification, proper use

of PPE, proper lockout/tagout procedures, first aid including

CPR, and proper rescue procedures. Provisions should be

made for periodic retraining as necessary.

Fire and Explosion Hazards Thermal power plants store, transfer, and use large quantities of

fuels; therefore, careful handling is necessary to mitigate fire and

explosion risks. In particular, fire and explosion hazards increase

as the particle size of coal is reduced. Particle sizes of coal that

can fuel a propagating explosion occur within thermal dryers,

cyclones, baghouses, pulverized-fuel systems, grinding mills, and

other process or conveyance equipment. Fire and explosion

prevention management guidance is provided in Section 2.1 and



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2.4 of the General EHS Guidelines. Recommended measures to

prevent, minimize, and control physical hazards at thermal power

plants include:

• Use of automated combustion and safety controls;

• Proper maintenance of boiler safety controls;

• Implementation of startup and shutdown procedures to

minimize the risk of suspending hot coal particles (e.g., in the

pulverizer, mill, and cyclone) during startup;

• Regular cleaning of the facility to prevent accumulation of

coal dust (e.g., on floors, ledges, beams, and equipment);

• Removal of hot spots from the coal stockpile (caused by

spontaneous combustion) and spread until cooled, never

loading hot coal into the pulverized fuel system;

• Use of automated systems such as temperature gauges or

carbon monoxide sensors to survey solid fuel storage areas

to detect fires caused by self-ignition and to identify risk

points.

Chemical Hazards Thermal power plants utilize hazardous materials, including

ammonia for NOX control systems, and chlorine gas for treatment

of cooling tower and boiler water. Guidance on chemical hazards

management is provided in Section 2.4 of the General EHS Guidelines. Additional, recommended measures to prevent,

minimize, and control physical hazards at thermal power plants

include:

• Consider generation of ammonia on site from urea or use of

aqueous ammonia in place of pure liquefied ammonia;

• Consider use of sodium hypochlorite in place of gaseous

chlorine.

Dust Dust is generated in handing solid fuels, additives, and solid

wastes (e.g., ash). Dust may contain silica (associated with

silicosis), arsenic (skin and lung cancer), coal dust (black lung),

and other potentially harmful substances. Dust management

guidance is provided in the Section 2.1 and 2.4 of the General EHS Guidelines. Recommended measures to prevent, minimize,

and control occupational exposure to dust in thermal power plants

include:

• Use of dust controls (e.g., exhaust ventilation) to keep dust

below applicable guidelines (see Section 2) or wherever free

silica levels in airborne dust exceed 1 percent;

• Regular inspection and maintenance of asbestos containing

materials (e.g., insulation in older plants may contain

asbestos) to prevent airborne asbestos particles.

1.3 Community Health and Safety

Many community health and safety impacts during the

construction, operation, and decommissioning of thermal power

plant projects are common to those of most infrastructure and

industrial facilities and are discussed in Section 3.0 the General EHS Guidelines. In addition to these and other aspects covered

in Section 1.1, the following community health and safety impacts

may be of particular concern for thermal power plant projects:

• Water Consumption;

• Traffic Safety.

Water Consumption Boiler units require large amounts of cooling water for steam

condensation and efficient thermal operation. The cooling water

flow rate through the condenser is by far the largest process water

flow, normally equating to about 98 percent of the total process

water flow for the entire unit. In a once-through cooling water

system, water is usually taken into the plant from surface waters,

but sometimes ground waters or municipal supplies are used.

The potential effects of water use should be assessed, as

discussed in Section 3.1 of the General EHS Guidelines, to



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ensure that the project does not compromise the availability of

water for personal hygiene, agriculture, recreation, and other

community needs.

Traffic Safety Operation of a thermal power plant will increase traffic volume, in

particular for facilities with fuels transported via land and sea,

including heavy trucks carrying fuel, additives, etc. The increased

traffic can be especially significant in sparsely populate areas

where some thermal power plants are located. Prevention and

control of traffic-related injuries are discussed in Section 3.4 of the

General EHS Guidelines. Water transport safety is covered in

the EHS Guidelines for Shipping.



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2.0 Performance Indicators and Monitoring

2.1 Environment

Emissions and Effluent Guidelines Effluent guidelines are described in Table 5. Emissions guidelines

are described in Table 6. Effluent guidelines are applicable for

direct discharges of treated effluents to surface waters for general

use. Site-specific discharge levels may be established based on

the availability and conditions in the use of publicly operated

sewage collection and treatment systems or, if discharged directly

to surface waters, on the receiving water use classification as

described in the General EHS Guideline. Guideline values for

process emissions and effluents in this sector are indicative of

good international industry practice as reflected in standards of

countries with recognized regulatory frameworks. These levels

should be achieved, without dilution, at least 95 percent of the

time that the plant or unit is operating, to be calculated as a

proportion of annual operating hours. Deviation from these levels

due to specific local project conditions should be justified in the

environmental assessment.

Table 5 - Effluent Guidelines (To be applicable at relevant wastewater stream: e.g., from FGD

system, wet ash transport, washing boiler / air preheater and precipitator, boiler acid washing, regeneration of demineralizers

and condensate polishers, oil-separated water, site drainage, coal pile runoff, and cooling water)

Parameter mg/L, except pH and temp pH 6 – 9 TSS 50 Oil and grease 10 Total residual chlorine

0.2

Chromium - Total (Cr)

0.5

Copper (Cu) 0.5 Iron (Fe) 1.0 Zinc (Zn) 1.0 Lead (Pb) 0.5 Cadmium (Cd) 0.1 Mercury (Hg) 0.005 Arsenic (As) 0.5 Temperature increase by thermal discharge from cooling system

• Site specific requirement to be established by the EA.

• Elevated temperature areas due to discharge of once-through cooling water (e.g., 1 Celsius above, 2 Celsius above, 3 Celsius above ambient water temperature) should be minimized by adjusting intake and outfall design through the project specific EA depending on the sensitive aquatic ecosystems around the discharge point.

Note: Applicability of heavy metals should be determined in the EA. Guideline limits in the Table are from various references of effluent performance by thermal power plants.

Emissions levels for the design and operation of each project

should be established through the EA process on the basis of

country legislation and the recommendations provided in this

guidance document, as applied to local conditions. The emissions

levels selected should be justified in the EA.30 The maximum

emissions levels given here can be consistently achieved by well-

designed, well-operated, and well-maintained pollution control

systems. In contrast, poor operating or maintenance procedures

affect actual pollutant removal efficiency and may reduce it to well

30 For example, in cases where potential for acid deposition has been identified as a significant issue in the EA, plant design and operation should ensure that emissions mass loadings are effectively reduced to prevent or minimize such impacts.



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below the design specification. Dilution of air emissions to

achieve these guidelines is unacceptable. Compliance with

ambient air quality guidelines should be assessed on the basis of

good international industry practice (GIIP) recommendations.

As described in the General EHS Guidelines, emissions should

not result in pollutant concentrations that reach or exceed relevant

ambient quality guidelines and standards31 by applying national

legislated standards, or in their absence, the current WHO Air

Quality Guidelines32, or other internationally recognized sources33.

Also, emissions from a single project should not contribute more

than 25% of the applicable ambient air quality standards to allow

additional, future sustainable development in the same airshed. 34

As described in the General EHS Guidelines, facilities or projects

located within poor quality airsheds35, and within or next to areas

established as ecologically sensitive (e.g., national parks), should

ensure that any increase in pollution levels is as small as feasible,

and amounts to a fraction of the applicable short-term and annual

average air quality guidelines or standards as established in the

project-specific environmental assessment.

Environmental Monitoring Environmental monitoring programs for this sector are presented

in Table 7. Monitoring data should be analyzed and reviewed at

regular intervals and compared with the operating standards so

31 Ambient air quality standards are ambient air quality levels established and published through national legislative and regulatory processes, and ambient quality guidelines refer to ambient quality levels primarily developed through clinical, toxicological, and epidemiological evidence (such as those published by the World Health Organization). 32 Available at World Health Organization (WHO). http://www.who.int/en 33 For example the United States National Ambient Air Quality Standards (NAAQS) (http://www.epa.gov/air/criteria.html) and the relevant European Council Directives (Council Directive 1999/30/EC of 22 April 1999 / Council Directive 2002/3/EC of February 12 2002). 34 US EPA Prevention of Significant Deterioration Increments Limits applicable to non-degraded airsheds. 35 An airshed should be considered as having poor air quality if nationally legislated air quality standards or WHO Air Quality Guidelines are exceeded significantly.

that any necessary corrective actions can be taken. Examples of

emissions, stack testing, ambient air quality, and noise monitoring

recommendations applicable to power plants are provided in

Table 7. Additional guidance on applicable sampling and

analytical methods for emissions and effluents is provided in the

General EHS Guidelines.



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Table 6 (A) - Emissions Guidelines (in mg/Nm3 or as indicated) for Reciprocating Engine Note:

- Guidelines are applicable for new facilities. - EA may justify more stringent or less stringent limits due to ambient environment, technical and economic considerations provided there is compliance with applicable ambient air

quality standards and incremental impacts are minimized. - For projects to rehabilitate existing facilities, case-by-case emission requirements should be established by the EA considering (i) the existing emission levels and impacts on the

environment and community health, and (ii) cost and technical feasibility of bringing the existing emission levels to meet these new facilities limits. - EA should demonstrate that emissions do not contribute a significant portion to the attainment of relevant ambient air quality guidelines or standards, and more stringent limits may be

required. Combustion Technology / Fuel Particulate

Matter (PM) Sulfur Dioxide (SO2) Nitrogen Oxides (NOx) Dry Gas, Excess O2 Content (%)

Reciprocating Engine NDA DA NDA DA NDA DA

Natural Gas N/A N/A N/A N/A 200 (Spark Ignition) 400 (Dual Fuel) (a)

200(SI) 400 (Dual Fuel / CI)

15%

Liquid Fuels (Plant >50 MWth to <300 MWth) 50 30 1,170 or use of 2% or less S fuel

0.5% S 1,460 (Compression Ignition, bore size diameter [mm] < 400) 1,850 (Compression Ignition, bore size diameter [mm] ≥ 400) 2,000 (Dual Fuel)

400 15%

Liquid Fuels (Plant >/=300 MWth) 50 30 585 or use of 1% or less S fuel

0.2% S 740 (contingent upon water availability for injection) 400 15%

Biofuels / Gaseous Fuels other than Natural Gas 50 30 N/A N/A 30% higher limits than those provided above for Natural Gas and Liquid Fuels.

200 (SI, Natural Gas), 400 (other)

15%

General notes: - MWth = Megawatt thermal input on HHV basis; N/A = not applicable; NDA = Non-degraded airshed; DA = Degraded airshed (poor air quality); Airshed should be considered as being degraded if

nationally legislated air quality standards are exceeded or, in their absence, if WHO Air Quality Guidelines are exceeded significantly; S = sulfur content (expressed as a percent by mass); Nm3 is at one atmospheric pressure, 0 degree Celsius; MWth category is to apply to the entire facility consisting of multiple units that are reasonably considered to be emitted from a common stack. Guideline limits apply to facilities operating more than 500 hours per year. Emission levels should be evaluated on a one hour average basis and be achieved 95% of annual operating hours.

- (a) Compression Ignition (CI) engines may require different emissions values which should be evaluated on a case-by-case basis through the EA process. Comparison of the Guideline limits with standards of selected countries / region (as of August 2008):

- Natural Gas-fired Reciprocating Engine – NOx o Guideline limits: 200 (SI), 400 (DF) o UK: 100 (CI) , US: Reduce by 90% or more, or alternatively 1.6 g/kWh

- Liquid Fuels-fired Reciprocating Engine – NOx (Plant >50 MWth to <300 MWth) o Guideline limits: 1,460 (CI, bore size diameter < 400 mm), 1,850 (CI, bore size diameter ≥ 400 mm), 2,000 (DF) o UK: 300 (> 25 MWth), India: 1,460 (Urban area & ≤ 75 MWe (≈ 190 MWth), Rural area & ≤ 150 MWe (≈ 380 MWth))

- Liquid Fuels-fired Reciprocating Engine – NOx (Plant ≥300 MWth) o Guideline limits: 740 (contingent upon water availability for injection) o UK: 300 (> 25 MWth), India: 740 (Urban area & > 75MWe (≈ 190 MWth), Rural area & > 150 MWe (≈ 380 MWth))

- Liquid Fuels-fired Reciprocating Engine – SO2 o Guideline limits: 1,170 or use of ≤ 2% S (Plant >50 MWth to <300 MWth), 585 or use of ≤ 1% S (Plant ≥300 MWth) o EU: Use of low S fuel oil or the secondary FGD (IPCC LCP BREF), HFO S content ≤ 1% (Liquid Fuel Quality Directive), US: Use of diesel fuel with max S of 500 ppm (0.05%); EU: Marine

HFO S content ≤ 1.5% (Liquid Fuel Quality Directive) used in SOx Emission Control Areas; India: Urban (< 2% S), Rural (< 4%S), Only diesel fuels (HSD, LDO) should be used in Urban Source: UK (S2 1.03 Combustion Processes: Compression Ignition Engines, 50 MWth and over), India (SOx/NOx Emission Standards for Diesel Engines ≥ 0.8 MW), EU (IPCC LCP BREF July 2006), EU (Liquid Fuel Quality Directive 1999/32/EC amended by 2005/33/EC), US (NSPS for Stationary Compression Ignition Internal Combustion Engine – Final Rule – July 11, 2006)



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Table 6 (B) - Emissions Guidelines (in mg/Nm3 or as indicated) for Combustion Turbine Note:

- Guidelines are applicable for new facilities. - EA may justify more stringent or less stringent limits due to ambient environment, technical and economic considerations provided there is compliance with

applicable ambient air quality standards and incremental impacts are minimized. - For projects to rehabilitate existing facilities, case-by-case emission requirements should be established by the EA considering (i) the existing emission levels and

impacts on the environment and community health, and (ii) cost and technical feasibility of bringing the existing emission levels to meet these new facilities limits. - EA should demonstrate that emissions do not contribute a significant portion to the attainment of relevant ambient air quality guidelines or standards, and more

stringent limits may be required. Combustion Technology / Fuel Particulate


Combustion Turbine NDA/DA NDA/DA

Natural Gas (all turbine types of Unit > 50MWth) N/A N/A N/A N/A 51 (25 ppm) 15%

Fuels other than Natural Gas (Unit > > 50MWth) 50 30 Use of 1% or

less S fuel Use of 0.5% or less S fuel

152 (74 ppm)a 15%


nationally legislated air quality standards are exceeded or, in their absence, if WHO Air Quality Guidelines are exceeded significantly; S = sulfur content (expressed as a percent by mass); Nm3 is at one atmospheric pressure, 0 degree Celsius; MWth category is to apply to single units; Guideline limits apply to facilities operating more than 500 hours per year. Emission levels should be evaluated on a one hour average basis and be achieved 95% of annual operating hours.

- If supplemental firing is used in a combined cycle gas turbine mode, the relevant guideline limits for combustion turbines should be achieved including emissions from those supplemental firing units (e.g., duct burners).

- (a) Technological differences (for example the use of Aeroderivatives) may require different emissions values which should be evaluated on a cases-by-case basis through the EA process but which should not exceed 200 mg/Nm3.

Comparison of the Guideline limits with standards of selected countries / region (as of August 2008): - Natural Gas-fired Combustion Turbine – NOx

o Guideline limits: 51 (25 ppm) o EU: 50 (24 ppm), 75 (37 ppm) (if combined cycle efficiency > 55%), 50*η / 35 (where η = simple cycle efficiency) o US: 25 ppm (> 50 MMBtu/h (≈ 14.6 MWth) and ≤ 850 MMBtu/h (≈ 249MWth)), 15 ppm (> 850 MMBtu/h (≈ 249 MWth)) o (Note: further reduced NOx ppm in the range of 2 to 9 ppm is typically required through air permit)

- Liquid Fuel-fired Combustion Turbine – NOx o Guideline limits: 152 (74 ppm) – Heavy Duty Frame Turbines & LFO/HFO, 300 (146 ppm) – Aeroderivatives & HFO, 200 (97 ppm) – Aeroderivatives & LFO o EU: 120 (58 ppm), US: 74 ppm (> 50 MMBtu/h (≈ 14.6 MWth) and ≤ 850 MMBtu/h (≈ 249MWth)), 42 ppm (> 850 MMBtu/h (≈ 249 MWth))

- Liquid Fuel-fired Combustion Turbine – SOx o Guideline limits: Use of 1% or less S fuel o EU: S content of light fuel oil used in gas turbines below 0.1% / US: S content of about 0.05% (continental area) and 0.4% (non-continental area)

Source: EU (LCP Directive 2001/80/EC October 23 2001), EU (Liquid Fuel Quality Directive 1999/32/EC, 2005/33/EC), US (NSPS for Stationary Combustion Turbines, Final Rule – July 6, 2006)



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Table 6 (C) - Emissions Guidelines (in mg/Nm3 or as indicated) for Boiler Note:

- Guidelines are applicable for new facilities. - EA may justify more stringent or less stringent limits due to ambient environment, technical and economic considerations provided there is compliance with

applicable ambient air quality standards and incremental impacts are minimized. - For projects to rehabilitate existing facilities, case-by-case emission requirements should be established by the EA considering (i) the existing emission levels and

impacts on the environment and community health, and (ii) cost and technical feasibility of bringing the existing emission levels to meet these new facilities limits. - EA should demonstrate that emissions do not contribute a significant portion to the attainment of relevant ambient air quality guidelines or standards, and more

stringent limits may be required. Combustion Technology / Fuel Particulate


Boiler NDA DA NDA DA NDA DA Natural Gas N/A N/A N/A N/A 240 240 3% Other Gaseous Fuels 50 30 400 400 240 240 3%

Liquid Fuels (Plant >50 MWth to <600 MWth) 50 30 900 – 1,500a 400 400 200 3%

Liquid Fuels (Plant >/=600 MWth) 50 30 200 – 850b 200 400 200 3%

Solid Fuels (Plant >50 MWth to <600 MWth) 50 30 900 – 1,500a 400 6%

Solid Fuels (Plant >/=600 MWth) 50 30 200 – 850b 200

510c

Or up to 1,100 if volatile matter of fuel < 10% 200 6%


nationally legislated air quality standards are exceeded or, in their absence, if WHO Air Quality Guidelines are exceeded significantly; CFB = circulating fluidized bed coal-fired; PC = pulverized coal-fired; Nm3 is at one atmospheric pressure, 0 degree Celsius; MWth category is to apply to the entire facility consisting of multiple units that are reasonably considered to be emitted from a common stack. Guideline limits apply to facilities operating more than 500 hours per year. Emission levels should be evaluated on a one hour average basis and be achieved 95% of annual operating hours.

- a. Targeting the lower guidelines values and recognizing issues related to quality of available fuel, cost effectiveness of controls on smaller units, and the potential for higher energy conversion efficiencies (FGD may consume between 0.5% and 1.6% of electricity generated by the plant). b. Targeting the lower guidelines values and recognizing variability in approaches to the management of SO2 emissions (fuel quality vs. use of secondary controls) and the potential for higher energy conversion efficiencies (FGD may consume between 0.5% and 1.6% of electricity generated by the plant). Larger plants are expected to have additional emission control measures. Selection of the emission level in the range is to be determined by EA considering the project’s sustainability, development impact, and cost-benefit of the pollution control performance. c. Stoker boilers may require different emissions values which should be evaluated on a case-by-case basis through the EA process.

Comparison of the Guideline limits with standards of selected countries / region (as of August 2008): - Natural Gas-fired Boiler – NOx

o Guideline limits: 240 o EU: 150 (50 to 300 MWth), 200 (> 300 MWth)

- Solid Fuels-fired Boiler - PM o Guideline limits: 50 o EU: 50 (50 to 100 MWth), 30 (> 100 MWth), China: 50, India: 100 - 150

- Solid Fuels-fired Boiler – SO2 o Guideline limits: 900 – 1,500 (Plant > 50 MWth to < 600 MWth), 200 – 850 (Plant ≥ 600 MWth) o EU: 850 (50 – 100 MWth), 200 (> 100 MWth) o US: 180 ng/J gross energy output OR 95% reduction (≈ 200 mg/Nm3 at 6%O2 assuming 38% HHV efficiency) o China: 400 (general), 800 (if using coal < 12,550 kJ/kg), 1,200 (if mine-mouth plant located in non-double control area of western region and burning low S coal (<0.5%))

Source: EU (LCP Directive 2001/80/EC October 23 2001), US (NSPS for Electric Utility Steam Generating Units (Subpart Da), Final Rule – June 13, 2007), China (GB 13223-2003)



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Table 7 – Typical Air Emission Monitoring Parameters / Frequency for Thermal Power Plants (Note: Detailed monitoring programs should be determined based on EA)

Emission Monitoring Stack Emission Testing Combustion Technology / Fuel Particulate

Matter (PM) Sulfur Dioxide

(SO2) Nitrogen Oxides

(NOx) PM SO2 NOx Heavy Metals Ambient Air Quality Noise

Reciprocating Engine Natural Gas (Plant >50 MWth to <300 MWth)

N/A N/A Continuous or indicative

N/A N/A Annual N/A

Natural Gas (Plant >/= 300 MWth)

N/A N/A Continuous N/A N/A Annual N/A

Liquid (Plant >50 MWth to <300 MWth)

Continuous or indicative


Liquid (Plant >/=300 MWth) Continuous or indicative

Continuous if FGD is used or monitor by S content.

Continuous

Annual

Biomass Continuous or indicative

N/A Continuous or indicative

Annual N/A Annual N/A

Combustion Turbine Natural Gas (all turbine types of Unit > 50MWth)

N/A N/A Continuous or indicative

N/A N/A Annual N/A

Fuels other than Natural Gas (Unit > 50MWth)



Continuous or indicative Annual

Boiler

N/A N/A Annual N/A Natural Gas N/A N/A Continuous or

indicative Annual Annual Annual N/A

Other Gaseous fuels Indicative Indicative Continuous or indicative

Liquid (Plant >50 MWth to <600 MWth)



Liquid (Plant >=600 MWth) Continuous

Solid (Plant >50 MWth to <600 MWth)

Continuous if FGD is used or monitor by S Content.


Solid (Plant >/=600 MWth)


Continuous

Annual

If incremental impacts predicted by EA >/= 25 % of relevant short-term ambient air quality standards or if the plant >/= 1,200 MWth: - Monitor parameters (e.g., PM10/PM2.5/SO2/NOx to be consistent with the relevant ambient air quality standards) by continuous ambient air quality monitoring system (typically a minimum of 2 systems to cover predicted maximum ground level concentration point / sensitive receptor / background point).

If incremental impacts predicted by EA < 25% of relevant short term ambient air quality standards and if the facility < 1,200 MWth but >/= 100 MWth - Monitor parameters either by passive samplers (monthly average) or by seasonal manual sampling (e.g., 1 weeks/season) for parameters consistent with the relevant air quality standards.

Effectiveness of the ambient air quality monitoring program should be reviewed regularly. It could be simplified or reduced if alternative program is developed (e.g., local government’s monitoring network). Continuation of the program is recommended during the life of the project if there are sensitive receptors or if monitored levels are not far below the relevant ambient air quality standards.

If EA predicts noise levels at residential receptors or other sensitive receptors are close to the relevant ambient noise standards / guidelines, or if there are such receptors close to the plant boundary (e.g., within 100m) then, conduct ambient noise monitoring every year to three years depending on the project circumstances.

Elimination of noise monitoring can be considered acceptable if a comprehensive survey showed that there are no receptors affected by the project or affected noise levels are far below the relevant ambient noise standards / guidelines.

Note: Continuous or indicative means “Continuously monitor emissions or continuously monitor indicative parameters”. Stack emission testing is to have direct measurement of emission levels to counter check the emission monitoring system.



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2.2 Occupational Health and Safety

Occupational Health and Safety Guidelines Occupational health and safety performance should be

evaluated against internationally published exposure guidelines,

of which examples include the Threshold Limit Value (TLV®)

occupational exposure guidelines and Biological Exposure

Indices (BEIs®) published by American Conference of

Governmental Industrial Hygienists (ACGIH),36 the Pocket

Guide to Chemical Hazards published by the United States

National Institute for Occupational Health and Safety (NIOSH),37

Permissible Exposure Limits (PELs) published by the

Occupational Safety and Health Administration of the United

States (OSHA),38 Indicative Occupational Exposure Limit Values

published by European Union member states,39 or other similar

sources.

Additional indicators specifically applicable to electric power

sector activities include the ICNIRP exposure limits for

occupational exposure to electric and magnetic fields listed in

Table 8. Additional applicable indicators such as noise,

electrical hazards, air quality, etc. are presented in Section 2.0

of the General EHS Guidelines.

Source: ICNIRP (1998) : “Guidelines for limiting exposure to time-varying electric, magnetic, and electromagnetic fields (up to 300 GHz)

36 http://www.acgih.org/TLV/36 Available at: http://www.acgih.org/TLV/ and http://www.acgih.org/store/ 37 Available at: http://www.cdc.gov/niosh/npg/ 38 Available at: http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9992 39 Available at: http://europe.osha.eu.int/good_practice/risks/ds/oel/

Accident and Fatality Rates Projects should try to reduce the number of accidents among

project workers (whether directly employed or subcontracted) to

a rate of zero, especially accidents that could result in lost work

time, different levels of disability, or even fatalities. The accident

and fatality rates of the specific facility may be benchmarked

against the performance of facilities in this sector in developed

countries through consultation with published sources (e.g., US

Bureau of Labor Statistics and UK Health and Safety

Executive)40.

Occupational Health and Safety Monitoring The working environment should be monitored for occupational

hazards relevant to the specific project. Monitoring should be

designed and implemented by accredited professionals41 as part

of an occupational health and safety monitoring program.

Facilities should also maintain a record of occupational

accidents and diseases and dangerous occurrences and

accidents. Additional guidance on occupational health and

safety monitoring programs is provided in the General EHS Guidelines.

40 Available at: http://www.bls.gov/iif/ and http://www.hse.gov.uk/statistics/index.htm 41 Accredited professionals may include Certified Industrial Hygienists, Registered Occupational Hygienists, or Certified Safety Professionals or their equivalent.

Table 8 - ICNIRP exposure limits for occupational exposure to electric and magnetic fields.

Frequency Electric Field (V/m) Magnetic Field (µT)

50 Hz 10,000 500

60 Hz 8300 415



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3.0 References and Additional Sources

American Society for Testing and Materials (ASTM) E 1686-02, Standard Guide for Selection of Environmental Noise Measurements and Criteria, January 2003.

ANZECC (Australian and New Zealand Environment and Conservation Council). 1992. National water quality management strategy: Australian water quality guidelines for fresh and marine waters. ISBN 0-642-18297-3. Australian and New Zealand Environment and Conservation Council. Canberra Act 2600. New Zealand.

Commission of European Communities (CEC). 1988. European community environmental legislation: 1967-1987. Document Number XI/989/87. Directorate-General for Environment, Consumer Protection and Nuclear Safety. Brussels, Belgium. 229 pp.

Euromot. 2006. World Bank – International Finance Corporation General Environmental, Health and Safety Guidelines. Position Paper. November 2006.

European Commission (EC), 2001. Integrated Pollution Prevention and Control (IPCC) Reference Document on the Application of Best Available Techniques to Industrial Cooling Systems, December 2001

European Commission (EC). 2006. Integrated Pollution Prevention and Control Reference Document on Best Available Techniques (BREF) for Large Combustion Plants. July 2006.

G. G. Oliver and L. E. Fidler, Aspen Applied Sciences Ltd., Towards a Water Quality Guideline for Temperature in the Province of British Columbia, March 2001.

International Energy Agency. 2007. Fossil Fuel-Fired power Generation. Case Studies of Recently Constructed Coal- and Gas-Fired Power Plants.

International Organization for Standardization, ISO/DIS 1996-2.2, Acoustics – Description, assessment and measurement of environmental noise – Part 2: Determination of environmental noise levels.

Jamaica. 2006. The Natural Resources Conservation Authority Act. The Natural Resources Conservation Authority (Air Quality) Regulations, 2006.

NRC. 2002. Coal Waste Impoundments: Risks, Responses, and Alternatives. Committee on Coal Waste Impoundments, Committee on Earth Resources, Board on Earth Sciences and Resources, National Research Council. ISBN: 0-309-08251-X.

Official Journal of the European Communities. 2001. Directive 2001/80/EC of the European Parliament and of the Council of 23 October 2001 on limitation of emissions of certain pollutants into the air from large combustion plants.

People’s Republic of China. 2003. National Standards of the People’s Republic of China. GB 13223-2003. Emission Standard of Air Pollutants for Thermal Power Plants. December 23, 2003.

Republic of the Philippines. 1999. DENR Administrative Order No. 2000-81. RA 8749: The Philippine Clean Air Act of f 1999 and its Implementing Rules and Regulations. December 2001.

Schimmoller, Brian K. 2004. "Section 316(b) Regulations: The Yin and Yang of Fish Survival and Power Plant Operation" Power Engineering/July 2004 p. 28.

Tavoulareas, E. Stratos, and Jean-Pierre Charpentier. 1995. Clean Coal Technologies for Developing Countries. World Bank Technical Paper 286, Energy Series. Washington, D.C.

The Gazette of India. 2002. Ministry of Environment and Forest Notification, New Delhi, the 9th of July, 2002. Emission Standards for Diesel Engines (Engine Rating More Than 0.8 MW (800kW) for Power Plant, Generator Set Applications and Other Requirements.

The Institute of Electrical and Electronics Engineers, Inc. (IEEE), IEEE Guide for Power-Station Noise Control, IEEE Std. 640-1985, 1985

UNIPEDE / EURELECTRIC. 1997. Wastewater effluents Technology, Thermal Generation Study Committee. 20.04 THERCHIM 20.05 THERRES. April 1997.

UNIPEDE. 1998. Wastewater and water residue management – Regulations. Thermal Generation Study Committee. 20.05 THERRES. February 1998

U.S. Department of Energy (DOE) / National Energy Technology Laboratory (NETL), 2007. Cost and Performance Baseline for Fossil Energy Plants

U.S. Environmental Protection Agency (EPA). 1994. Water Quality Standards Handbook: Second Edition (EPA-823-B94-005a) August 1994.

U.S. Environmental Protection Agency (EPA). 1988d. State water quality standards summary: District of Columbia. EPA 440/5-88-041. Criteria and Standards Division (WH-585). Office of Water Regulations and Standards. Washington, District of Columbia. 7 pp.

U.S. Environmental Protection Agency (EPA). 1997. EPA Office of Compliance Sector Notebook Project Profile of the Fossil Fuel Electric Power Generation Industry. EPA/310-R-97-007. September 1997.

U.S. Environmental Protection Agency (EPA). 2001. Federal Register / Vol. 66, No. 243, National Pollutant Discharge Elimination System: Regulations Addressing Cooling Water Intake Structures for New Facilities, December 18, 2001 pp. 65256 – 65345.

U.S. Environmental Protection Agency (EPA), 2005. Control of Mercury Emissions from Coal Fired Electric Utility Boilers: An Update. Air Pollution Prevention and Control Division National Risk Management Research Laboratory Office of Research and Development.

U.S. Environmental Protection Agency (EPA), 2006. Federal Register / Vol. 71, No. 129, Standards of Performance for Stationary Combustion Turbines; Final Rule, July 6, 2006 pp. 38482-38506.

U.S. Environmental Protection Agency (EPA), 2006. Federal Register / Vol. 71, No. 132, Standards of Performance for Stationary Compression Ignition Internal Combustion Engines; Final Rule, July 11, 2006 pp. 39154-39184.

U.S. Environmental Protection Agency (EPA). 2006. Final Report. Environmental Footprints and Costs of Coal-Based Integrated Gasification Combined Cycle and Pulverized Coal technologies. July 2006.

U.S. Environmental Protection Agency (EPA). 2007. Federal Register / Vol. 72, No. 113, Amendments to New Source Performance Standards (NSPS) for Electric Utility Steam Generating Units and Industrial-commercial-Institutional Steam Generating Units; Final Rule, June 13, 2007 pp. 32710-32768

U.S. Environmental Protection Agency (EPA), 2008. Federal Register / Vol. 73, No. 13, Standards of Performance for Stationary Spark Ignition Internal Combustion Engines and National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines; Final Rule. pp3568-3614

West Virginia Water Research Institute. 2005. Guidance Document for Coal Waste Impoundment Facilities & Coal Waste Impoundment Inspection Form. Morgantown, WV. December 2005.

WHO (World Health Organization). 2006. Air Quality Guidelines Global Update 2005, Particulate matter, ozone, nitrogen dioxide and sulphur dioxide.

World Health Organization Regional Office for Europe Copenhagen. 2000. Air quality guidelines for Europe, 2nd edition, 2000.

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World Bank Group. Sep 2006. Technical and Economic Assessment of Off-Grid, Mini-Grid and Grid Electrification Technologies Summary Report.



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Annex A: General Description of Industry Activities

Thermal power plants burn fossil fuels or biomass to generate

electrical energy and heat. Mechanical power is produced by a

heat engine, which transforms thermal energy from combustion

of a fossil fuel into rotational energy. A generator converts that

mechanical energy into electrical energy by creating relative

motion between a magnetic field and a conductor. Figure A-1 is

a generalized flow diagram of a boiler-based thermal power

plant and its associated operations.

Not all thermal energy can be transformed to mechanical power,

according to the second law of thermodynamics. Therefore,

thermal power plants also produce low-temperature heat. If no

use is found for the heat, it is lost to the environment. If reject

heat is employed as useful heat (e.g., for industrial processes or

district heating), the power plant is referred to as a cogeneration

power plant or CHP (combined heat-and-power) plant.

Types of Thermal power plants Thermal power plants can be divided based on the type of

combustion or gasification: boilers, internal reciprocating engines,

and combustion turbines. In addition, combined-cycle and

cogeneration systems increase efficiency by utilizing heat lost by

conventional combustion systems. The type of system is chosen

based on the loads, the availability of fuels, and the energy

requirements of the electric power generation facility. Other

ancillary processes, such as coal processing and pollution control,

must also be performed to support the generation of electricity.

The following subsections describe each system and then discuss

ancillary processes at the facility (USEPA 1997).

Boilers (Steam Turbines) Conventional steam-producing thermal power plants generate

electricity through a series of energy conversion stages: fuel is

burned in boilers to convert water to high-pressure steam, which is

then used to drive a steam turbine to generate electricity. Heat for the

system is usually provided by the combustion of coal, natural

gas, oil, or biomass as well as other types of waste or recovered

fuel. High-temperature, high-pressure steam is generated in the

boiler and then enters the steam turbine. At the other end of the

steam turbine is the condenser, which is maintained at a low

temperature and pressure. Steam rushing from the high-

pressure boiler to the low-pressure condenser drives the turbine

blades, which powers the electric generator.

Low-pressure steam exiting the turbine enters the condenser

shell and is condensed on the condenser tubes, which are

maintained at a low temperature by the flow of cooling water.

As the steam is cooled to condensate, the condensate is

transported by the boiler feedwater system back to the boiler,

where it is used again. A constant flow of low-temperature

cooling water in the condenser tubes is required to keep the

condenser shell (steam side) at proper pressure and to ensure

efficient electricity generation. Through the condensing

process, the cooling water is warmed. If the cooling system is

an open or a once-through system, this warm water is released

back to the source water body.42 In a closed system, the warm

water is cooled by recirculation through cooling towers, lakes, or

ponds, where the heat is released into the air through

evaporation and/or sensible heat transfer. If a recirculating

cooling system is used, only a relatively small amount of make-

up water is required to offset the evaporative losses and cooling

tower blowdown that must be discharged periodically to control

the build-up of solids. A recirculating system uses about one-

twentieth the water of a once-through system.

Steam turbines typically have a thermal efficiency of about 35

percent, meaning that 35 percent of the heat of combustion is

transformed into electricity. The remaining 65 percent of the

heat either goes up the stack (typically 10 percent) or is

42 If groundwater is used for cooling, the cooling water is usually discharged to a



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discharged with the condenser cooling water (typically 55

percent).

Coal and lignite are the most common fuels in thermal power

plants although heavy fuel oil is also used. Coal-fired steam

generation systems are designed to use pulverized coal or

crushed coal. Several types of coal-fired steam generators are

in use, and are generally classified based on the characteristics

of the coal fed to the burners and the mode of burning the coal.

In fluidized-bed combustors, fuel materials are forced by gas

into a state of buoyancy. The gas cushion between the solids

allows the particles to move freely, thus flowing like a liquid. By

using this technology, SO2 and NOX emissions are reduced

because an SO2 sorbent, such as limestone, can be used

efficiently. Also, because the operating temperature is low, the

amount of NOX gases formed is lower than those produced

using conventional technology.

Natural gas and liquid fuels are usually transported to thermal

power plants via pipelines. Coal and biomass fuels can be

transported by rail, barge, or truck. In some cases, coal is

mixed with water to form slurry that can be pumped to the

thermal power plant in a pipeline. Once coal arrives at the plant,

it is unloaded to storage or directly to the stoker or hopper. In

transporting coal during warmer months and in dry climates,

dust suppression may be necessary.

Coal may be cleaned and prepared before being either crushed

or pulverized. Impurities in coal such as ash, metals, silica, and

sulfur can cause boiler fouling and slagging. Coal cleaning can

be used to reduce sulfur in the coal to meet sulfur dioxide (SO2)

emissions regulations and also reduce ash content and the

amount of heavy metals. Cleaning the coal is costly, but the

cost can be at least partially offset by an increase in fuel

efficiency, reduced emission control requirements, and lower

waste management costs. Coal cleaning is typically performed

surface water body.

at the mine by using gravity concentration, flotation, or

dewatering methods.

Coal is transported from the coal bunker or silo to be crushed,

ground, and dried further before it is fired in the burner or

combustion system. Many mechanisms can be used to grind

the coal and prepare it for firing. Pulverizers, cyclones, and

stokers are all used to grind and dry the coal. Increasing the

coal’s particle surface area and decreasing its moisture content

greatly boosting its heating capacity. Once prepared, the coal is

transported within the plant to the combustion system. Devices

at the bottom of the boilers catch ash and/or slag.

Reciprocating Engines Internal combustion engines convert the chemical energy of

fuels (typically diesel fuel or heavy fuel oil) into mechanical

energy in a design similar to a truck engine, and the mechanical

energy is used to turn a generator. Two types of engines

normally used: the medium-speed, four-stroke trunk piston

engine and the low-speed, two-stroke crosshead engine. Both

types of engine operate on the air-standard diesel

thermodynamic cycle. Air is drawn or forced into a cylinder and

is compressed by a piston. Fuel is injected into the cylinder and

is ignited by the heat of the compression of the air. The burning

mixture of fuel and air expands, pushing the piston. The

products of combustion are then removed from the cylinder,

completing the cycle.

The exhaust gases from an engine are affected by the load

profile of the prime mover; ambient conditions such as air

humidity and temperature; fuel oil quality, such as sulfur content,

nitrogen content, viscosity, ignition ability, density, and ash

content; and site conditions and the auxiliary equipment

associated with the prime mover, such as cooling properties and

exhaust gas back pressure. The engine parameters that affect

NOX emissions are fuel injection in terms of timing, duration, and

atomization; combustion air conditions, which are affected by



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valve timing, the charge air system, and charge air cooling

before cylinders; and the combustion process, which is affected

by air and fuel mixing, combustion chamber design, and the

compression ratio.43 The particulate matter emissions are

dependent on the general conditions of the engine, especially

the fuel injection system and its maintenance, in addition to the

ash content of the fuel, which is in the range 0.05–0.2%. SOx

emissions are directly dependent on the sulfur content of the

fuel. Fuel oil may contain as little as 0.3% sulfur and, in some

cases, up to 5% sulfur.

Diesel engines are fuel flexible and can use fuels such as diesel

oil, heavy fuel oil, natural gas, crude oil, bio-fuels (such as palm

oil, etc.) and emulsified fuels (such as Orimulsion, etc.).

Typical electrical efficiencies in single mode are typically ranging

from 40 % for the medium speed engines up to about 50 % for

large engines and even higher efficiencies in combined cycle

mode. Total efficiency in CHP (Combined Heat and Power) is

typically in liquid operation up to 60 – 80 % and in gas mode

even higher dependent on the application. The heat to power

ratio is typically 0.5 to 1.3 in CHP applications, dependent on

the application.

Lean Burn Gas Engines

Typical electrical efficiencies for bigger stationary medium

speed engines in single mode are typically 40 – 47 % and up to

close to 50 % in combined cycle mode. Total efficiency in CHP

facilities is typically up to 90 % dependent on the application.

The heat to power ratios are typically 0.5 to 1.3 in CHP-

applications, dependent on the application.

43 If the fuel timing is too early, the cylinder pressure will increase, resulting in higher nitrogen oxide formation. If injection is timed too late, fuel consumption and turbocharger speed will increase. NOX emissions can be reduced by later injection timing, but then particulate matter and the amount of unburned species will increase.

Spark Ignition (SG)

Often a spark ignited gas-otto engine works according to the

lean burn concept meaning that a lean mixture of combustion air

and fuel is used in the cylinder (e.g., much more air than needed

for the combustion). In order to stabilize the ignition and

combustion of the lean mixture, in bigger engine types a

prechamber with a richer air/fuel mixture is used. The ignition is

initiated with a spark plug or some other device located in the

prechamber, resulting in a high-energy ignition source for the

main fuel charge in the cylinder. The most important parameter

governing the rate of NOx formation in internal combustion

engines is the combustion temperature; the higher the

temperature the higher the NOx content of the exhaust gases.

One method is to lower the fuel/air ratio, the same specific heat

quantity released by the combustion of the fuel is then used to

heat up a larger mass of exhaust gases, resulting in a lower

maximum combustion temperature. This method low fuel/air

ratio is called lean burn and it reduces NOx effectively. The

spark-ignited lean-burn engine has therefore low NOx

emissions. This is a pure gas engine; it operates only on

gaseous fuels.

Dual fuel engines (DF)

Some DF engine types are fuel versatile, these can be run on

low pressure natural gas or liquid fuels such as diesel oil (as

back-up fuel, etc.), heavy fuel oil, etc. This engine type can

operate at full load in both fuel modes. Dual Fuel (DF) engines

can also be designed to work in gas mode only with a pilot liquid

fuel used for ignition of the gas.

Combustion Turbines Gas turbine systems operate in a manner similar to steam

turbine systems except that combustion gases are used to turn

the turbine blades instead of steam. In addition to the electric

generator, the turbine also drives a rotating compressor to

pressurize the air, which is then mixed with either gas or liquid



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fuel in a combustion chamber. The greater the compression,

the higher the temperature and the efficiency that can be

achieved in a gas turbine. Higher temperatures, however,

typically lead to increases in NOX emissions. Exhaust gases are

emitted to the atmosphere from the turbine. Unlike a steam

turbine system, gas turbine systems do not have boilers or a

steam supply, condensers, or a waste heat disposal system.

Therefore, capital costs are much lower for a gas turbine system

than for a steam system.

In electrical power applications, gas turbines are often used for

peaking duty, where rapid startup and short runs are needed.

Most installed simple gas turbines with no controls have only a

20- to 30-percent efficiency.

Combined Cycle Combined-cycle generation is a configuration using both gas

turbines and steam generators. In a combined-cycle gas turbine

(CCGT), the hot exhaust gases of a gas turbine are used to

provide all, or a portion of, the heat source for the boiler, which

produces steam for the steam generator turbine. This

combination increases the thermal efficiency to approximately

50 - 60 percent. Combined-cycle systems may have multiple

gas turbines driving one steam turbine. Combined-cycle

systems with diesel engines and steam generators are also

sometimes used.

In addition, integrated coal gasification combined-cycle (IGCC)

units are emerging technologies. In an IGCC system, coal gas

is manufactured and cleaned in a "gasifier" under pressure,

thereby reducing emissions and particulates.44 The coal gas

then is combusted in a CCGT generation system.

44 Gasification is a process in which coal is introduced to a reducing atmosphere with oxygen or air and steam.

Cogeneration Cogeneration is the merging of a system designed to produce

electric power and a system used for producing industrial heat

and steam and/or municipal heating. This system is a more

efficient way of using energy inputs and allows the recovery of

otherwise wasted thermal energy for use in an industrial

process. Cogeneration technologies are classified as "topping

cycle" and "bottoming cycle" systems, depending on whether

electrical (topping cycle) or thermal (bottoming cycle) energy is

derived first. Most cogeneration systems use a topping cycle.



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Figure A-1 Generalized Flow Diagram of a Thermal power plant45 and Associated Operations

Source: EC 2006

45 Applicable to boiler plant with cooling tower only. Diagram does not apply to engines and turbines which have completely different configurations.



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Annex B: Environmental Assessment Guidance for Thermal Power Projects

The development of an environmental assessment (EA) for a

thermal power project should take into account any government

energy and/or environmental policy or strategy including

strategic aspects such as energy efficiency improvements in

existing power generation, transmission, and distribution

systems, demand side management, project siting, fuel choice,

technology choice, and environmental performance.

New Facilities and Expansion of Existing Facilities An (EA) for new facilities and a combined EA and environmental

audit for existing facilities should be carried out early in the

project cycle in order to establish site-specific emissions

requirements and other measures for a new or expanded

thermal power plant. Table B-1 provides suggested key

elements of the EA, the scope of which will depend on project-

specific circumstances.

Table B-1 Suggested Key EHS Elements for EA of New Thermal Power Project

Analysis of Alternatives

• Fuel selection including non-fossil fuel options (coal, oil, gas, biomass, other renewable options – wind, solar, geothermal, hydro), fuel supply sources

• Power generation technology o Thermal generating efficiency

(HHV-gross, LHV-gross, HHV-net, LHV-net)

o Cost o CO2 emissions performance

(gCO2/kWh) • GHG emissions reduction / offset

options o Energy conversion efficiency o Offset arrangement o Use of renewable energy

sources, etc. • Baseline water quality of receiving water

bodies • Water supply

o Surface water, underground water, desalination

• Cooling system o Once-through, wet closed

circuit, dry closed circuit • Ash disposal system - wet disposal vs.

dry disposal • Pollution control

o Air emission – primary vs. secondary flue gas treatment (cost, performance)

o Effluent (cost, performance) • Effluent discharge

o Surface water o Evaporation o Recycling – zero discharge

• Siting o Land acquisition

consideration o Access to fuel / electricity

grid o Existing and future land use

zoning o Existing and predicted

environmental baseline (air, water, noise)

Impact Assessment

• Estimation of GHG emissions (tCO2/year, gCO2/kWh)

• Air quality impact o SO2, NO2, PM10, PM2.5,

Heavy metals as appropriate, Acid deposition if relevant

o Incremental impacts to the attainment of relevant air quality standards

o Isopleth concentration lines (short-term, annual average, as appropriate) overlaid with land use and topographic map

o Cumulative impacts of existing sources / future projects if known

o Stack height determination o Health impact consideration

• Water quality / intake impact o thermal discharge if once-

through cooling system is used

o other key contaminants as appropriate

o water intake impact • Noise impact

o Noise contour lines overlaid with land use and locations of receptors

• Determination of pollution prevention and abatement measures

Mitigation Measures /

• Air (Stack height, pollution control measures, cost)



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Management Program

• Effluent (wastewater treatment measures, cost)

• Noise (noise control measures, cost) • Waste utilization / disposal (e.g., ash,

FGD by-product, used oil) o Ash management plan

(quantitative balance of ash generation, disposal, utilization, size of ash disposal site, ash transportation arrangement)

• Fuel supply arrangement • Emergency preparedness and response

plan • Industrial risk assessment if relevant

Monitoring Program

• Parameters • Sampling Frequency • Evaluation Criteria • Sampling points overlaid with relevant

site layout / surrounding maps • Cost

Tasks related to carrying out the quality impact analysis for the

EA should include:

• Collection of baseline data ranging from relatively simple

qualitative information (for smaller projects) to more

comprehensive quantitative data (for larger projects) on

ambient concentrations of parameters and averaging time

consistent with relevant host country air quality standards

(e.g., parameters such as PM10, PM2.5, SO2 (for oil and

coal-fired plants), NOX, and ground-level ozone; and

averaging time such as 1-hour maximum, 24-hour

maximum, annual average), within a defined airshed

encompassing the proposed project;46

• Evaluation of the baseline airshed quality (e.g., degraded

or non-degraded);

• Evaluation of baseline water quality, where relevant;

• Use of appropriate mathematical or physical air quality

46 The term “airshed” refers to the local area around the plant whose ambient air quality is directly affected by emissions from the plant. The size of the relevant local airshed will depend on plant characteristics, such as stack height, as well as on local meteorological conditions and topography. In some cases, airsheds are defined in legislation or by the relevant environmental authorities. If not, the EA should clearly define the airshed on the basis of consultations with those responsible for local environmental management.

dispersion models to estimate the impact of the project on

the ambient concentrations of these pollutants;

• If acid deposition is considered a potentially significant

impact, use of appropriate air quality models to evaluate

long-range and trans-boundary acid deposition;

• The scope of baseline data collection and air quality impact

assessment will depend on the project circumstances (e.g.,

project size, amount of air emissions and the potential

impacts on the airshed). Examples of suggested practices

are presented in Table B-2.

Table B-2 - Suggested Air Quality Impact Assessment Approach

Baseline air quality collection

• Qualitative information (for small projects e.g., < 100MWth)

• Seasonal manual sampling (for mid-sized projects e.g., < 1,200MWth)

• Continuous automatic sampling (for large projects e.g., >= 1,200MWth)

• Modeling existing sources

Baseline meteorological data collection

• Continuous one-year data for dispersion modeling from nearby existing meteorological station (e.g., airport, meteorological station) or site-specific station, if installed, for mid-sized and large projects

Evaluation of airshed quality

• Determining if the airshed is degraded (i.e., ambient air quality standards are not attained) or non-degraded (i.e., ambient air quality standards are attained)

Air quality impact assessment

• Assess incremental and resultant levels by screening models (for small projects)

• Assess incremental and resultant levels by refined models (for mid-sized and large projects, or for small projects if determined necessary after using screening models)47

• Modify emission levels, if needed, to ensure that incremental impacts are small (e.g., 25% of relevant ambient air quality standard levels) and that the airshed will not become degraded.

47 For further guidance on refined / screening models, see Appendix W to Part 51 – Guidelines on Air Quality Models by US EPA (Final Rule, November 9, 2005)



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When there is a reasonable likelihood that in the medium or long

term the power plant will be expanded or other pollution sources

will increase significantly, the analysis should take account of

the impact of the proposed plant design both immediately and

after any formally planned expansion in capacity or in other

sources of pollution. Plant design should allow for future

installation of additional pollution control equipment, should this

prove desirable or necessary based upon predicted air quality

impacts and/or anticipated changes in emission standards (i.e.,

impending membership into the EU). The EA should also

address other project-specific environmental concerns, such as

fuel and emissions from fuel impurities. In cases where fuel

impurities lead to known hazardous emissions, the EA should

estimate the emission amount, assess impacts and propose

mitigations to reduce emissions.48 Examples of compounds

which may be present in certain types of coal, heavy fuel oil,

petroleum coke, etc. include cadmium, mercury, and other

heavy metals.

Rehabilitation of Existing Facilities An environmental assessment of the proposed rehabilitation

should be carried out early in the process of preparing the

project in order to allow an opportunity to evaluate alternative

rehabilitation options before key design decisions are finalized.

The assessment should include an environmental audit that

examines the impacts of the existing plant’s operations on

nearby populations and ecosystems, supplemented by an EA

that examines the changes in these impacts that would result

under alternative specifications for the rehabilitation, and the

estimated capital and operating costs associated with each

option. Depending on the scale and nature of the rehabilitation,

the audit/environmental assessment may be relatively narrow in

48 Several U.S. states have adopted regulations that give coal-fired power plants the option to meet either a mercury emissions standard based on electricity output or a control-based standard. For instance, Illinois requires all coal-fired power plants of 25 MW electrical capacity or greater to meet either an emissions standard of 0.0080 lbs mercury per gigawatt hour (GWh) gross electrical output or an emissions control requirement of 90 percent relative to mercury input.

scope, focusing on only a small number of specific concerns

that would be affected by the project, or it may be as extensive

as would be appropriate for the construction of a new unit at the

same site. Normally, it should cover the following points:

• Ambient environmental quality in the airshed or water basin

affected by the plant, together with approximate estimates

of the contribution of the plant to total emissions loads of

the main pollutants of concern

• The impact of the plant, under existing operating conditions

and under alternative scenarios for rehabilitation, on

ambient air and water quality affecting neighboring

populations and sensitive ecosystems

• The likely costs of achieving alternative emissions

standards or other environmental targets for the plant as a

whole or for specific aspects of its operations

• Recommendations concerning a range of cost effective

measures for improving the environmental performance of

the plant within the framework of the rehabilitation project

and any associated emissions standards or other

requirements implied by the adoption of specific measures.

These issues should be covered at a level of detail appropriate

to the nature and scale of the proposed project. If the plant is

located in an airshed or water basin that is polluted as a result of

emissions from a range of sources, including the plant itself,

comparisons should be made of the relative costs of improving

ambient air or water quality by reducing emissions from the

plant or by reducing emissions from other sources.


Hagler Bailly Pakistan Appendix B

R4V03FBE: 02/19/14 B-1

Appendix B: Socioeconomic Survey Form

See following pages.



R4V03FBE: 02/19/14 B-2

SETTLEMENT FORM

Demography

Settlement name

Total population Household size

Religion Muslims % Other: %

Ethnic Groups Group name Share in population

Group name Share in population

% %

% %

% %

Occupational Profile

Occupation Share in employed population

Location/Industry (industrial area or

outside)

Occupation Share in employed population

Location/Industry (industrial area or

outside)

% %

% %

% %

Physical Infrastructure

Security Police station Check Post

Electricity Availability: Yes No

Source: Grid Independent Supply

For independent supply, mention source:

Natural Gas Availability: Yes No

Potable water Availability: Yes No

Source:

Housing Pakka (%) _____ Katcha (%) _____ Semi-pakka (%) _____

Additional Comments



R4V03FBE: 02/19/14 B-3

Social Infrastructure

Health Facility Nearest facility: km

Level (Private clinic, BHU, RHC, Hospital etc):

Educational Facility

Nearest facility: km

Level (primary, intermediate etc) :

Additional Comments

Literacy

Literacy rate (10 years and above)

%

Common diseases Adult men:

Adult women:

Children:

Crime and Security Conditions (Nature of Crime and Frequency)

1

2

3

4

5


Hagler Bailly Pakistan Appendix C

R4V03FBE: 02/19/14 C-1

Appendix C: Background Information Document

August 2013

BACKGROUND INFORMATION DOCUMENT

Environmental Impact Assessment for FFBL Coal Power Plant Project

Introduction and Background

Fauji Fertilizer Bin Qasim Limited (FFBL) is operating a fertilizer plant in the Eastern

Industrial Zone of Port Qasim. FFBL intends to install a coal power plant (the “Project”)

within the existing complex of the fertilizer plant (the “Complex”). FFBL has initiated an

Environmental Impact Assessment (EIA) to assess the likely environmental and

socioeconomic impacts that may result from Project activities and to mitigate any

potential negative impacts. The EIA process and the report will meet national regulations

and international environmental guidelines.

FFBL has acquired the services of Hagler Bailly Pakistan (Pvt.) Ltd. (HBP) to undertake

the EIA study. As part of the EIA process, consultations are undertaken with

communities and institutions that may have interest in the Project or may be affected by

the Project (the “Stakeholders”). For informed consultations with the Stakeholder, this

Background Information Document (BID) has been prepared and contains information on

the proposed Project, its setting, and the EIA process that is being followed.

The process of consultations is an on-going activity, which will continue throughout the

project activities, and beyond the closure of the Project. The information provided in this

BID is subject to changes as further information on some aspects of the Project becomes

available or the Project is modified because of the EIA process.

Project Setting

The Complex lies about 45 kilometers southeast of the city of Karachi, inside the Eastern

Industrial Zone of Port Qasim Area (PQA), which is a designated industrial estate

(Exhibit C.1). Towards the east and south, the Complex borders with developed

industrial estate, whereas the estate in the west of the Complex is yet to be developed.

The Complex is spread on 350 acres of land. It is conveniently located at a distance of

about one kilometer from the National Highway, which links Karachi to southern Sindh

and the rest of the country.



R4V03FBE: 02/19/14 C-2

Exhibit C.1: Project Setting



R4V03FBE: 02/19/14 C-3

Project Outline

FFBL’s existing fertilizer plant is operating on natural gas. The shortfall in the supply of

natural gas in Pakistan has affected fertilizer production adversely. Under the Project, the

fertilizer plant’s steam and power generation processes will be shifted from natural gas to

coal. The main components of the Project are briefly described in (Exhibit C.2), whereas

the layout of the existing facilities at the Complex and the proposed site for the

installation of the Project is given in Exhibit C.3.

Exhibit C.2: Brief Description of Main Components of the Project


Site preparation

Existing boilers and power system will remain in place, therefore no major decommissioning will be required. Any minor replacement and consequent waste will be handled through existing waste management systems.

New facilities

FFBL plans to install a new coal power plant at an empty space situated within the existing fertilizer complex. The Project consists of two equal capacity circulating fluidized bed (CFB) boiler units, each of 250 Met/hr. Out of the 500 Met/hr of steam produced by the two boilers, 140 Mett/hr will be used to operate three steam turbine generators each with a capacity of 16 MWe. Power produced by these will be sent to the existing 13.8 kV grid inside the FFBL Complex to supply power to the existing fertilizer plant which operates at 60 Hz and is not connected to the national grid connection. About 200 Met/hr of steam will be used as process steam for the manufacture of fertilizer.

FFBL has kept extra margin in the two coal fired CFB boilers and auxiliaries capacities to generate additional power at 50 Hz from dedicated Steam Turbine Generator for export to Pakistan National Electric Grid

Coal storage facilities at the port

Coal will be transported from Port Qasim or Karachi Port using existing port facilities. No new water front facility or expansion of the coal yard will be required at the ports, for the Project.


From the Karachi Port (s), the coal will be transported to the Project site via trucks. It will then be stacked in a coal yard to be set up within the fertilizer plant complex from where it will be reclaimed and used as fuel in the boilers.

Ash disposal

Two distinct types of ash are generated during combustion of coal in Circulating Fluidized Bed (CFB) boiler technology: bottom bed ash and fly ash. Bottom bed ash consists of larger particles that exit the bottom of the boiler while fly ash consists of finer particles that exit the boiler with the flue gas and are recovered in the de-dusting process. FFBL plans to acquire suitable low land areas for the disposal of these ashes, which will be covered properly after filling, to minimize dust emissions from the deposits. Utilization of the ash in local cement and concrete brick manufacturing plants is also being considered. In-addition to these options, CFB ashes can be considered for other applications that require less stringent specifications, which include soil stabilization, road base and structural fill.

Emission Control



De-sulfurization with the help of sorbent (limestone) inside the CFB boilers to capture and to prevent SOx emission

Fabric Bag house filters for de-dusting of fly ash from coal combustion to prevent particulate matter emission

Emission monitoring system at flue gas ducts of each CFB boiler outlet to monitor NOx, SOx, PM, CO, temperature, CO2 & O2.



R4V03FBE: 02/19/14 C-4

Exhibit C.3: Layout of the Existing and Proposed Facilities at

Fertilizer Plant Complex



R4V03FBE: 02/19/14 C-5

Approach to the EIA

The EIA for the Project will be undertaken in compliance with relevant national

legislation and in accordance with recognized international standards, such as those of

International Finance Corporation. The major components of the EIA include:

comprehensive baseline studies to characterize the existing socioeconomic and

biophysical environment;

a public consultation process to ensure that project stakeholders are informed of

the project development plan and have an opportunity to influence it;

a comprehensive analysis of the environmental and social impacts of the project,

both negative and positive; and,

the development of impact mitigation plans and an environmental management

plan.

A brief overview of the conceptual components of an EIA process that meets both

Pakistan and international standards is given in Exhibit C.4.

A preliminary list of potential environmental and social impact of the Project that will be

investigated during the EIA is provided below.

Release of gases from the combustion of coal into the atmosphere causing decline

in air quality;

Effluent from the Project impacting the biodiversity and ecological functions;

Construction related impacts such as noise and dust;

Dust, noise, vibration, road congestion, and safety hazard from truck traffic

carrying coal and ash; and,

Social and ecological impacts of the development and operation of the ash

disposal sites.



R4V03FBE: 02/19/14 C-6

Exhibit C.4: Conceptual Components of an EIA Process

Component Main purpose Activities related to Stakeholder Consultations

Scoping Identify the issues on which the EIA should focus.

Identify project alternatives that should be evaluated during the course of the EIA.

Identify institutional and community stakeholders

Engage stakeholders and record issues raised

Provide feedback to the EIA team to incorporate stakeholders’ concern in baseline investigations and impact assessment

Baseline investigations

Collect background information on the environmental and social setting of the project.

Incorporate additional issues raised during the baseline survey

Impact assessment, studies

Define the potential impacts of the project

Undertake specialist investigations to predict changes to environment due to the project

Determine the significance of the potential impacts

Identify measures for the management of the impacts

Determine the residual impacts of the project after incorporation of the management measures.

Evaluate the overall acceptability of the project (from environmental and social perspectives).

Assess issues raised by stakeholders

Mitigation Measures and management plan

Environmental mitigation and monitoring plan will describe the measures proposed to ensure implementation of the mitigation measures identified during the impact assessment. It will include, for example, specific designs and plans, training requirements, resource requirements, monitoring details (sampling locations, methodology, and frequency), review and reporting requirements and budget.

Assess the acceptability and practicability of the proposed mitigation measures

EIA Report Preparation

After the studies, the EIA team will pull together the detailed assessment of impacts and mitigation measures. This may involve liaison with various specialists to ensure correct interpretation of information and compile EIA report.

Provide stakeholders with a feedback on the EIA specifically communicate how the project proponent proposes to address the issues raised by the stakeholders.

EIA submittal to regulatory authorities and decision making

Submittal and review of the EIA report by regulatory authorities and other interested stakeholders. The reviewers will inform about their decision on the acceptability of the Project from environmental and social perspectives and the conditions of approval for the development

Attend the public hearings and respond to the issues raised during the public hearings.

For more information on the EIA contact

Zirgham Nabi Afridi Hagler Bailly Pakistan 39, Street 3, E-7, Islamabad Tel: +92 51 261 0200 Fax: +92 51 261 0208 Email: [email protected]

Hidayat Hasan Hagler Bailly Pakistan 39, Street 3, E-7, Islamabad Tel: +92 51 261 0200 Fax: +92 51 261 0208 Email: [email protected]

mailto:[email protected]



Hagler Bailly Pakistan Appendix D

R4V03FBE: 02/19/14 D-1

Appendix D: Institutional Stakeholder Attendance Record

No Name Designation Company Contact Details (Cell/Phone/Email)

1. Fahim Afzal QA Manager Bake Parlor Cell/Phone: 0333 991 2295

Email: [email protected]

2. Shabbir K Hussain

HSE & Business Development Manager


Cell/Phone: 0300 820 4796

Email:

3. Faisal Abubakar DG Material Manager

Bake Parlor Cell/Phone:0321 840 5603


4. Tariq Jawad Plant Manager Exide Pakistan

Cell/Phone: 0333 212 8866

Email:

5. G M Lodhi Manager Finance Textile Institute of Pakistan

Cell/Phone:0345 265 9039


6. Mohsin Raza Manager Administration

Textile Institute of Pakistan

Cell/Phone: 0300 289 9881


7. Shabir A Memon

Staff Unit Manager (Electrical)

FFBL Cell/Phone: 0301 354 4677


8. Syed Sarfaraz Ahmed

Staff Unit Manager (Utility)

FFBL Cell/Phone: 0308 555 9657


9. Shafiq A Khan Manager HSEQ FFBL Cell/Phone: 0301 868 0017

Email:

10. Lt Col Asad Ullah Chugthai ®

General Affairs & Security Manager


Cell/Phone: 0300 820 6088


11. Bilal Ahmed Project Director Kausar Ghee Mills

Cell/Phone: 0302 844 8169


12. Hamid Ali Malik Director Kausar Ghee Mills

Cell/Phone: 0300 844 8169


13. Murtaza Ali Operations Manager

Northwest Minerals

Cell/Phone: 0300 240 2728


14. Kamran Aziz Manager Eipp PTB Foods Cell/Phone:0300 055 5754


15. M Sadeqian Ahmed

Deputy Manager PTB Foods Cell/Phone: 0300 841 7019















Hagler Bailly Pakistan Appendix E

R4V03FBE: 02/19/14 E-1

Appendix E: Environmental Management Plan

E.1 Purpose and Objectives of the EMP

The primary objectives of the EMP are to:

Facilitate the implementation of the identified mitigation measures in the

environmental assessment

Define the responsibilities of the project proponent and contractor, and provide a

means of effective communication of environmental issues between them.

Identify monitoring parameters in order to ensure the effectiveness of the

mitigation measures.

Provide a mechanism for taking timely action in the face of unanticipated

environmental situations.

Identify training requirements at various levels.

The EMP is prepared on the basis of detail currently available on the construction phase

of the project. As a construction contractor is appointed and further information is

available, the EMP will be amended to reflect the changes. However, no mitigation

measures committed in the EMP can be changed.

E.2 Management Approach

The organizational roles and responsibilities of the key players are summarized below:

The Owners: The project proponent will undertake overall responsibility for compliance

with the EMP. The Owners will carry out verification checks to ensure that the

contractors are effectively implementing their environmental and social requirements.

Contractors: The contractors will implement the majority of environmental and social

mitigations as required by their contract with the Owners. The contractors will carry out

field activities as part of the proposed project. The contractors are subject to certain

liabilities under the environmental laws of the country, and under their contracts with the

Owners.

E.3 Management Responsibilities

The responsibilities of the client and contractor are briefly described below:

Primary responsibilities:

As regards environmental performance during the project, the respective

highest-ranking officers in the country will assume the primary

responsibilities on behalf of both the project proponent and EPC contractor.



R4V03FBE: 02/19/14 E-2

The Owner’s Project Manager will be responsible for environmental

assessment and EMP compliance throughout the project on behalf of the

company itself.

The Owners will coordinate with the concerned government departments.

Project management and quality control:

Carrying out construction activities in an environmentally sound manner

during the project will be the responsibility of the contractor’s site manager.

Owner’s representative will be responsible for the overall environmental

soundness of all field operations.

Specific roles and responsibilities for environmental monitoring are provided in

Exhibit E.1.

E.4 Mitigation Plan

The mitigation plan is a key component of the EMP. It lists all of the mitigation measures

identified in the environmental assessment and the associated environmental and social

aspects of those measures. The mitigation measures for the proposed project are

presented in Exhibit E.2 for construction phase and in Exhibit E.3 for operational phase.

Major mitigation measures are proposed for following environmental aspects:

E.5 Waste Management

The waste management plan is summarized in Exhibit E.4.



R4V03FBE: 02/19/14 E-3

Exhibit E.1: Roles and Responsibilities for Environmental Monitoring

Aspect The Owners’ Responsibilities Contractor’s Responsibilities Relevant Documentation

Contracting Ensuring that monitoring and mitigation requirements are included in the contract between the Owners and the construction contractor(s).

Understanding the requirements and estimating the required resources

Contract between the Owners and the construction contractor(s)

Monitoring plan Ensuring finalization of monitoring plan before construction commencement

Prepare a construction management plan Finalized monitoring plan and Construction Management Plan

Resources Ensuring availability of resources required for environmental monitoring

Ensuring availability of resources required for environmental monitoring

Project budgets

Environmental staff Designating an Environmental Manager for the project

Designating an Environmental Manager for the project (may be combined with health and safety)

Job descriptions

Monitoring surveys and inspections

Undertaking regular inspections and carrying out further measurements when necessary

Undertaking regular inspections and collecting data on environmental performance, and carry out surveys

Inspection and survey reports

Environmental audit Conducting periodic audits of the construction site and commissioning third party audits

Conducting periodic internal audits Audit reports

Reporting Ensuring that periodic environmental monitoring reports are received from the construction contractor(s) and reviewing those reports

Producing environmental monitoring reports periodically and distributing those among the Owners management and appropriate staff members

Environmental monitoring reports

Corrective actions Verifying that activities carried out comply with the EIA/EMP and identifying corrective actions if needed

Carrying out corrective actions as required Corrective action record

Maintenance of record

Maintaining monitoring data and recording all incidents of environmental significance and related corrective measures

Maintaining monitoring data and recording all incidents of environmental significance and related corrective measures

Environmental databases



R4V03FBE: 02/19/14 E-4

Exhibit E.2: Mitigation Plan during Construction Phase

Environmental or Social Aspects

ID Measure Responsibility

Air Quality 1.1 Water will be sprinkled when there is an obvious dust problem on all exposed surfaces (in the construction area) susceptible to producing dust emissions. Treated wastewater will be used for sprinkling.

Construction contractor

1.2 Soil and aggregate storage piles stored for extended periods will be kept moist, and will either be covered with a tarpaulin or thick plastic sheets or have windshield walls 0.5 m higher than the pile.


1.3 All roads within the plant site and campsite that are to be paved or sealed will be paved as soon as possible after the commencement of construction work. Tracks will be sprinkled regularly until they are paved. Temporary roads will be compacted and sprinkled with water during construction.


1.4 Project traffic will observe a maximum speed limit of 20 km/h during construction on all unsealed roads within the construction site.


1.5 Construction materials that are susceptible to dust emission will be transported only in securely covered trucks. Aggregate material will be delivered in a damp condition, and water sprays will be applied if needed.


Soil and Water Contamination

2.1 Measures will be taken to avoid oil and grease spills, and immediate remedial measures will be taken in the event of a spill.

Construction contractor, the Owners

2.2 Tarpaulins or other impermeable materials will be spread on the ground to prevent contamination during on-site maintenance of construction vehicles.


2.3 Regular inspections will be carried out to detect leakages from construction vehicles and equipment, and vehicles/equipment with leakages will not be used until repaired.


2.4 Fuels, lubricants and chemicals will be stored in covered areas, underlain with impervious liners.


2.5 Spill control arrangements including shovels, plastic bags, and absorbent materials will be available near hazardous material storage areas.




R4V03FBE: 02/19/14 E-5



2.6 Measures will be taken to deal with soil contamination. Contaminated soil will be immediately collected and disposed of appropriately.


2.7 Storm water runoff will be redirected away from the construction site through the use of contouring and embankments.


2.8 Soil banks from ditching operations will not be placed where they might impair drainage. Construction contractor

Traffic 3.1 All vehicles will be NEQS compliant for noise and air emissions. Construction contractor

3.2 Construction materials that are susceptible to dust emission will be transported only in securely covered trucks. Aggregate material will be delivered in a damp condition, and water sprays will be applied if needed.


3.3 Over-loading of vehicles will be avoided. The recommended axle load of each truck will be logged and it will be ensured that the load limit is not exceeded.


3.4 Non-conformance and incident reporting system will be used to record and evaluate the cause of traffic accidents and to update traffic safety procedures accordingly.


Land Reclamation 4.1 During reclamation, the prevention dyke will be constructed as early as possible to minimize coming in contact of sea water with disturbed land.


4.2 A quarterly monitoring program will be initiated to study the abundance of Avicenna sp. in the Project area.


Occupational health and safety

5.1 Personnel will be provided with appropriate personal protection equipment (PPE). Staff will be trained in PPE use.

Construction contractor / Owner

5.2 Vehicles and equipment maintenance will be scheduled in accordance with manufacturer’s instructions.


5.3 Visitors to the construction site will be required to wear PPE (helmets, hard boots, ear protection, and safety goggles) if visiting areas where occupational health and safety hazards exist.


5.4 Health and safety management plan will be developed for construction phase to cover identified health and safety risks that are likely to occur during construction.




R4V03FBE: 02/19/14 E-6



5.5 Health and safety risks in the construction phase will be systematically and continuously identified, assessed and responded to.


5.6 Prevent access to areas with high hazard potential and clearly mark such areas with suitable warning signs showing written and visual representation of the hazard.


5.7 Encourage personnel to report near misses where construction activities or infrastructure could have potentially resulted in harm to staff, visitors or local communities




R4V03FBE: 02/19/14 E-7

Exhibit E.3: Mitigation Plan for the Operation Phase

Aspect ID Mitigation Measure Achievement Indicators

Air Quality 1.1 Maintain vehicles and equipment (including abatement equipment) in accordance with manufacturer’s instructions.

Maintenance log

1.2 Soil, coal and ash piles and aggregate storage piles will be kept moist, and will either be in shed or have windshield walls 0.5 m higher than the pile,

Visual inspection

Hazardous Materials

2.1 Develop and implement a Hazardous Material Management Plan including procedures for transport, handling and storage of hazardous substances to minimize risk of accidental exposure. Include clear instructions on what to do should exposure occur. Hazardous materials include fuel, lubricants, laboratory chemicals, chemical cleaning agents, etc.

Procedures for transport, handling and storage of hazardous substances with evidence of implementation

2.2 Require vehicle maintenance be performed in designated workshops where appropriate pollution control measures are provided.

Visual inspection

2.3 Record and report information on spills including:

location of spill;

material type (hazard potential) and quantity released;

quantity of material recovered;

media affected (soils, water, air);

actions taken to contain, recover and remove material released;

methods and location of disposal of recovered material or affected media;

cause of the spill; and

how future spills could be avoided.

Records of spills showing lessons learnt

2.4 Provide spill prevention and response training to staff , contractors and visitors, including:

an explanation of good house-keeping practices;

identification and use of equipment and engineering controls designed to prevent spills;

description of proper spill response procedures; and

indication of possible health, safety and environmental risks potentially occurring as a result of a spill.

Training/induction logs



R4V03FBE: 02/19/14 E-8


2.5 Develop and implement Spill Prevention and Mitigation Plan for the plant site and road transportation

Plan document, training provided as documented in training logs

Health 3.1 Undertake health screening of employees. Health screening reports

Local Economy 4.1 Look into possibility of engaging locally contractors that are within the Records of procurement contracts awarded to local companies

4.2 Develop and maintain a supplier and contractor database, along with a process to review, monitor and strengthen capabilities of local suppliers and contractors on an ongoing basis.

Database established and being used

Noise impacts 5.1 Provide hearing protection for operators. Protective equipment available and staff know how to use

5.2 Maintain vehicles and equipment in accordance with manufacturer’s instructions. Maintenance log

5.3 Require visitors to the site to wear ear protectors if working or visiting areas where appropriate occupational health and safety sound levels are exceeded.

Protective equipment available for use

Occupational health and safety

6.1 Develop health and safety management plan to cover identified health and safety risks likely to occur during start up, operation, phases of the project.

Plan in place with evidence of review

6.2 Systematically and continuously identify, assess and respond to health and safety risks throughout the Project life cycle.

Record of risk identification and management

6.3 Restrict the noise levels emitted from equipment or provide suitable personal protection devices if this limit cannot be achieved.

Noise levels known and equipment provided where necessary

6.4 Provide fire protection systems to comply with National Fire Protection Association regulations. Systems in place and tested

6.5 Provide personnel with appropriate personal protection equipment (PPE). Provide staff with training on how and when to use the PPE.

PPE available and staff know how to use it

6.6 Prevent access to areas with hazard potential and clearly mark such areas with suitable warning signs showing written and visual representation of the hazard.

Hazard areas identified on a plan and barriers in place with suitable warning signs

6.7 Encourage personnel to report near misses where Project activities or infrastructure could have potentially resulted in harm to staff, visitors, local communities or ecological systems.

Near miss register established and used



R4V03FBE: 02/19/14 E-9


Road traffic 7.1 Provide driver training, assessment and monitoring including what to do in the event of an emergency.

Training reports

7.2 Maintain vehicles in accordance with manufacturer’s instructions. Maintenance logs

7.3 Use the non-conformance and incident report system to record and evaluate the cause of traffic accidents and update traffic procedures accordingly.

Accidents are recorded and investigated

7.5 Prohibit unnecessary off road driving. No visual evidence of Project related off road driving.

7.6 Loading on each truck will be noted and should not exceed the allowable limit. Vehicle log

7.7 All vehicles will be covered to avoid dust emissions during transportation. Visual inspections

Stakeholder engagement

8.1 Develop and implement Stakeholder Engagement Plan that includes:

maintaining regular communication with stakeholders to address any potential

issues in timely manner;

maintaining a complaint procedure, and encourage and facilitate stakeholders to

use the mechanism to express concerns; and

provides sufficient resources to the community

Plan in place with records of implementation including records of communication/ information sharing

Waste Management

9.1 Prepare operation waste management plans and implement these consistent with Pakistan regulations and international standards to the extent practicable.

Plan in place with evidence of review



R4V03FBE: 02/19/14 E-10


9.2 Include in the waste management plans the following:

a commitment to a waste hierarchy comprising a) waste avoidance, source

reduction, prevention or minimization; b) waste recovery for materials that can

be re-used specifically ash; c) waste treatment to avoid potential impacts to

human health and the environment or to reduce the waste to a manageable

volume; and d) safe and responsible waste disposal specifically for ash

disposal;

inventory of wastes identifying the source/s, characteristics and expected

volumes;

waste segregation requirements;

location and type of waste collection points, which are conveniently located,

have adequate capacity, are frequently serviced and clearly labelled;

storage requirements;

opportunities for source reduction, re-use or recycling;

targets for waste re-use, recycling and incineration;

opportunities to minimize bulk or render waste non-hazardous;

procedures for operating waste storage, treatment and disposal facilities;

labeling requirements for waste disposed of offsite;

method of tracking waste recovered, incinerated or disposed of to the site’s

landfill;

method of tracking quantity, date, transporter and fate of waste disposed of

offsite;

a contingency plan should waste disposal facilities be unavailable for a time;

and

Waste management plan in place with evidence of implementation



R4V03FBE: 02/19/14 E-11


training requirements for waste management staff and other employees and

contractors.

9.3 Recycle and reuse non-hazardous waste to the extent practicable. Records of waste recycled, composed or incinerated

9.4 Preferably return hazardous waste to the associated supplier or transport to other appropriately licensed facilities off-site to the extent practicable and permitted.

Records of waste returned to supplier

9.6 Develop and implement supporting procedures to the waste management plans as needed, for the transport, storage, handling and disposal of waste materials (including hazardous waste)

Procedures in place with evidence of implementation

9.7 Maintain sewage treatment facilities according to manufacturers’ specifications and Pakistan requirements.

Maintenance logs

Wastewater 10.1 Minimize release of potentially contaminated storm water from the plant site by segregating water from potentially contaminated areas from rest of the plant.

Construction signed off by appropriately qualified engineer

10.2 Treat sewage effluent. Sewage treatment facilities in place and operating according to instructions

10.3 Deploy erosion control and sediment management measures around areas disturbed during construction.

Construction signed off by appropriately qualified engineer

Water conservation

11.1 Recycle wastewater after treatment for horticulture and road sprinkle Maintenance of water balance to track water usage

11.2 Use water efficiency technologies, as far as practicable, to minimize raw water consumption. Maintenance of water balance to track water usage

11.3 Train staff and keep them aware of good water conservation practices. Training material and records

11.4 Develop a water management plan for the Project that includes monitoring of water use, development of water balance, and periodic review of use predictions, impacts and mitigation.

Plan in place with evidence of implementation and review

Ash Disposal 12.1 Collect the ash from different sources in a timely manner

12.2 Segregate of wet and dry ash

12.3 Transport the ash from different sources to the ash disposal area immediately after collection

12.4 Proper lining of the ash disposal area with clay



R4V03FBE: 02/19/14 E-12


12.5 Compaction of the cell during the ash disposal

Coal Dust 13.1 Develop a detailed coal dust management plan Plan in place

13.2 Provide wind barriers where all potential coal / sorbent emission. Shed over coal storage and coal truck unloading area. Conveying and crusher hall to be covered for both items.

Installation of system

13.3 Use sprinkler system to suppress emission of dust from coal and for fire mitigation

13.4 Rainfall runoff from the coal pile and runoff from the application of dust suppression sprays will be routed to the settling basin for retention and settling of suspended solids, and the clear water from there may be used for the dust suppression system

Installation of system

13.4 Use dust sheild / bag house at equipment Installation of system

13.5 Maintain all dust collection and suppression systems System maintained



R4V03FBE: 02/19/14 E-13

Exhibit E.4: Waste Management Plan Summary

No. Material Waste Final Disposal Method Associated Risks Recommended Procedure

1 Iron Material returned to Store as unserviceable

Scrap Store

Recycling

Equipment and parts may be contaminated with oil or other liquids. This may pose hazards during recycling and/or melting.

Separate contaminated parts and ensure disposal contractor cleans and removes contaminations before recycling equipment.

2 Copper Recycling

Scrap Store

Copper wires and tubes may be covered with insulation and may pose hazard if melted.

Separate insulated copper from rest and ensure disposal contractor removes it before recycling.

3 Other Materials Material returned to Store as unserviceable

Scrape Store

Recycling

Landfill

Some waste materials may contain hazardous materials (such as mercury and lead) which may pose health risks if not handled or disposed of properly.

All hazardous substances such as lead and mercury will be identified and separated.

Ensure waste contractor disposes hazardous materials in accordance with accepted methods.

4 Wood, Cotton, Plastic, Waste and Packing Materials

Recycling

Landfill

Burning of wood, paper, plastic and other materials may cause air pollution

Littering due to improper disposal

Ensure waste contractor disposes all non–recyclable plastic wastes and other non–recyclable materials at land disposal.

5 Electronics Material returned to Store as unserviceable

Some electronic equipment may contain toxic materials and pose a health risk if opened or dismantled.

Ensure contractor disposes equipment properly and equipment is opened only under guidance of qualified professional.

6 Insulation Material Re–used

Landfill

Burning may cause air pollution.

Littering due to improper disposal

Ensure contractor disposes insulation properly at landfill site.

7 Oil Recycling Contractors May cause contamination of soil or waterways Ensure properly certified recycling contractors are used.

8 Concrete Landfill or reuse as for filling None Ensure safe storage till disposal

9 Asbestos To be handled according to the Asbestos Management plan



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E.6 Monitoring Plan

Environmental monitoring is a vital component of an EMP. It is the mechanism through

which the effectiveness of the EMP is gauged. The feedback provided by environmental

monitoring is instrumental in identifying any problems and planning corrective actions.

E.6.1 Objective of Monitoring

The main objectives of environmental monitoring during the construction phase of the

proposed coal conversion plan will be:

To provide a mechanism to determine whether the project construction

contractors and the Owners plant management are carrying out the project in

conformity with the EMP.

To identify areas where the impacts of the projects are exceeding the criteria of

significance and, therefore, require corrective actions.

To document the actual project impacts on physical, biological, and

socioeconomic receptors, quantitatively where possible, in order to design better

and more effective mitigation measures.

To provide data for preparing the monitoring report to be submitted to the Sindh

EPA in accordance with the national law requirement.

E.6.2 Performance Indicators

The environmental parameters that may be qualitatively and quantitatively measured and

compared are selected as ‘performance indicators’ and recommended for monitoring

during project stages. These monitoring indicators will be monitored to ensure

compliance with the national or other applicable standards and comparison with the

baseline conditions established during design stage. The list of indicators and their

applicable standards to ensure compliance are given below.

Construction Phase

1. Ambient air quality (PM10, PM2.5, SO2, and NO2) – Pakistan National

Environmental Quality Standards,(NEQS) 2010

2. Noise levels – Pakistan National Standards, NEQS 2100

Operation Phase

1. Stack emissions (SO2, NOX, PM10) – NEQS. Continuous emission monitoring

on new boilers. Monthly testing on other boilers. (Exhibit E.5 and Exhibit E.6)

2. Ambient air quality (PM10, PM2.5, SO2, and NO2) – Pakistan National

Environmental Quality Standards,(NEQS) 2010

3. Noise levels – Pakistan National Standards, NEQS 2010

4. Wastewater quality (Exhibit E.7 and E.8) – Pakistan National Standards, NEQS

2000

5. Cooling water inlet and outlet temperature – Continuous measurement

6. Coal consumption per unit of power generated (Kg/unit) and generation of bottom

and fly ash (Exhibit E.9) – Comparison with design data



R4V03FBE: 02/19/14 E-15

Exhibit E.5: Air Emission Monitoring Plan

As per requirement.

Within and outside CPP project locations

Circulating Fluidized Bed (CFB) Boilers.

Temperature

SOx

Flow

CO

NOx

Particulate

Matter

CFB

Boiler 2

NOx1

SOx

Particulate

Matter

Ambient Air

Monitoring2

Flow

Temperature

CO

NOx

SOx

Particulate

Matter

CFB3

Boiler 1



R4V03FBE: 02/19/14 E-16

Exhibit E.6: Environmental Monitoring Schedule for Air Emission

Effluent Source Nature of Discharge Treatment End Point Analysis Frequency

CFB Boiler 1 Flue Gas Yes1 To Atmosphere As per requirement

CFB Boiler 2 Flue Gas Yes1 To Atmosphere As per requirement

CFB boiler technology operates at lower furnace thus generate NOx and will be within the NEQS / WBG guidelines as compared to other boiler technology. Moreover, sulfur will be captured inside the furnace by the help of sorbent while PM will be removed (>99.9%) in bag house filter (provided for each boiler). Moreover, emission monitoring system shall be available to ensure better operational& environmental control as well as stack height has been considered based on dispersion modeling.



R4V03FBE: 02/19/14 E-17

Exhibit E.7: Liquid Effluents Sampling and Monitoring Plan

Effluents

Treatment

End Point

SP: Proposed Sampling Point & PQA: Port Qasim Authority

SP -Flow /Temp -pH -TSS / Cond./TDS - COD / BOD - PO4 - Chloride /Sulfate - F.Cl2 - Oil

- Cadmium

Cooling Tower

Blow-Down

Oil

Spill

Chemical

Effluent

Sanitary

Wastes

Strom Water

Offsite Plant

site

Holding

Basin

Decantation

Basin

Septic Tank

Ash conditioning &

Horticulture

Neutralization

if required

Evaporation Pond

PQA Sanitary Sewer (When

available) Soaking Pit

SP -Flow -Temp -pH -TSS -F.Cl -PO4

No flow during normal operation

Coal yard Dust & Fire

Mitigations

Main flow towards CPP plant during normal plant operation however in case of rain to be routed to storm water after detention time of 10 ~ 15min.

Oil spill control to be included.

Plant Effluent Channel / PQA Drain Channel



R4V03FBE: 02/19/14 E-18

Exhibit E.8: Environmental Monitoring Schedule for Liquid Effluents

Effluent Source Nature of Discharge

Treatment End Point

Cooling Tower Blow Down Not required1 Re-use in Ash

conditioning, Horticulture

1 & balance in

Plant Effluent Channel

Boiler

Boiler

Cooling Tower & BFW Chemicals

Continuous Blow down

Intermittent Blow down

Spills2

Heat recovery

Heat recovery

Neutralization

Cooling tower basin

Cooling tower basin / Evaporation pond

Evaporation pond

CPP Building Sanitary Sewage Septic tank Soaking Pit

Paved Area and Rain Water Drains from coal handling area

Washings Decantation & Filtration

Recycling for dust suppression at coal yard

1. Will be within NEQS limits and will be used for ash conditioning as well as for horticulture and balance to be routed to storm water channel.

2. There will be no flow during normal operation. All chemicals used will be stored in day tanks and used at cooling tower & BFW area only and tanks will be in RCC dyke as a spill control measure however effluent outlet from dyke to be routed to evaporation pond after neutralization. Chemicals are mostly environmental friendly.



R4V03FBE: 02/19/14 E-19

Exhibit E.9: Environmental Monitoring Schedule of Solid Waste

Effluent Source Nature of Discharge

Treatment End Point Analysis Frequency

Fly Ash

Bottom Ash

Coal dust

Decantation Basin

Ash

Ash

Dust

Sludge

Conditioning to minimize dust generation

Conditioning to minimize dust generation

Dedusting system included

1

Decantation & Filtration

Land filling /Other industry usage

Land filling /Other industry usage

Recycling

Recycle to coal yard

On-as-and-when-required basis

On-as-and-when-required basis

-

-

1 All dust generation locations (conveyors, crushers, cyclones, bag house filters, etc) to be equipped with dust control and recycling arrangement. Moreover, dust suppression (water based & fogging system) to be included at coal yard and at all appropriate points.

E.6.3 Environmental Monitoring Plan

The detailed environmental monitoring plan will be finalized prior to commencement of

construction and operation. The requirements identified in the environmental assessment

are presented in Exhibit E.3 for construction phase and in Exhibit E.11 for operation

phase.



R4V03FBE: 02/19/14 E-20

Exhibit E.10: Monitoring Plan during Construction Phase

Project Activity and Potential Impact

Objective of Monitoring

Parameters to be Monitored

Measurements Location Frequency Responsibility

Air Quality

Dust emissions during construction

To determine the effectiveness of dust control programs at receptor level

PM10 (particulate matter <10 microns) and PM2.5 concentration

1 hour and 24 hour concentration levels

At three representative locations

Once every three months on a typical working day

Contractor’s environmental officer, the Owners

Visible dust Visual observation of size of dust clouds, their dispersion and direction of dispersion

Construction site Daily during construction period


Exhaust emissions from generators and other construction equipment

To determine the effectiveness of gaseous emission control measures

Gaseous emission rates from generators and other equipment

COx, NOx. SOx, and PM measurements should be taken at full, typical, and idling conditions

Exhaust Baseline when equipment is first put into use, and once a week after that


Erosion

Creek bank erosion due to wind and construction activities

To determine the effectiveness of erosion control measures

Visual inspections Creek banks Weekly Contractor’s environmental officer, the Owners

Water/Soil Contamination

Contamination due to oil/chemical leakages

To determine the effectiveness of control measures taken to minimize the risk of oil and chemical spills

Procedures in place to handle liquids and availability of procedures and equipment for emergency response incidents

Visual inspections and availability checks

Construction site Weekly Contractor’s environmental officer, the Owners



R4V03FBE: 02/19/14 E-21

Project Activity and Potential Impact

Objective of Monitoring

Parameters to be Monitored

Measurements Location Frequency Responsibility

Traffic

Exhaust and PM emissions from trucks transporting construction materials

To determine the effectiveness of control measures taken to minimize exhaust and dust emissions from trucks

Vehicle exhaust emissions and visual inspection to ensure vehicle load is secured

Vehicle exhaust emissions, Smoke, NOx, SOx and CO

Construction material transport trucks

Weekly Contractor’s environmental officer, the Owners

Land Reclamation

Reclaimed land for ash disposal

To determine the effectiveness of control measures taken to minimize impacts of land reclamation

Abundance of Avicenna sp

Number of individuals Land reclamation site Quarterly Contractor’s environmental officer, the Owners



R4V03FBE: 02/19/14 E-22

Exhibit E.11: Monitoring Requirements during Operational Phase

Aspect Type of monitoring Frequency Location/s

Land disturbance Soil quality (major metals, nutrients, organic contents, and TPH)

As per requirement Monitoring points around the plant and Ash Disposal Area

Visual inspection of road condition Quarterly or on receipt of grievance

Access road for coal transport

Effluent Water Water quality (as indicated in NEQS) Daily All the effluent channels exit point from the plant into the sea

Water resources Groundwater quality around ash disposal site to monitor any leachate

Quarterly 3 monitoring points around the plant and Ash Disposal Area

Air PM10 and TSP for 24 hour filter-based low-volume sampler

Annually 4 monitoring points around the plant

Ambient 24 hr NO2 and SO2 concentrations (using active sampler)

Once every year 4 monitoring points around the plant

Stack testing As per the regulations All stacks

Continuous Emission Monitoring (CEM)

New coal boilers

Times and duration of upset conditions When upset conditions occur All plant stacks

Vehicles and equipment Random speed checks As per the regulations

Records of vehicle and equipment maintenance As per manufacturer’s instructions

Transport office and workshop

Baseline noise emissions of new equipment On commissioning of new equipment

Within 100m of equipment

Ecological Records of animal and fish kills On occurrence Surrounding areas around plant site and ash disposal area

Records of major wildlife sightings On occurrence Access road and surrounding areas



R4V03FBE: 02/19/14 E-23

Aspect Type of monitoring Frequency Location/s

Community Community grievances or complaints, categorized by type.

Monthly Grievance register maintained at plant site

Hazardous material Records of hazardous materials used On arrival at site Warehouse or storage facility

Inspections of hazardous substances containment facilities, instrumentation and detection systems.

On occurrence

Waste Volume of different wastes types disposed of to landfill or incineration

Continuous Waste disposal sites

Volume of different waste types recycled or reused Continuous Waste disposal sites

Volume of soil bio-remediated Continuous Waste management site at mine



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E.6.4 Environmental Records

The following environmental records will be maintained:

Periodic inspection reports of Contractor’s Environmental Officer or his designate

Incident record of all moderate and major spills. The record will include:

Location of spill

Estimated quantity

Spilled material

Restoration measures

Photographs

Description of any damage to vegetation, water resource

Corrective measures taken, if any

Corrective measures taken, if any

Waste Tracking Register that will records of all waste generated during the

construction and operational period. This will include quantities of waste

disposed, recycled, or reused

Survey reports, in particular, the following:

Soil erosion: Baseline survey, including photographs (or video), will be conducted

to document pre-construction condition of the construction corridor

Vehicle and equipment noise

Ambient noise survey reports

E.7 Communication and Documentation

An effective mechanism to store and communicate environmental information during the

project is an essential requirement of an EMP.

E.7.1 Meetings

Two kinds of environmental meetings will take place during the project:

Kick-off meetings

Fortnightly meetings

The purpose of the kick-off meeting will be to present the EMP to project staff and

discuss its implementation.

A fortnightly meeting will be held during construction phase at site. The purpose of this

meeting will be to discuss the environmental issues and their management. The

proceedings of the meeting, the required action, and responsibilities will be recorded in

the form of a brief report.



R4V03FBE: 02/19/14 E-25

E.7.2 Reports

Environmental reports will be prepared on a bi-monthly basis during the construction and

quarterly during the operation. The report will be provided to the Owners.

E.7.3 Change-Record Register

A change-record register will be maintained at the site, in order to document any changes

in EMP and procedures related to changes in the project design, construction plan or

external environmental changes affecting the EMP. These changes will be handled

through the change management mechanism discussed later in this chapter.

E.8 Change Management

An environmental assessment of the proposed project has been made on the basis of the

project description available at the time the environmental assessment report was

prepared. However, it is possible that changes in project design may be required at the

time of project implementation. This section describes the mechanism that will be put

into place to manage changes that might affect the project’s environmental impacts.

Potential changes in project design have been categorized as first-order, second-order,

and third-order changes. These are defined below.

E.8.1 First-Order Change

A first-order change is one that leads to a significant departure from the project described

in the environmental assessment report and consequently requires a reassessment of the

environmental impacts associated with the change.

In such an instance, the environmental impacts of the proposed change will be reassessed,

and the results sent to the Sindh EPA for approval.

E.8.2 Second-Order Change

A second-order change is one that entails project activities not significantly different

from those described in the environmental assessment report, and which may result in

project impacts whose overall magnitude would be similar to the assessment made in this

report.

In case of such changes, the environmental impact of the activity will be reassessed,

additional mitigation measures specified if necessary, and the changes reported to the

Sindh EPA.

E.8.3 Third-Order Change

A third-order change is one that is of little consequence to the environmental assessment

reports’ findings. This type of change does not result in impact levels exceeding those

already discussed in the environmental assessment; rather these may be made onsite to

minimize the impact of an activity. The only action required in this case will be to record

the change in the change record register.

E.8.4 Changes to the EMP

Changes in project design may necessitate changes in the EMP. In this case, the

following actions will be taken:



R4V03FBE: 02/19/14 E-26

A meeting will be held between the Owners and the contractor representatives, to

discuss and agree upon the proposed addition to the EMP

Based on the discussion during the meeting, a change report will be produced

collectively, which will include the additional EMP clause and the reasons for its

addition

A copy of the report will be sent to the head offices of the Owners and the

contractor

All relevant project personnel will be informed of the addition

E.9 Environmental Training

Environmental training will help to ensure that the requirements of the environmental

assessment and EMP are clearly understood and followed by all project personnel in the

course of the project. The contractor will be primarily responsible for providing training

to all project personnel. An indicative environmental and social training program is

provided in Exhibit E.12, which will be finalized before the commencement of the

project.



R4V03FBE: 02/19/14 E-27

Exhibit E.12: Training Program

Type of Training Training By

Personnel to be Trained

Training Description Period Duration

Occupational Health and Safety External

Sources

EHS Manager Training should be provided to aware staff to

conform to safety codes.

Before starting of

project activities

Full day

Occupational Health and Safety EHS

Manager

Workers

Staff

Health, safety and hygiene

Proper usage of personnel protective gear

Precautions to be taken for working in confined

areas.

Before starting of

project activities

During Project

Activities

Full day

Health, Safety and Environmental

Auditing

External

Sources

Staff responsible

for

inspection/audits

Procedures to carry out Health, Safety and

Environmental Audits

Reporting requirements

Before starting of

project activities

Full day

Waste Disposal and Handling External

Sources

Relevant Workers

Relevant Staff

Segregation, identification of hazardous waste, use

of PPEs, waste handling

Before starting of

project activities

Full day

Social & Environmental laws &

regulations, norms, procedures

and guidelines of Government

External

sources

EHS staff

Plant managers

and supervisors

Environmental standards and their compliance

Govt. regulations

Before starting

the project

activities

Full day

Implementation of environmental

management and monitoring plant

External

Sources

EHS staff

Responsible

supervisory staff

Management

Concepts of environmental management and

monitoring plan

Once in 3 months

during the entire

construction

period

Full day

Asbestos management External

Sources

EHS staff

Responsible

supervisory staff

Management

As per Asbestos Management Plan Before starting of

project activities

Two full day



R4V03FBE: 02/19/14 E-28

E.10 Construction Management Plan

The construction contractor will develop a specific construction management plan (CMP)

based on the CMP included in the Exhibit E.13. The CMP will be submitted to the

BQPS for approval.

The CMP will clearly identify all areas that will be utilized during construction for

various purposes. For example, on a plot plan of the construction site the following will

be shown:

Areas used for camp

Storage areas for raw material and equipment

Waste yard

Location of any potentially hazardous material such as oil

Parking area

Loading and unloading of material

Septic tank

Exhibit E.13: Construction Management Plan

Aspect Objective Mitigation and Management Measure

Vegetation

clearance

Minimize vegetation

clearance and felling

of trees

Removal of trees should be restricted to the development footprint.

Construction activities shall minimize the loss or disturbance of vegetation

Use clear areas to avoid felling of trees

A procedure shall be prepared to manage vegetation removal, clearance and reuse

Inform the plant management before clearing trees

Cleared areas will be revegetated

Poaching Avoid illegal poaching Contractual obligation to avoid illegal poaching

Provide adequate knowledge to the workers relevant government regulations and punishments for illegal poaching

Discharge

from

construction

sites

Minimize surface and ground water contamination

Reduce contaminant and sediment load discharged into water bodies affecting humans and aquatic life

Install temporary drainage works (channels and bunds) in areas required for sediment and erosion control and around storage areas for construction materials

Prevent all solid and liquid wastes entering waterways by collecting waste where possible and transport to approved waste disposal site or recycling depot

Ensure that tires of construction vehicles are cleaned in the washing bay (constructed at the entrance of



R4V03FBE: 02/19/14 E-29


the construction site) to remove the mud from the wheels. This should be done in every exit of each construction vehicle to ensure the local roads are kept clean.

Soil Erosion

and siltation

Avoid sediment and

contaminant loading of

surface water bodies

and agricultural lands.

Minimize the length of time an area is left disturbed or exposed.

Reduce length of slope of runoff

Construct temporary cutoff drains across excavated area

Setup check dams along catch drains in order to slow flow and capture sediment

Water the material stockpiles, access roads and bare soils on an as required basis to minimize dust.

Increase the watering frequency during periods of high risk (e.g. high winds)

All the work sites (except permanently occupied by the plant and supporting facilities) should be reinstated to its initial conditions (relief, topsoil, vegetation cover).

Excavation,

earth works,

and

construction

yards

Proper drainage of

rainwater and

wastewater to avoid

water and soil

contamination.

Prepare a program for prevent/avoid standing waters, which Construction Supervision Contractor (CSC) will verify in advance and confirm during implementation

Establish local drainage line with appropriate silt collector and silt screen for rainwater or wastewater connecting to the existing established drainage lines already there

Ponding of

water

Prevent mosquito

breeding

Do not allow ponding of water especially near the waste storage areas and construction camps

Discard all the storage containers that are capable of storing of water, after use or store them in inverted position

Reinstate relief and landscape.

Storage of

hazardous

and toxic

chemicals

Prevent spillage of

hazardous and toxic

chemicals

Implement waste management plans

Construct appropriate spill containment facilities for all fuel storage areas

Remediate the contaminated land using the most appropriate available method to achieve required commercial/industrial guideline validation results



R4V03FBE: 02/19/14 E-30


Land clearing Preserve fertile top

soils enriched with

nutrients required for

plant growth or

agricultural

development.

Strip the top soil to a depth of 15 cm and store in stock piles of height not exceeding 2m and with a slope of 1:2

Spread the topsoil to maintain the physio–chemical and biological activity of the soil.

The stored top soil will be utilized for covering all disturbed area and along the proposed plantation sites

Topsoil stockpiles will be monitored and should any adverse conditions be identified corrective actions will include:

Anaerobic conditions – turning the stockpile or creating ventilation holes through the stockpile;

Erosion – temporary protective silt fencing will be erected;

Avoid change in local

topography and

disturb the natural

rainwater/ flood water

drainage

Ensure the topography of the final surface of all raised lands are conducive to enhance natural draining of rainwater/flood water;

Reinstate the natural landscape of the ancillary construction sites after completion of works

Construction

vehicular

traffic

Control vehicle

exhaust emissions

and combustion of

fuels.

Use vehicles with appropriate exhaust systems.

Establish and enforce vehicle speed limits to minimize dust generation

Cover haul vehicles carrying dusty materials (cement, borrow and quarry) moving outside the construction site

Level loads of haul trucks travelling to and from the site to avoid spillage

Use of defined haulage routes and reduce vehicle speed where required.

Regular maintenance of all vehicles

All vehicle exit points from the construction site shall have a wash-down area where mud and earth can be removed from a vehicle before it enters the public road system.

Minimize nuisance

due to noise

Maintain all vehicles in good working order

Make sure all drivers comply with the traffic codes concerning maximum speed limit.

Avoid impact on

existing traffic

conditions

Prepare and submit a traffic management plan

Restrict the transport of oversize loads.

Operate transport vehicles, if possible, in non–peak periods to minimize traffic disruptions.



R4V03FBE: 02/19/14 E-31


Prevent accidents and

spillage of fuels and

chemicals

Restrict the transport of oversize loads.

Operate transport vehicles, if possible, in non–peak periods to minimize traffic disruptions.

Design and implement safety measures and an emergency response plan to contain damages from accidental spills.

Designate special routes for hazardous materials transport.

Construction

machinery

Prevent impact on air

quality from emissions

Use machinery with appropriate exhaust systems.

Regular maintenance of all construction machinery

Provide filtering systems, duct collectors or humidification or other techniques (as applicable) to the concrete batching and mixing plant to control the particle emissions in all stages

Reduce impact of

noise and vibration on

the surrounding

Appropriately site all noise generating activities to avoid noise pollution to local residents.

Ensure all equipment is in good repair and operated in correct manner.

Install high efficiency mufflers to construction equipment.

Operators of noisy equipment or any other workers in the vicinity of excessively noisy equipment are to be provided with ear protection equipment

Construction

activities

Minimize dust

generation

Water the material stockpiles, access roads and bare soils on an as required basis to minimize dust.

Increase the watering frequency during periods of high risk (e.g. high winds).

Stored materials such as gravel and sand should be covered and confined

Locate stockpiles away from sensitive receptors

Reduce impact of noise and vibration on the surrounding

Avoid driving hazard where construction interferes with pre– existing roads.

Notify adjacent landholders or residents prior to noise events during night hours

Install temporary noise control barriers where appropriate

Avoid working during 21:00 to 06:00 within 500m from residences.

Minimizing impact on water quality

Stockpiles of potential water pollutants (i.e. bitumen, oils, construction materials, fuel, etc.) shall be locate so as to minimize the potential of contaminants to enter local watercourses or storm-water drainage.



R4V03FBE: 02/19/14 E-32


Storm-water runoff from all fuel and oil storage areas, workshop, and vehicle parking areas is to be directed into an oil and water separator before being discharged to any watercourse.

An Emergency Spills Contingency Plan shall be prepared.

Siting and

location of

construction

camps

Minimize impact from

construction footprint

Locate the construction camps at areas which are acceptable from environmental, cultural or social point of view.

Construction

Camp

Facilities

Minimize pressure on

local services

Adequate housing for all workers

Safe and reliable water supply.

Hygienic sanitary facilities and sewerage system.

Treatment facilities for sewerage of toilet and domestic wastes

Storm water drainage facilities.

In–house community entertainment facilities.

Disposal of

waste

Minimize impacts on

the environment

Ensure proper collection and disposal of solid wastes in the approved disposal sites

Store inorganic wastes in a safe place within the household and clear organic wastes on daily basis to waste collector.

Establish waste collection, transportation and disposal systems

Ensure that materials with the potential to cause land and water contamination or odor problems are not disposed of on the site.

Ensure that all on-site wastes are suitably contained and prevented from escaping into neighboring fields, properties, and waterways, and the waste contained does not contaminate soil, surface or groundwater or create unpleasant odors for neighbors and workers.

Fuel supplies

for cooking

purposes

Discourage illegal fuel

wood consumption

Provide fuel to the construction camps for domestic purpose

Conduct awareness campaigns to educate workers on preserving the biodiversity and wildlife of the project area, and relevant government regulations and punishments on wildlife protection.

Site

Restoration

Restoration of the

construction camps to

original condition

To the extent possible, restore the camp site and all other areas temporarily used for construction to their conditions that existed prior to commencement of construction work.



R4V03FBE: 02/19/14 E-33


Construction

activities near

religious and

cultural sites

Avoid disturbance to

cultural and religious

sites

Stop work immediately and notify the site manager if, during construction, an archaeological or burial site is discovered.

It is an offence to recommence work in the vicinity of the site until approval to continue is given by the plant management.

Maintain appropriate behavior with all construction workers especially women and elderly people

Resolve cultural issues in consultation with local leaders and supervision consultants

Best practices Minimize health and

safety risks

Implement suitable safety standards,

Provide the workers with a safe and healthy work environment, taking into account inherent risks in its particular construction activity and specific classes of hazards in the work areas,

Provide personal protection equipment (PPE) for workers, such as safety boots, helmets, masks, gloves, protective clothing, goggles, full–face eye shields, and ear protection.

Maintain the PPE under a regular checking and replacement program

Water and

sanitation

facilities at the

construction

sites

Improve workers’

personal hygiene

Provide portable toilets at the construction sites and drinking water facilities.

Portable toilets should be cleaned once a day.

All the sewerage should be pumped from the collection tank once a day into the common septic tank for further treatment.

E.11 Coal Dust Management Plan

Coal dusts from coal stockpile and coal conveyor belt area are the major source of

fugitive emissions. It is recommended that all activities where dust is anticipated to be

properly covered and sealed. Dust suppression using a sprinkler system will be primarily

employed to control the coal dust from these areas. Recycled water from the waste water

treatment plants and fire water (in case of fire in coal) will be the primary source of water

to the sprinkler system.

Two methods of dust control will be implemented: dust extraction and dust suppression.

Coal dust suppression will comprise wetting air–borne dust particles with a fine spray of

water, causing the dust particles to agglomerate and move by gravity to the coal stream

flow. Once properly wetted, the dust particles will remain wet for some period and will

not tend to become airborne again. The dust suppression system in the stockpile yard will

consist of swivelling and wide–angle full–cone spray nozzles. These nozzles will be

provided on both sides of the pile and at ground level, spaced every 50 m. Ventilation



R4V03FBE: 02/19/14 E-34

slots are proposed in the top portion of the raw coal bunkers, allowing coal fed into the

bunkers to displace any gases that may have formed as a result of resident coal.

In the coal dust extraction system, dust will be extracted from screening feeders and belt

feeders by suctioning the dust–laden air and trapping coal particles in fine water sprays,

thereafter discharging the clean air into the atmosphere. The dust collection equipment

will include cyclones, wet scrubbers, fans, collecting hoppers, filters, hoods, ducts,

dampers, and drain pipes. In this system, the dust–laden air will enter the collector where

it comes in contact with water; the slurry will be collected in the hopper and disposed of

in the settling pond. Settle dust will be put back into the stockyard where it will be mixed

with crushed coal for use. In addition, roof extraction fans will be provided in essential

areas like crusher house and boiler bunker floors. Air conditioning for control room and

pressurized ventilation with unitary air filter unit for Electrical and Control buildings of

coal handling plant will be provided.

Rainfall runoff from the coal pile and runoff from the application of dust suppression

sprays will contain mainly suspended solids. This runoff will be routed to the settling

basin for retention and settling of suspended solids, and the clear water from there may be

used for the dust suppression system.

The volatility of the coal of this project is high, easy to cause spontaneous combustion;

therefore, the coal to the coal yard must be stored in different piles and compacted, the

earlier it comes, the earlier it is to be used, with regular rearrangement of the coal piles.

The bucket wheel machine itself is equipped with water tank to spray water over the fly

dust points so as to reduce the fly dust. The coal pile shall have an automatic temperature

monitoring system; when an increase in temperature is detected, an alarm will be

immediately triggered, alerting of the presence of hot spots. Based on the temperature

and the risks, the coal will be either immediately sent to the boiler for utilization, or the

portion of coal will be isolated and allowed to burn off. Coal fires cannot be extinguished

by water. Rubber belt of the belt conveyer shall use flame retardant material.

E.12 Ash Management Plan

The ash pond will have a raised bund. For ease of operation, the ash pond plot will be

divided into smaller plots. This enables the ponds to be filled properly. The ash pond is to

be lined with a layer of HDPE membrane or compact clay liner in order to avoid water

seepages to the ground or the sea.

The options of ash utilization including the ash–based products include:

Brick/Block/Tiles Manufacturing

Cement Manufacturing

Roads and Embankment Construction

Structural Fill for Reclaiming Low Lying Areas

Mine–Filling

Agriculture, Forestry and Waste–land Development



R4V03FBE: 02/19/14 E-35

Part Replacement of Cement in Mortar, Concrete and Ready Mix Concrete

Hydraulic Structure (Roller Compacted Concrete)

Building Components – Mortar, Concrete,

Concrete Hollow Blocks, Aerated Concrete Blocks etc.





Component in road bases, sub–bases, and pavement


Other Medium and High Value Added Products (Ceramic Tiles, Wood, Paints)

Pavement Blocks, Light Weight Aggregate, Extraction of Alumina, Cenospheres,

etc.

The following strategies will be adopted to ensure full fly ash utilization in brick and

cement block manufacturing:

Practically there should not be any leachate from ash pond due to provision of

impermeable layer at the bottom of ash pond. However, a groundwater monitoring

program is recommended to detect any possible groundwater contamination from ash

pond. 3 piezometers, one on upstream, 2 on downstream of the ash pond will be installed

for collection of water levels and water samples.

E.13 Asbestos Management Plan

Asbestos is recognized internationally as a hazardous material because it can present a

risk to human health. In many jurisdictions asbestos is classified as hazardous and is a

controlled chemical waste or a hazardous waste because if it is mishandled it can release

airborne fibers that are known to cause asbestosis and have also associated with other

lung diseases and cancer. All forms of the asbestos mineral will release asbestos fibers if

broken up and all types of asbestos containing material (ACM) will release asbestos

fibers to some degree if damaged or abraded.

Asbestos has been widely used in numerous types of materials, usually because of its

good qualities as a thermal insulation material. Asbestos has also been used extensively

in numerous types of cement materials, pipe insulation plaster and in refractory brick

work. Asbestos is often used because of its good qualities as a thermal insulation material

but it is also useful as a binder to form complicated cement shapes and durable pipes. The

amounts of asbestos used vary from product to product but certain types of asbestos

cement can contain more than 50% asbestos. When bound in the cement matrix the

asbestos is generally considered safe. However over time the cement surface can become

corroded or abraded leading to the release of asbestos fibers. The surface of the ACM,

such as pipe and corrugated sheets can gradually become more friable and release

asbestos fibers. Exposure to chemicals and moisture also affects the rate of deterioration



R4V03FBE: 02/19/14 E-36

of ACM as they gradually wear out or become more fragile. The removal and

replacement of ACM also give rise to some release of fiber as it is almost impossible to

remove more fragile old material without breaking them. Therefore in addition to giving

rise to a controlled waste the removal of the ACM can also easily lead to the release of

asbestos fibers if the removal is not conducted under controlled conditions.

This plan has been prepared because the ACM is likely to be present in the power plants

which may be broken or cracked during the demolition work of old structure. The

procedures to be adopted are outlined in this framework by reference to known asbestos

in ACM. This framework should be applied whenever any ACM is identified. Prior to

any removal work asbestos investigation should be carried out to check if there is any

likelihood of ACM being implicated.

E.13.1 Requirement for Asbestos Management

Best practice asbestos management usually entails several stages. Survey and

investigation are the first steps in which all structural elements, fixtures and fittings are

checked for fibrous materials that are potentially asbestos. Samples are taken under

controlled conditions and an accredited laboratory analyses the samples using polarized

light microscopy. The type, location and condition of asbestos is assessed to undertaken a

hazard assessment. If asbestos needs to be removed an asbestos abatement plan is usually

prepared to cover removal with detailed work specifications for specialist contractors. In

all cases the asbestos should be labeled and safety procedures instigated to prevent

disturbance, until such time as it can be removed safely.

There are as yet no statutory controls on hazardous waste in Pakistan. The Hazardous

Substances Rules were drafted in 2003 but were never brought into force. Asbestos waste

is listed in the draft Hazardous Substances Rules 2003. If enacted the HSR would require

an entity licensed under the Pakistan Environmental Protection Act 1997 to have a waste

management plan for any listed hazardous substance.

Therefore as there are as yet no local standards for asbestos control in Pakistan, any

known asbestos waste requiring removal should be disposed of following best

international practice.

E.13.2 Responsibilities and Authorities

Potential environmental liabilities with respect to asbestos associated with subprojects

will be minimized by implementing the requirements of the AMF and by prescribing the

selection of alternative non-asbestos materials.

The owners will:

Prepare an asbestos investigation report (AIR) before undertaking any demolition

work.

Ensure that adequate sampling and analysis has been carried out to ensure all

environmental liabilities with respect to asbestos have been identified, and review

the asbestos assessments AIR.

Ensure that the contracts have specified the asbestos management procedure

(AMP) to be used in the construction of the subproject to control environmental

liabilities to acceptable levels.



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Ensure that the asbestos abatement procedures, including all proposed mitigation

measures and monitoring are properly implemented.

Monitor the implementation of AMPs and present its monitoring report.

E.13.3 Minimizing Asbestos Liabilities

Potential environmental liabilities with respect to asbestos associated with subprojects

will be minimized by taking the following measures:

Implementing the requirements of the AMF and by prescribing the selection of

alternative non-asbestos materials.

Where ACM must be disturbed in a equipment the ACM shall only be removed

under controlled conditions for disposal in line with the provisions of the AMF or

any rules subsequently promulgated by the Sindh EPA.

All Contractors shall agree through their agreement to carry out the asbestos

abatement procedures in line with the procedures included in the AMF.

Conducting sampling of potential asbestos containing materials (ACM) and

compiling an asbestos investigation report (AIR) with adequate implementation.

E.13.4 Monitoring During the Construction Period

Monitoring during construction will be the responsibility of the Contractor. The

Contractor may acquire the services of an Asbestos Specialist. The monitoring will relate

to compliance with construction contracts. The Asbestos Specialist will inspect the

ongoing works regularly and systematically; checking that the above-mentioned the

asbestos abatement mitigation measures specified in the AMP have been implemented

effectively during the design and construction stages of the project and ensure the

implementation and effectiveness of mitigation measures. Reporting will be to the the

Owners on a regular basis.

The Contractor will also be responsible for coordinating and supervising monitoring of

asbestos abatement, quality control, and writing the periodic progress reports on

implementation of the AMF.

E.14 Spill Management

Liquid waste spills that are not appropriately managed have the potential to harm the

environment. By taking certain actions BQPS can ensure that the likelihood of spills

occurring is reduced and that the effect of spills is minimized.

To enable spills to be avoided and to help the cleanup process of any spills, the EPC

contractors and the management and staff of the Owners should be aware of spill

procedures. By formalizing these procedures in writing, staff members can refer to them

when required thus avoiding undertaking incorrect spill procedures.

A detailed spill management plan will be prepared for the construction phase. Similar,

plan will also be developed for specific areas during plant operation. The plan will

contain the following:



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Identification of potential sources of spill and the characterization of spill material

and associated hazards.

Risk assessment (likely magnitude and consequences)

Steps to be undertaken taken when a spill occurs (stop, contain, report, clean up

and record).

A map showing the locations of spill kits or other cleaning equipment.

E.14.1 Avoiding spills

By actively working to prevent spills, money and time can be saved by not letting

resources go to waste. In addition, the environment is protected from contaminants that

can potentially cause harm.

All liquids will be stored in sealed containers that are free of leakage. All containers will

be on sealed ground and in an undercover area. Sharp parts will be kept away from liquid

containers to avoid damage and leaks.

Bunding: To prevent spills from having an effect on the plant site operations or the

environment, bunding will be placed around contaminant storage areas. A bund can be a

low wall, tray, speed bump, iron angle, sloping floor, drain or similar and is used to

capture spilt liquid for safe and proper disposal.

E.14.2 Spill Kits

Spill kits are purpose designed units that contain several items useful for cleaning up

spills that could occur. Typical items are:

Safety gloves and appropriate protective clothing (depending on the type of

chemicals held onsite)

Absorbent pads, granules and/or pillows

Booms for larger spills

Mops, brooms and dustpans.

Spill kits are used to contain and clean up spills in an efficient manner. Sufficient number

of spill kits will be provided. Spill kits will be kept in designated areas that are easily

accessible to all staff. Staff members will be trained in using the spill kit correctly.

After cleaning up a spill, the materials used to clean up will be disposed of correctly.

Depending on the spill material, the used material may be disposed in the hazardous

waste facility or the landfill site.

E.14.3 Responding to spills

Stop the source: If it is safe to do so, the source of the spill should be stopped

immediately. This may be a simple action like upturning a fallen container.

Contain and control the flow: To stop the spill from expanding, absorbent materials and

liquid barriers should be placed around the spill. Work from the outside to soak up the

spill. It is vital that spilt liquid is not allowed to reach storm water drains, sewer drains,

natural waterways or soil.



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For large scale spills that involve hazardous materials, authorities may have to be alerted.

Clean up: Using information from Material Safety Data Sheets (MSDS) about the

properties of the liquid spilled and the spill equipment available, spills should be cleaned

up promptly.

Record the incident: By keeping a simple log of all spills, precautionary measures can be

put in place to avoid similar accidents from occurring in the future.