Environmental Impact Assessment

(EIA)
of

Acorn Infrastructure
Services (Unit-3) Limited
at

Jhulda, Chittagong

Prepared By:
Adroit Environment Consultants Ltd (AECL)
6/8, Sir Syed Road, Mohammadpur, Dhaka-1207, Bangladesh
Tel: 8126082, 8152113, Fax: 880-2-8155542
E-Mail: [email protected], Web: www.aecl-bd.org
February, 2018
Contents
 Table of Contents

Table of Contents

Abbreviation 1
Glossary 6
Executive Summary 10

Chapter - 1 Introduction
1.1 Project Background 15
1.2 Objective 17
1.3 Study Area 18
1.4 Scope Of Work 18
1.5 The EIA Team 19
1.6 Limitations 20
1.7 Acknowledgement 21

Chapter - 2 Policy and Legal Consideration

2.0 Policy and Legal Consideration 23
2.1 Background 23
2.2 Policies 23
2.2.1 Industrial Policy 1991 23
2.2.2 National Environmental Policy 1992 24
2.2.3 National Conservation Strategy 24
2.2.4 National Environmental Management Action Plan 25
(NEMAP), 1995
2.3 National Legislation 26
2.3.1 Environment Conservation Act 1995 (ECA 1995) 26
2.3.2 Environment Conservation Rules, 1997 (subsequent 28
amendments in 2002 and 2003)
2.4 Other Legislations 31
2.4.1 Environmental and Social Guidelines of the World Bank 31
2.4.2 Environmental Requirements of the Asian Development 33
Bank (ADB)
2.5 Environmental Clearance 35
2.6 Power Scenario and Master Plan in Bangladesh 36
2.7 Institutional structure of power sector in Bangladesh 37

Chapter – 3 Description of the Project

3.0 Description of The Project 39
3.1 Type and Category of Project 39
3.2 Site Description 40
3.2.1 Location of the Project 40
 3.2.2 Electrical Interconnection 47
3.2.3 Fuel Transportation 48
3.2.4 Topography of the Site & Surrounding Land 48
3.3 Project Activity 48
3.3.1 Site Development & Construction 48
3.3.1.1 Site Preparation 48
3.3.1.2 Piling 48
3.3.1.3 Foundations 48
3.3.1.4 Roads 49
3.3.1.5 Drainage 49
3.3.1.6 Power Station Buildings 49
3.3.1.7 Sub Station 50
3.3.1.8 Site Fencing 50
3.4 Equipment & Process Flow 50
3.4.1 Power Generation Method 50
3.5 POWER GENERATION DETAILS 51
3.5.1 Technical Data of Engine 51
3.6 Fuel 51
3.6.1 Fuel Treatment 51
3.6.1.1 HFO Purifier 51
3.6.1.2 Oily water Treatment 51
3.6.2 Fuel Specifications 52
3.7 Water Purification System 52
3.8 Engine Emission Specifications 52

Chapter - 4 BASELINE ENVIRONMENT

4.1 General Consideration 54
4.2 Physico-Chemical Environment 54
4.2.1 Land 54
4.2.1.1 Surrounding Land Uses 54
4.2.2 Topography, Soil & Geology 54
4.2.3 Hydrology 60
4.2.4 Water Quality 60
4.2.4.1 Surface Water 60
4.2.4.2 Ground water 60
4.2.5 Air Quality 62
4.2.6 Noise Level 63
4.2.7 Climatic Condition 65
4.2.8 Coastal Region 68
4.2.9 Cyclone and Tidal Surge 71
4.2.10 Seismicity 76
4.3 Biological Environment 81
4.3.1 Flora and Fauna 81
4.3.1.1 General Consideration 81
4.3.1.2 Flora 83
 4.3.1.3 Fauna 86
4.4 Socio-economic Condition 89
4.4.1 Population and Social Structure 89
4.4.2 Living and Cultural Standard 89
4.4.3 Agriculture 89
4.4.4 Housing 90
4.4.5 Public Health 91
4.4.6 Industries and Commerce 91

Chapter - 5 Potential Impacts Of The Proposed Project

5.1 General Considerations 93
5.2 Scoping of Impacts 93
5.2.1 Checklist 93

Chapter - 6 Prediction and Evaluation of Impacts

6.0 Evaluation of Impacts 97
6.1 General Considerations 97
6.2. Adverse Impacts And Mitigation 97
6.2.1 Impact due to project location 97
6.2.1.1 Land Acquisition 97
6.2.1.2 Loss and Displacement from Agricultural Land 97
6.2.1.3 Disruption of Earth Surface 98
6.2.1.4 Change in Landscape 98
6.2.2 Impacts during construction 99
6.2.2.1 Disruption of Earth surface - Site preparation and 99
Clearing and Earthworks
6.2.2.2 Impacts On Air Environment 100
6.2.2.2.1 Potential Environmental Impacts Of Dust 101
6.2.2.2.2 Proposed Mitigation Measures 102
6.2.2.3 Impacts On Acoustic Environment 102
6.2.2.3.1 Potential Environmental Impacts of Noise 103
6.2.2.3.2 Proposed Mitigation Measures for Noise Nuisance 104
Management
6.2.2.4 Sanitation Hazard & Drinking Water 104
6.2.2.5 Overland Drainage and Impact on surface water 105
6.2.2.6 Social Acceptability of Construction Workers to the Host 106
Communities
6.2.2.7 Accidents or Occupational Health Hazard 106
6.2.2.8 Increase in Vehicular Traffic in the Area 106
6.2.2.8.1 Potential Negative Environmental Impacts Likely to 106
Result From Increased Vehicular Traffic in the Area
6.2.2.8.2 Proposed Mitigation Measures To Mitigate Increase in 107
Vehicular Traffic In the Area
6.2.2.9 Impact due to HFO Transportation 107
 6.2.3 Impact during Operation Stage 108
6.2.3.1 Impact on Air quality 108
6.2.3.2 Impact due to Liquid Discharge 117
6.2.3.3 Impact due to Solid Waste 118
6.2.3.4 Impact due to HFO & Lubricating Oil 118
6.2.3.5 Noise and vibration impacts 119
6.2.3.6 Occupational Health 121
6.2.4 Socio-economic Impacts 121
6.3 Beneficial Impacts and Enhancement 122
6.3.1 During Construction 122
6.3.2 During Operation Phase 122
6.4 Decommissioning 122
6.4.1 General principles for Environmental Management during 122
decommissioning

Chapter - 7 Environmental Management Plan (EMP)

7.1 General Considerations 125
7.2 Mitigation/Benefit Enhancement Measures 125
7.3 Environmental Management during Operation Phase 126
7.3.1 Overview of Impacts and Mitigation Measures 126
7.3.2 Atmospheric Emission Management 127
7.3.3 Management of Solid Wastes 128
7.3.4 Water & wastewater Management 128
7.3.5 Domestic Sewage Management 128
7.3.6 Noise and Vibration Level Management 128
7.3.7 Greening Program 128
7.4 Monitoring Requirement 129
7.5 Monitoring Indicators 129
7.6 Cost of Monitoring 131
7.7 Management Capacity: 132
7.8 Safety Mitigation Plan 132

Chapter – 8 Emergency Response and Disaster Management Plan

8.1 Emergency Response 141
8.1.1 Six Steps in Emergency Response 143
8.1.2 Reporting Incidents and Accidents 143
8.1.3 Approaches to Emergency Response 144
8.2 Disaster Management Plan 146
8.3 Environment, Health and Safety (EHS) 147
8.4 Fire Hazard & Fire Evacuation Plan 147

Chapter - 9 Alternative Analysis

9.1 The ‘No Build’ Scenario 151
 9.2 Consideration of Alternatives 151
9.3 Site Alternatives 152

Chapter - 10 Stakeholder Consultation

10.1 Objectives of Stakeholders Consultation 154
10.2 Consultation Process 155
10.3 Stakeholder Consultation Technique 155
10.4 Stakeholders Consulted 156
10.5 Stakeholder Concerns and Recommendations 156
10.5.1 Community Concerns 156
10.5.2 Local Government Representatives 158

Chapter - 11 Grievance Redress Mechanism 164

Chapter - 12 Conclusion and Recommendations

12.1 Conclusions 169
12.2 Recommendations 170

References 171
Abbreviation

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 ABBREVIATION

ADB Asian Development Bank

AECL Adroit Environment Consultants Limited

AISL Acorn Infrastructure Services Limited

BBS Bangladesh Bureau of Statistics

BMD Bangladesh Meteorological Department

BNBC Bangladesh National Building Code

BPPL AISL Unit-3.

BPDB Bangladesh Power Development Board

CCC Chittagong City Corporation

CDA Chittagong Development Authority

CDMP Comprehensive Disaster Management Programme

CEPZ Chittagong Export Processing Zone

CO2 Carbon Dioxide

DAE Department of Agricultural Extension

DOE Department of Environment

DMB Disaster Management Bureau

DPZ Detailed Planning Zones

ECA Environment Conservation Act 1995

ECR Environment Conservation Rules 1997

EIA Environmental Impact Assessment

EMP Environmental Management Plan

EMS Environmental Management System

EPZ Export Processing Zone

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ESMF Environmental and Social Management Framework

ESSF Environmental and Social Safeguards Framework

GSHAP Global Seismic Hazard Assessment Program

GIS Geographic Information System

GOB Government of Bangladesh

GPS Global Positioning System

GRC Grievance Redress Committee

HFO Heavy Fuel Oil

HYV High-yielding Varieties

IEE Initial Environmental Examination

IUCN International Union for Conservation of Nature

MIM Management Information & Monitoring

MoEF Ministry of Environment and Forests

NEMAP National Environmental Management Action Plan

NGO Non-Government Organization

NOx Oxides of Nitrogen

PAPs Project Affected Persons

PGA Peak Ground Acceleration

PPIDF Private Public Infrastructure Development Facility

PM2.5 Particulate Matter < 2.5µm

PM10 Particulate Matter < 10µm

REB Rural electrification Board

SO2 Oxides of Sulfur

SPM Suspended Particulate Matter

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TOR Terms of Reference

TSP Total Suspended Particulates

TSS Total Suspended Solids

UNDP United Nations Development Programme

UNCED United Nations Conference on the Environment and Development

WEIGHTS AND MEASURES

o
C degree Celsius

dB(A) decibel acoustic

GWh giga watt hour

ha hectare

km kilometer

km/h kilometer per hour

kWe kilowatt-electric

KV kilovolt(s)

KVA kilo Volt-Amps

m meter

mm millimeter

m3 cubic meter

m3/hr cubic meters per hour

mg/l milligrams per liter

m/s meters per second

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MTPA metric tons per annum

MW megawatt

ppm parts per million

ppt parts per thousand

Rpm revolutions per minute

TPD tons per day

μg/m3 microgram per cubic meter

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Glossary

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 GLOSSARY
Adverse impact: An impact that is considered undesirable.
Ambient air: Surrounding air.
Aquatic: Growing or living in or near water.
Bangla: Bengali language.
Baseline (or existing) conditions: The „baseline‟ essentially comprises the factual
understanding and interpretation of existing environmental, social and health conditions
of where the business activity is proposed. Understanding the baseline shall also
include those trends present within it, and especially how changes could occur regardless
of the presence of the project, i.e. the „No-development Option‟.
Bazar: Market.
Beel: A „back swamp‟ or depression. Can be either perennial or seasonal.
Beneficial impacts: Impacts, which are considered to be desirable and useful.
Biological diversity: The variety of life forms, the different plants, animals and micro
organisms, genes they contain and the ecosystems they form. It is usually considered at
three levels: genetic diversity, species diversity and ecological diversity.
Char: Newly accreted land: Land, sometimes islands, within main river channels and
nearby mainland or in the estuary, subject to erosion and accretion.
Ecosystem: A dynamic complex of plant, animal, fungal and microorganism communities
and associated non-living environment interacting as an ecological unit.
Emission: The total amount of solid, liquid or gaseous pollutant emitted into the
atmosphere from a given source within a given time, as indicated, for e.g., in grams per
cubic meter of gas or by a relative measure, upon discharge from the source.
Endangered species: Species in danger of extinction and whose survival is unlikely if
the existing conditions continue to operate. Included among those are species whose
numbers have been reduced to a critical level or whose habitats have been so
drastically reduced that they are deemed to suffer from immediate danger of extinction.
Environmental effects: The measurable changes, in the natural system of productivity
and environmental quality, resulting from a development activity.
Environmental impact assessment (EIA) / Environmental assessment: The
systematic, reproducible and interdisciplinary identification, prediction and evaluation,
mitigation and management of impacts from a proposed development and its
reasonable alternatives, sometimes known as environmental assessment.

7|Page
Environmental Impact: An estimate or judgment of the significance and value of
environmental effects for natural, socio-economic and human receptors.
Environment Management Plan (EMP): A Plan to undertake an array of follow-up
activities which provide for the sound environmental management of a project/
intervention so that adverse environmental impacts are minimized and mitigated;
beneficial environmental effects are maximized; and sustainable development is ensured.
Environmental Management: Managing the productive use of natural resources
without reducing their productivity and quality.
Erosion: Process in which wind and water removes materials from their original place;
for instance, soil washed away from an agricultural field.
Evaluation: The process of looking back at what has been really done or
accomplished.
Fauna: A collective term denoting the animals occurring in a particular region or period.
Field Reconnaissance: A field activity that confirms the information gathered through
secondary sources. This field study is essentially a rapid appraisal.
Flora: All of the plants found in a given area.
Habitat: The natural home or environment for a plant or animal.
Household: A household is identified as a dwelling unit where one or more persons live
and eat together with common cooking arrangement. Persons living in the same
dwelling unit having separate cooking arrangements constitute separate household.
Important Environmental Component (IEC): These are environmental components of
biophysical or socio-economic importance to one or more interested parties. The use of
important environmental components helps to focus the environmental assessment.
Initial Environmental Assessment / Evaluation: Preliminary analysis undertaken to
ascertain whether there are sufficient likely significant adverse impacts to warrant a „full‟
EIA. In some countries, use of initial assessment forms a meaning of “screening”
proposed projects.
Khal: Small Channel, canal.
Land use: Types include agriculture, horticulture, settlement, pisciculture and
industries.
Mauza: A Bangla word for the smallest government administrative area corresponding
to village revenue unit.
Mitigation: An action, which may prevent or minimize adverse impacts and enhance
beneficial impacts.

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Negative Impact: Negative change from the existing situation due to the project.
Public involvement / Public consultation: A range of techniques that can be used to
inform, consult or interact with stakeholders‟ affected / to be affected by a proposal.
Reversible impact: An environmental impact that recovers either through natural
process or with human assistance (e.g. cutting off fish migration by an embankment might
be reversible at a later stage if a proper regulator is built).
Stakeholders: Those who may be potentially affected by a proposal, e.g. Local people,
the proponent, government agencies, NGOs, donors and others, all parties who may be
affected by the project or to take an interest in it.
Taka: Unit of Bangladeshi currency.
Terrestrial: Living on land.
Thana: Sub-district level of government administration, comprising several unions
under district.
Union: Smallest unit of local self government comprising several villages.
Upazila: Sub-district name. Upozila introduced in 1982.
Zila: Bengali word of district.

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Executive Summary

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 EXECUTIVE SUMMARY
This report represents the results of Environmental Impact Assessment (EIA) of
AISL Unit-3. The company will install 13.201 MW 8 units of ultra-efficient Caterpillar HFO
Generator sets with combined capacity of 100 (± 10 %) MW to supply to the national
grid at Jhulda, Chittagong. The objective of the study is to provide an examination and
assessment of the principal environmental impacts of the industry. The main objective of
AISL Unit-3, a 100 (±10 %) MW Power Plant Project is to establish, operate and maintain
the facilities for power generation and transmission of electricity. The company has
received the consent and approval from Government of Bangladesh for establishment
of this power plant.

The Company has signed Power a Purchase Agreement with Bangladesh Power
Development Board (BPDB) and Implementation Agreement with Government of
Bangladesh. AISL Unit-3 is located in a heavy industrial and commercial setting of
Jhulda, Chittagong. There are no particularly sensitive ecological, cultural and
archeological targets. The plants shall not have to relocate any human settlement, as
the project is situated on the purchased vacant land of the private individuals. The
area enjoys necessary facilities for years, which include communication, gas, electricity,
telecommunication etc.

The report comprises 12 Sections. 1st Section of the report gives a background and
objective of this study. The scope of work and methodology of the project followed by
EIA process and EIA Team members are also described in this section. Section 2
describes the different policy and legal requirements for installation of new power plant.
In section 3 the proposed project is being described with a detail study area, plants
description and technical specification. The basic information of the project is given
below:

1. Name of the Project AISL Unit-3

2. Project Location Power Plant: Jhulda, Chittagong. Dhaka
Office: House 4, Block E, Road 19/A, Banani,
Dhaka-1213
3. Type of Business Power Generation
4. Final Product 100 MWh Electricity installed capacity
5. Net Plant Capacity 100 MWh net output capacity
6. Project Cost BDT. 700.00 Crore
9. Total Area of Land 4 Acres (approximately)
7. Total Area Developed 16,000 sqm (approximately)
8. Employment 98 persons
9. Fuel Requirement Heavy Fuel Oil: 6500 M.Ton/Month
10. Source of Water Deep Tube well
11. Water Requirement Household/Domestic: 1 cubic meter/hour

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The project is located in a heavy industrial area with different industrial set already exists
within the 10km radius of the project as stated in Table 3.2 which indicated that those
industries are already producing around 1993 MW power as captive or IPP basis. The
project will transport HFO from the storage facility at Chittagong Port area at a distance
of approximately 3-4 km from the power plant.

The plant is powered by 8 engines, each of capacity 13.201MW.

The installed capacity of the project is 105 MW. However, the declared capacity of the
power plant is 100MW as per the PPA with the Bangladesh Power Development Board.

The project will have some other facilities, as water treatment plant, oily water
separation plant etc to support the main equipment of the project.

Baseline environment is described in section 4 with existing physical, chemical and

biological conditions of the area where the plant is going to be set up. The surface
water, ground water, ambient air quality and noise level have been analyzed to evaluate
the primary baseline of the area. The Continuous Air Monitoring Station-7, Agrabad
(CAMS) have been presented to evaluate the monthly concentrations of PM2.5 and PM10
in the project area which are much higher compared to the National standards (Table
4.5).

Prediction and evaluation of impacts are done in section 5. Simple checklists used to
identify the impacts due to installation of the power plant. Both construction and
operational stage of the project are considered separately to identify the short and long
term impacts. All the prediction and evaluation of impacts are described in chapter 6
with a mitigation options.

The construction of the plant may create some adverse impact on the existing
environment. The Acoustic impacts, dust emission, traffic congestion and sanitation
during the construction period would be limited to construction of building and site
preparation and due to installation of power plant itself. Since the plant would be set up
on AISL’s own land, so, the resettlement would not be an issue here. During
construction, the plant authority will adopt all necessary measures to reduce the
probable environmental impacts from different aspects.

The project authority will transport the HFO from the Chittagong port by oil tanker and
unload the tanker to the HFO storage tank. The HFO unloading area would be well
protected with hard standing floor so that there is no scope of oil spillage. The HFO
storage tank should have secondary containment (bund) 110% capacity of the storage
tank so that the oil could be retained in the bund in case of any accidental spillage or
disaster.
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Chap-6 describes all environmental impacts and its mitigation measures. As the
proposed power plant will utilize Heavy Fuel Oil (HFO) as fuel, the pollutants of
potential concern are Particulates, sulfur dioxide, oxides of nitrogen, carbon dioxide
and carbon monoxide during the operation period of the project. Each of these
pollutants has been examined to ensure the Bangladesh emission limit standard as
well as IFC/WB, where appropriate, the required emission control techniques would be
incorporated into the mitigation measures. The ground concentration of NOx and SO2
emission have been determined by air emission dispersion modeling by using USEPA
approved AERMOD model at a distance of 10km radius to the project site.

The main potential environmental impacts, which may arise as a result of construction
of the power plant, can be grouped as follows-

o Atmospheric emissions and Air quality

o Water pollution and waste water disposal
o Noise generation

All these aspects have been examined and the findings are as follows:

Atmospheric Emission and Air Quality: Emission of sulfur dioxide, Nitrogen Oxides,
Carbon dioxides and particulates would be the major concern of air pollution for the
project. The plant will have 8 Caterpillar engines, each of capacity 13.201MW. Besides,
the plant will install a Co-generation unit to produce Superheat Steam by using the
waste heat from the 8 HFO Engines and the superheated steam will then fed to the
steam turbine to generate additional 3.3MW electricity and final rated capacity of the
power plant would be 59 MW. Thus the exhaust heat temperature will be reduced
from 315 0C to 174 0C. In addition to that, the project authority will also install a flue gas
de-sulpharisation (FGD) plant to reduce the Sulpher content from the exhaust which
will remove approximately 90% Sulpher from the exhaust. So, after taking all those
mitigation measures, it is expected that the final exhaust from power plant project should
comply all the standards parameters of IFC/WHO and as well as Bangladesh. To
evaluate the ground concentration of the above emissions to the surrounding
environment, an emission dispersion modeling (USEPA approved AERMOD model)
has been done and the result shows that all emission would be within the Bangladesh
limit.

Liquid Discharge: The power plant will not produce any wastewater since it has mainly
air cooling and close looped water cooling system. The steam turbine will have a
condensation cooling system by a close loop cooling tower. Only small amount of make-
up water (21 cu.m/hour) will be needed in the system. The project would have a water
treatment plant with a capacity of 34 cu.m/hour with a facility of multimedia and Iron
13 | P a g e
filter followed by 1st stage Reverse Osmosis (RO) and the water would be collected in a
storage tank. The make-up water for the condenser cooling tower will be supplied from
this storage tank and remaining water would be pumped to the 2nd stage RO for
producing de-mineralized (DI) water which would be fed to the waste heat steam boiler.
The domestic liquid wastes would be disposed through septic tank. The surface
drainage network would be connected with an interceptor prior to discharge through
natural water. The interceptor will trap all oily matter present in the water.

Noise: The project will generate 108 dBA noise in the engine room, 90 dBA in the steam
turbine room and 85 dBA from the stack after silencer. The project authority will take
necessary noise abatement measures (brick wall + Styrofoam + brock wall =
150mm + 50mm + 150mm) to prevent the engine room noise emitted outside the project
boundary. The stack noise emission has been predicted by means of noise impact
modeling. The maximum result has been predicted as 38.47 dBA at 50m distance and
6.41 dBA at 500m radius from the project site.
Chap-7 describes the Environmental Management Plan and monitoring plan for
construction and operation period of the project, the detail of the FGD plant has been
discussed here, a continuous emission monitoring for SO2, NOx and PM have been
suggested during operation period as per IFC/WB legislation. The other monitoring has
been suggested for monthly, quarterly or yearly basis. Disaster Management Plan and
Alternative Analysis are also presented in Section 8 & 9 respectively in this report.

Stakeholder consultation and Grievance Redress Mechanism are very important and
sensitive issues for setting up a new industry in any area of Bangladesh. It was initiated
with an open objective to ensure people’s participation right from the planning stage of
the project. More specially, this was aimed at improving the study taking into account
opinions from the people of the impacted area which is presented in Section 10 & 11
respectively and conclusion and reference are presented in Section 12.

It is obvious from noting the many environmental, safety, and social requirements
outlined in this report that a comprehensive documents is needed which incorporates
these requirements, in order to guide and track the projects performance from project
planning through construction and operation-maintenance. That is the essential
purpose of this Environmental Impact Assessment (EIA) Report.

The present EIA report finds that though there are certain adverse environmental
impacts associated with the industrial unit under consideration, those are however
manageable. Given the location, proponent’s commitments, measures undertaken and
commitment for further measures to be adopted in due course of time if needed, AISL
Unit-3 is going to be a nationally important and environmentally compatible industrial
venture.

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 INTRODUCTION
1.1 PROJECT BACKGROUND:

Electricity is the major source of power for country's most of the economic activities. It is
the key ingredient of socio-economic development of the country. Adequate and reliable
supply of electricity is an important pre-requisite for attracting both domestic and foreign
investment. Reliable supply of electricity is a pre-condition for poverty reduction and
economic development. In Bangladesh, 47% of total populations have access to electricity
but reliable and quality power is still a faraway. To alleviate poverty in the face of resource
limitations and high population density, Bangladesh requires an economic growth rate of
more than 7% p. a. In order to achieve this growth rate, electricity growth needs to be
achieved by 10%. By best utilizing the natural, human and agricultural resources the
desired pace of GDP growth could be attained by increasing electricity generation at much
higher rate, which is the key target for development.

According to Ministry of Power, Energy & Mineral Resources, Bangladesh presently

total electricity generation capacity is 12376 MW. Of this capacity 6491 MW is from public
sector and 5885 MW is from the private sector, which is 52% and 48% respectively of
the total generation capacity. Considering 10 - 15 % Maintenance and Forced Outage,
Available Generation Capacity is in the range of 9000 MW without fuel constraint.

Problems in the Bangladesh's electric power sector include corruption in administration,

high system losses, delays in completion of new plants, low plant efficiencies, erratic
power supply, electricity theft, blackouts, and shortages of funds for power plant
maintenance, diversion of electricity to irrigation in rural areas. Overall, the country's
generation plants have been unable to meet system demand over the past decade.

A recent survey reveals that power outages result in a loss of industrial output worth $1
billion a year which reduces the GDP growth by about half a percentage point in
Bangladesh. A major hurdle in efficiently delivering power is caused by the inefficient
distribution system. It is estimated that the total transmission and distribution losses in
Bangladesh amount to one-third of the total generation, the value of which is equal to US
$247 million per year.

Recognizing the need to improve the performance of the power sector, the government
adopted a policy paper titled power Sector Reforms in Bangladesh (PSRB) in 2001. PSRB
outlined the reform process to gradually remove constraints in the sector through
improvements in the sector and corporate governance, introduction of competition, and
public private partnerships. The PSRB envisioned in the long term a structure of the power
sector based on (i) separation of sector regulation and operation; (ii) autonomy and

15 | P a g e
commercial orientation of the sector entities; (iii) separation of generation, transmission,
and distribution; and (iv) increased private sector participation. Transmission assets would
remain in the public sector, while generation and distribution assets would have both
public and private ownership.

It is a well-recognized fact that each development activity has an impact on the natural
molding of the environment. As development activities are of prime importance for the
economic growth and fulfillment of basic needs of the society, the environmental aspects
of development activities must be taken into account and due attention must be paid to
protect the environment. The first step in this direction is to evaluate the probable impacts
of the project on the surrounding environment so that suitable measures could be taken
during early stages of the project to minimize negative impacts.

The socio-cultural roots of our present environmental crisis lie in the paradigms of scientific
materialism and economic determinism, which fail to recognize the physical limits,
imposed by ecological systems on economic activity. The economies must expand within
ecosystems, which have limited regenerative capacities. Contrary to the neoclassical theory
of continuous material growth, economic activities directly undermine the potential for
development through over-exploitation of natural resources, and indirectly compromise
future production through the discharge of residuals. The entrenchment with quantitative
growth as a major instrument of social policy is thus quite paradoxical.

The emergence of the concept of sustainable development in recent years has brought in
the general realization that societal perceptions must shift towards ecological determinism
so as to achieve qualitative growth within the limits of ecosystem carrying capacity. The
carrying capacity based planning process, innovative technologies for enhanced material
and energy effectively of production and consumption, structural economic change
towards less resource-intensive sectors, and preventive environmental management
through increasingly interventionist policies are some of the strategies for reconciling
developmental goals with ecological capabilities.

Proper location / sitting, its process and waste abatement and control are very important
for a development activity to be environmentally sound. To ensure this, an Environmental
Impact Assessment (EIA) is a very effective tool, which delineates what needs to be done
to make a development activity suitably located and operate in an environment friendly way.

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The EIA will, therefore, examine the technical aspects of the project activities, which are
likely to interact with the surrounding environment. This EIA study will cover possible
activities and impacts with the environment and community. The report will also provide a
suggestive EMP along with certain mitigation measures plan with a view to reduce effect
of the adverse impacts.

AISL Unit-3. has made Power Purchase Agreement with its buyer, Bangladesh Power
Development Board (BPDB) on February, 2017 and Implementation Agreement with
Government of Bangladesh on March, 2017.

It is located in a commercial setting at Jhulda, Chittagong. There are no particularly sensitive

ecological, cultural and archeological targets. The plants shall not have to relocate any
human settlement, as the project is situated on purchased nonagricultural land. The area
enjoys necessary facilities for years, which include communication, gas, electricity,
telecommunication etc.

Proper location, its process and waste abatement and control are very important for a
development activity. To ensure this, an Environmental Impact Assessment (EIA) is a
very effective tool, which delineates what needs to be done to make a development
activity suitably located and operated in an environment friendly way.

1.2 OBJECTIVE

This report presents the findings of an Environmental Impact Assessment (EIA) of the
project namely AISL Unit-3. They will install 100 (± 10 %) MW 8 units of ultra-efficient
Caterpillar HFO Generator sets with combined capacity of 50 (± 10 %) MW at the grid at
Jhulda, Chittagong. The objective of the study is to provide an examination and
assessment of the principal environmental impacts of the industry. The outline of an
environmental management plan also suggested with an indication of the extent of work to
be done to keep the development and environment compatible. In this context, it should be
noted that the term “environment” and its derivatives have been used in a wide sense, which
covers not only physical and chemical aspect, but also the human dimension. The specific
objectives of this EIA are to:

o Present a brief discussion on the EIA process and its role in the planning and
implementation of development projects;

o Present a general description of the project and the process;

o Present a description of the pre-project environment;

o Delineate the significant environmental issues found and believed to be involved;

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 o Identify the environmental impacts of the project and quantify them to the extent
possible;

o Suggest the plan for management of the environment, during the implementation
and operation of the plant.

1.3 STUDY AREA

The proposed AISL Unit-3 plant will be set up at Jhulda, Chittagong. The site of the project
falls under Jhulda which is resided near Port. Also near there are fuel storage facilities
& other small industries. The project is situated on the East Side of the river Karnaphuli.
The location is well communicated by road and river ways. The site covers an area of 3.0
acres of land.

1.4 SCOPE OF WORK

The description of the environment and social baseline conditions are made
encompassing all relevant current baseline data on the environmental and social
characteristics of the study area including physical, biological, ecological and social
environments. In the backdrop of the above scenarios, the relevant regulations and
standards governing environmental quality, health and safety, protection of sensitive
areas, protection of endangered species, land use control, land acquisition,
compensation, etc. at every level are described.

In action to the above, an analysis was conducted of reasonable alternatives in meeting

the ultimate objects of the project including the „no action‟ alternative, alternative means
of meeting the energy requirements, alternative means of delivering gas, alternative
methods of construction including cost and reliability factors.

Viewed against these, all significant impacts were identified and evaluated including
atmospheric emissions and changes in ambient air quality, discharge of effluent and
ambient water quality impacts, changes in ambient noise and local land use patterns,
impacts due to land acquisition, impacts of the project and its activates on the
community’s access to social infrastructure (e .g. potable water, health centers, school,
irrigation and extension services), and local developments.

Following identification of potential impacts, efforts have been taken to distinguish

between positive and negative impacts, direct and indirect impacts including impacts from
possible accidents and long-term impacts. Attempts are made to describe the

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impacts quantitatively in terms of environmental and social cost and benefits and
assigning economic values where feasible.

Finally, an Environmental, Safety and Social Management Plan to mitigate negative

impacts has been developed, including a detailed Environmental and Social Management
Plan with feasible and cost-effective measures to prevent or reduce significant negative
impacts to an acceptable level, and containing detailed implementation plans, monitoring
indicators and clear allocation of responsibility among project sponsors construction
contractors, government agencies, and community-based organization. Also, an
Environmental and Safety Management Plan, focusing on mitigation measures to address
the environmental and safety consequences associated with the project for both
construction and operational phases has been prepared. Also, a Social Management Plan
is developed which includes a Resettlement Action Plan to address the adverse impacts
on project-affected persons displaced by the power plant construction. It is to be mentioned
that before preparation on the above, construction and participation with the affected
persons were undertaken formally.

1.5 THE EIA TEAM

Adroit Environment Consultants Ltd. (AECL) has prepared this report under the
guidance and supervision of Dr. Nasir Uddin Khan. The total team composition and their
expertise have been given in the table below:

Professional Name Expected Expertise

EIA & Emission Dr. Nasir Uddin Khan Highly experienced on conducting EIA of
Modeling various nature in home and abroad.
Expert Have vast experience on identifying different
environmental impacts and suggesting mitigation
measures for any project. Experienced on
emission and noise modeling of various projects.
Experienced on Project stakeholder
engagement - Public consultation and
Disclosure Plans.

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Legal & Policy Mohammad Experienced on environmental issues, Legislative
experts, EIA Reazuddin bindings, legal and policy framework in
analyst Former Director conjunction with the Department of Environment,
(Technical) & Former ADB, World Bank/IFC or other donor agencies.
Chairman, Have vast knowledge on EIA report review and
Environmental analysis.
Clearance Technical
Committee,
Department of
Environment (DoE)
Power Plant Engr. Zahurul Islam Expert on power plant operation and EIA report.
Engineer Khan

Socio- Mukul Ashraf Experienced on Social baseline studies,

economist community needs assessment, Social and
Community Health Impact Studies/Assessments
etc.
Field Engr. Irfan Ullah Make Liaison with all field staff and Consultants;
Investigator/ co- allocate staff & resources to different places
coordinator when necessary. Background of organizing site
visits, surveys, liaison with community, public and
govt. organizations, etc.
Md. Akter-uz-Zaman Background of organizing site visits, surveys,
liaison with community, public and govt.
organizations, Base line data collection etc.
Mr. Golam Mostafa Base line data collection, sample collection from
site, sample preservation and laboratory analysis.
Mr. Ratan Biswas Base line data collection, secondary data
collection, sample collection and site survey

1.6 LIMITATIONS

An IEE/EIA is generally carried out as an integral part of the Feasibility Study (FS) or
together with it and before going into the final design phase and into the construction phase
of a particular development project. If so than the findings of the EIA could be incorporated
in the project design, overall planning and budget and that the project could be implemented
accordingly. When an EIA is conducted separately as just an add-on, often it does not get
due importance in the overall implementation of the project, which undermines the role of
the EIAs and can contribute to environmental damages.

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In case of AISL Unit-3, an IEE has been prepared at the initial stage of the project. Though
the IEE was prepared as a separate document of Feasibility Study (FS), but all the
Significant Environmental Impacts (SEIs) were identified in IEE for the above project and
conclusions for site clearance were made accordingly. DoE has cleared the present site
with subject to undertaking an EIA and adoption of necessary and effective pollution
control measures. So, this report has been prepared to fulfill the requirement of DoE and
emphasizes have been on the issues which has been considered to be significant in IEE
and the conditions imposed in site clearance by DoE. Keeping all into consideration the
present report delineates the environmental factors and conclusions are made accordingly.

Services performed by the consultant are conducted in a manner consistent with that level
of care and skill generally exercised by members of the engineering and consulting
profession. The report may not exhaustively cover an investigation of all possible aspects
and circumstances that may exist. However, an effort is made to discover all meaningful
areas under the stipulated time available.

In evaluating subject site, consultant relies in good faith on information provided by client‟s
management or employees. The Consultant assume that the information provided is factual,
accurate and accepts no responsibility for any deficiency, misstatement or inaccuracies
contained in this report as a result of omission or misrepresentation of any person
interviewed or contacted. However, the consultant notifies the contradictions and errors in
the data, where it seems appropriate.

It should be recognized that the information given in the report is time specific and with the
passage of time the relevancy of data and analysis may suffer. Specific circumstances and
condition of site can change due to which conclusion and opinions may also change

1.7 ACKNOWLEDGEMENT

In this EIA study many individuals and agencies helped in gathering data and providing
information & services. Almost all of them were most helpful & cooperative to provide data
& related information and discus with them surrounding environmental issues. We also are
thankful to the DoE personnel of Chittagong Division for their Co-operation in various
aspects of this study.

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 Chapter -2
Policy and Legal
Consideration

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 POLICY AND LEGAL CONSIDERATION
2.0 POLICY AND LEGAL CONSIDERATION

2.1 BACKGROUND

The emerging environmental scenario calls for attention on conservation and judicious
use of natural resources. There is a need to integrate the environmental consequences
of the development activities and for planning suitable measures in order to ensure
sustainable development. The environmental considerations in any developmental
process have become necessary for achieving sustainable development. To achieve such
goals the basic principles to be adopted are:

 To enhance the quality of environment in and around the project area by

adopting proper measures for conservation of natural resources;

 Prevention of adverse environmental and social impact to the maximum possible

extent;

 To mitigate the possible adverse environmental and socio-economic impact on

the project-affected areas.

The proposed Project is covered under several environmental Policies & legislations
pertained with GOB, ADB`s Environmental and Social Safeguards Framework (ESSF),
IDCOL‟s Environmental and Social Management Framework (ESMF) and as well as
IFC/World Bank‟s Environmental Safeguards (relevant policies). All of the policies or
legislation aimed at the conservation and protection of the environment. The existing
policies and legislation, which are relevant to the environment, are described in the
following sections.

2.2 POLICIES

2.2.1 Industrial Policy 1991

The Industrial policy of 1991 contains the following clauses in respect of environmental
protection

o To conserve ecological balance and prevent pollution during industrialization

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 o To take effective steps for pollution control and conservation of environment
during industrialization

To ensure embodying of necessary pollution control and preventive measures by

industrial investment project endangering environment.

2.2.2 National Environmental Policy 1992

Bangladesh National Environmental Policy (GoB, 1992) was approved in May 1992,
and sets out the basic framework for environmental action, together with a set of broad
sectoral action guidelines. Key elements of the policy are:

o Maintenance of the ecological balance and overall progress and development of the
country through protection and improvement of the environment.

o Protection of the country against natural disasters

o Identification the regulation of all types of activities which pollute and degrade the
environment

o Ensuring sustainable utilization of all natural resources

o Active association with all environmentally-related international initiatives

Environmental policy contains the following specific objectives with respect to the industrial
sector:

o To adopt corrective measures in phases in industries that causes pollution.

o To conduct Environmental Impact Assessments for all new public & private industries.

o To ban the establishment of any industry that produces goods cause environmental
pollution, closure of such existing industries in phases and discouragement of the use
of such goods through the development and/or introduction of environmentally sound
substitutes.

o To ensure sustainable use of raw materials in the industries to prevent their wastage.

2.2.3 National Conservation Strategy

National Conservation Strategy (GoB/IUCN, 1992) was drafted in late 1991 and submitted
to the Government in early 1992. This was approved in principle; however the final
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approval of the document is yet to be made by the cabinet. It underwent a number of
modifications over the last five years, and is waiting to be placed before the cabinet finally
sometime in late September 1997. For sustainable development in industrial sector, the
report offered various recommendations; some of those are as follows:

o Industries based on nonrenewable resources should be made to adopt technology

which conserves raw materials, and existing industries should be given incentives to
install technical fixes to reduce wastage rate

o All industries, especially those based on imported raw materials, should be subjected
to EIA and adoption of pollution prevention/control technologies should be enforced.

o No hazardous or toxic materials/wastes should be imported for use as raw material.

o Import of appropriate and environmentally sound technology should be ensured.

o Complete dependence on imported technology & machinery for industrial

development should gradually be reduced so that industrial development is
sustainable with local skills and resources.

2.2.4 National Environmental Management Action Plan (NEMAP), 1995

National Environmental Management Action Plan, also referred to as NEMAP (GoB,

1995) is a wide-ranging and multi-faceted plan, which builds on and extends the
statements set out in the National Environmental Policy. NEMAP was developed to
address issues and management requirements during the period 1995 to 2005, and
sets out the framework within which the recommendations of the National Conservation
Strategy are to be implemented.

NEMAP has the broad objectives of:

o Identification of key environmental issues affecting Bangladesh;

o Identification of actions necessary to halt or reduce the rate of environmental

degradation;

o Improvement of the natural and built environment;

o Conservation of habitats and biodiversity;

o Promotion of sustainable development;

o Improvement in the quality of life of the people.

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One of the key elements of NEMAP is that sectoral environmental concerns are identified.
In outline, the environmental issues of the industrial sector include the following:

o Pollution arising from various industrial processes and plants throughout the
country causing varying degrees of degradation of the receiving environment
(Air, Water, and Land).

o There is a general absence of pollution abatement in terms of waste minimization

and treatment.

o Low level of environmental awareness amongst industrialists and entrepreneurs.

o Lack of technology, appropriate to efficient use of resources and waste

minimization leading to unnecessary pollution loading in the environment.

o Economic constraints on pollution abatement and waste minimization such as the

cost of new technology, the competitiveness of labor, and intensive production
methods as compared to more modern methods.

o Concentration of industry and hence pollution in specific areas which exacerbate

localized environmental degradation and exceed the carrying capacity of the
receiving bodies.

o Unplanned industrial development has resulted in several industries located

within or close to residential areas, which adversely affects human health and
quality of human environment.

o Establishment of industries at the cost of good agricultural lands and in the

residential areas.

o Lack of incentives to industrialists to incorporate emission/discharge treatment plant

in their industries.

2.3 NATIONAL LEGISLATION

2.3.1 Environment Conservation Act 1995 (ECA 1995)

Formal concern at the national level, for the state of environment in Bangladesh can be
traced back to at least Independence and passing of the Water Pollution Control Act in
1973. Under this a small unit was established in the Directorate of Public Health
Engineering (DPHE) to monitor pollution of ground water and surface water.

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In order to expand the scope of environmental management and to strengthen the powers
for achieving it, the Government issued the Environmental Pollution Control Ordinance in
1977. The ordinance provided for the establishment of an Environmental Pollution Control
Board, which was charged with formulating policies and proposing measures for their
implementation. In 1982, the board was renamed as Department of Environmental
Pollution Control (DEPC). Four divisional offices were established in Dhaka, Chittagong,
Khulna and Bogra. A special presidential order again renamed the DEPC to the
Department of Environment (DOE) and placed under newly formed ministry of
Environment and Forest (MoEF) in 1989.

The national environmental legislation known as Environmental Conservation Act,

1995 (ECA'95) is currently the main legislative document relating to environmental
protection in Bangladesh, which repealed the earlier environment pollution control
ordinance of 1997 and has been promulgated in 1995. The main objectives of ECA‟95
are:
o Conservation and improvement of environment, and

o Control and mitigation of pollution of environment.

The main strategies of the act can be summarized as:

o Declaration of ecologically critical areas, and restriction on the operation and

process, which can be carried, out or cannot be initiated in the ecologically
critical areas.

o Regulation in respect of vehicles emitting smoke harmful for the environment.

o Environmental clearance

o Regulation of the industries and other development activities - discharge

permit.

o Promulgation of standards for quality of air, water, noise and soil for different
areas for different purposes.

o Promulgation of standard limit for discharging and emitting waste.

o Formulation and declaration of environmental guidelines.

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2.3.2 Environment Conservation Rules, 1997 (subsequent amendments in 2002
and 2003)

A set of the relevant rules to implement the ECA‟ 95 has been promulgated (August
1997). The rules mainly consist of:

 The national Environmental Quality Standards (EQS) for ambient air, surface
water, groundwater, drinking water, industrial effluents, emissions, noise and
vehicular exhaust;

 Categorization of industries, development projects and other activities on the

basis of pollution activities of the existing or proposed industries/development
projects/activities.

 Procedure for obtaining environmental clearance;

 Requirement for undertaking IEE and EIA as well as formulating EMP according
to categories of industries/development projects/activities;

 Procedure for damage-claim by persons affected or likely to be affected due to

polluting activities or activities causing hindrance to normal civic life.

The Rules incorporate "inclusion lists" of projects requiring varying degrees of

environmental investigation.

Green: Industries/development projects/activities are considered relatively pollution-free

and therefore do not require an environmental clearance certificate from the DOE and
no environmental study.

Orange: Industries/development projects/activities fall into two categories. Orange “A” are
less polluted and Orange “B” are moderately polluted required to submit general
information, a process flow diagram and schematic diagrams of waste treatment
facilities along with their application to DOE for obtaining environmental site clearance
and environmental clearance.

Red: Industries/development projects/activities are those which may cause „significant

adverse‟ environmental impacts and are therefore required to submit an EIA report. It
should be noted that they might obtain an environmental site clearance on the basis of
an IEE report, and subsequently submit an EIA report for obtaining environmental
clearance along with other necessary papers.

Environmental standards in operation in Bangladesh also Promulgated under the

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Environment Conservation Rules 1997. There are standards prescribed for varying
water sources, ambient air, noise, odor, industrial effluent and emission discharges,
vehicular emission etc.

The Bangladesh standards intend to impose restrictions on the volume and

concentrations of wastewater/solid waste/gaseous emission etc. discharged into the
environment. In addition a number of surrogate pollution parameters like Biochemical
Oxygen Demand, or Chemical Oxygen Demand; Total Suspended Solids, etc. are
specified in terms of concentration and/or total allowable quality discharged in case of
waste water/solid waste. Additionally specific parameters depending on the
manufacturing process are specified such as phenol, cyanide, copper, zinc, chromium
etc. Air emission quality standards refer mostly to concentration of mass emission of
various types of particulate, sulfur dioxide, and oxides of nitrogen and in some cases
volatile organic compounds and other substances.

The Bangladesh standards in general are less stringent compared to the developed
countries. This is in view to promote and encourage industrialization in the country. The
Bangladesh standards are not for any specific period of time. There is no provision for
partial compliance too.

The ambient standard of water quality, air quality and noise are presented in Table 2.1
to Table 2.5 in the following page. Standards refer to discharges to freshwater bodies with
values in parentheses referring to direct discharges to agricultural land.

Table 2.1: Inland Surface Water Quality Standards

Best practice based PH BOD DO Total Coliform

Classification mg/l mg/l No./100
Source of drinking water for 6.5-8.5 2 or less 6 or above 50 or less
supply only after disinfecting
Water usable for recreational 6.5-8.5 3 or less 5 or above 200 or less
activity
Source of drinking water for 6.5-8.5 6 or less 6 or above 5,000 or less
supply after conventional
treatment
Water usable by fisheries 6.5-8.5 6 or less 5 or above -
Water usable by various 6.5-8.5 10 or less 5 or above 5,000 or less
process and cooling industries
Water usable for irrigation 6.5-8.5 10 or less 5 or above 1,000 or less
Source: ECR- Schedule 3

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 Table 2.2: Standards for Waste from Industrial Units

Parameters Unit Inland Surface Irrigated

Water Land
Biological Oxygen Demand (BOD5) at mg/l 50 100
200 C
Chemical Oxygen Demand (COD) mg/l 200 400
Dissolve Oxygen (DO) mg/l 4.5-8 4.5-8
Total Dissolved Solids (TDS) µmho/cm 2,100 2,100
PH 6-9 6-9
Suspended Solid (SS) mg/l 150 200
Chloride mg/l 600 600
Iron µmho/cm 2 2
Source: ECR- Schedule 10

Table 2.3: Ambient Air Quality Standards

Source: ECR- Schedule 2 (Amended in 2005)

Abbreviation: ppm: Parts Per Million

Notes:

(Ka) Not to be exceeded more than once per year

(Kha) Annual average value will be less than or equal to 50 microgram/cubic meter
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(Ga) Average value of 24 hours will be less or equal to 150 microgram/cubic meter for one day
each year.
(Gha) Maximum average value for every one hour each year will be equal or less than 0.12
ppm.

At national level, sensitive areas include national monuments, health resorts, hospitals,
archaeological sites and educational establishments.

Table 2.4: Standards for Gaseous Emission from Industries

Parameters for power plant (<200 MW) Standard present

Particulate 350 mg/Nm3

Oxides of Nitrogen 30 ppm
Source: ECR- Schedule 11

Table 2.5: Ambient Noise Standards

Areas Day Time Night Time

dBa dBa
Silence Zone: Zone A 50 40
Residential Area: Zone B 55 45
Mixed Activity Area: Zone C 60 50
Commercial Area: Zone D 70 60
Industrial Area 75 70
Source: ECR- Schedule 1 (Amendment in 2006)

The second column of limits values refer to day time (06.00 to 21:00) and the third column
to night time (21.00 to 06.00). A silence zone is defined as an area within 100m, around
hospitals or educational institutions.

2.4 Other Legislations

2.4.1 Environmental and Social Guidelines of the World Bank

The World Bank procedures for EA study cover policies, guidelines and good practices.
Such guidelines therefore follow the national best practices in undertaking any
development project in Bangladesh. The environment safeguards policies applicable to
the proposed project are the following:

• Environmental Assessment (EA) (OP 4.01/BP/GP 4.01): An Environmental

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Assessment is conducted to ensure that IFC-financed projects are environmentally
sound and sustainable, and that decision-making is improved through appropriate
analysis of actions and of their likely environmental impacts. Any IFC-funded project
that is likely to have potential adverse environmental risks and impacts in its area of
influence requires an EA indicating the potential risks, mitigation measures and
environmental management framework or plan.

• Natural Habitats (OP/BP 4.04): Natural habitats are land and water areas where most
of the original native plant and animal species are still present. Natural habitats
comprise many types of terrestrial, freshwater, coastal, and marine ecosystems. They
include areas lightly modified by human activities, but retaining their ecological functions
and native species. The Natural habitats policy is triggered by any project (including any
subproject under a sector investment or financial intermediary loan) with the potential to
cause significant conversion (loss) or degradation of natural habitats, whether directly
(through construction) or indirectly (through human activities induced by the project).
The policy has separate requirements for critical (either legally or proposed to be
protected or high ecological value) and non-critical natural habitats. World Bank‟s
interpretation of “significant conversion or degradation” is on a case-by-case basis for
each project, based on the information obtained through the EA.

• Forestry (OP/GP 4.36): This policy is triggered by forest sector activities and World Bank
sponsored other interventions, which have the potential to impact significantly upon
forested areas. The World Bank does not finance commercial logging operations but aims
to reduce deforestation, enhance the environmental contribution of forested areas,
promote afforestation, reduce poverty and encourage economic development.

• Cultural Property (OPN 4.11): Physical cultural resources are defined as movable or
immovable objects, sites, structures, groups of structures, natural features and
landscapes that have archaeological, paleontological, historical, architectural, religious,
aesthetic, or other cultural significance. Physical cultural resources may be located in
urban or rural settings, and may be above ground, underground, or underwater. The
Bank seeks to assist countries to manage their physical cultural resources and to avoid
or mitigate adverse impact of development projects on these resources. This policy is
triggered for any project that requires an EA.

• Policy on Disclosure of Information, 2002: There are disclosure requirements at every

part of the project preparation and implementation process. Consultation with affected
groups and local community should take place during scoping and before Terms of
references (ToRs) are prepared; when the draft EA is prepared; and throughout project
implementation as necessary. The Borrower makes the draft EA and any separate EA
report available in country in a local language and at a public place accessible to
project-affected groups and local community prior to appraisal. Besides, IFC has set out
8 (eight) performance standards in respect of various parameters pertaining to a
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proposed project. These eight performance standards of IFC with their corresponding
parameters as under:

• Performance Standard 1: Social and Environmental Assessment and Management

System

• Performance Standard 2: Labour and Working Conditions

• Performance Standard 3: Pollution Prevention and Abatement

• Performance Standard 4: Community Health, Safety and Security

• Performance Standard 5: Land Acquisition and Involuntary Resettlement

• Performance Standard 6: Biodiversity Conservation and Sustainable Natural Resource

Management

• Performance Standard 7: Indigenous Peoples

• Performance Standard 8: Cultural Heritage.

Of the above eight performance standards set by IFC, the Performance Standard 1
envisages establishing the importance of: (i) integrated assessment to identify the social
and environmental impacts, risks and opportunities; (ii) effective community
engagement through disclosure of project-related information and consultation with local
communities on matters that directly affect them; and (iii) the client‟s management of
social and environmental impacts throughout the life of the project. The rest seven of
the performance standards, i.e., Performance Standards 2 through 8 seek to ascertain
establishing requirements to avoid, reduce, mitigate or compensate the impacts on people
and the environment, and to improve conditions where appropriate.

2.4.2 Environmental Requirements of the Asian Development Bank (ADB)

The ADB Safeguard Policy Statement 2009 sets out the requirements for ADB's
operations to undertake an environmental assessment for projects funded by the bank.
The environmental assessment requirements for projects depend on the significance of
impacts on the environment by the project. Each proposed project is scrutinized as to its
type; location; the sensitivity, scale, nature, and magnitude of its potential environmental
impacts; and availability of cost-effective mitigation measures.

A project is classified as one of the environmental categories (A, B, C, or FI).

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Category A (OM 20): Projects with potential for significant adverse environmental impacts.
An environmental impact assessment (EIA) is required to address significant impacts.

Category B (OM 20): Projects judged to have some adverse environmental impacts, but
of lesser degree and/or significance than those for category A projects. An initial
environmental examination (IEE) is required to determine whether or not significant
environmental impacts warranting an EIA are likely. If an EIA is not needed, the IEE is
regarded as the final environmental assessment report.

Category C (OM 20): Projects unlikely to have adverse environmental impacts. No EIA
or IEE is required, although environmental implications are still reviewed.

Category FI (OM 20): Projects are classified as category FI if they involve a credit line
through a financial intermediary or an equity investment in a financial intermediary. The
financial intermediary must apply an environmental management system, unless all
subprojects will result in insignificant impacts.

Categorization based on the Most Environmentally Sensitive Component.

Categorization is to be based on the most environmentally sensitive component. This

means that if one part of the project is with potential for significant adverse
environmental impacts, then project is to be classified as Category A regardless of the
potential environmental impact of other aspects of the project. Of course only those
aspects of the project with potential for significant adverse environmental impacts need
to be assessed in detail. The scoping for the EIA and the TOR for the EIA report should
focus on the significant environmental issues.

Basic Environmental Assessment Requirements

Category A. EIA is required to examine the project‟s potential impacts, and to

recommend an environmentally sound project by comparing all possible alternatives.
Public consultation must be undertaken at least twice during the EIA process, once during
the early stage of the EIA field studies and after the draft EIA report has been prepared.
The EIA should recommend mitigation measures for minimizing the adverse impacts and
identify environmental monitoring requirements. The mitigation measures and proposed
monitoring are to be incorporated into the EMP. An EIA report must be prepared following
the recommended format in Appendix 2. The SEIA shall be circulated to the Board
at least 120 days prior the Board consideration. The EIA and SEIA are to be made
available for public (and published it on ADB‟s web-site). The Borrower should translate
the SEIA into the local language.

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Category B. An IEE is required for Category B projects to determine whether or not
significant environmental impacts warranting an EIA are likely. If an EIA is not needed,
the IEE is regarded as the final environmental assessment report. Public consultation
must be undertaken during the IEE process. An IEE report is required to follow the
recommended format. For Category B projects deemed environmentally sensitive, the
SIEE should be submitted to the Board at least 120 days prior to the Board consideration.
In addition to the SIEE, IEE will be made available to Board members upon request. The
Bank may make the SIEE available to locally affected groups and NGOs, upon request,
through the Board Member of the DMC concerned, or through the Bank‟s Depository
Library program, except where confidentiality rules would be violated.

Category C. No EIA or IEE is required but environmental implications of the project still
need to be reviewed and mitigation measures if any should be directly integrated into
the project design.

Category FI. Environmental Assessment of the financial intermediation and equity

investments is required. A due diligence assessment of the financial intermediary and
its environmental management system (EMS) is required, except in the where the
subproject involves only small loans with insignificant impacts. In the cases where there
will be on lending through credit lines, an environmental assessment and review
procedures for subprojects are required. The environmental assessment and review
procedures are similar to that for sector loans and the requirements for public
involvement, information disclosure, and in some cases, clearances by ADB apply.

2.5 ENVIRONMENTAL CLEARANCE

Formal EIA guidelines in Bangladesh are set out in “Rules and Regulations under the 1995
Environmental Protection Acts” as published in the official Gazette on August 27, 1997. Any
proponent planning an industrial project is currently required under Paragraph 12 of the
Environmental Protection Acts, 1995 to obtain “environmental clearance letter:” from the
Department of Environment.

The first to obtain environmental clearance is for the project proponent to complete & submit
an application form which may be obtained from the appropriate DoE regional offices as per
the category. The application is accompanied by other supporting documents (i.e. project
profile, lay-out plan, NOC from local authority, Govt fees etc.) reviewed by the divisional and
district offices of DOE who has the authority to request supporting documents as
applicable. The divisional office has the power to take decision on Green and Amber-A & B
category projects and the Red category projects are forwarded to head office for approval.
The proposed projects receive an environmental site clearance at the beginning and the
environmental clearance subject to the implementation of the project activities and all
mitigation measures suggested in the IEE report or in the application. In
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case of Red category, the client needs to submit an IEE report for site clearance and EIA to
obtain EIA approval and environmental clearance.

2.6 POWER SCENARIO AND MASTER PLAN IN BANGLADESH

Power and energy are vital factors that determine the growth path of a developing country
like Bangladesh whereas; electricity is the major source of power for country's most of
the economic activities. Consistent supply of power and energy can ensure development
of the economy. Nonetheless the huge demand supply gap prevailing in the power
sector has turned out to be a hurdle for the economic expansion of the nation.

The per capital electricity consumption in Bangladesh remains one of the lowest in the
Asian region, At present, only about 47% of the total population of Bangladesh has access
to electricity. Even though power has reached many urban areas, approximately
53,000 of the 68,000 villages are connected to power. Further, one million retail electricity
connections are pending. The contribution of power sector to GDP ratio has been
stagnant around 1.3% for last 5 years with the power generation being increased annually
by 2.8% during this period. The majority of power produced in the country is used for
commercial purposes. Hence, the electricity supply to households remains delicate which
is also a politically sensitive issue. The demand for electricity in the rural areas has
experienced significant growth over the years mainly driven by agriculture and small &
medium enterprises.

According to Bangladesh Power Development Board (BPDB) presently the installed

capacity as on July 2017 in the power sector is 12,376.00 MW, whereas the derated
generation capacity is approx. 9000.00 MW. According to a demand projection analysis,
the peak electricity demand is more than 8700 MW in 2016 and 9500 MW in 2017. So,
still there is a gap between supply and generation of electricity.

Because of the critical nature, the Government of Bangladesh has given highest priority
to the power sector to enhance the generation capacity. BPDB has come up with a
comprehensive plan to meet the surging demand in power. Accordingly, the government
plans to eliminate the demand supply gap and achieve the ultimate goal of providing
"electricity to all" by 2021 by having generation capacity of 20,000 MW. To ensure
overall and balanced development of the sector government has devised immediate,
short term, medium term and long term generation plans.

However, the timely implementation of above plans is a concern as there are issues

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with regards to availability of finance, competency of project sponsors and inherent
bureaucracies and other bottlenecks in the system. Further, the demand estimates for
power may also be understated to some extent. Strategies have been made to meet the
investment requirement by involving private sector with Government through Public
Private Partnership (PPP) initiatives. A successful IPP model has been designed with a
lot of comforts and protection to investors.

2.7 INSTITUTIONAL STRUCTURE OF POWER SECTOR IN BANGLADESH

Power Division is responsible for formulating policy relating to power and supervise,
control and monitor the developmental activities in the power sector of the country. To
implement its mandate, the Power Division is supported by a number of organizations,
related with generation, transmission and distribution. The overall organizational structure
and linkage is shown below:

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 Chapter 3

DESCRIPTION OF THE PROPOSED PROJECT

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3.0: DESCRIPTION OF THE PROPOSED PROJECT
3.1 TYPE AND CATEGORY OF THE PROJECT

This report is prepared following the IEE/EIA methodology as described in the Asian
Development Bank (ADB, 2003) Environmental, Health, and Safety Guidelines of IFC
(World Bank Group) (IFC 2008), and also EIA guidelines for Industries (DoE, ECR 1997,
amended in 2010) to a certain extent, but not limited to those.

All the relevant social and environmental risks and potential impacts have been taken due
care of as part of the assessment in compliance of the Performance Standards set by the
World Bank and also that of the Safeguard Standard of the Asian Development Bank
besides following the guidelines set forth by DoE.

The basic data of the AISL Unit-3 are furnished in Table-3.1

Table-3.1: Basic data on AISL Unit-3:

1. Name of the Project AISL Unit-3

2. Project Location Power Plant: Jhulda, Chittagong. Dhaka
Office: House 4, Block E, Road 19/A, Banani,
Dhaka-1213
3. Type of Business Power Generation
4. Final Product 100 MWh Electricity installed capacity
5. Net Plant Capacity 100 MWh net output capacity
6. Project Cost BDT. 700.00 Crore
9. Total Area of Land 4 Acres (approximately)
7. Total Area Developed 16,000 sqm (approximately)
8. Employment 98 persons
9. Fuel Requirement Heavy Fuel Oil: 6500 M.Ton/Month
10. Source of Water Deep Tube well
11. Water Requirement Household/Domestic: 1 cubic meter/hour

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3.2 SITE DESCRIPTION

3.2.1 Location of the Project

The proposed AISL Unit-3 plant will be set up at Jhulda, Chittagong. The location of
the project is shown in different maps in Fig 3.1(a), 3.1(b) & 3(c). The location
is well communicated by both road and river ways. The site covers an area of 4 acres of
land. The Project layout plan is presented in Annexure – 1.

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 Proposed
AISL Site

Fig: 3.1(a): Location of AISL Unit-3 in South Asia with respect to

Bangladesh

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 Proposed
AISL Site

Fig: 3.1(b) Location of AISL Unit-3 within Chittagong District

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Fig: 3.1(c) Location of AISL Unit-3

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 Table 3.2: Industries in the 10km Air shed

Aerial Distance Power

No Name of Industries from AISL Generation
(Approx.)
01 National Cement Factory Ltd. 4.6 Km 5MW (Approx.)
02 Star Cement 3.5 Km 4 MW (Approx.)
03 CEPZ (United Power Generations & 2.8 Km 44MW
Distributions Ltd., Malancha)
04 Super Petro Chemicals 3.6 Km 5 MW (Approx.)
05 Heidelberg Cement Bangladesh ltd. 3.5 Km 10 MW
(Captive Generation)
06 TSP Fertilizer Factory 4.1 Km 5MW
07 Karnafuli EPZ 2.2 Km 44MW
08 LP Gas Ltd 5.8 Km 5 MW (Approx.)
09 Petro Bangla Chittagong Refinery 5.0 Km 5 MW (Approx.)
10 NGS Cement Ltd 5.4 Km 5 MW (Approx.)
11 Eastern Refinery Ltd 5.0 Km 9 MW
(Captive Power Generation)
12 Shah Amanat International Airport 5.8 Km 3 MW (Approx.)
13 Naval Academy 5.5 Km 2 MW (Approx.)
14 KAFCO 5.5 Km 21MW
(Captive Power Generation)
15 CUFL 4.3 Km 25MW
(Captive Power Generation)
16 Anwara 1300 MW Power plant (Proposed) 9.3 Km 1300MW
17 Shikalbaha Gas Fired Steam Turbine Power 2.5Km 88MW
Station
18 Shikalbaha Energis Power Plant 4 Km 55MW
19 Shikalbaha (Duel Fuel Combined Cycle) 2.77 Km 150MW
Power Plant
20 EnergyPac Power Plant 3.34 Km 108MW
21 Baraka Patenga HFO Power Plant 9 Km 50MW
Total Generation of Power (Approx.) 1993MW

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The Detailed Planning Zones within the Chittagong City Corporation (CCC) area are
shown in table 3.3.

Table 3.3: The Detailed Planning Zones (DPZ) within the Chittagong City Corporation

Chittagong City Corporation (CCC) Detailed

Planning Zones (DPZ)
Within DPZs are: Area
CCC (acre)
DP Z 01 Patenga-Halishahar 12,704
DP Z 02 Agrabad-Kattali 10,085
DP Z 03 Sadarghat - Chawk bazaar 3,326
DP Z 04 Bakalia -Chandgaon 8,195
DP Z 05 Lalkhan bazaar-Pahartali 5,914
DP Z 06 Panchlaish - Baizid 9,601

The table 3.1 above shows that the project is within the detailed planning zone 1 (DPZ-
01). Bounded by the Karnaphuli River on the east and the Bay of Bengal on the west this
area of 51.24 sq km / 12,662 acres (BBS); is on the southernmost tip of the City. Due its
geographical location bordering the river and the sea, the port has been established here.
The openness has made it convenient to establish the only airport, which has been
upgraded to an international one in 1995. Large public sector manufacturing industries and
two EPZ’s have been established here. The riverside, coast and beach are tourist
attractions. The Area consists of four wards which are; Ward 38, Ward 39, Ward 40 & 41.
The project site is located at Jhulda which is Ward no. 41. The landuse map of DPZ-01
(Patenga-Halishahar) is shown below in figure 3.1 (g).

Significant uses are the port, airport, major industrial areas and defense establishments.
Residential uses dominate around 24%, Water bodies consisting of khals; ponds and
marshy areas, coastal chars and vacant land consist of 35.63% area.

Large public sector and heavy manufacturing industries such as the Karnaphuli EPZ
(former Steel mill), the General Electric Manufacturing GEM Plant, oil installations, cement
factory, grain silo are situated here. In the first phase the Karnaphuli EZP has leased 85
plots (@ 2000 sq m sized plots) to 7 overseas and 8 domestic companies. Two firms have
started construction and it is estimated to be in operation within 2 years. In full capacity it is
assumed to create a total of 40,000 jobs. The Chittagong EPZ (built in the 80's) has 295
industrial plots in some 560 ha of land in which 135 industries are in operation, currently
employing some 130,000 persons.

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 Figure 3.1 (g): Landuse Map of DPZ-01 (Patenga-Halishahar)

3.2.2 Electrical Interconnection

The AISL plant output evacuating power will be of 33KV from the plant’s 33KV Sub-
station, which will be hooked to the 33/132KV Halishahar Sub-station of Bangladesh
Power Development Board (BPDB) through a 6.5Km overhead transmission line. The
electrical interconnection transmission line would be constructed by AISL.

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Electrical interconnection facility is shown in a flow diagram-

Fuel Generator 11 KV BUS Transformer

PGCB Substation
(Halishahar) 33 KV Step up
Overhead Line Transformer
(33KV BUS)

3.2.3 Fuel Transportation

Vessel carrying HFO will be offloaded at a rented HFO storage facility at Chittagong Port
area at a distance of approximately 3-4 km from the power plant site..

Fig 3.2: Surrounding features of Patenga

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3.2.4 Topography of the Site & Surrounding Land

The site of the project falls under Jhulda on the East side of the river Karnaphuli. The
surrounding terrain is a low land seasonally flooded during rainy season.

3.3 PROJECT ACTIVITY

3.3.1 Site Development & Construction

3.3.1.1 Site Preparation

Site preparation would comprise the partial land filling and compaction in around 4 acres
of land prior to construction a 300mm thick carpet of crushed stone should be spread in
the lay-down areas and on the working surface. All known underground services should
be flagged up and all redundant services coming onto the site should be blanked off and
removed.

3.3.1.2 Piling

The proposed power plant is being founded on piles. The piles could be bored,
augured or driven and the type will depend upon the geotechnical data available.
However given the close location of existing generating plant it is anticipated that the
piles will be of a type which could be installed with the minimum of disturbance to existing
equipment. This would imply bored or augured piles rather than driven types.

Design load tests should be made on test piles for design purposes (design piles).
Design piles are normally loaded until the failure of the bearing soil as an aid to the
pile design in similar conditions.

3.3.1.3 Foundations

Foundations should be designed to British Standard Code of Practice BS 8004 or

equivalent Bangladesh National Building Code. The design of foundations for all
structures and equipment are to be such that differential and total settlements or other
movements should not exceed acceptable limits and ensure safe and maintenance
free operation of the plant.

Detail design parameters for the civil works would be provided by the relevant
consultant. The nature of the fill material and the construction techniques used should
be such that the less heavily loaded equipment and the buildings may be founded on
rafts or spread footings.

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3.3.1.4 Roads

The roads should be designed to be capable of carrying all the vehicles likely to be
used during construction and throughout the life of the plant including articulated
vehicles and transporters used for the removal and replacement of major items of the
plant.

Car parking and hard standing areas should be of similar construction to the roads.
The road pavements should be of reinforced concrete and in conformity with relevant
British or equivalent Bangladesh National Code of Practice.

3.3.1.5 Drainage

It is recommended that the surface water and foul drainage systems should be
separate and should be designed in accordance with BS EN 752 Parts 1 to 4 "Drain
and sewer systems outside buildings". Manhole and chamber covers should be heavy
duty throughout.

Surface Water Drainage

The capacity of the surface water drainage system should be sufficient to deal with a
storm return period of 1 in 5 years. The surface water drainage should include all
necessary gutters, down pipes, gullies, traps, catch pits, manholes etc. The quality of
the discharge shall be acceptable in all respects to the local water and environmental
authorities.

Foul Water Drainage

All waste drainage should be taken to a septic tank. A septic tank is a long retention time
tank where solids deposit out in an anaerobic bottom layer. A septic tank will be
constructed for the original power station. The Contractor shall satisfy himself that the
capacity of the septic tank is sufficient to cater for the additional load arising from the
new power station. The septic tank should be connected to a soak way by means of
an overflow pipe whereby the liquid effluent can be drained.

3.3.1.6 Power Station Buildings

The various buildings comprising the works should have a common architectural concept
in order to unify the various elements and should be suitable for the operating and
climatic conditions at site. The design should make selective use of materials to produce
a pleasing concept throughout and a working environment, which is safe, durable and
functional.

The dimension of all the buildings should be such as to provide generous space for
the safe installation and proper operation and maintenance of the plant and its
49 | P a g e
equipment. In particular generous space should be provided immediately in front of,
behind and beside all items of the plant.

In all rooms or buildings housing switchgear, a clear working space should be

provided around switchboards of at least 1.0 m behind and in front of the fully
withdrawn trucks.

It is recommend that the floors should be constructed in reinforced concrete and

designed to accommodate all foreseeable static and dynamic loads. They should be
provided with surface finish appropriate for their intended usage and properly drained
bounded areas should be provided wherever necessary to contain accidental spillage
of oil or other harmful liquids.The design of all buildings must ensure that noise, vibration
and temperature levels are within permissible limit.

3.3.1.7 Sub-station

Transformer compounds should be constructed with oil containment facilities.

Compounds should each be provided with suitable fencing and a lockable access
gate. Fences to transformer compounds and other electrical areas within the site
boundary should be of 2.4 m minimum height.

The tank should be fitted with a suitable overflow system, air vents, access hatches,
ladders, a sump and a means of emptying the tank

3.3.1.8 Site Fencing

A security fence should be provided around the permanent boundary of the site that
should be 3 m high above the site formation level.

Gates should be fabricated from galvanized steel and as a minimum provide the same
level of security as the perimeter fence. All gates should be provided with suitable
locking devices

3.4 EQUIPMENT & PROCESS FLOW

3.4.1 Power Generation Method

The AISL Unit-3 is an HFO based IPP power plant of installed capacity 105MW. However,
the declared capacity of the power plant is 100MW as per the PPA with the Bangladesh
Power Development Board.

The plant is powered by 8 engines from the world renowned Caterpillar Company, each of
capacity 13.201MW.

A small portion of the produced electricity will be consumed by all electrically operated
machinery and for lighting of the plant. All the system of the plant is being installed as per
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the design, drawing and guide lines by the Original Equipment Manufacturer (OEM) and
complying the Standards as set by the OEM. The engines are started by High Pressure Air.

The carefully designed forced ventilated Power House will contain the generating units
and other auxiliary machinery. All MV and LV electrical controls will be from the Plant’s
Control Room through the MV and LV Switch Room.

The other supporting machineries are HP Air Compressors, Charge Air Filters, Engine Hall
Ventilation Air Filters, Fuel Treatment Plant, Water Treatment Plant, Oily Water Treatment
Plant, Auxiliary Boiler, Auxiliary Diesel Generator etc.

3.5 POWER GENERATION DETAILS

The proposed power plant will use imported Heavy Fuel Oil for the generation of electricity.
This supplied fuel will be burnt in internal combustion engine for complete combustion;
the generated pressure as a result of combustion will operate the generator sets by some
rotating mechanism and will produce electricity.

3.5.1 Technical Data of Engine

The engine specifications of the HFO engine are attached in the annexure-2.

3.6 Fuel

3.6.1 Fuel Treatment

Liquid fuels vary substantially in hydrocarbon composition, physical properties and level of
contaminants. Hence, treatment of the heavy fuel oil is mandatory. The imported heavy fuel
oil would undergo proper treatment before feeding to the engines.

The major functions of a heavy fuel forwarding system are: pumping, heating, fuel selection,
filtration, and metering. Heating requirements will vary depending on the viscosity of the
fuel. However, heavy fuel oils may require heating to 135-160°C to reduce viscosity to an
acceptable level.

3.6.1.1 HFO Purifier

HFO Purifier will be used to separate sludge and water content from HFO. The separated
water and sludge will be properly treated.

3.6.1.2 Oily water Treatment

There will be an oily water separator which will trap waste oil from the oily water. The
treated water will be drained properly.

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3.6.2 Fuel Specifications

The fuel specification is provided in the annexure – 3

3.7 Water Purification System

There would be efficient water purification system for the proper treatment of water to be
used in the cooling towers and the boilers. The required water would be the extracted from
the ground by deep tube well. The raw water would be filtered through Multimedia filter,
Iron filter & Reverse Osmosis filter respectively. After filtration about 35 cubic m. per hour
RO filtered water will be available which will be stored in the filtered water tank.

There will be closed loop cooling system in the power plant. The amount of make-up water
for these cooling towers is about 21 cu. m. which will be supplied from the filtered tank.
About 8 cu. m water will be pumped to the Reverse osmosis unit for second phase RO
filtration for the boiler feed. The detail of water purification system is shown in flow diagram
presented in the Annexure – 4.

3.8 Engine Emission Specifications

The engine emission specification is provided below in table 3.4:

Table 3.4: Flue Gas Data (Design Condition)@ESP inlet "40 mg/nm3" @ 02 Dry volume basis
Unit "13.201" Remarks
Items MW/set
Flue Gas Flow Nm3/hr‐wet "86200" "315" deg. C at
(design) 100% load
"(m3/hr)"
kg/hr "51100" At "315" deg. C
one standard
atmospheric
pressure
Flue Gas Density mg/m3 0.59280742 "kg/m3" at 315
5 Deg C & 1.013 bar
(abs)
Temperature C ( Normal) "315"
C (Maximum) "355" MAX
Pressure mmH2O "400" mmWC
Flue Gas analysis Molecular Weight
CO2 % by vol
N2 % by vol
O2 % by vol
H2O % by vol
SO2 % by vol "0.02"
SO3 % by vol "0.02"
NOx % by vol "1390" mg/nm3 at 15%

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 O2
HF % by vol
HCI % by vol
TOTAL % by vol
Inlet Dust mg/nm3 " 40 A means the
mg/nm3" amount of dust in
per nm4 air

Guarantee @ stack

"Not
Outlet Dust mg/nm3
Applicable"
Removal Efficiency % "Not
Applicable"
Pressure Drop mmH2O "Not Max
Applicable"

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 Environmental Impact Assessment of AISL Unit-3.
At Jhulda, Chittagong.
Chapter4: Baseline Environment

4.0: BASELINE ENVIRONMENT

4.1 General Consideration

Baseline condition of environment states the present status of different components of

environment in absence of the project. The main objective of examining the present
environment is to provide an environmental baseline against which potential impacts from
construction and operational phases of any project can be compared. A second important
function of establishing a baseline for parameters such as air and water quality is to
ensure that any problems arising from existing sources are not erroneously attributed to the
project under study. In the present study the different environmental components examined
for setting baseline conditions of the project area, are physico-chemical, biological and
socio-economical. The study area covered both the immediate site, and an extended area
of about 5 km radius. In physico-chemical component, parameters included are land, water
quality, air quality, climate, and noise.

4.2 Physico-Chemical Environment

4.2.1 Land

4.2.1.1 Surrounding Land Uses

The AISL Unit-3, a Bangladesh company, intends to build and operate a Power plant based
on imported Heavy Fuel Oil (HFO) at Jhulda, Chittagong. The proposed power plant will
be constructed to produce 100 (± 10 %) MW electricity. Industries, such as oil refinery,
metal industries are primarily located at Jhulda.

4.2.2 Topography, Soil & Geology

Chittagong city has a unique topography and is well known for the panoramic view of its
hilly landscape. This is the only mega city of the county having wide variety of
morphological features, the spectacular undulating hill topography in one side and the low
lying coastal mud flats on the other side. It is not the urban planners; rather it is the natural
process that has given the city morphology in to its present shape. The Karnafully
River in the east, the Bay of Bengal in the West and the Tertiary hill landscape

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in the North are three major determinants for origin, development, and horizontal and
vertical expansion of the city. A total of eight geomorphic units have been identified, which
are Tertiary hills, piedmont and valleys, alluvial plain, ancient point bar, tidal mud plain,
supra tidal plain, natural levee and sandy beach. The soil is made up of
93% loamy mainly with non-calcareous alluvium and non-calcareous flood plain soil. The
remaining 7% has clayey texture.

The land use pattern and landform in Chittagong City is given in the following table 4.1-

Table 4.1: Interrelation between Land use and Landform in Chittagong City
Landforms Major Land uses
High Class Residential Area,
1. Hill Vegetation Coverage, Vacant Land,
Government Buildings
Middle Class Residential Area, Roads
2. Piedmont & High Ways, Commercial Area,
Industrial Area, Administrative Uses,
Slums and Squatters, Educational
Institutes, Religious Places, Park and
Playground etc.
Agricultural Uses Middle Class
3. Alluvial Plain Residential Area, Agrabad
Commercial Area, Industrial Area,
Administrative Uses
Agriculture, Mixed Residential Area,
4. Ancient Point Bar Industrial, EPZ Airport and
Commercial Activities.
5. Supra Tidal Plain Agriculture Area, Low Income
Residential
6. Tidal Mud Plain Vacant, Mangrove forest, Shrimp
farms,
7. Natural Levee Port Activities, Navy office and
residents, Mixed Residential use
8. Sandy Beach Recreational (Tourism), Vacant Land
(Source: Department of Geography and Environment, University of Dhaka)

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The river Karnafully with its strong tidal behaviour has been playing a major role to
determine the land-ocean interface in city morphology. Except the hilly, valley and
piedmont areas, remaining of the city is generally a plain land. The project area is located
in the Jhulda plain which contains the interfingering of sand and silt-clay layers. The type
of landform of Jhulda is recent alluvial, point bar and tidal deposits and abandoned
channel and depression. The Physiographic Map of Bangladesh, Digital Elevation Model
of Bangladesh & Geomorphic map of Chittagong is shown in figure- 4.1, figure- 4.2 &
figure- 4.3 respectively.

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Fig. 4.1: Physiographic Map of Bangladesh

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Fig. 4.2: Digital Elevation Model of Bangladesh

Fig. 4.2: Digital Elevation Model of Bangladesh

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Fig. 4.3: Geomorphic Map of Chittagong (Source: CDMP)

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4.2.3 Hydrology

Surface Water of Project Area

Water supply of the Chittagong City is largely dependent on ground water abstraction from
underlying aquifer system. As other parts of the country this area also receives sufficient
amount of rainfall and there is a good availability of ground water, which is being, used by
hand pumps for drinking and domestic purposes. Most of the water bodies in the area are
ponds and some of these ponds are generated due to excavation of earth. There are
some low lying flood plain areas, which remain under water during flood period (July-
October).

4.2.4 Water Quality

4.2.4.1 Surface Water

The Karnafuli River is the only surface water body adjacent to the project site. The river
carries run-off water from adjoining areas and Chittagong city, which might contain some
pollutants. Water was collected from the river and analyzed in AECL Laboratory. The
water quality of limited parameters of the ditch near the project site as analyzed is given
below in Table 4.2.

Table-4.2: Surface Water quality (limited parameters) of the Karnafuli River

Parameter Value
PH 7.5
TDS 1010 mg/l
DO 6.8 mg/l
BOD5 0.5 mg/l
COD 6.0 mg/l
Chloride 252 mg/l
Alkalinity 126 mg/l
Source: AECL Lab (sample collected on 05.12. 2011 and reporting on 10.12.2011)

4.2.4.2 Ground Water

Ground water level exists at a moderate (Generally below 8.0 m) depth, which is being
recharged mainly by infiltration of rainwater. The ground water zoning map is shown in fig
4.4. Ground water is the source of water for domestic use in this area. Usage of ground
water for irrigation is limited here. The recharge capacity of the ground water level seems
to be adequate. To determine quality of ground water, water sample was collected from a
nearby tube well of the existing plant of the AISL and analyzed for different parameters.
The results shows that all the parameters remain within the allowable limit of drinking
water value as per as Environmental Quality Standards for Bangladesh. The parameters
which have been analyzed during this study are presented below in Table 4.3 –

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 Table-4.3: Ground Water quality (limited parameters) of Project Site
Parameter Value
H
P 7.1
Total Dissolved Solids 280 mg/l
Iron 1.2 mg/l
Alkalinity 62 mg/l
Hardness 74 mg/l
Chloride 16 mg/l
Source: AECL Lab (water collected on 05.12. 2011 and reporting on 10.12.2011)

Fig. 4.4: Ground Water Zoning Map of Bangladesh

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4.2.5 Air Quality

Air quality depends on substances, which are present in atmosphere in such concentrations
that they produce undesirable effects on human beings, animal and as well as plant life.
These substances include gases (SOx, NOx, CO2, etc.), Suspended Particulate Matter
(smoke, dust, fumes, etc.), and many others. Concentration of different pollutants above
allowable level can have adverse impacts on plant, animal and human life.

In order to establish baseline air quality, monitoring program was undertaken at the area.
An eight hourly air sample was collected through high volume air sampler. Monitoring was
done for SPM, SOx, and NOx and monitoring results are given in Table 4.4.

Table-4.4: Ambient air quality of the nearby Road of the project

Parameter Value (µg/m3)
PM 2.5 44
PM 10 113
SPM 270
SO2 22
NOx 24
CO 70
Source: AECL Lab (measured on 05.12. 2011 by Respirable Dust Sampler of AECL)

However, the measured air quality data is not sufficient for the assessment of degraded air
shed in an area. The Continuous Air Monitoring Station-7, Agrabad (CAMS) shows the
monthly concentrations of PM 2.5 and PM10 are much higher compared to the National
standards. The Continuous Air Monitoring Stations reports for the months of September-
2017to December 2017 is presented in Annexure - 5

The following are the summery result of the CAMS report:

Table-4.5: Ambient air quality of Chittagong According to CAMS-7

Parameter Value (µg/m3)

Monthly Average
September October November December
2017 2017 2017 2017
PM 2.5 – 24hr 140.44 177.95 126.89 100.90
PM 10 -24hr 195.42 277.62 231.20 193.83
Source: CAMS -7 (MoEF, Monthly Air Quality Monitoring Report)

PM 2.5 - Fine Particulate Matter

PM10 - Respirable dust content

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 SPM - Suspended Particulate Matter
SO2 - Sulfure di-Oxide
NOX_- Oxides of Nitrogen
CO- Carbone Mono-oxide

As per the Environmental, Health & Safety guidelines (for Thermal power plant) of IFC/WB
2008, a degraded air shed should be considered if nationally legislated air quality standards
are exceeded or in their absence, if WHO air quality guidelines are exceeded standards
are exceeded significantly. So, from the above table it is evident that the national air quality
has been exceeded in all months, so the area falls under degraded air shed (DA) for the
emission standard comparison with IFC/WB.

4.2.6 Noise Level

The most sophisticated machineries will be installed in AISL Unit-3, which will produce little
significant noise. It is suggested that the proponent should create a green belt around the
project site, administrative building and other services buildings, which would reduce the
noise level significantly. The ambient noise level data were collected from different sides of
the project by noise level meter and they are given below in Table 4.6.

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 Table 4.6: Ambient Noise Quality Analysis

Sample Location Project from West side (near boundary area)

Time of Day Time Night Time

Experiments
06.00 To 09.00 am 12.00 To 03.00 To 06.00 To 09.00 To 12.00 To 03.00 To
09.00 am To 12.00 03.00 pm 06.00 pm 09.00 pm 12.00 am 03.00 am 06.00 am
pm

Concentrations Max: 66 Max: 68 Max: 70 Max: 66 Max: 65 Max: 62 Max: 59 Max: 58

present (LAeq) Avg: 55 Avg: 56 Avg: 54 Avg: 53 Avg: 55 Avg: 50 Avg: 48 Avg: 46
dBA. Min: 45 Min: 47 Min: 44 Min: 42 Min: 44 Min: 41 Min: 38 Min: 40

Sample Location Project from East side (near boundary area)

Time of Day Time Night Time

Experiments
06.00 To 09.00 am 12.00 To 03.00 To 06.00 To 09.00 To 12.00 To 03.00 To
09.00 am To 12.00 03.00 pm 06.00 pm 09.00 pm 12.00 am 03.00 am 06.00 am
pm

Concentrations Max: 68 Max: 72 Max: 71 Max: 69 Max: 68 Max: 66 Max: 64 Max: 63

present (LAeq) Avg: 54 Avg: 58 Avg: 55 Avg: 57 Avg: 56 Avg: 52 Avg: 49 Avg: 50
dBA. Min: 47 Min: 48 Min: 43 Min: 50 Min: 44 Min: 42 Min: 40 Min: 42

Sample Location Project from North side (near boundary area)

Time of Day Time Night Time

Experiments
06.00 To 09.00 am 12.00 To 03.00 To 06.00 To 09.00 To 12.00 To 03.00 To
09.00 am To 12.00 03.00 pm 06.00 pm 09.00 pm 12.00 am 03.00 am 06.00 am
pm

Concentrations Max: 69 Max: 71 Max: 72 Max: 70 Max: 69 Max: 68 Max: 67 Max: 66

present (LAeq) Avg: 52 Avg: 56 Avg: 53 Avg: 54 Avg: 55 Avg: 52 Avg: 46 Avg: 48
dBA. Min: 41 Min: 44 Min: 42 Min: 44 Min: 43 Min: 41 Min: 38 Min: 39

Sample Location Project from South side (near boundary area)

Time of Day Time Night Time

Experiments
06.00 To 09.00 am 12.00 To 03.00 To 06.00 To 09.00 To 12.00 To 03.00 To
09.00 am To 12 pm 03.00 pm 06.00 pm 09.00 pm 12.00 am 03.00 am 06.00 am

Concentrations Max: 68 Max: 71 Max: 70 Max: 68 Max: 69 Max: 68 Max: 69 Max: 75

present (LAeq) Avg: 56 Avg: 59 Avg: 56 Avg: 58 Avg: 57 Avg: 53 Avg: 50 Avg: 49
dBA. Min: 42 Min: 49 Min: 44 Min: 49 Min: 44 Min: 42 Min: 40 Min: 40
DoE
(Bangladesh)
Standard Day Time – 75 dBA & Night Time – 70 dBA (For Industrial Zone)

IFC/Int’l Standard 70 dBA - Day & Night time (For Industrial/commercial Zone)

Remark Maximum noise source from vehicular/Ship movement and human activities.
All units are in (LAeq) dBA
Source: AECL Lab (measured on 04.12. 2017 by Sound Level Meter of AECL)

64 | P a g e
4.2.7 Climatic Condition

The climate of Chittagong of which the project is a part, is average tropical monsoon with
alternating dry/wet seasons. The weather condition of the area is described in this report to
have an idea of the project site in terms of climatic condition.

 November to February: The dry (winter) season is the coolest and driest period.
Monthly average temperatures are below 280C with a minimum at 15.70C. Rainfall
is very rare during this period. Winds are predominantly blowing from the Northwest
but with a high frequency of calm wind situations.

 March and April: In the pre-rainy season (summer) and the early months of the wet
seasons, the highest temperatures are reached. The monthly average temperature
can rise up to 330C. During this period, air becomes more humid, rainfall increases,
and heavy rains with thunderstorm occur. This period is locally called as
“Kalbaaishakhi”. Sometimes the rain falls with hail.

 May to October: In the wet season (“monsoon period”) more than 85% of the total
annual rainfall occurs. Monthly average temperatures remain high with a maximum
of 32.40C. The period of periodic heavy thunderstorms lasts until June. June to mid-
September to early November is the transitional period with decreasing rainfall, often
thunder. During the wet season, the winds are predominantly blowing from the
South.

During the pre-monsoon period, squally winds of up to 130 km/h or occasionally more, often
accompanied by thunderstorms may damage assets and crops. Cyclonic storms occurring
in the Bay of Bengal in April-May and October-November rarely penetrate as far as Comilla,
but may cause serious damage to crops, livestock, assets, and people when they do so.
Monsoon rains are generally not stormy, but downpours of 50-75 mm per day are not
uncommon and rainfall with more than 250mm per day is occasionally experienced.

In the wet seasons, between June and September, the cloud cover reduces the hours of
daily sunshine from about 8 to 5 hours. The cloud cover is thicker and appears more
frequently than in other months. This is accompanied by a higher stability of the
atmosphere, which reduces dispersion of emitted air pollutants and hence may cause
higher concentration levels of pollutants in the vicinity of emission sources.

The relative humidity rises to above 90% during the wet season. The mean annual
evaporation is high, with the highest daily figures occurring during March to May when the
mean daily temperatures are at their highest. The mean monthly maximum temperature in
Chittagong varies from 28.0°C in January, to 33.8°C in April. A maximum daily of 33.8°C
and a minimum of 14.9°C have been recorded. The mean daily maximum temperatures

65 | P a g e
rise during March (33.0°C) and April (33.8°C) as a prelude to the oncoming rains. As is to
be expected, the mean daily maximum temperature drops when the rainy season starts.

The name of the weather station at Patenga is 419780 (VGEG). The monthly average
climatic values of past few years are shown below:

Table 4.7: Monthly average climatic values (2014-2017)

[Year: 2014]
Month Mean Max Min Mean sea Mean Precipitation Mean Mean Maximum
temp temp temp level humidity amount visibility wind sustained wind
pressure speed speed
(°C) (°C) (°C) (hPa) (%) (mm) (Km) (Km/h) (Km/h)

Jan 20.8 25 15.8 1011.8 70.7 67.82 3.5 7.9 16.7

Feb 21.8 26.1 16.6 - 61.6 8.13 4.2 8.7 18

March 26.3 29.7 22.7 1011.8 74.7 6.35 4.6 7.1 17.2

April 28.7 31.9 24.8 - 70 0 5.7 10.4 20

May 29 31.9 25.8 - 74.8 228.33 6.7 11.3 22.8

June 28.1 30.5 26.2 - 81.5 612.89 6.3 15.8 24.2

July 27.3 29.4 25.7 - 85.6 941.32 6.4 15.2 23.1

Aug 27.8 30.3 25.9 - 83.7 528.58 6.5 14.5 22.8

Sep 28.2 30.9 25.9 1001.6 81.2 247.39 6.7 11.5 20.2

Oct 28 30.8 25 1009.7 78.2 176.28 5.9 8.9 17

Nov 25.7 29.6 20.9 1009.4 68.8 30.98 5.6 6 14

Dec 23.1 26.5 18.6 - 72.7 0 3.9 8 13.1

- The highest temperature recorded was 34.2°C on June 15.

- The lowest temperature recorded was 12°C on February 3.
- The maximum wind speed recorded was 74.1 km/h on May 26.
- Annual total precipitation: 2848.07 mm
- Annual average wind speed:10.2 km/h

[Year: 2015]
Month Mean Max Min Mean sea Mean Precipitation Mean Mean Maximum
temp temp temp level humidity amount visibility wind sustained
pressure speed wind speed
(°C) (°C) (°C) (hPa) (%) (mm) (Km) (Km/h) (Km/h)

Jan 22.4 26.5 16.1 1011.8 63.1 0 4.1 7.4 17

Feb 24.5 29 17.9 1013.9 58 1.78 4.4 9.9 18.7
March 27.3 31.6 22.8 1011.3 65.3 42.93 4.6 8 16.3
April 28.9 31.9 25.8 1007.6 7602 75.95 6.1 13.3 21.4

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May 29.2 32.6 25.8 - 75.4 374.39 6.8 11.4 20.5

June 29 31.7 26.5 1001.9 79.9 431.81 6.8 13 19.9

July 27.7 30.5 25.8 - 85.9 1248.15 5.9 15.8 24.8

Aug 28 30.8 26.2 - 84.9 580.64 6 11.6 20.4

Sep 28.3 31.3 25.8 - 82.1 281.18 6.1 9.9 20.6

Oct 27.8 31.2 24.8 1007.7 76.8 299.72 5.1 7.3 17.6

Nov 25.6 29.9 21.5 1014.3 70.7 17.27 4 5.1 14.7

Dec 21.7 26.3 16.8 1014.3 69.9 0 3.6 5.9 15.5

- The highest temperature recorded was 38.7°C on July 28.

- The lowest temperature recorded was 10.8°C on January 20.
- The maximum wind speed recorded was 79.5 km/h on September 21.
- Annual total precipitation: 3353.82 mm.
- Annual average wind speed: 9.9 km/h.

[Year: 2016]
Month Mean Max Min Mean Mean Precipitation Mean Mean Maximum
temp temp temp sea level humidity amount visibility wind sustained wind
pressure speed speed
(°C) (°C) (°C) (hPa) (%) (mm) (Km) (Km/h) (Km/h)

Jan 20.6 25.2 15.1 - 67.9 0 3.2 9.1 16.4

Feb 24 28.9 17.7 - 56.9 7.87 3.8 6.5 20.6

March 27.6 31.3 23.3 - 69.5 154.18 4.7 11.5 20.3

April 29.3 32 26.6 1011.8 76.3 31.49 5.9 14.2 22.2

May 29 31.9 26.1 1005.2 78.8 373.63 5.8 11.9 23.5

June 28.4 31.2 26.3 1004.7 84.9 648.46 5.4 13.2 23

July 28.6 31.6 26.4 1004.1 82.6 295.39 6 12.5 20.4

Aug 28.5 31.7 26.1 1006.1 84 460.01 5.9 9.3 17.2

Sep 28.6 31.8 26.2 1005.4 82.7 116.82 5.9 7.8 14.5

Oct 28.4 31.8 25.4 1005.5 80.3 320.81 5 5.4 15.8

Nov 26.1 29.8 22 - 73.3 37.59 4.4 3.8 13.9

Dec 21.9 26.4 16.8 - 69.2 19.05 3.4 4.5 14.4

- The highest temperature recorded was 36.3°C on March 18.

- The lowest temperature recorded was 12.6°C on January 13.
- The maximum wind speed recorded was 55.4 km/h on May 27.
- Annual total precipitation: 2465.30 mm.
- Annual average wind speed: 9.2 km/h.

67 | P a g e
[Year: 2017]
Month Mean Max Min Mean Mean Precipitation Mean Mean Maximum
temp temp temp sea level humidity amount visibility wind sustained wind
pressure speed speed
(°C) (°C) (°C) (hPa) (%) (mm) (Km) (Km/h) (Km/h)

Jan 19.9 24.8 13.9 - 62.4 0 3 6.5 16

Feb 23.6 28.4 17.5 - 60.8 0 3.5 6.9 16.9

March 26.2 30.6 21 - 63.9 109.72 4.1 9.2 21.2

April 28 31.1 24.4 - 75 49.28 4.3 6.5 17.8

May 28.7 31.5 25.5 1002.9 79 299.46 5.3 9.9 22

June 28.1 30.3 26.2 - 84.4 456.43 4.9 10.6 18.9

July 28.3 30.9 26.1 - 83.4 583.96 5.3 9.7 18.5

Aug 27.8 30.3 25.7 - 85.3 807.47 5.1 8.7 17.1

Sep 27.9 30.5 25.6 - 84.3 764.79 5.2 9.3 20.6

Oct 28.2 31.1 25.1 - 77.7 23.87 4.8 4 13.2

Nov 24.7 28.9 20.2 - 70 0 4.1 3.6 15.4

Dec 21.3 25.3 17.2 - 73.1 0 3.2 4.6 15.1

- The highest temperature recorded was 34.4°C on June 15.

- The lowest temperature recorded was 8°C on January 8.
- The maximum wind speed recorded was 66.5 km/h on September 23.
- Annual total precipitation: 3094.98 mm
- Annual average wind speed: 7.5 km/h

4.2.8 Coastal Region

Bangladesh is one of the largest deltas in the world and it is formed mainly by the Ganges-
Brahmaputra- Meghna river system, except for the hilly regions in the northeast and
southeast and terrace land in northwest and central zones. It has about 710 km long
coastline. About 28% of the populations live in coastal region.

The coastal region of Bangladesh is prone to multi hazard threats such as cyclones, storm
surges and floods, as well as earthquakes and above all, climate change. It is frequently
visited by the cyclone-induced storm surge. Figure 4.5 & Figure 4.6 shows the coastal
region of Bangladesh as well as the disaster prone areas in Bangladesh. Jhulda where the
project site is located falls in the exposed coastal zone as shown in the figures below.

68 | P a g e
Fig. 4.5: Map of the Coastal Zone of Bangladesh

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 N Disaster Prone Areas in Bangladesh
G (By Districts)
E A
T
L
i
B N
s
t
a

R.
50 0 50 Kil om eters

M IN D IA
IN D I A E H A A
O G L Y
l
A d A

t a
B
r m
r u
a
r S

S A
h
a
G m
i

M
a
A R. p
N u
T
G
t r
E a

S R
I
G R.
A
o
P M
IN D I A
r
IN D I A
R
a U
I

R.

IN D IA O
P
a
s R
K
h a
c
u h
a
A
r R.

R.
M

A
LEG EN D B A Y O F B E N G A L
In ter n atio na l B o un d ar y
M
D istr ict B o u nd ar y A
Riv er Sys tem s N
Cy clo ne & T id al Su rge
Y
Floo d
Fla sh Flo od
Dr oug ht M

Man ag em ent Inf orm ati on & Mo nitor ing (MI M) D iv is io n

Dis a st er M an age me nt Bu reau (DM B) , Se pte mb er 1 3 ' 99 St. Martin Is.

Fig. 4.6: Disaster Prone Areas in Bangladesh

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4.2.9 Cyclone and Tidal Surge

Bangladesh very often becomes the landing ground of cyclones formed in the Bay of
Bengal. This is because of the funnel shaped coast of the Bay of Bengal, Most of the
damage occurs in the coastal regions of Khulna, Patuakhali, Barisal, Noakhali and
Chittagong and the offshore islands of Bhola, Hatiya, Sandwip, Manpura, Kutubdia,
Maheshkhali, Nijhum Dwip, Urir Char and other newly formed islands. The coastal zone of
Bangladesh is disaster prone. Jhulda is in the exposed coastal area which is frequently
subjected to cyclone and storm surges.

Areas Affected By Cyclone in Bangladesh

50 0 50 Kilo m et e rs

Sev e re Cy c lo nic S tor m s in R ec e nt Yea rs

Da te o f E ve n t W i nd s p ee d S tor m S u r ge De a th s ( n r)
Ma x (K m /h r ) H e ig h t ( m )
Lege nd O ct 0 9 , 1 9 6 0 16 0 3.0 3000
O ct 3 0 , 1 9 6 0 20 8 4 .0 - 6.0 5149
Cyc lon ic R isk Zo n e Ma y 0 9 , 1 9 6 1 14 4 2 .4 - 3.0 11 4 6 6
No R isk Ma y 2 8 , 1 9 6 3 20 0 4 .2 - 5.1 11 5 2 0
W in d R isk Ma y 1 1 , 1 9 6 5 16 0 3.6 19 2 7 9
De c 1 4 , 1 9 6 5 20 8 4 .6 - 6.0 873
Ris k
O ct 0 1 , 1 9 6 6 14 4 4 .6 - 6.1 850
Hig h R is k
No v 1 2 , 1 9 7 0 22 4 6 .0 - 9.1 3 00 0 0 0
Ma y 2 5 , 1 9 8 5 15 2 3 .0 - 4.6 11 0 6 9
Ma nage m en t I nformation & Mo nitoring ( MI M ) Div isio n No v 2 9 , 1 9 8 8 16 0 1 .5 - 3.0 5708
Disas te r M anag em ent Bure au ( DM B ), Jan uary 2001 Ma y 2 9 , 1 9 9 1 22 5 4 .0 - 5.0 1 38 8 6 8

Fig. 4.7: Areas Affected by Cyclone in Bangladesh

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A cyclone risk map, prepared by the Management Information & Monitoring (MIM) Division
of the Disaster Management Bureau (DMB) in 2001 (Fig: 4.7), was available that
distinguishes between the following risk zones:

- No risk
- Wind risk
- Risk (low risk as mentioned in 2003)
- High Risk

Further communications have happened with the Disaster Management Bureau (DMB) in
2003.
Both the “risk” and “high risk” zones have been incorporated as coastal zone.

The inundation risk map for storm surge (Figure: 4.8) shows that the highest inundation
depth having range between 5 m and 7.5 m lies in the Noakhali coast, Bhola, Urir Char,
Sandwip and small islands in the Meghna Estuary. The eastern coast experiences
maximum inundation between 4m and 6 m. Jhulda is located in the north eastern coastal
area. Figure 4.9 shows the Tropical cyclones from the Bay of Bengal accompanied

Fig. 4.8: Inundation risk map generated from 18 cyclones from 1960-2007 (Source: IWM)

72 | P a g e
by storm surges are one of the major disasters in Bangladesh. The country is one of the
worst sufferers of all cyclonic casualties in the world. The high number of casualties is due
to the fact that cyclones are always associated with storm surges. Storm surge height in
excess of 9m is not uncommon in this region. For example, the 1876 cyclone had a surge
height of 13.6 m and in 1970 the height was 9.11 m (WARPO, 2005). Another high intensity
cyclone of 1991 caused large scale destruction to coastal embankments along the
Patenga area in Chittagong, destroyed runways of Chittagong airport, ceased port activities
by sinking a number of ships in the Patenga channel and also in offshore anchorage. The
storm surge height with respect to ground was within the range of 3.0 m to
3.7 m. A list of devastating cyclones in Bangladesh is given in Table 4.8.

Table 4.8: Major Cyclones in Bangladesh (Source: BMD)

Maximum Wind Storm Surge height
Year
Date Death Toll
speed (km/hr) (metres)
11 May 1965 161 3.7-7.6 19,279
15 December 1965 217 2.4-3.6 873
01 October 1966 139 6.0-6.7 850
12 November 1970 224 6.0-10.0 300,000
25 May 1985 154 3.0-4.6 11,069
29 April 1991 225 6.0-7.6 138,882
19 May 1997 232 3.1-4.6 155
15 November
(SIDR) 2007 223 - 3363
25 May (AILA) 2009 92 - 190
Chronology of major cyclonic storms in Chittagong

1960 (30-31 October) Chittagong, Noakhali, Bakerganj, Faridpur, Patuakhali and eastern
Meghna estuary; severe cyclonic storm, maximum wind speed 210 km/h, surge height
4.5m -6.1m; about 10,000 persons killed, 27,793 cattle lost and 568,161 houses destroyed
(especially 70% of houses in Hatiya blown off), two large ocean liners washed ashore, 5-7
vessels capsized in Karnafuli river.

1963 (28-29 May) Chittagong, Noakhali, Cox's Bazar and the offshore islands of Sandwip,
Kutubdia, Hatiya and Maheshkhali were badly affected; severe cyclonic storm with storm-
wave rising 4.3-5.2m in Chittagong, maximum wind speed 203 km/hr and at Cox's Bazar
164 km/hr; more than 11,520 people killed, 32,617 cattle lost, 376,332 houses, 4,787
boats and standing crops destroyed.

1966 (1 October) Sandwip, Bakerganj, Khulna, Chittagong, Noakhali and Comilla; severe
cyclonic storm with storm-waves of 4.7-9.1m, maximum wind speed 146 km/hr; affected

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1.5 million people, loss of human life and livestock were 850 and 65,000 respectively in
Noakhali and Bakerganj.

1970 (12-13 November) The most deadly and devastating cyclonic storm that caused the
highest casualty in the history of Bangladesh. Chittagong was battered by hurricane winds.
It also hit Barguna, Khepupara, Patuakhali, north of Char Burhanuddin, Char Tazumuddin
and south of Maijdi, Haringhata and caused heavy loss of lives and damage to crops and
property. Officially the death figure was put at 500,000 but it could be more. A total of
38,000 marine and 77,000 inland fishermen were affected by the cyclone. It was estimated
that some 46,000 inland fishermen operating in the cyclone affected region lost their lives.
More than 20,000 fishing boats were destroyed; the damage to property and crops was
colossal. Over one million cattle head were reported lost. The maximum recorded wind
speed of the 1970 cyclone was about 222 km/hr and the maximum storm surge height
was about 10.6m and the cyclone occurred during high-tide.

1974 (24-28 November) Coastal belt from Cox's Bazar to Chittagong and offshore
islands; severe cyclonic storm with a wind speed of 161 km/h and storm surge of 2.8-5.2
m; 200 people killed, 1000 cattle lost and 2,300 houses perished.

1977 (9-12 May) Khulna, Noakhali, Patuakhali, Barisal, Chittagong and offshore islands;
cyclonic storm with a wind speed of 112.63 km/h.

1983 (14-15 October) Offshore islands and chars of Chittagong and Noakhali; severe
cyclonic storm with a wind speed of 122 km/h; 43 persons killed, 6 fishing boats and a
trawler lost, more than 150 fishermen and 100 fishing boats missing and 20% Aman crops
destroyed.

1983 (5-9 November) Chittagong, Cox's Bazar coast near Kutubdia and the low lying areas
of St Martin's Island, Teknaf, Ukhia, Moipong, Sonadia, Barisal, Patuakhali and Noakhali;
severe cyclonic storm (hurricane) with a wind speed of 136 km/h and a storm surge of
1.52m height; 300 fishermen with 50 boats missing and 2,000 houses destroyed.

1985 (24-25 May) Chittagong, Cox's Bazar, Noakhali and their offshore islands (Sandwip,
Hatiya, and Urirchar); severe cyclonic storm, wind speed Chittagong 154 km/h, Sandwip
140 km/h, Cox's Bazar 100 km/h and storm surge of 3.0-4.6m; about 11,069 persons killed,
94,379 houses damaged, livestock lost 135,033 and road damaged 74 km, embankments
damaged.

1986 (8-9 November) Offshore island and chars of Chittagong, Barisal, Patuakhali and
Noakhali; cyclonic storm hit 110 km/h at Chittagong and 90/h at Khulna; 14 persons killed,
damaged 97,200 ha of paddy fields.

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1991 (29 April) The Great Cyclone of 1991, crossed the Bangladesh coast during the night.
It originated in the Pacific about 6,000 km away and took 20 days to reach the coast of
Bangladesh. It had a dimension of more than the size of Bangladesh. The central overcast
cloud had a diameter exceeding 600 km. The maximum wind speed observed at Sandwip
was 225 km/hr. The wind speeds recorded at different places were as follows: Chittagong
160 km/hr, Khepupara (Kalapara) 180 km/h, Kutubdia 180 km/h, Cox's Bazar
185 km/h, and Bhola 178 km/h. The maximum wind speed estimated from NOAA-11
satellite picture obtained at 13:38 hours on 29 April was about 240 km/h. The cyclone was
detected as a depression (wind speed not exceeding 62 km/h) on the 23rd April first in the
satellite picture taken at SPARRSO from NOAA-11 and GMS-4 satellites. It turned into a
cyclonic storm on 25 April. The cyclone in its initial stage moved slightly northwest and then
north. From 28 April it started moving in a north-easterly direction and crossed the
Bangladesh coast north of Chittagong port during the night of the 29th April. The cyclone
started affecting the coastal islands like Nijhum Dwip, Manpura, Bhola and Sandwip from
the evening of that day. The maximum storm surge height during this cyclone was
estimated to be about 5 to 8m. The loss of life and property was colossal. The loss of
property was estimated at about Tk 60 billion. The death toll was estimated at 150,000;
cattle head killed 70,000.

1991 (31 May to 2 June) Offshore islands and chars of Patuakhali, Barisal, Noakhali and
Chittagong; cyclonic storm, maximum wind speed 110 km/h and surge height of 1.9m;
people killed, cattle head perished, boats lost and standing crops destroyed.

1997 (16-19 May) Offshore islands and chars of Chittagong, Cox's Bazar, Noakhali and
Bhola; severe cyclonic storm (hurricane) with a wind speed of 225 km/h, storm surge of
3.05m (similar strength to that of 1970 cyclone); only 126 people killed because of better
disaster management measures taken by the government and the people.

1997 (25-27 September) Offshore islands and chars of Chittagong, Cox's Bazar, Noakhali
and Bhola; severe cyclonic storm (hurricane) with a wind speed of 150 km/h, storm surge
of 1.83 to 3.05m.

1998 (16-20 May) Offshore islands and chars of Chittagong, Cox's Bazar and Noakhali;
severe cyclonic storm (hurricane) with a wind speed of 150 km/h, storm surge of 1.83 to
2.44m.

2007 (12-15 May) Upon striking Bangladesh, Cyclonic Storm Akash produced a moderate
storm tide, along with strong winds and heavy rains. The storm left dozens of boats missing,
with three fisherman confirmed killed and another 50 missing. Near the coast, thousands
of houses were damaged from the flooding caused by the storm. Cyclone Sidr formed in
2007 did not put much affect in this area.
2009 (14-17 April) Cyclonic Storm Bijli formed from an area of Low Pressure on April 14.
As the storm neared landfall, ports in Chittagong raised their warning level to seven.

75 | P a g e
Following the increased warning level, an estimated 10,000 evacuated from coastal regions.
Weather officials estimated that the storm would produce a storm surge of 2.1 to 3 m (7 to
10 ft). On April 17, all flights in and out of Bangladesh were cancelled due to dangerous
conditions. Shelters were also opened and were reportedly able to accommodate about one
million people.

2009 (23-26 May) Cyclonic Storm Aila was about 475 km southwest of Chittagong port,
435 km southwest of Cox's Bazar port and 345 km south southwest of Mongla port.
Maritime ports of Chittagong and Cox's Bazaar had been advised to keep hoisted danger
signal number 6. Maximum sustained wind speed within 54 km of the storm centre was
about 70 km/h rising to 90 kph in gusts or squalls.

(Source: DMB)

The tracks of few major cyclones that hit Bangladesh are shown in Figure 4.9

Fig. 4.9: Tracks of major cyclones crossed Bangladeshi coast during the period 1960-
2007 with information on landfall date and maximum wind speed

4.2.10 Seismicity

Bangladesh is possibly one of the most vulnerable to potential earthquake threat and
damage. Earthquake vulnerability of any place largely depends on its geology and

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topography, population density, building density and quality, and finally the coping strategy
of its people and it shows clear spatial variations. Most of the parts of Chittagong, the port
city of Bangladesh consisting of fine sand and silt deposits are susceptible to liquefaction.
Chittagong City is mostly a hilly region, but it also consists of alluvial flood plain and sandy
sea-shore area. Although the hilly region is less susceptible to liquefaction, it is formed by
sandy and clayey soil and the area bottom of the hill also liquefy if the intensity of shaking
is high, which may cause landslide in the highly region. On the other hand, flood plains
and sea shore areas consisting of fine sand and silt deposit with shallow water table in most
of the places, which may liquefy during a strong earthquake.

According to the Global Seismic Hazard Assessment Program (GSHAP), the most
hazardous division in Bangladesh is the port city, Chittagong. Chittagong metropolis
together with its surroundings is situated in the seismic zone 2, which has a basic seismic
coefficient, Z=0.15 (BNBC, 1993). The Seismic zoning map is shown in fig 4.10

Fig 4.10: Earthquake Zoning Map of Bangladesh (BNBC 1993)

The most hazardous division in Bangladesh is Chittagong division. Northern and southern
sections could expect to have maximum peak ground acceleration (PGA) ranging between
0.24g to 0.40g. The Chittagong Hill Tracts region can expect the highest PGA of up to 0.4g
to 0.48g. In the basic seismic zoning map of Bangladesh, Chittagong and its surrounding

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region has been shown under Zone II with basic seismic coefficient of 0.15 (BNBC-1993),
but recent repeated shocking around this region indicating the possibilities of potential threat
of even much higher intensity like 0.35g than projected. If the Indian seismic zones were
extended across the border into Bangladesh, the country would lie in zones IV and V.
Southern Chittagong division also would lay in zone IV with a PGA of 0.4g. The seismicity
Bangladesh is shown in Fig. 4.11

Fig. 4.11: Seismic Activity of Bangladesh

It is required that artificial fill area is incorporated in the geomorphic map (refer to Figure
4.12), because these areas are high risk for the liquefaction hazard due to distribution of
loose sand caused by uncompacted work and high groundwater level. These geomorphic

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units are corresponded with the deposit type and the geological age shown in Table 4.9,
and Figure 4.12 shows liquefaction susceptibility map in Chittagong.

Table-4.9: Susceptibility for each Geomorphic Unit in Chittagong

Geological Susceptibility
Geomorphic Unit Type of Deposit Age
Depression Flood plain Holocene Moderate
Beach -Low Wave
Sandy Beach Energy Modern High
Beach -High Wave
Clayey Beach Energy Modern Moderate
Beach -Low Wave
Lower Tidal Flat Energy Holocene Moderate
Estuarine Tidal Flat Estuarine Holocene Moderate
Beach -Low Wave
Inter Tidal Flat Energy Holocene Moderate
Beach -Low Wave
Supra Tidal Flat Energy Holocene Moderate
Dunes / Delta and fan-
Younger Point Bar delta Modern High
Dunes / Delta and fan-
Ancient Point Bar delta Holocene Moderate
Dunes / Delta and fan-
Natural Levee delta Modern High
Sand Dune Dunes Modern High
Gully Fill Colluvium Holocene Moderate
Deep Valley Fill Colluvium Holocene Moderate
Isolated Valley Colluvium Holocene Moderate
River Tidal Flat Flood plain Holocene Moderate
Fluvio Tidal Plain Flood plain Holocene Moderate
Alluvial Fan Flood plain Holocene Moderate
Piedmont Plain Flood plain Holocene Moderate
Hill Slope Talus Holocene Low
No liquefiable soil
Level Hill deposit - None
Rounded Top Highly No liquefiable soil
Dissected Hill deposit - None
Sharp Crest Highly No liquefiable soil
Dissected Hill deposit - None
Sharp Crest Slightly No liquefiable soil
Dissected Hill deposit - None
(Source: CDMP, June 2009)

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The geomorphic unit of Jhulda is Ancient Point Bar (Figure - 4.3). The type of deposit is
Dunes / Delta and fan-delta and the geological age is Holocene. According to the Table 4.9
and the liquefaction susceptibility map (Figure 4.12), the liquefaction susceptibility in Jhulda
is moderate.

Fill Area Liquefaction Susceptibility

Chittagong
Legend

Fig 4.12: Geomorphic Maps with Fill Area and Liquefaction Susceptibility in Chittagong
(Source: CDMP, June 2016)

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Table 4.10 Major earthquake affect in Chittagong

1762
The great earthquake of April 2, which raised the coast of Foul island by 2.74m and the
northwest coast of Chedua island by 6.71m above sea level and also caused a
permanent submergence of 155.40 sq km near Chittagong. The earthquake proved very
violent in Dhaka and along the eastern bank of the Meghna as far as Chittagong. In
Dhaka 500 persons lost their lives, the rivers and jheels were agitated and raised high
above their usual levels and when they receded their banks were strewn with dead fish.
A large river dried up, a tract of land sank and 200 people with all their cattle were lost.
Two volcanoes were said to have opened in the Sitakunda hills.
1950
Known as the Assam Earthquake. Occurred on 15 August with a magnitude of 8.4 with
the epicentre in Assam, India. The tremor was felt throughout Bangladesh but no damage
was reported.
1997
Occurred on 22 November in Chittagong with a magnitude of 6.0. It caused minor
damage around Chittagong town.
1999
Occurred on 22 July at Maheshkhali Island with the epicentre in the same place, a
magnitude of 5.2. Severely felt around Maheshkhali island and the adjoining sea.
Houses cracked and in some cases collapsed.
2003
Occurred on 27 July at Kolabunia union of Barkal upazila, Rangamati district with
magnitude 5.1. The time was at 05:17:26.8 hours.

4.3 BIOLOGICAL ENVIRONMENT

4.3.1 Flora and Fauna

4.3.1.1 General Consideration

Forests, pasture lands, rivers, surface water and other water bodies, etc. are the most
important natural ecosystems. They are the foundation on which conservation of biological
diversity depends. Biological diversity, which refers to genetic variation as well as to the
diversity of human populations and ecosystems, is a resource that belongs not only to
regions and to nations but also to all of humankind. Although it is a renewable resource, it
can be irreversibly destroyed. Future uses of this resource (medicine, plant breeding. etc.)
cannot be foreseen at present, although they will certainly be extensive in scope, and they
even are crucial to the survival of humankind.

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It is extremely rare to encounter completely natural areas nowadays. On the other hand,
both extensive and local use of natural flora and fauna can be regarded as normal
occurrences in natural ecosystems. Although the transition from hunting and gathering to
settle agriculture in established agro-ecological zones is complete almost everywhere,
traditional forms of resource use continue to play an important role in the lives of rural
populations. Current pressure due to increase production and extend the area of land under
cultivation is leading to more intensive use of remaining predominantly natural areas. This
results in environmental stress and rapid loss of biological diversity, as well as permanent
conversion of land to agricultural use.

Opening up natural areas in order to exploit their resources with modern technology
frequently leads to additional forms of resource use. For example, forests opened up to
commercial forestry are more exposed to uncontrolled over exploitation, as well as being
subjected to ecological stress by migrants who practice agriculture.

Both extensive resource use over large areas and selective, intensive use of every
favorable site can severely damage an ecosystem. Small-scale operations preservation of
remaining natural areas and resource use in harmony with nature are important if the
resources of a region are to be managed in an ecologically appropriate manner. Proper
monitoring is needed in order to obtain reliable information about significant changes in an
ecosystem.

Every region needs areas set aside to preserve ecological balance (nature reserves, of
natural vegetation, fallow land) in order to conserve its biological diversity. The form, extent
and location of these areas must be carefully evaluated in each individual case.

Because many different products in predominantly natural areas are not traded in great
volume and do not appear in statistics on trade, their immediate value to the local
population is often underestimated. The use of such areas is often of great economic
importance to the poorer segments of rural populations. Intense exploitation of such areas
is therefore usually accompanied by corresponding social consequences and social costs,
even when it appears reasonable on economic grounds.

Many predominantly natural areas are of environmental and economic value beyond their
own borders. Forests, for instance, guarantee safe and regular supplies of water because
they protect headwaters. The protective function of forests is often recognized only after its
neglect has produced negative consequences (deforestation that leads to erosion,
landslides, sedimentation in reservoirs, floods).

Intensification of resource use in harmony with nature should be based primarily on

indigenous knowledge and modes of production established in the local culture. There is a
need to undertake scientific studies in this area since information based on such studies is
presently lacking. Locally established responsibility for conservation of natural resources

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requires appropriate local rights of use. These rights must be regulated by grass-roots
organizations.

Regarding the ecological setting of the area has been already mentioned, the area in mostly
high and wet ecosystem with forest and other forms of greenery quite at abundance. There
had been extensive field survey during the study to assess and also quantify to a certain
extent the flora and fauna richness. These concentrated among others, on the wildlife
(reptiles, amphibians, mammals and birds), separately on fishes and a floral species (Grass,
shrubs, timber/fuel wood trees and fruit trees). Findings of the survey have been presented
in Table 4.11 to Table 4.13, respectively in the following pages.

As this is obvious from the above-mentioned tables, the area is quite rich in flora and fauna.
However, many of those are quite common for different other areas in Bangladesh. The
already existing industries in the study area not just brought, some of the utility services,
but have also provided with a different look of infrastructure setting in the area. This is still
not something, which can be called aesthetically unacceptable or directly detrimental to the
floral growth of the area. However, the industrial activities along with their discharges may
prove quite detrimental to both flora and fauna in the area eventually, provided no
appropriate corrective measures are taken.

4.3.1.2 Flora

The proposed plant is completely in an industrial and commercial setting with limited
greenery. But the other side of river (Anwara Upajilla) which cover the study area has floral
abundance, these includes roadside plantation, natural vegetation, coastal greenery and
agricultural crops. The project area has very few homesteads, mostly industrial in nature
generally interconnected with certain manmade barriers and roads here and there.

Due to roadside plantations and certain homestead forests, the area is rich with floral
diversities. Different fruit, fuel wood trees along with various shrubs are abundant. Among
the trees, the most widely available ones are Shilkoroi, fulkoroi, Mehagani, Shimul, etc. Also
there are some fruit trees such as Mango, Coconut, Jackfruit, Battle nut, guava etc.

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Table - 4.11: Floral Species in the project area.

Scientific Name English Name Local Name

Reptiles
Vulpes bengalensis Bengal fox Khek Shial
Enhudris enhydris Smooth Water Snake Painnya Shap/ Huriya
Hemidactylus House Lizard Goda Tik Tiki
Naja naja Kaouthia Narrwo headed Softshell
Chitra indicad Turtee Chitra Katchap

Amphibians
Bafo melanostictus Common Toad Bang
Rana Cyanophyctis Skipper Frog Bang

Mammals
Callosciurus sp. Squirrel Kat Biral
Cynopterus spinex Short nosed fruit Bat Badur
Funumbalus pennanti Squirrel Kat Biral
Herpestes Mongoose Bheji
Auropuncatus
Mus booduga Mus Field Mouse Idur
musculus Pteropus House Mouse Nengti Idur
giganteus Gaint Flying Fox Boro Badur

Birds
Alcedo atthis Common Kingfisher Machranga
Copsychus saularis Robin Doel
Corvus splendens House Crow Kak
Egretta albe Great Egret Boro Bak
Egretta gazetta Small Egret Chhoto Bak
Dirrurus adsimilies Black Drongo Fingry
Passer domesticus House Sparrow Choroi

Table 4.12: Plant Species in the Study Area

English Name Scientific Name Local Name Main Name

Grass
Grass Spontaneum Khar Fuel/Covering
Saccharum Gash (Kaichi
Cynodon dactylon Kash, Dubla etc.) Soil Binder

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 English Name Scientific Name Local Name Main Name
Trees
Lichi Lichi chinensis Lichu Fruit
Mango Mangifera indica Aam Fruit, Timber
Date Palm Phoenix sylvestris Khejur Fruit, Timber
Balck Berry Syzygium cumini Jam Brown sugar
Jackrfuit heterophyllus Khatal Fruit, Timber
Coconut Cocos nucifera Narikel Fruit, Timber
Papya Carica Papaya Pape Fruit, Fuel
Gauva Psidium guajva Piara Fruit
Banana Musa Sepientum Kala Fruit Fuel
Wood Tree
(Timber/Fuel
wood)

Mehagani, Shorea Robusta Shil koroi Fuel, Timber

Shal, Albizia procera Silk cotton Fuel, Timber
Shilkoroi, Salmalia Fuel, Pillow
Shimul malabaricum
Eucalyptus Eucalyptus Foliage
Eucalyptus cinerea

Table 4.13: Fish Species in the Study Area

Family Species English Name Local Name

Stromateidae Pampus Chinensis Chinese Pomfret Rup chanda
Trichiuridae Lepturacanthus savala Hairtail Chhuri mach
Sparidae Argyrops spinifer Long spine sea Lal datina
Bream Bambay
Harpadontidae Harpadon nehereus duck Gaint sea Loittya mach
Centropomidae Lates calcarifer perch Bhetki/koral
Mach
Ariidae Arius sp. Mystus Cat fish Kata mach
Bagridae gulio Johnius Bagrid catfish Nuna tengra
Sciaenidae argentatus Silver pennah Lalpoa
Croaker
Stromateidae Pampus argenteus Silver pomfet Foli chanda
Sciaenidae Protonibea Spotted croaker Kala poa
diacanthus
Pangasidae Pangasius Fatty catfish Pangas
pangasius
Palaemonidae Macrobrachium Gaint river prawn Golda chingri
Rosenbergii

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 Penaeidae Penaeus monodon Giant tiger Bagda chingri
prawn
Carangidae Parastromateus niger Black pomfret Hail chanda

4.3.1.3 Fauna

Fishes

Fish is still reasonably available in the area as it is a part of coastal area in Bangladesh.
Sea fish is available in this area. Among reptiles, narrow headed soft-shell turtle deserves
special mention. Among birds, Bok, Salik, Finge, Machranga etc. deserve special mention.

The fishes include Pomfrets (Rup chanda, Foli chanda and Hail Chanda), prawns (Golda
Chingri, Bangda Chingri), catfishes (Katamachh, Nuna Tengra), other (Churi Mach,
Koral/Bhetki Mach, Loitya Macch).

Wildlife and Reptile

The common types of reptiles are found in the area, water snake, house lizard, soft-shell,
turtle etc.

Amphibians

Mostly Toads and frogs- two species are prominent.

Mammals

These include fruit bat, Squirrel, field and house mousses, and flying fox. No major
mammal species of national significance are present in this area.

Birds

A number of those are including common kingfishers, House crow, House sparrow, little
fern etc.

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Figure 4.13 Water Hyacinth near the proposed project site

Fig 4.14: Terrestrial flora (tree) close to the project site

Fig 4.15: Terrestrial flora (herb) nearby the project site

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Fig 4.16: Terrestrial fauna close to the project site

Fig 4.17: Aquatic fauna at Jhulda

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4.4 Socio-economic Condition

4.4.1 Population and Social Structure

According to Statistical Pocket Book Bangladesh 2009 (Zilawise Household And Population
of Bangladesh, 2009) , the total population of Chittagong was 6611000, where the total
household is 1241000, total male 3475000 and total no of female 3136000 respectively.
The population density was 1251 persons per sq.km. Being rather lowest compared with
1584 of the country. However according to statistical year book 2009
Upazila wise population, census 2001, total population of Chittagong Port or Bandar thana
was 213598, where the total household no. is 41,466, Total male115,058 and female
98,513. The average literacy rate is 72.59%, with male 75.35% and female 69.32%.

4.4.2 Living and Cultural Standard

The study area of AISL Unit-3 is located at Jhulda, Chittagong Disrtict. Only the
lightweight vehicles like scooters, cars, rickshaws and rickshaw-vans are running on both
the roadway and branch road.

According to Banglapedia Main occupations of this area: Agriculture 1.46%, fishery 1.29%,
transport 6.3%, agricultural labourer 1.99%, wage labourer 3.02%, industry 2.04%,
commerce 11.70%, construction 1.4%, services 53.20%, house rent 1.82%, others
15.78%

The average annual population growth rates were 6.3% according to City Mayors
statistics. Such a rapid population increase must have been one of the most important
factors, which restricted the alleviation of poverty, and satisfaction of basic human needs
in the area.

4.4.3 Agriculture

Crops and Cropping Pattern:

The major crops grown in the project study area (Patenga and part of Anwara) are varieties
of rice. Major areas are put under Aus, Aman and Boro cultivation. Local Boro is grown in
medium low land and low land areas. T. Aman (HYV) and T. Aman (L) are also grown, the
former being preponderant. Other crops of importance are jute, oil seeds, potatoes, pulses
and vegetables.

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The three agro climatic cropping seasons prominent in the impact area are:

 Kharif 1 : March-May

 Kharif 2 : June-October

 Rabi : November to February

During Kharif 1 season HYV rice is the principal crop, during Kharif 2 medium Aman and
Aus crops are grown or jute is cultivated in medium lowland. During the Rabi season,
wherever the land dried up in early October to mid-October, farmers grow legumes, oil seed
and vegetables. Vegetables are mostly confined to highland, oil seeds to medium land and
pulses to medium lowland. Paddy is major cash crop of the farmers in the study area and
requires year-round production activity. Cropping patterns and crop diversity for kharif and
Rabi seasons are scheduled according to land types, flooding frequency and duration of
floods. The patterns in the study area are dictated by the local hydrologic regime and are
essentially based on rice. Pre-monsoon and post-monsoon drainage congestion limits crop
production. In monsoon season, the duration of water logging thus limiting the crop choice.
Non-rice crops are grown mostly in the non-irrigated land in rotation with Rabi Aus and
Aman, depending on the land type. Winter crops are inter- cropped with sugarcane.
Irrigated HYV Boro is grown is winter in sequence with T. Aman on medium high land and
T. Aman on medium lowland.

According to the 1996 agricultural census the study area has a relatively medium
agricultural potentiality. Rice is still the dominant crop in this area and most of the lands
are under paddy cultivation for at least a part of the year. Oilseeds, vegetables and other
seasonal crops are the significant crops in this area.

Fertilizers and pesticides are increasingly used, particularly on rice, but in general, such use
is at a fairly low level. Mechanization still plays small role in agriculture in this area, although
many farmers spoken to during field visits said that they commonly used a combination of
draught animals and hired-in mechanical cultivators for land preparation. Some of the
villagers and semi-urbanites also practiced limited animal husbandry for the production of
milk, eggs or meat. Animal kept includes cattle, goats, and poultry.

4.4.4 Housing

Majority of housing in this area is of pacca, semi-pacca, semi-permanent building i.e. walls
made of 5 inch brick works and corrugated iron roof. The homestead areas are relatively
medium.

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4.4.5 Public Health

Health services are mainly provided by hospitals run by the Health Ministry. The City
Corporation has its own Health Services and hospitals which supplement the services
provided by the government and the NGOs. There are a number of NGO-run clinics in
addition to mushrooming private clinics, which are run on a commercial basis. Chittagong
Medical College Hospital is the largest government-run health service provider. This huge
medical has so many wards, cabins and units. At present this facility also provides medical
treatment of ICU and CCU for the serious patients. Other medical service institutes include
General Hospital, TB Hospital, Infectious Disease Hospital, Diabetic Hospital, Mother and
Children Hospital and Police Hospital. Notably, the total health service of Chittagong is
intensificating day by day. At present, many non-government hospitals and clinics also
belong to the city. Chittagong Metropoliton Hospital, Surgiscope Hospital, CSCR, Centre
Point Hospital, National Hospital etc. are the noteworthy non-government hospitals and
clinics Chittagong City. The nearest in the area is the CEPZ Hospital which within 1.25 km
from plant location.

4.4.6 Industries and Commerce

The proposed AISL Unit-3 plant will be set up at Jhulda, Chittagong. The site of the project
falls near Patenga Heavy Industrial Zone where there are fuel deposit of Padma Oil
Company Ltd., Jamuna Oil Company Ltd., Meghna Oil Company Ltd., International Oil
Tankers Ltd., Food Silo, Heidelberg cement Bangladesh Ltd., TSP Fertilizer Factory, LP
Gas Ltd, Petro Bangla Chittagong Refinery, NGS Cement Ltd., Eastern Refinery Ltd. (ERL),
CEPZ Area and the Shah Amanat International Airport. On the other side of the river there
are Karnaphuli Fertilizer Company Limited (KAFCO), Anwara 1300 MW Power plant,
Shikalbaha Power Station, National cement Factory Ltd., Super Petro Chemicals, Star
Cement, and Chittagong Urea Fertilizer Factory (CUFL) situated at Anwara. The project is
situated on the West Side of the river Karnaphuli and about 1km meter distance from the
Shah Amanat International Airport Road. The location is well communicated by road and
river ways.

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 Chapter 5

Potential Impacts of the Proposed Project

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 Environmental Impact Assessment of AISL Unit-3.
At Patenga,Chittagong.
Chapter 5: Potential Impact of the Proposed project

5.0: POTENTIAL IMPACTS OF THE PROPOSED PROJECT

5.1 GENERAL CONSIDERATIONS

In case for most industrial projects, potential negative impacts sometime could be far
more numerous than beneficial impacts. The regional and national economic benefits
associated with the implementation of any development project are considered to fall
outside the scope of an EIA, and therefore not considered here. However, it is
generally expected that these long-term benefits will ultimately trickle down to the local
population and will make a contribution to an improvement in the quality of life.

Likewise, the indirect benefits of strengthening of technical capabilities of local persons

through association with foreign experts and other training elements that may form part
of a project have been considered to fall outside the scope of EIA.

5.2 SCOPING OF IMPACTS

The potential impacts due to implementation of Project are identified by using simple
checklists. This method is described below:

5.2.1 Checklist

Checklist is comprehensive lists of environmental effects and impacts indicator

designed to stimulate the analysts to think broadly about possible consequences of
contemplated actions (Munn, 1979). Table 5.1 represents the checklists developed for
the present plant. In this checklist, actions, which may affect at the various stages of
the project activities, are listed and the degrees of Significant Environmental Impacts
(SEIs) are shown. The terms none, minor, moderate and major are used in the
checklists to evaluate the magnitude of SEIs. In the checklist, both the construction and
operational phases of the proposed development are considered separately in order to
distinguish the short term and long-term impacts. As can be observed from the
checklists, major environmental components, which will be adversely affected by
activities of the project, are air, noise & water quality and socio-economic environment.
All these impacts will arise in operation phase of the project. It should be noted that
identification indicated in the Checklist relates to the significant level of impact.

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 Table 5.1: Checklists of AISL Unit-3.

Project Phase Action Affecting SEIs without Mitigation Type Comments

Environmental Measures
Resources & Values None Minor Medium Major Adverse Beneficial
Plant Land value x No land value changes anticipated
Location depreciation
Loss of and x No loss of and displacement from
displacement from homesteads land; no impact
homestead land
Loss of and x Loss of and displacement from
displacement from Agricultural land will not occur; no
agricultural land impact
Damage to nearby x No impact anticipated
operation
Disruption to drainage x x Land development may create problems
pattern in local drainage pattern, minor impact
Inadequacy of buffer x x Buffer strip is absent
zone
Encroachment into x No precious ecological issues; no
precious ecological impact
Construc Run off erosion x x Filling would create runoff erosion
tion during rainy season
Stage Worker accident x x Irregularly may occur in construction
period
Sanitation diseases x x Concentration of labor force create un-
hazard hygienic condition

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 Noise/vibration x x Piling/equipment installations create
hazard noise

Project Phase Action Affecting SEIs without Mitigation Type Comments

Environmental Measures
Resources & Values None Minor Medium Major Adverse Beneficial
Traffic congestion x x Carrying of construction materials will
create traffic congestion
Blockage of wildlife x No wildlife in the area; no impact
passage
Employment x x Major employment opportunity during
construction
Operation Pollution from liquid x Oily liquid waste may generate due to
Stage discharge handling of HFO, medium impact
Pollution from solid x x No significant solid waste; minor impact
waste
Air quality x x Air pollution from stack emission, major
impact
Occupational health x x Inherently will occur, medium impact
hazard
Odor hazard x No obnoxious odor will be generated; no
significant impact
Traffic congestion x No traffic congestion: no impact
Noise hazard x x Heavy noise generation is expected;
major impact.
Employment x x Major Employment opportunity during
operation

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 Chapter 6

Prediction and Evaluation of Impacts

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 6.0: PREDICTION AND EVALUATION OF IMPACTS
6.0 EVALUATION OF IMPACTS

6.1 GENERAL CONSIDERATIONS

The Impacts, which are likely to be occurred in the different phases of the project, are
identified in section 5.0. In this section, evaluation of these impacts was done mentioning
their origin and characteristics along with their possible mitigation/enhancing
measures. At the end of each sub section, status of residual impact is also mentioned.

6.2. ADVERSE IMPACTS AND MITIGATION

6.2.1 Impact due to Project Location/Pre-construction Phase

6.2.1.1 Land Acquisition

Impact Origin

As discussed earlier the Proposed Project will require 3.00 acres of land. Land
acquisition could affect the environment and peoples by the following ways

i. Loss of Homestead land

ii. Loss of Agricultural Land
iii. Cultural, historical and Aesthetic Loss
iv. Loss of sensible places
v. Corruption and partiality during acquisition and Reacquisition process, etc.

Mitigation Measures

The proposed project didn’t require any relocation of homestead and land acquisition
has been done by paying proper compensation of land to the land owners. The entire
land was fallow & vacant land in the project site. There is no homestead land falls inside
the proposed project site. There was no cultural, historical and aesthetic interest in the
project land and no loss of sensible place. So the above mentioned impacts are
negligible.

6.2.1.2 Loss and Displacement from Agricultural Land

Impact Origin

The land was flat, vacant land. So, there was no loss of agricultural land hence
agricultural product in the country.

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Mitigation Measures

Since there is no loss of agricultural land, no mitigation measures needed in this

regard. The land use map has been attached in annexure- 6.

6.2.1.3 Disruption of Earth Surface

Impact Origin

As mentioned earlier that a part of land filling would be required to develop the site to
provide protection against flood. This land filling will be from its original level which will
not disrupt the natural surface of earth and obstruct the natural drainage system of the
area.

Mitigation Measure

According to the plan, AISL Unit-3 will not create any water logging and drainage
problem as the AISL authority collects the soil to develop the area by carried sand
from different places. Cross drainage works should be constructed to bypass the
surface water and other discharges. A land development map has been attached in the
annexure-7.

Residual Impact

Provided that the mitigation measure indicated above is fully implemented, residual
impact to be very insignificant.

6.2.1.4 Change in Landscape

Impact Origin

A landscape is a subjective concept that cannot be precisely quantified. However, in

general, any project when not designed considering the local landscape, then it creates
visual intrusion to the people. The proposed project may change the local landscape to
some extent.

Mitigation Measure

Any built up part of the plant should be designed considering key criteria of landscape
like coherence, readability, hierarchy and stability. It is understood that AISL Unit-
3 will have a modern architectural view, which does not provide any significant visual
intrusion. One simple way by which the altered green area can be turned into its original
visual quality is the plantation of trees around the project area. The greenery layout plan
shown in the annexure-8 indicates the tree plantation around the project site.

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Residual Impact

Provided that the mitigation measure indicated above is fully implemented, residual
impact to be very insignificant.

6.2.2 Impacts during Construction

6.2.2.1 Disruption of Earth surface-Site preparation and Clearing and Earthworks

Impact Origin

Each development project more or less requires site preparation. The preparation works
generally done during constriction stages includes

 Biomass Removal
 Biomass Disposal
 Property removal
 Construction of access road
 Cut and fill operation
 Soil Export and Import
 Drainage works etc.

The impacts generally arise from the above activities are as follows:

 Noise
 Fugitive dust
 Runoff and flooding
 Soil erosion: Land erosion along the uncovered space due to soil removal and
excavation.
 Water Pollution through runoff and sedimentation
 Social concerns
 Infrastructure disruption
 Safety Concerns

However the proposed site is of the nature that it will cause negligible impacts in the
pre-construction stages. The site will require some land filling. The proposed site has no
homestead land so impact from property removal activities is negligible.

Mitigation Measures

Cutting and filling operation should be kept minimum. The proponent should ensure
construction of proper drainage facility. Regular water sprinkle should be used to
minimize fugitive dust emission. Safe working procedures should be ensured by the
contractor. Undertaking construction work during dry seasons. The heavy equipment
should be operated at day time.

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6.2.2.2 Impacts on Air Environment

Impact Origin

The air quality in the project area may slightly deteriorate for the time being during
construction. The major construction activities from which air emission mostly dust
emission may occur are;

 Poorly paved service lane;

 Ground excavation;
 Delivery of building materials to site;
 Handling and mixing of cement

Poorly Paved Service

The access road to the proposed project should be perfectly paved. Dust nuisance
from unpaved or partly paved road is of concern because:-

 There will be increased traffic driving in and out of the proposed site to deliver
construction material;
 If soil moisture content becomes very low; it could create increasing quantity of
loose particulate matter on road surface;
 There could be no or little vegetation cover to act as dust trap.

Ground Excavation

Site preparation in readiness for construction work may require vegetation clearance
stripping off of overburden material, ground leveling and compaction. These activities
will open-up the ground to wind action and thus potentially resulting in dust generation.
This is because:-

 Vegetation clearance will directly expose the ground to agents of erosion;

 Stripping off of overburden material will loosen soil aggregates thus making
them easily susceptible to wind action;
 Removal of tree stumps and roots will weaken soil bounding and thus can easily
be blown by wind

Delivery of Building Materials to Site

Construction materials such as building blocks, cement, sand, steel bars, stone/brick
chips will be bulky and thus will require to be delivered on site by a fleet of trucks driving
in and out of the construction site. During this exercise dust is likely to be generated
from the following:-

 Handling of cement which is dusty by nature of the way it is;

 Handling of sand, stone/brick chips may contain loose dust particles;

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  Site clearing of area of holding ballast , building blocks and sand will expose the
site to wind action;

Handling and Mixing of Cement

The powdery nature of cement will be a potential source of dust especially during
handling and mixing it with other materials such as sand and gravel. Cement dust will
likely be of concern during:-

 Opening-up of cement bags and empting the cement in order to mix with other
construction material;
 During loading and offloading of cement.

6.2.2.2.1 Potential Environmental Impacts of Dust

Dust produced will potentially negatively affect the following:

1) Employees generally construction workers;

2) Immediate neighbors and general public; and
3) Vegetation.

1. Effects of Dust to Employees

Cement dust can affect plant employers in the following way

 Eye irritation;
 Skin irritation;
 Impairment of normal sweating of the skin as it blocks pores on the skin;
 chocking of the throat;
 Respiratory difficulties;
 Difficulty in breathing;
 Potential course of chest complication and ailment.

2. Dust Impacts to Immediate Neighbors and General Public

 Reduced visibility; emission of high particulate matter to the environment will

reduce local visibility;
 Continuous exposure of people to dust will likely affect one’s eye sight that can
potentially result in an outbreak of eye infection;
 Chest related aliment; continuous exposure of people to dust will likely result in
chest complications and respiratory disorders.

3. Dust Impacts to Vegetation

 Dust settling on plant leaf surface will block leaves stoma hence interfering with
normal respiration of the plants;

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  Dust settling on plants will reduce the evapo-transpiration of plants and animals
such as butterflies, caterpillars, grasshoppers who feed of foliage will be affected
as the dust settled on foliage will render the foliage unpalatable;
 Heavy dust settling on plant matter will impair on normal growth of the plant; and
 Heavy dust settled on plants will choke and kill plants.

6.2.2.2.2 Proposed Mitigation Measures

Following mitigation measures are proposed to minimize the air pollution during the
construction stage:-

 The Project Proponent should ensure the complete paving of the service road
 Regular sprinkling of water to be done on open surface and dust grounds until
paving is done;
 Transport of materials in tarpaulin- covered trucks
 The sand and other such dispersible material will be stored at site for minimum
working period.
 Removal of soil/mud from trucks and other appliances prior to leaving the project
area.
 Storage of top-soil in a safe space and creation of top-soil on filled land utilizing
this preserved soil
 Selective cutting of trees in the site should be carried out. Only trees which on
exact proposed position of the building should be cleared any other vegetation
outside proposed building position should be maintained;
 Plantation of trees in the construction yard as quickly as possible. Any open
area should be planted with appropriate vegetation (trees, flowers and grasses) ;
 Project management and contractor to enforce strict use of personal protective
clothing;
 Complains of dust related ailments among employees and neighbours to be given
access to medical attention.
 The equipment design will be chosen for least suspension of dust/sand into
atmosphere.
 The construction activity will be carried out during day time only.

The emissions are temporary and not expected to contribute significantly to the
ambient air quality and will be within prescribed limits for industrial regions by National
Ambient Air Quality Standards.

Residual Impact

Provided that the mitigation measure indicated above is fully implemented, residual
impact to be very insignificant.

6.2.2.3 Impacts on Acoustic Environment

Noise is likely to be generated from the following activities/areas:

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  During ground preparation;
 During assembly of building materials on site;
 During construction of the various components of the proposed power plant.

A brief elaboration of each of the potential source/cause of noise is as follows:-

Ground Preparation

Ground preparation is another activity that will potentially result in noise nuisance.
Activities of ground preparation that are likely to result in noise nuisance include:-

 Use of heavy machinery such as excavators, caterpillars in ground excavation

will be a source of noise nuisance; and
 Transportation of excavated earth material from site by use of dump trucks will
result in noise nuisance. The noise will be mainly from the trucks.

Assembly of Building Materials

Building materials to be used in construct site will first be gathered and assembled on
site. These include building blocks, timber, steel bars, sand, gravel, cement. Possible
courses of noise nuisance when assembling construction material on site include:-

 Offloading of building materials on site especially steel bars, gravel and building
blocks can result in noise;
 Trucks ferrying in building materials can be a source of noise;
 Employees involved in offloading of building material can be a source of noise.

Construction of the Various Components of the Proposed Power Plant

Construction of the civil work structures for the proposed power plant will be labour
intensive. This will involve engaging a large workforce, also during construction
some machines and equipment will be in use. Possible sources of noise during
construction work may include the following:-

 Loud talking, shouting and conversation among employees;

 Noise from equipment such as cement mixers;
 Noise from machines such as welding machines and wood working machines;
 Increased machine and equipment activity on site.

6.2.2.3.1 Potential Environmental Impacts of Noise

Impacts of noise will potentially affect the following:-

a. Immediate neighbors; and

b. Employees.

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a. Impacts of Noise to Immediate Neighbors

 Continuous exposure of neighbors to noise nuisance may result in noise

induced hearing lose;
 Noise nuisance may reduce concentration of neighbors in their private matters.

b. Noise Impacts to Employees

 High noise level will force employees to shout laud when communicating to one
another;
 Exposure of employees to high noise level (above 85dB ) continuous for 8hours
per day may result in noise induced haring lose;
 Exposure of ear to peak sound level instantaneously may result to deafness.

6.2.2.3.2 Proposed Mitigation Measures for Noise Nuisance Management

 Noisy construction works to be limited to daytime hours

 Immediate neighbours to be notified in writing on the date of
commencement of construction work at least one month in advance;
 All employees likely to be exposed to ear noise to be provide with ear protectors;
 The project Proponent and contractors to ensure strict enforcement on user of
ear protectors;
 Where applicable and possible exceptionally noisy machines to be fitted with
noise reduction devices;
 Any employee who may complain about ear related pain and or complication while
at work to access medical attention at the expense of the contractor or project
proponent;
 Fitting noise machines with noise reduction devices;
 Providing suitable hearing protection to all workers exposed to noise levels above
85dB(A);

The noise impacts will be local; limited to the premises and very short – term.

6.2.2.4 Sanitation Hazard & Drinking water

Impact Origin

The health of the project personnel, construction workers and laborers living at the
base camp could be impacted if arrangement of sanitation and drinking water is not
ensured adequately and properly. During construction stage, lot of local labors will work
and hence they would generate considerable amount of human waste. These are the
potential source for spread of diseases, as various insects will play dominating role in
the spread of diseases. There are chances for the spread of water borne diseases also.

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Mitigation Measures

Proper sanitation system should be provided and at the same time, regular, proper and
safe disposal of human waste should be ensured. Contractors and workers should obey
appropriate means of waste removal and sanitation measures. Adequate number of
toilets and bathrooms should be made for the workers, and proper disposal system of
sewage waste should be implemented for sanitation purpose and the workers should be
aware to practice those facilities.

The project activities shall make higher demand on the local utilities and service facilities
particularly potable water, health and sanitary facilities. There should be sufficient
number of tube-wells for drinking purpose.

Residual Impact

If, the mitigation measure indicated above is fully implemented, residual impact to be
very insignificant.

6.2.2.5 Overland Drainage and Impact on Surface Water

The potential impacts on local hydrology are principally those of altered patterns as a
result of onside construction and earthwork activities. The proposed project will affect
natural drainage, surface and ground water quality if not managed the construction
works properly. There could be Siltation of water system or drainage from uncovered
piles of soil

Proposed Mitigation Measures

 Surface drainage shall be controlled to divert surface runoff away from the
construction area;
 Laying barrier net
 Undertaking construction work during dry seasons:
 Completed areas should be restored/re-vegetated as soon as practicable;
 Temporary silt-trap or digging of pond toward siltation prevention
 Stockpiling of spoil soil at a safe distance from the drainage system
 Utilizing spoil soil in land-fill
 Strict supervision should be maintained to avoid blockage of natural creeks during
the construction period, and
 Containment of sanitary waste should be adequately disposed off to avoid surface
and ground water contamination.
 Making provision for temporary disposal of wastes inside construction yard and
disposal of solid wastes in an appropriate manner:
 Adequate provision has to be retained for the treatment and disposal of cuttings,
drilling fluids and other chemicals and lube oil wastes generated during drilling,
testing and commissioning stage.

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6.2.2.6 Social acceptability of Construction workers to the host communities

The differences in the cultures of workers (in case hiring is required) and local
community may create some problems. In the rural area, the local people especially the
religiously conservative section of the community will not accept the foreign workers in
general. However the proposed site is in a rural industrial mixed area, where there are
other industries for years and people living in the area are very much used to this kind
of industrial activity.

Mitigation measures

The project proponent and his organization have practice of working with the workers of
different cultures. It is recommended to aware the foreign workers (if any) about the
social & religious actability in the area so that they could maintain those when they will
have touch with local community.

6.2.2.7 Accidents or Occupational Health Hazard

Impact Origin

Under controlled situation, accident is not expected. However, occasionally it occurs

during construction works. Accident may occur during earth cutting, casting, construction
works and installation of heavy machinery. The protection of head, eye, ear, and hand,
foot of the workers, laborers and project personnel could be affected if proper and
adequate arrangement is not ensured.

Mitigation Measures

The workers should wear PPE (Personal Protective Equipment), safety goggles, and
other necessaries.

6.2.2.8 Increase in Vehicular Traffic in the Area

Increase in vehicular traffic in the area is likely to be experience during

construction phase of the power plant. During the construction phase, increase in
vehicular traffic in the area is likely to be because of-

Trucks ferrying construction material to site;

Trucks ferrying waste material from site; and
Ferrying in of construction tools and equipment.

6.2.2.8.1 Potential Negative Environmental Impacts Likely to Result From

Increased Vehicular Traffic in the Area

 Possible traffic congestion of local roads and lanes;

 Possible of occasional experience of delays on the said local roads;

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  Increased number of vehicles on local roads will result in increased wear and tear
of local roads thus reducing lifespan of affected roads;
 Cost of maintaining local roads will increase;
 Pedestrians and cyclists using local roads will have to exercise more care with
increase of vehicular traffic on the said roads; and
 There will be an increase of exhaust emission from vehicles, which will pollute local
atmospheric air.

6.2.2.8.2 Proposed Mitigation Measures to Mitigate Increase in Vehicular Traffic

in the Area

The following measures can be put in place to mitigate possible negative impacts likely
to result from increase in vehicular traffic in the area:

 Management to provide for adequate internal parking, for all vehicles coming to
the plant premises;
 Management to pave the dilapidated service road with tarmac or more durable
material;
 All users of said roads to always observe traffic rules this will give pedestrians and
cyclist their space and safety while using the road; and
 Marking of the roads to be clearly done.

6.2.2.9 Impact due to HFO Transportation

Impact Origin

AISL will use HFO would be imported by vessel from abroad through Chittagong port.
Vessel carrying HFO will be offloaded at a rented HFO storage facility at Chittagong Port
area at a distance of approximately 3-4 km from the power plant site.

Mitigation measures

The AISL HFO storage facility will be designed so that there is no chance to spill HFO
and mixing the HFO with surface water body. The unloaded area should have hard
standing floor with sealed drainage ended up to oil water separator. The HFO storage
tanks should be double skinned and have secondary containment 110% bigger than the
storage capacity so that the HFO could be retained in the containment area in case of
any emergency failure.

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6.2.3 Impact during Operation Stage

6.2.3.1 Impact on Air quality

Impact Origin

Emission from the engine and generator stack may affect the ambient air quality.
Unburned gases from the engine operation may affect the air quality. The situation
aggravates when the fuel (here HFO) contains high percentage of impurities like sulfur,
hydrocarbon etc. The high temperature of flue gases also impacts the air quality in terms
of thermal pollution. The combustion of heavy fuels for power Generation inevitably
results in emission of gaseous pollutants to the atmosphere. As the proposed power
plants would be fired with Heavy fuel oil, the air pollutants emitted by the power plant
will be Particulate matter, carbon monoxide, nitrogen oxides and sulfur dioxide.

Sulfur dioxide (SO2) Emissions from the power plant

SO2 is a colorless gas. It smells like burnt matches. It can be oxidized to Sulfur
trioxide, which in the presence of water vapor is readily transformed to Sulfuric
acid mist. SO 2 can be oxidized to form acid aerosols. SO 2 is a precursor to
Sulfates, which are one of the main components of respirable particles in the
atmosphere.

Health Effects

Health effects caused by exposure to high levels of SO 2 include breathing

problems, respiratory illness, changes in the lung's defenses, and worsening
respiratory and cardiovascular disease. People with asthma or chronic lung or
heart disease are the most sensitive to SO 2. It also damages trees and crops.
SO2, along with nitrogen oxides, are the main precursors of acid rain. This
contributes to the acidification of lakes and streams, accelerated corrosion of
buildings and reduced visibility. SO 2 also causes formation of microscopic acid
aerosols, which have serious health implications as well as contributing to climate
change.

Nitrogen Oxides (NOx) Emissions from the Proposed Plant

Nitrogen gas, normally relatively inert (nonreactive), comprises about 78% of the air. At
high temperatures and under certain other conditions it can combine with oxygen in the
air, forming several different gaseous compounds collectively called oxides of nitrogen
(NOx). Nitric oxide (NO) and nitrogen dioxide (NO2 - the criteria pollutant) are the two
most important. Major source of nitrogen oxides in the proposed power plant include the
fuel combustion in power plants.

The engine emission data from the HFO generator shows that NOx emission from each
engine will be below 1390 mg/Nm3 (15% O2), which is higher than the IFC/WB

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guideline. NOx emission guideline for liquid fuel-fired reciprocating engine power plants
located in degraded air shed is 400 mg/Nm3 (15%O2).

Health Effects

Certain members of this group of pollutants, especially nitrogen dioxide (NO2), are
known to be highly toxic to various animals as well as to humans. High levels may be
fatal, while lower levels affect the delicate structure of lung tissue. In experimental
animals this leads to a lung disease that resembles emphysema in humans. As with
ozone, long-term exposure to nitrogen oxides makes animals more susceptible to
respiratory infections. Nitrogen dioxide exposure lowers the resistance of animals to
such diseases as pneumonia and influenza. Humans exposed to high concentrations
suffer lung irritation and potentially lung damage. Increased respiratory disease has been
associated with lower level exposures.

The human health effects of exposure to nitrogen oxides, such as nitrogen dioxide, are
similar to those of ozone. These effects may include:

 Short-term exposure at concentrations greater than 3 parts per million (ppm)

can measurably decrease lung function.
 Concentrations less than 3 ppm can irritate lungs.
 Concentrations as low as 0.1 ppm cause lung irritation and measurable
decreases in lung function in asthmatics.
 Long-term lower level exposures can destroy lung tissue, leading to
emphysema.

Children may also be especially sensitive to the effects of nitrogen oxides.

Other Effects

Oxides of nitrogen also can:

 Seriously injure vegetation at certain concentrations. Effects include:

o Bleaching or killing plant tissue.
o Causing leaves to fall.
o Reducing growth rate.
 Deteriorate fabrics and fade dyes.
 Corrode metals (due to nitrate salts formed from nitrogen oxides).
 Reduce visibility.

Oxides of nitrogen, in the presence of sunlight, can also react with hydrocarbons, forming
photochemical oxidants. Also, NOx is a precursor to acidic precipitation, which may
affect both terrestrial and aquatic ecosystems.

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Particulate Matter

Amount of dust will be negligible and within the allowable limit in normal operating
conditions of the power project at the rated output.

Carbon monoxide and carbon dioxide Emissions from the Proposed Plant

Carbon monoxide is generated when incomplete combustion takes place. The

emission of carbon dioxide depends on the fuel burn and the carbon content in the fuel.
The proposed power station is a heavy fuel oil fired modern design with optimum
designed cycle efficiency in order to maximize the MW output and less consumption of
fuel and water, CO & CO2 emission per unit of fuel burnt will be smaller amount
compare to other power stations.

Mitigation Measures

The plant will be powered by 8 engines from the world renowned Caterpillar Company,
each of capacity 13.201MW.

A. Engine Emission

SO2 Emission

The emissions of SO2 are dependent on the sulfur content of the fuel. The project
authority will use HFO with approximated sulfur content of 2.80% which is above the
allowable limit of IFC/WB Environmental Heal & Safety Guideline 2008, is 0.5% Sulfur
content for the SO2 emission of liquid fuel oil power plant in degraded air shed. There
is no standard set in the Bangladesh ECR 1997 for the SO2 emission for the liquid fuel
fired power station. So we should consider the standard of IFC/WB guideline in this
situation.

NOx Emission

The engine emission data from the HFO generator shows that NOx emission from each
engine will be below 1390 mg/Nm3 (15% O2), which is higher than the IFC/WB
guideline. NOx emission guideline for liquid fuel-fired reciprocating engine power plants
located in degraded air shed is 400 mg/Nm3 (15%O2). There is no standard set in the
Bangladesh ECR 1997 for the NOx emission for the liquid fuel fired power station. So
we should consider the standard of IFC/WB in this situation. The exhaust temperature
from the reciprocating engine would be 315 0C, which would be reduced to 173 0C at
the exhaust of the steam boiler. The project will also install a Flue Gas de-sulfurization
plant (FGD) to reduce the sulfur content and it is expected that the final exhaust
temperature will be much lower after the FGD plant. Moreover, the NOx content will also
be reduced significantly due to the FGD plant operation. So, it is assumed that the NOx
level at the final exhaust would be lower the IFC/WB standard.

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B. Ambient air quality

An effect on ambient air quality has been assessed based on air emission dispersion
modeling. In this study, the SO2 and NOx emissions for the reciprocating HFO engine
system discharged through stack were modeled to obtain maximum possible
downward ground concentration. USEPA AERMOD view version 8.0.5 model was
used to estimate emission concentration from the plant. The exhaust specifications and
stack parameters for the proposed reciprocating HFO engine are used as input to
AERMOD model. The individual engine stack data was used as point source of SO2 &
NOx emissions and the results are the summation of 8 emission sources. The
parameters and corresponding values are summarized in the table 6.1 below:

Table 6.1: Summary of the exhaust specifications and model input data

Parameters values
Stack height (m) 30
Stack inside diameter (m) 1.2
Stack exit velocity (m/s) 21.7
Exhaust temperature (K) (315+273) = 588
3
Exhaust flow rate (Nm /sec) 23.94
NOx emission rate as NO2 (gm/sec) 15.456*
SO2 emission rate (gm/sec) 17.55*
Ambient temperature (K) 273
*calculations have been attached in annexure-9

The model assumes the stack tip downwash with receptors on flat terrain and no flagpole
receptor heights. The NOx and SO2 concentration contour have been analyzed
with 500 m interval with a radius of 5000m from the point source.

NO2 concentration:

The NO2 concentration contour of 24 hour and annual average of have been analyzed.
The maximum of 24 hour concentration of NOx has been predicted 180 µg/m3 at a
radius of 500m east, whereas the concentrations is within 120 µg/m3 at max of 200m
north, 85 µg/m3 at max of 300m south and 110 µg/m3 at max of 300m north west to the
project site. The concentration are within 20-50 µg/m3 beyond the 500m radius at all
sides. The maximum annual concentration of NOx has been detected as 10-20 µg/m3
at 500m east, west and north to the project site. The concentrations have been
detected below 05 µg/m3 on either side beyond 500m radius to the project site.

There is no IFC/WHO and Bangladesh standard set for 24 hour concentration for NOx.
The maximum yearly concentration of NOx have been detected (below 20 µg/m3) well
below the IFC/WHO and Bangladesh standard at all sides at any radius around the
project.

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SO2 concentration:

The SO2 concentration contour of 24 hour and annual average of have been analyzed.
The maximum of 24 hour concentration of SO2 (180 µg/m3 ) has been predicted at a
radius of 500m east, whereas the concentrations are within 80-150 µg/m3 at a radius of
200-500m west, north and south to the project site. The concentrations have been found
below 50 µg/m3 beyond 500m radius around the project site. The maximum annual
concentration of SO2 has been detected as 42 µg/m3 at 500m east, whereas the
concentrations are within 15-25 µg/m3 on the other sides at around 200-500m to the
project. The concentration has been found below 06 µg/m3 on either sides of the project
beyond 500m radius.

The modeling result shows the 24 hour and annual average of SO2 concentration. There
is no IFC/WHO annual standard set for SO2 for ambient air quality, But the 24 hour
concentration of SO2 have been found beyond the standard of IFC/WHO standard
(42 µg/m3) but below Bangladesh standard (365 µg/m3) at all sides with 500 m radius.
The concentrations beyond the 500m radius have been found within the IFC/WB and
Bangladesh standard at all sides.

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Figure 6.1: Emission contour map showing the NOx concentration (24 hour average) at 5000m surrounding the project location

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6.2: Emission contour map showing the NO2 concentration (Annual average) at 5000m surrounding the project location

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Figure 6.3: Emission contour map showing the SO2 concentration (24 hour average) at 5000m surrounding the project location

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Figure 6.4: Emission contour map showing the SO2 concentration (Annual average) at 5000m surrounding the project location

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From the Table 3.2 & Table 4.5, it is evident that the area fall under degraded air shed
(IFC/WB definition) and after taking all above mitigation measures, the AISL will
contribute very negligible amount of air emission (NOx, SO2 & PM) to the surrounding
pollution comparing to the air existing emission source in the study area.

For the well dispersion of the hot air from the generator, the project authority will
construct a 30 m high stack from the ground level. The stack would be connected with
a silencer to prevent the noise from the engine. The stack heights have been designed
to facilitate undisturbed and free dispersion of the emitted air pollutants. Exhaust gas
sample extraction facilities shall be installed for emission monitoring on each stack.

The detail emission modeling report has been attached as annexure 10.

Residual Impact

It is clear from above study that the project proponent will adopt necessary options
suitable to their needs meeting the national standards. Adoption of measures set out
above is not expected to provide total mitigation, because no machine works at 100%
efficiency. After adopting proper mitigation measures to maintain national/international
standards, AISL Unit-3. will emit some residual pollutants, which can affect the
environment in the long run. On the other hand, if other industries located in the area,
emits air meeting the national requirement as AISL Unit-3. the cumulative residual
pollutants will create an adverse situation in the ambient air quality. So, this situation can
be overcome by determining the exact level of treatment and maintaining it by following
the management plan properly, which is required to maintain the normal ambient air
quality of the area.

6.2.3.2 Impact due to Liquid Discharge

Impact Origin

The Proposed power plant will not create any process liquid from the production process.
The power plant will have close loop water cooling system for the main reciprocating
engine system and in the waste heat steam turbine condensation unit (900 cu.m/hour).
Where small amount of water will be required as makeup water only which is
approximately 21 cu.m/hour. In addition, small amount of water will also be used for
occupational floor, equipment washing and for domestic purposes. This wash water will
not contain significant amount of pollution, which may impact the surface water quality.

Mitigation Measures

The cooling water will be used in a close loop system having no discharge. Some make
up water would be added (approximately 21 cu.m/hour) to the system. The domestic
liquid waste will be disposed through a septic tank with a soak pit. The project will have
planned drainage system to discharge the surface runoff. The surface drainage

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network would be connected with an interceptor prior to discharge through natural water.
The interceptor will trap all oily matter present in the water.

Residual Impact

Provided that the mitigation measure indicated above is fully implemented, residual
impact to be very insignificant.

6.2.3.3 Impact due to Solid Waste

Impact Origin

The operation of the plant itself would not generate any solid waste. Solid waste
generated by the people working at the proposed site is paper, cartoons, bags, boxes,
office wastes, pallets, empty drums etc. along with negligible quantity of domestic waste.
There will have waste Air filters and waste rugs be generated occasionally which
need to be properly disposed.

Mitigation Measures

All solid waste will be segregated properly. Some solid Waste has tremendous
secondary demand and sold to the secondary dealers. Other solid wastes will be
disposed to the safe places carefully. The air filters and waste rugs should be collected
in a safe place and should be disposed to the land fill.

Residual Impact

Provided that the mitigation measure indicated above is fully implemented, residual
impact to be very insignificant.

6.2.3.4 Impact due to HFO and Lubricating Oil

Impact Origin

The proposed project will be operated by HFO, so, there is HFO preheating and
treatment system in the project before feeding the HFO to the engine. This will end up
with some oily sludge & water. Moreover, the project will use lubricating oil in the engine
cooling system from where insignificant amount of used lubricating oil would be
generated from the plant. The generated waste oil will be stored in a sealed tank.

Mitigation Measures

The oil storage of the project (fresh and used) should be done on hard standing floor
and roofing with a secondary containment facility of 110% bigger than the allowable
maximum storage capacity. The project will produce 2000 liter per day of separated oil
water sludge from the HFO preheater. This oily water sludge would be treated

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PureBilge Oily water cleaning system, where clean water would be discharged with the
oil content below Bangladesh national standard (below 10mg/l) and sludge thus
collected and the waste lubricating oil will be supplied /sold to the venders for recycling.
These vendors or the Lube Oil Re-cycling facilities should be approved by DoE. As there
is no chance of mixing and disposal of oil onto land or water, so there is no mitigating
measure to be suggested.

Detail on oil water separation has been attached in Annexure-11

Residual Impact

Provided that the mitigation measure indicated above is fully implemented, residual
impact to be very insignificant.

6.2.3.5 Noise and Vibration Impacts

Impact Origin

The generator room will have internal noise level of around 108 dBA at 1m distance from
the reciprocating engines and 90 dBA at 1m distance from the steam tubine unit which
will be minimized by sophisticated acoustic power house building design so as to
minimize the noise up to standard.

The individual reciprocating engine stack will emit a noise level of 85 dBA after
providing the silencer. These noises will be dispersed to the surrounding atmosphere to
certain extent.

Mitigation Measures

Necessary noise abatement measures will be taken as required avoiding adverse noise
& vibration impact on the neighborhood. To reduce the effect, most costlier and
effective Critical Type Silencers will be used in the stack. In particular, significant noisy
components such as the generators and turbines are enclosed in buildings acoustically
designed, providing Styrofoam filler of 100 mm width in between 150 mm thick brick
walls both side of the styrofoam filter around the power house building. The following
are the noise protection capacity of the material which would be used for sound insulation
for the power house building:

Material Thickness, Surface density, Transmission

mm kg/sq.m loss, dBA
Styrofoam (Acrylic -Poly- 15 18 32
Methyl-Meta- Acrylate
(PMMA)
Brick with or without plaster 150 288 40

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As per above calculation the Styrofoam filter and brick wall are capable to absorb noise
as following:

Material Thickness, Approximated noise

mm absorption capacity, dBA
Styrofoam (Acrylic -Poly- 100 90
Methyl-Meta- Acrylate
(PMMA)
Brick with or without plaster 150 40
Total 130

It is estimated that the noise abatement measures of the power house building will be
capable to absorb around 130 dBA noise from the engine room, but the maximum
engine room noise is around 108 dBA near the generators, which is lower enough to
minimize the engine room noise by the acoustic measurement and it is expected that
the noise emission from the engine room would be within the limit. Moreover, Vibration
pad will also be used at the bed of all power generation units to prevent the vibration.

For the measurement of the dispersion of the stack noise to surrounding environment,
a noise modeling simulation has been done by using CUSTIC-3.2 noise modeling
software. The model has calculated the aggregated noise from the 8 HFO engines of
85 dBA each. The result of the modeling has been given below.

Radius, m 50 100 200 300 400 500

Output Sound power level in 38.47 32.08 25.65 19.24 12.82 6.41
Db

The modeling result shows that the power plant will produce max noise 38.47dBA within
50m radius and minimum 6.41dBA in 500m radius respectively in combined 8 stacks
together in running condition. There are few homesteads at the south west and North
West side of the project within the 100m radius of the proposed project where the noise
contribution from the project would be around 32.08 dBA.

The following are the World Bank and Bangladesh standard for the ambient noise:

Standard Zone Day time Night time,

dBA Dba
World Bank Residential, Institutional, 55 45
educational
EHS Guideline 2007 Industrial, commercial 70 70

Bangladesh Mixed area 60 50

Commercial 70 60
ECR, 1997 Industrial 75 70

The AISL will be established in an area with heavy industrial set up within 5 km radius
falls under the industrial zone category of Bangladesh standard. The day & night time

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average noise was found during the baseline study below the standard of industrial zone
concentration. But noise generation from the power project was found below 70 dBA at
a distance of 100m away from the project. Since the project itself will contribute little
amount of noise to the surrounding atmosphere, it is expected that the cumulative noise
would meet the standard of industrial area of Bangladesh standard. The noise modeling
report has been attached in annexure-12.

Residual Impact

Provided that the mitigation measure indicated above is fully implemented, residual
impact to be very insignificant.

6.2.3.6 Occupational Health

Impact Origin

The proposed project will employ around 98 people during its operational period. The
workers who work inside the plant will face occupational health hazards due to different
operational processes. Safe and good occupational health status of the employees and
workers is important for only the persons working in the plant, but also for the better
plant operation and maintenance.

Mitigation Measures

Protective clothing, earplug, helmets, shoes and accessories should be provided to the
workers specially who will work in the power house building and engine room. Adverse
impact on worker’s safety would be minimized by implementing an occupational health
program. Regular medical checkup would be done to ensure the soundness of health
of employees and workers. Pollution control measures would duly adopt if necessary,
including noise and air pollution.

Residual Impact

Provided that the mitigation measure indicated above is fully implemented, residual
impact to be very insignificant.

6.2.4 Socio-economic Impacts

The AISL Unit-3 will contribute to cover the increasing demand of electricity which is a
beneficial operation factors, e.g. for producing industries. Site development will not lead
to the loss of any jobs; instead will create around 98 new job opportunities for the local
workers. On the other hand, during the construction activities of the AISL Unit-3, jobs
and income opportunities will be created and as such per capita income will be enhanced
in this area. For operation, a number of long-term skilled and unskilled personnel will be
required which will create employment opportunities for the local inhabitants also.

Since there was no habitation located inside the proposed site, resettlement would not
be necessary for the project. But migration will be increased due to creating new job

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opportunities in the plant area. People in the neighborhood are expected to get benefit
from the employment that would be generated and from the increased business activities
during construction period. There is no religious, cultural or historic place near the site,
so the noise and air pollution during construction of the project would not create any
potential impact. People of the surrounding area will be benefited by the development of
local small businesses due to the increase of migration in the area.

6.3 Beneficial Impacts and Enhancement

6.3.1 During Construction

Impact Origin

During construction period, the plant will create job opportunities for approximately 300
of skilled, semi-skilled and unskilled labors. However, the impact will be a relatively short
duration, being restricted locally to the construction period. In addition to this, all
construction sites attract small traders, who supply food and other consumable to the
work force. Although the numbers of people who benefited in this way are relatively
small, the impacts on individuals can be disproportionately high compare to the other
local people.

Benefit Enhancement Measure

Although labor recruitment is a matter of construction contractor who has the right to
determine whom he shall not employ, but still the project proponent shall encourage him
to hire local people wherever possible and to give preference to employment of the land
less people.

6.3.2 During Operation Phase

Impact Origin

The most significant positive impact of the plant would be the generation of electricity,
which will reduce the gap between supply and demand of electricity. The other important
positive impact of the plant would be the employment of personnel for the operation of
the plant. The project envisages employing 98 skilled and unskilled personnel during its
operational phase. Apart from the positive impacts other beneficial impacts include
benefit to local economy due to employment, community development, etc.

Benefit Enhancement Measure

Although labor recruitment is a matter of company who has the right to determine whom
he shall and shall not employ, but still the project proponent should take initiative to
employ local people wherever possible and to give preference to employment of the
jobless people.

6.4 Decommissioning

6.4.1 General principles for Environmental Management During

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Decommissioning

At this project of the project planning & implementation process, the necessity for and
timing of the decommissioning of the AISL Unit-3 is not known. Therefore, only general
principles of decommissioning are detailed below. These principles must be required to
be revisited and supplemented in the event of decommissioning of the power plant.

On decommissioning of the power project, AISL will:

 Ensure that all sites not only vegetated are vegetated as soon as possible after
operation ceases with species appropriate to the area.

 All structures, foundations, concrete, and tarred areas are demolished, removed
and waste material disposed of at an appropriately licensed waste disposal site.

 All access/service roads not required to be retained by landowners are closed

and rehabilitated.

 All disturbed areas are compacted, sloped and contoured to ensure drainage
and runoff and to minimize the risk of erosion.

 All hazardous materials should be kept separate, documented and disposed to

the safe recycling or disposal site.

A detail decommissioning and restoration of site plan should have to be

development prior to the decommissioning of the project.

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 Chapter 7

Environmental Management Plan (EMP)

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 7.0: ENVIRONMENTAL MANAGEMENT PLAN (EMP)

7.1 GENERAL CONSIDERATIONS

In the context of a project, Environmental Management Plan (EMP) is concerned with the
implementation of the measures necessary to minimize or offset adverse impacts and to
enhance beneficial impacts. Unless the mitigation and benefit enhancement measures,
identified in IEE or EIA, are fully implemented, the prime function of IEE or EIA cannot
be achieved. All the measures are said to be successful when they comply with the
Environmental Quality Standard (EQS) of Bangladesh. Thus the objectives of EMP for
the present project would be:

o Mitigation measures to reduce or eliminate negative impacts

o Enhancement measures to maximize positive impacts
o Monitoring requirement and
o Monitoring indicators

7.2 MITIGATION/BENEFIT ENHANCEMENT MEASURES

For effective and environment friendly operation of an industry, a set for guiding tools
and suggestions are necessary which need to be followed at various stages of plant
installation, operation and maintenance. This plan generally has various components of
management depending on the type of industry or plant activity and types of discharge
and their pollution potential. This Environmental Management Plan (EMP) once
prepared forms the basis of environmental management actions from the part of the
plant authority may need modification or up-gradation because of changes in the plant
operation or accurate pollution load/environmental problems detected afterwards. The
plant authority may also be needed to expand the suggested outline of the EMP
proposed in this report.

All beneficial and adverse impacts which may likely to occur at different phases of the
project are identified in section 5.0. In section 6.0 predictions, evaluation and aspect of
mitigation and benefit enhancement measures have also been discussed concurrently
with impacts prediction and evaluation. In view of the earlier discussion summary of
recommended mitigation and benefit enhancement measures are presented in Table
7.1.

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 Table 7.1: Recommended mitigation/enhancement measures
Potential Impacts Mitigation/Benefit Enhancement Measures
Impact on surface o Dispose all domestic waste water through septic tank
water quality o Surface drainage should be disposed through an
interceptor.
o Collect the waste oil in a sealed tank, store in safe place
and dispose through secondary trader for recycling.
Impact on solid o Collect all solid wastes properly, recycle where possible
waste and dispose in proper place.
o Waste rugs and waste air filters are collected properly
and disposed to the landfill.
Impact on Air Quality o Proper stack height (30m) has to be installed and
maintained for each 8 stacks
Impact on health and o Set up warning signs, signals and provide helmets for
safety workers in accordance with relevant accident prevention
and work safety procedure
o Restrict access to plan site
o Supply good quality drinking water to the workers
o Provide well-planed sanitary facilities
o Provide regular health inspection among workers
o Promote health education campaign among workers
Noise/vibration o Proper acoustic design should be made for the power
hazard house building and silencer in the exhaust of each
engine.
o Provide sufficient buffer strip around the project site and
power house building
Traffic congestion Avoid carrying of materials in peak hour of road traffic
Impact on Employ local people wherever possible
employment & family
finance

7.3 Environmental Management during Operation Phase

7.3.1 Overview of Impacts and Mitigation Measures

Power plants invariably have potential for environmental impacts during the operational
phase of the project. The following impacts are normally of most significant:

o Impacts on air quality;

o Acoustic and vibration impacts
o Socio-economic impacts;

Over viewing of mitigation measures due to impacts arises from the operation of power
plant is atmospheric pollutant emissions, which are being controlled at source by the
following mitigation measures:

o The plant would have a flue gas de-sulpherisation (FGD) plant to reduce the
sulpher content from the exhaust. Using low concentration sulfur HFO fuel will
also ensure that the Bangladesh emission limits will be met.

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 o A stack height of 30 m will ensure compliance with the National air quality limits.
o Using waste heat to steam turbine for extra power generation will reduce the
pollutant level.
o A septic tank will be provided to ensure that effluent discharge standards are met.
o Environmental noise from engine will be controlled through proper acoustic design
within the plant.

7.3.2 Atmospheric Emission Management

The combustion of fossil fuels for power generation inevitably results in emission of
gaseous pollutants to the atmosphere. As the proposed power plant is fired with HFO,
the pollutants of potential concern are likely to be oxides of nitrogen (NOX), Sulpher Di-
Oxide (SO2) and Particulate (PM). The project will install a waste heat recovery steam
turbine unit to generate additional electricity by using the waste heat from the stack and
the final temperature of the exhaust stack would be reduced from 315 0C to 174 0C,
which indicates that the pollution level will be minimum. In addition, the project authority
will also install a flue gas de-sulpharisation (FGD) plant to reduce the sulpher content
from the exhaust which will remove 90% sulpher from the exhaust.

The FGD plant will consists of main scrubber tower, limestone mixing and preparation,
gypsum buffer solution collection tank, gypsum dehydrating system for gypsum recovery
etc.

To comply with World Bank Group’s “Environmental, Health and Safety Guidelines
for Thermal Power Plants” a desulphurization equivalent to an operation with 0,5%
sulphur HFO is necessary. The plant is thought to be fired with 2,8% sulphur oil.
Resulting thereof a SO2 removal efficiency of 82% is required. Considering
maximum sulphur content in the HFO of 3,5%, the required removal efficiency is
86%. Each engine comprises an own waste heat boiler and an own hot gas stack for
boiler bypass operation. The flue gases of all engines are routed to one common
header ducting after cooling in the individual boilers and afterwards to the scrubber
of FGD plant. There the SO2 as well as other acidic gases are reduced below emission
limits.

In general limestone CaCO3, quick lime (CaO) or hydrated lime (Ca(OH)2) can be
used for the wet FGD process. Normally limestone is the best-available and
cheapest absorbent.

The flue gas desulphurization process consists mainly:

 1free space nozzle scrubber plant with bypass-free liquid distribution system
with integrated hot gas quencher and mist eliminator, capable for the flue gas
of all 8 engines;
 Utility supplement equipment with reagent storage silo for limestone or lime
powder and slurry preparation facility;
 Gypsum preparation plant by de-watering.

After implementing the above measures it is expected that the SO2, NOx and PM
emission level will meet the GOB and IFC/WB Environment, Health & Safety

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guidelines. The lay-out plan and technical description of the FGD plant has been
attached in annexure 13 (a) & 13 (b).

7.3.3 Management of Solid Wastes

The area has no planned solid waste collection system in the area. So, the AISL authority
will have their own solid waste collection and disposal system in place to abate the
pollution from the solid waste. The solid waste which has secondary demand will be sold
to the local traders after inspection and other waste will be properly managed and
disposed of off-site. The air filter system shall be equipped with pressure measuring
devices to indicate the operating conditions and the degree of filter contamination.
Therefore, no significant ecological impacts arising from solid waste management are
anticipated. Any excavated earth will be stored on-site and later used for landscaping
activities.

7.3.4 Water & wastewater Management

The proposed project would have water use for the domestic use, make up water from
cooling tower and de-mineralized water treatment plant. There is no chance of polluting
surface water from either sources since there will be no discharge from the project to
the surrounding environment. The surface drainage network would be connected with
an interceptor prior to discharge through natural water. The interceptor will trap all oily
matter present in the water.

7.3.5 Domestic Sewage Management

All domestic sewage will be treated in a septic tank. The treated water will be discharged
through soak pit.

7.3.6 Noise and Vibration Level Management

Adequate measures have been proposed for the control of noise and vibration from the
equipment installed in the plant. Noise level monitoring would be performed periodically
and the workers exposed to noise would have adequate protective device. Vibration
protecting pad (shoe) would be provided under the generator during installation to
protect the vibration during operation. An inlet silencer shall be incorporated to reduce
the noise level to the specified level. The silencer shall consist of individual noise
absorbing exchangeable elements filled with mineral wool.

7.3.7 Greening Program

A green belt development program with different kinds of trees would be undertaken.
The vegetation would purify the air, reduce noise level, maintain ecological balance and
generally contribute to the scenic beauty of the air. Soil in and around the plan site is
fertile and plenty of water is available. Hence, the green belt as an environmentally
sound and friendly project with a buffer zone surrounding the plant area may be
created in a short time and therefore green area will be increased and reduce the
environmental impacts.

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7.4 MONITORING REQUIREMENT

Environmental monitoring is an essential tool in relation to environmental management

as it provides the basic information for rational management decisions. The prime
objectives of monitoring are-

o To check on whether mitigation and benefit enhancement measures are actually

being adopted and are providing effective in practice
o To provide a means whereby impacts which were subject to uncertainty at the
time of preparation of EIA, or which were unforeseen, can be identified, and steps
to be taken to adopt appropriate control measures.
o To provide information on the actual nature and extent of key impacts and the
effectiveness of the mitigation measures which, through a feedback mechanism,
can be taken into account in the planning and execution of similar projects in
future

There are two basic forms of monitoring:

o Visual observation or checking, coupled with inquiries

o Physical measurement of selected parameters

In the case of industrial projects in general, monitoring is done by physical measurement

of some selected parameters like air, water, noise etc. It should be mentioned here that
the monitoring program should be such so that it can ensure compliance with national
environmental standards. The importance of this monitoring program is also for ensuring
that the plant does not create adverse environmental changes in the area and providing
a database of operations and maintenance, which can be utilized if unwarranted
complaints are made.

7.5 MONITORING INDICATORS

Environmental monitoring requires a set of indictors that could be conveniently

measured, assessed and evaluated periodically to establish trends of impacts. The
indicators may be independent or may be functionally related. The physico-chemical,
ecological and human interest including socio-economic indicators should be well
understood. The monitoring program, in view of the possible impacts as assessed
earlier, should consider the indicators for the impact assessment related to following
issues is presented in Table 7.2 in the following page.

It is desirable that the mitigation measures for the negative impacts and environmental
enhancement for positive impacts are implemented according to the suggestions
presented in this report. There are two types of environmental monitoring activities
associated with the project, during construction and during operation of the project. Each
of the components is to be dealt with according to the requirement of suggested
measures.

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Monitoring During Construction

The environmental monitoring during the construction phase should primarily be

focused on addressing the possible negative impacts arising from:

(a) Generation and disposal of sewage, solid waste and construction waste
(b) Increased traffic
(c) Generation of dust (particulate matter)
(d) Generation of noise
(e) Deterioration of water quality

The environmental monitoring should also focus on enhancing the possible beneficial
impacts arising from employment of local workforce for construction works. Table 7.2
summarizes the potentially significant environmental parameters needed to be
monitored during the construction phase.

Table 7.2 Monitoring plan during construction phase of the project

Issue Parameters Location Monitoring
Frequency
Ambient air SPM, PM10 and PM2.5 Around the Once a month
Quality project site
Groundwater Groundwater level, pH, TDS, At the project site Once a Quarter
Ammonia, Nitrate, Phosphate,
As, Fe, Mn and Coliforms
Soil quality Cr, Cd, Pb and Oil and Grease At the project site Once during the
construction phase

Noise level Noise at different locations and Around the Once a month.
to nearest receptor project site and
nearest receptor
Construction Solid waste/construction debris, At site Once a month
waste visual observation and record
check

Health Health status of the workers, At site Once every 2 months

visual observation and record by the contractor’s
check appointed health
professional

Monitoring During Operation

Post construction monitoring is limited to a number of impact parameters to see the

actual performance of the project. Some monitoring may be necessary during the
operation period of the power plant. Environmental monitoring requires set of indicators
that could be conveniently measured, assessed and evaluated periodically to observe
the trends of change in base line environmental quality.

Most of the environmental parameters will experience beneficial effects during the
operation phase of the power plant project. The plant management authority of AISL
should be responsible for overall environmental monitoring during the operation phase

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of the project. The environment monitoring during the operation phase should primarily
be focused on addressing the following issues:

(a) Emission from the power plant

(b) Generation of noise
(c) Waste generation at the plant

Table 7.3 summarizes the potentially significant environmental parameters needed to

be monitored during the construction phase.

Table 7.3 Monitoring plan during operational phase of the project

Issue Parameters Location Monitoring
Frequency
Stack NOx, SO2, PM Final exhaust Continuous
emissions (FGD)
Ambient air CO, NOx, SO2, PM10, PM2.5, Around the project Once in 3 months
quality site
Noise level Noise at different locations at Around the project Once in 3 months
day & night site and nearest
receptor
Surface water TSS, TDS, COD, BOD, pH, Oil & At outlet point of Once in 6 months
quality grease, Total Nitrogen, Total drain after the
Phosphorus and total coliform interceptor.

7.6 Cost of Monitoring

The following are the cost of monitoring for the environmental parameters during
construction and during operation period of the proposed power plant respectively:

Table 7.4 Cost estimate for environmental monitoring other measures during construction
Item Parameters unit cost Unit per Total cost per
(Taka) year year (Taka)
Ambient air SPM, PM10 and PM2.5 30000.00 12 360,000.00
Quality
Groundwater Groundwater level, pH, TDS, 30000.00 04 120,000.00
Ammonia, Nitrate, Phosphate,
As, Fe, Mn and Coliforms
Soil quality Cr, Cd, Pb and Oil and Grease 30000.00 1 30,000.00
Noise level Noise at different locations 10000.00 12 120,000.00
Total Cost 6,30,000.00

Table 7.5 Cost estimate for environmental monitoring during operational phase
Item Parameter unit cost Unit per Total cost per
(Taka) year year (Taka)
Stack NOx, SO2, PM 500000.00 01 500,000.00
emissions
Ambient air CO, NOx, SO2, PM10, PM2.5, 30000.00 04 120,000.00
quality
Effluent pH, DO, Sulfate, TSS, TDS, 30000.00 04 120,000.00
quality BOD, COD, Total N, Total P
Noise level Noise at different locations 10000.00 12 120,000.00
Total cost 9,20,000.00

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7.7 Management Capacity:

The environmental monitoring program should be carried out as an integral part of the
project planning and execution. It must not be seen merely as an activity limited to
monitoring and regulating activities against a pre-determined checklist of required
actions. Rather it must interact dynamically as project implementation proceeds,
dealing flexibly with environmental impacts, both expected and unexpected. For this
purpose, it is recommended that the Project Director (PD) for this specific project
should take the overall responsibility of environmental management and monitoring
during the construction period. The PD will form a team with required manpower and
expertise to ensure proper environmental monitoring and to take appropriate measures
to mitigate any adverse impact and to enhance beneficial impacts, resulting from the
project activities. The PD through its team will make sure that the Contractor undertake
and implement appropriate measures as stipulated in the contract document, or as
directed by the PD to ensure proper environmental management of the project activities.
It should be emphasized that local communities should be involved in the management
of activities that have potential impacts on them (e.g., traffic congestion in the
surrounding areas). They should be properly consulted before taking any management
decision that may affect them. Environmental management is likely to be most
successful if such decisions are taken in consultation with the local community.

To be an environmentally acceptable industrial unit, the proposed project should have

its own environment monitoring unit/cell with trained manpower with necessary
equipment and other logistics along with required budget. During the operation period,
the project authority should establish their own monitoring team headed by the plant
manager. Alternatively, AISL may hire any local reputed monitoring company to
undertake the environmental monitoring as suggested in the EMP of the ESIA report. In
such case, the Plant manager will engage one of his Plant Engineer to look after the
monitoring activities and keep the records available to view any concerned people or
authority when necessary. In all occasions, AISL authority should ensure that the
equipment used for the monitoring services are properly calibrated and internationally
accepted monitoring methods are followed to monitor the above parameters.

AISL Unit-3 should develop a working relationship with the Department of Environment
(DoE) by undertaking a joint monitoring program per year or they may exchange data
and information or submit periodic report of self-monitoring to the DoE or as the situation
may require.

7.8 SAFETY MITIGATION PLAN

Safety Management System

Safety is an integral part of the company’s work. It is part of the company’s operations
and there to protect employees, clients, property, the environment and the public.
There are many costs to accidents and unsafe work practices. The greatest costs are
human cost. Protecting employees also protects their friends, families, fellow workers,
management, the public and the environment from the far-reaching effects of serious
accidents. In addition to protecting lives, a safety program contributes to employee

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morale and pride because employees participate in identifying safety needs and
developing safe work procedures.

Visitors to the worksite may also face legal action if they knowingly disobey safety
rules. In addition, the company may face legal action and fines for violations of
regulatory requirements. Those individuals who do not fulfill their safety responsibilities
will become accountable for any problems their negligence creates and may be liable
under the law.

Everyone employed by a company is responsible for maintaining the safety program.

Managers and supervisors are responsible for identifying safety needs, communicating
safety hazards, investigating hazardous conditions and accidents, providing training,
supply or wearing appropriate safety and personal protective equipment, and ensuring
all equipment is properly maintained and meets legislated safety standards. Their role is
supported by input from all employees.

All company employees are responsible for obeying all safety rules, following
recommended safe work procedures, wearing and using personal protective equipment
when required, participating in safety training programs and informing supervisors of any
unsafe work conditions. Everyone has the right and responsibility to refuse to do work
when unsafe conditions exist. By fulfilling safety responsibilities, workers will share
the benefits of a safety place.

The company must have its own safety management and mitigation plan and policy.
Listed below are the important features that need proper attention of company
management.

Company Safety Policy

The company must have its own safety policy. The safety policy should be updated from
time to time. The policy should be signed and dated by the chief safety officer. The policy
should be discussed with all personnel. The chief safety officer should periodically review
the policy and re-issue the policy.

Safety Responsibilities

All personnel should have safety responsibilities assigned to them. The documented
responsibility should be included in the program manual. Compliance with the
responsibilities should be monitored and if these are not carried out for some good
reason, corrective measures should be taken.

Management Communication

The management should decide how it communicates periodically with the personnel
regarding safety. A site schedule for conducting site tasks should be developed; this
should be included in the safety program manual. Documentation of site tours should be
retained for verification.

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Inspections

A list of all work sheets, equipment, vehicles and work practices requiring inspection
should be developed. Checklists and schedules should be developed as part of the
inspection program. A system for correcting deficiencies noted during the inspection
process must be developed. The system should prioritize deficiencies noted so that
serious hazards are dealt with immediately.

Personnel Protective Equipment (PPE)

The work site should be assessed to determine what personal protective and safety
equipment is needed and the equipment must be available. A maintenance schedule
must be developed for PPE and records for maintenance retained on file. Employees
must be trained in fitting, care, maintenance and use of PPE.
Detailed rules and procedures identifying company and legislative requirements and
expectations must be communicated to all employees and contractors. They serve as a
reference and describe the minimum standard by which business is conducted. Most
important rules and procedures ensure consistency in the performance of tasks by all
employees. The current rules should be reviewed and assessed as to whether they are
appropriate for the operation/facility/employees. The formulated rules must be
communicated to the workers effectively, and workers must ensure that they understand
the rules and have no difficulty to comply with the rules.

Standard Work Procedure

The intent of standard work procedures is to ensure consistency in the performance of

hazardous work and it must form the minimum standards by which specific tasks are
performed. Workers must have clear understanding of the procedures they are
required to follow. A system for periodic review of procedures must be developed. The
employees involved in the work will be given an opportunity to suggest steps that would
provide for continuous improvement to the procedures. The work procedures shall also
ensure that all hazardous tasks have been accounted for. Procedures and codes of
practice have to be developed for hazardous work. To determine compliance with safety
and hazard issues while performing a task by a worker, efforts should be made to ensure
the following:

o Confirm that employees affected by these tasks participate in the development

of safe work procedures,
o Confirm that the employees are involved in the maintenance of safe work
procedures,
o Interview workers to determine if they know what tasks have work procedures,
where these procedures are located and generally what makes up to content,
o Review records to ensure that employees receive training on hazardous work
procedures and codes and practices,
o Where practical, observe employees performing critical tasks to confirm use of
standard work procedures and codes of standards.

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Emergency Procedures

Emergency procedures will identify who does what and when in the event of an
emergency. Responsibility for who is in charge of the co-ordination of emergency actions
shall be identified. The procedures shall be easily referenced, concise and
understandable. All employees shall be aware of the content and location of the
procedures. The content lists associated with the procedures will be current. The
procedures will be updated and tested on a regular basis. The training record and level
of training gained by an employee shall be verified so as to ensure his first aid training.
Subcontractor employees will also be trained in first aid. The following are the important
events that need emergency procedures.

o Fire
o Injury/death
o Leakages and other releases of hazardous substances
o Natural disasters

Safety Orientation and Training

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

o Employees
o Contactors
o Sub-contractors
o Visitors

The orientation shall also include a review of the following:

o Company safety policy and procedures

o Specific job hazards
o Safety precautions
o Job responsibilities
o Regulatory requirements
o Company enforcement policy, and
o Worker right-to-know and authority to refuse unsafe work.

Reporting Incidents and Accidents

All accidents and near-miss incidents shall be investigated to determine what caused
the problem and what action is required to prevent a recurrence. Employees required to
perform investigations shall be trained in accident investigation techniques. The
incident/accident investigation should be a fact-finding exercise rather than faultfinding.
The investigations will focus on collection of evidence to find out the “root cause” of the
incident. The recommendations of the investigation report are implemented in phases.
Power plant construction and operation facilities have been and will continue to be
designed to comply with the legal elements of both national and international
standards, legislation, codes of practice and design specifications, and best practices.

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As a part of this process, measures to minimize the probability of releases and reduce
potential impacts through selection of alternative processes to be considered as an
integral part of the development.

Mitigation should reflect the intent and regulatory framework outlined in the GoB
Environmental policy and in applicable World Bank Operational Directives. The
purpose of impact mitigation and counter measures is to avoid creating negative
impacts wherever possible, to minimize impacts where they may be unavoidable, and
to generate opportunities for improvements or positive impacts where appropriate.

Protective Equipment

The main reason for protecting workers is to eliminate or reduce the possibility of injury.
The Occupational Health and Safety Act (USA) requires that every worker shall “wear
or use such personal protective clothing, equipment or devices and is necessary for his
or her protection from the particular hazards to which he or she is exposed”.

There are some people who resist wearing protective clothing or devices, and will only
wear protective equipment when forced to do so. This is not the right attitude to take for
the worker’s own safety. The consequences of an accident to his quality of life can be
major. He can also lose his life. Personal protective equipment provides the worker with
a measure of protection, but for it to be really effective; it must be accompanied by the
right attitude towards during his job the right way. The wearing of personal protective
equipment does not guarantee that he won’t get injured. However, when coupled with a
good safety attitude it will reduce the likelihood and severity of accidents

Body Parts That Require Protection

The body and its internal organs can be seriously injured, by any violent impact with an
object. A direct blow to any part of a worker’s body, even with protection, can easily
result in some injury, either major or minor. The following eight areas or parts of the
body require protection:

o Head
o Arms
o Eyes
o Chest
o Hearing
o Legs
o Hands
o Feet

The worker’s head houses his brain, which controls all the motor and sensory functions
of his body. Any blow to his head, no matter how slight, can be very dangerous and
result in injuries ranging from dizziness to total disability and even death. One of our
most valuable senses is light. One must protect his eyes from the dangers of flying
objects, bright light and chemicals. Without eyes one would live a life in total darkness.
Hearing damage is not often a result of an accident, unless someone has had a head
injury. A more common problem is hearing loss which can occur one exposed to noise

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levels above the exposure limits, as outlined in the Noise Regulation. In Table 7.6
Occupational Exposure Limits are described with a maximum permitted duration in the
following page. Without hearing protection in a sound level of 100 dBA maximum
permitted duration is 1 hour/day.

Table 7.6: Occupational Exposure Limits (Without hearing protection)

Sound level Maximum Permitted Duration
(dBA) (hours per day)
85 8
90 4
95 2
100 1
105 2
110 1/4
115 1/8
Greater Than 115 0

The longer one is expected to high noise levels, the greater the potential hearing loss.
Hearing loss associated with exposure to noise tends to be gradual. It may take several
years before one can realize that for some reason he has difficulty hearing normal
conversation. Hearing is a valuable asset that should be preserved, so the worker can
have a full and productive life. In Table 7.7, Safety hazard prevention, control and
mitigation measures are described for particular event.

Table 7.7: Safety Hazard Prevention, Control and Mitigation Measures

Event Prevention, Control and Mitigation Measures
General Instruction of o Personal and continuous visual supervision of the worker
Workers who is not competent to perform the job.
o Workers to be conversant on the codes and standards of
safety.
o Workers must be confident that they have adequate training
on handling or unsafe hazards material.
Maintenance of Equipment o Employer shall ensure that all equipment used on a work
site is maintained in a condition that will not compromise the
health and safety of workers using or transporting the
equipment.
o Will perform the function foe which it is intended or was
designed
o Is of adequate strength for that purpose
o Is free from potential defects.
Traffic Hazard o Where there is a danger to workers from traffic, an employer
shall take appropriate measures to ensure that the workers
are protected from traffic hazards.
o Ensure that workers who are on foot and who are exposed
to traffic hazards on traveled rural roads wear reflective
vests or alternative clothing that is cleanly distinguished.
o Where the operator of vehicle does not have a clear view of
the path to be traveled on a work site, he shall not proceed
until he receives a signal from a designated signaler who
has a clear view of the path to be traveled.
o

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 Event Prevention, Control and Mitigation Measures
Illumination o Ensure that illumination at a work site is sufficient to enable
work to be done safely.
o Where failure of the normal lighting system would endanger
workers, the employer shall ensure that emergency lighting
is available that will generate sufficient dependable
illumination to enable the workers to
a) Leave the work site in safety
b) Initiate emergency shutdown procedures
c) Restore normal lighting
House keeping o Ensure that each work site is clean and free from stepping
and tripping hazards
o Waste and other debris or material do not accumulate
around equipment, endangering workers
Falling Hazards o Ensure that where it is possible for a worker to fall a vertical
distance greater than 3.5 meters the worker is protected
from the falling by guard rail around the work area a safety
net fall arresting device
Overhead power Lines o Ensure that no worker approaches and that no equipment is
operated and no worker shall approach or operate
equipment, within 7 meters of a overhead power line.
Sanitary facilities & drinking o Ensure that an adequate supply of drinking fluids is
Water available at the work site.
o Ensure that work site is provided with toilet facilities in
accordance with the requirement of general health
protection guidelines.
Working proper clothing o Ensure that where is a possibility that a worker or worker’s
clothing might come in to contact with moving parts of
machinery, the worker:
a. wears close-fitting clothing
b. confines or cuts short his head and facial hair
c. avoids wearing jewelry or other similar items
Head protection o Ensure that during the work process adequate alternative
means of protecting the workers head is in place.
Eye protection o Where there is a danger of injury to or irritation of a worker’s
eyes, his employer shall ensure that the worker wears
property fitting eye protective equipment.
Foot protection o Where there is a danger of injury to a worker’s feet, ensure
that the worker wears safety footwear that is appropriate to
the nature of the hazard associated with particular activities
and conditions.
Respiratory protective o Where the worker is exposed to hazards gases, gums,
Equipment vapors, or particulates appropriate respiratory protective
equipment to be supplied.
Transportation of water o A worker in a vehicle shall not allow any part of his body to
produce from the vehicle where this action creates or may
create danger to the worker.
o A worker shall ensure that no equipment or materials for
which he is responsible is carried in the compartment of a
vehicle in which another worker is traveling unless it is so
placed and secured as to prevent injury to himself and other
workers.

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 Event Prevention, Control and Mitigation Measures
Testing & commissioning o Mobilize test rigs at site
o Ensure that the test equipment is in good condition
o Ensure other equipment and facility conforms to the
approved specification of test.
o Public notice to be served before testing.

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 Chapter – 8
Emergency Response and
Disaster Management Plan

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 EMERGENCY RESPONSE AND DISASTER MANAGEMENT PLAN
8.1 EMERGENCY RESPONSE

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

response. Like all other Industries and installations, Power generation facilities must have
adequate measures against accidents or incidents to meet the emergency. The purpose of
having an Emergency Response Plan (ERP) is to:

 Assist personnel in determining the appropriate response to emergencies.

 Provide personnel with established procedures and guidelines.

 Notify the appropriate Company Emergency Response Team personnel and

regulatory/ Govt. agencies.

 Manage public and media relations.

 Notify the next-to-kin of accident victims.

 Promote inter-departmental Communications to ensure a “Companywide” Co-

ordinated emergency response.

 Minimize the effects that disruptive events can have on company operations by
reducing recovery times and costs.

 Respond to immediate requirements to safeguard the subtending environment and

community.

Generally, the initial response is guided by three priorities Ranked in importance

these priorities are:

1. People

2. Property

3. Environment

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Emergency Response Procedures will identify who does what and when in the event of an
emergency. Responsibility for who is in charge and their coordination of emergency actions
shall be identified. Nature of Emergency & Hazardous Situations may be of any or all
of the following categories:

I. Emergency

 Fire,

 Explosion,

 Electric shock

 Medical emergency,

II. Natural Disasters

 Flood,

 Earthquake/ cyclone,

 Storm/ typhoon/ tornados, and

 Cloud burst lightning.

III. External Factors

 Food poisoning/water
poisoning,

 Sabotage, and

 War.

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8.1.1 Six Steps in Emergency Response

Step-1)

a) Determine the potential hazards associated with the incident, substance or

circumstances and take appropriate action identify the type and qualities of
dangerous goods involved and any known associated hazards.

b) Determine potential hazards stemming from local conditions such as

inclement weather water bodies etc. and ensure that the initial response
team is aware of these conditions.

Step-2)

Determine the source/cause of the event resulting to the emergency and prevent
further losses.

Step-3)

Conduct an assessment of the incident site for any further information on hazards
or remedies.

Step-4)

Initiate redress procedures.

Step-5)

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

Step-6)

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

8.1.2 Reporting Incidents and Accidents

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

8.1.3 Approaches to Emergency Response

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

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

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145 | P a g e
 8.2 DISASTER MANAGEMENT PLAN

In normal operation of the plant, when all environmental protection equipment works
according to design specification, then there would be no environmental problems for the
present plant.

Disaster (to certain degree) may occur if the environmental protection equipment fails to
work at normal condition. This situation may arise for any of the following causes-

o When plant runs at abnormal situation e.g. if emission level increases than its
normal level or if the engines give unwanted noise than normal level

o If liquid waste over flows and pollutes the surroundings

Therefore, appropriate management plan should have to be taken by the project

proponent to prevent any unwanted disaster in the plant. In this regard, there should be a
provision to stop the production immediately during any process failure as discussed above.

The disaster management plan should consist of preventive measures including, among
others, the following.

o Formulation and strict implementation of safety codes and measures;

o Periodic inspection of safety relief valves provided with pressure vessels and
equipment;

o Preventive maintenance;

o Aware the workers about electric shock

o Declaring the factory a “no smoking zone”

o Mock drills by the fire fighting cells/ groups

o Provision and inspection of firefighting equipment and fire hydrant system in all the
sections;

o Proper training of the employees about the importance of codes;

o Training the employees and the residents of the surrounding villages about the
actions to be taken during an accident, disaster etc.

It is imperative to develop entire facility environment policy and display necessary

documentation for ease in accessing information. Some of these documents include:

 Emergency contacts;

 Emergency response procedures for fires

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The facilities operations and monitoring are carried out under the management and help
from both the employees and relevant government lead agencies. In order to take care of
any hazards the following control should be adopted:

All safety precautions and provisions covering the general cleanliness of the entire
facility down to, ventilation, lighting, sanitary, waste collection, smoke detector, heat
detector, sand bucket, water bucket, fire blanket, first aid box provision, adequate
fire extinguishers and site security by fencing.

8.3 ENVIRONMENT, HEALTH AND SAFETY (EHS)

Health and safety aspects of the entire facility should be given due attention. Protective
devices as provided should continuously be used within the unit’s operations to ensure the
safety of the natural resources and boat owners is guaranteed.

The maintenance of Material Safety Data Sheets (MSDS) will be followed to ensure safety
all section of the facility that chemicals are utilized.

An Environment, Health and Safety register is essential for monitoring of performance of

the entire facility community in relation to the environment. The management will use this
as a self-auditing tool. This register should include:

 Fire extinguisher servicing records

 EHS meeting schedules and training records

 Electrical installations

 Generator inspection and maintenance records

 Waste disposal records

 Inventory records (fuels, paints, cleaning agent

 Emergency response procedure.

 Record off all incidents, accidents, near miss etc.

8.4 FIRE HAZARD & FIRE EVACUATION PLAN

Fire hazards such as large quantities of fuel, combustible/flammable liquids, electrical

hazards, combustible dusts, and warehousing are common in electric power generating
plants. Although fires are not a daily occurrence, they usually will cause severe property

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damage and business interruption. Sometimes the fire protection equipment systems have
not received attention since they were installed. If these systems are needed, however,
they are counted upon to perform reliably and protect vital plant equipment from fire. Fire
protection systems are a combination of mechanical and electrical components and, like
power generation equipment, need regular attention.

In addition, some people in charge of fire protection do not have an adequate knowledge
of necessary inspection and testing frequencies, or they use the minimum frequencies
prescribed by their authority having jurisdiction. For example, some jurisdictions only
require annual water flow alarm tests on sprinkler systems, a frequency which is considered
inadequate by most fire protection professionals.

The information contained in this part is based on the current standards established by the
National Fire Protection Association (NFPA); the most widely used in North America, and
generally accepted guidelines. Most fire protection systems are designed and installed
according to these standards. Unfortunately, information on inspection, testing and
maintenance is not contained in a single standard but is contained within the various
system-specific standards, making it cumbersome and difficult to obtain an overview of the
tasks which need to be accomplished.

Other codes and standards such as UBC, UFC, BOCA, OSHA and MSHA also address fire
protection, but their contents are usually based on NFPA documents and may not address
testing/maintenance requirements. Members on the NFPA technical committees comprise
a wide range of fire protection expertise and include representatives from
manufacturers, testing laboratories, users, authorities having jurisdiction and insurance
companies. Adherence to NFPA standards will satisfy most jurisdictions and insurance
companies.

Suitable fire protection and detection systems shall be provided designed to the
requirements of National Fire Protection Association (NFPA) standards. Gas detection
systems and alarms shall also be included.

Fire protection shall consist of wet pipe, automatic deluge systems, hydrants, CO2 gas
flooding systems, and portable extinguishers of CO2 and dry powder in sufficient
quantities.

Areas to be covered by fixed protection installations shall be included but not be limited to:

 All oil filled transformers

 Gas engine

 Lub oil system

 Cable areas
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  Storage areas.

The gas engines are to be protected against fire by a CO2 total flood system within the
enclosures. The only other significant fire risks are associated with the lube oil systems on
the gas engines, cable areas, stores and with oil contained within transformers. Such
systems will be protected from fires by water deluge sprays. All necessary systems are
required to be fire 'protected' with suitable extinguishing agents. Additional protections are
to be provided by a ring main and hydrant system with hose/equipment cabinets located at
strategic points. This ring main shall be provided with suitable section valves located in
valve pits.

The firefighting water will be taken from the fire tank and will be pumped by a dedicated
electric pump with a diesel powered back-up pump available in case of electrical failure.
Pressure in the firefighting mains is maintained using an electric jockey pump.

A site wide fire and gas detection system will be provided to initiate the fire protection and
alarms. Manual "break glass" fire alarms shall also be situated at strategic locations around
the site and inside the buildings.

A modern electronic fully addressable master fire alarm panel shall be located in the Central
Control Room. All local fire panels shall be linked into the master fire alarm panel. This
master panel should have a separate section for the gas detection system. A repeater panel
should be provided in the site gatehouse to allow swift identification of the affected fire zone
to incoming local fire-fighting appliances. This master fire panel shall be provided with its
own dedicated battery system.

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 Chapter – 9
Alternative Analysis

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 ALTERNATIVE ANALYSIS

9.1 THE ‘NO BUILD’ SCENARIO

From a purely physical environmental point of view, the ‘do-nothing’ is preferable to any
project implementation, since it would avoid creation of any of the adverse impacts
associated with the project. However, the potential socio-economic benefits to the nation
would be foregone and industrial growth would be hampered.

It is concluded that the ‘No build’ alternative is unacceptable, and the potential socio-
economic benefits of implementation of such project far outweigh the adverse impacts, all
of which can be controlled and minimized to an allowable level.

The project will be HFO fired. The power generation cost and environmental consequence
of any HFO fired power project is minimum.

9.2 CONSIDERATION OF ALTERNATIVES

i. Hydroelectricity:

The country is flat having relatively limited potential for hydroelectricity.

ii. Geothermal Plant:

No active geothermal site has been found.

iii. Renewable Energy Plant:

Solar and wind energy can be considered as renewable energy but per KWh cost of
renewable energy is not cost effective for the end users especially in the country like
Bangladesh.

iv. Coal-Fired Plant:

The country has about 1700 million tons of bituminous coal, most of which lie buried at
depth of over 400-900 meters thus making extraction relatively expensive. However, coal
from low-lying structure (Barapukuria) is being dug out for power generation. Coal is less
environment friendly as it gives high emission of dust sulfur dioxide and carbon dioxide
which lead to the acid rain.

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v. Resettlement :

Site selection is ideal as it involves no resettlement issues.

vi. Pollution Control:

As shown in subsequent sections, environmental pollution during the period of construction

and also during the period of operation will be mostly insignificant.

vii. Connectivity with High transmission line:

The proposed site is in a fairly close proximity to the 33/132KV Halishahar Sub-station.
So, the project is in a suitable location to get connected with the high tension grid line.

As per Power Purchase Agreement (PPA) signed with Bangladesh Power Development
Board (BPDB) the Power Plant need to be connected and deliver its generated electricity
through the existing Halishahar 132/33 kV grid sub-station. So, as per BPDB requirement
and contractual obligation the power plant need to be installed at a place from where the
plant can be connected with Halishahar 132/33 kV grid sub-station.

9.3 SITE ALTERNATIVES

After signing the Power Purchase Agreement with BPDB and Implementation Agreement
with Power Division, Ministry of Power, Energy and Mineral Resources AISL conducted a
detailed area survey for selecting a suitable site for the 100MW HFO Fired Power Plant
from where the plant can be connected to the Jhulda 132/33 kV grid sub-station.
Due to the site nearby AISL Unit-1 was the most suitable place for installing the power plant.
Prior to selecting the site AISL representatives physically met the concern authority of
relevant government entity like Bangladesh Navy, Airport Authority, Chittagong
Development Authority (CDA), etc. and found they have no objection with location of the
proposed project. Moreover the land was unutilized and very near to port storage area from
where HFO can be very comfortably transported to plant. The site is well connected with
the river which is also very suitable for transportation of project equipment and raw
materials.
The plant’s visual looks are modern and environmentally compatible, the site is
environmentally acceptable, the plant construction has started and the IEE checklist has
been submitted to DOE earlier for obtaining the Environmental Site Clearance Certificate.
So there is no logical need to look into alternative sites.

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 Chapter – 10
Stakeholder
Consultation

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 Stakeholder Consultation
Stakeholder consultation is a means of involving all primary and secondary
stakeholders in the project’s decision-making process in order to address their
concerns, improve project design, and give the project legitimacy. Stakeholder
consultation, if conducted in a participatory and objective manner, is a means of
enhancing project sustainability.

Community input (both of knowledge and values) on socioeconomic and environmental

issues can greatly enhance the quality of decision-making. Stakeholder consultation
was therefore conducted in the project area not only to satisfy the legal requirements of
the EIA process in Bangladesh but also to improve and enhance the social and
environmental design of the project.

10.1 Objectives of Stakeholders Consultation

The process of public participation and consultation was endorsed in the United Nations
Conference on the Environment and Development (UNCED) in 1992 through one of the
key documents of the conference⎯ Agenda 21. Agenda 21 is a comprehensive strategy
for global action on sustainable development and deals with issues regarding human
interaction with the environment. It emphasizes the role of public participation in
environmental decision-making for the achievement of sustainable development.

For projects that have environmental and social impacts, consultation is not a single
conversation but a series of opportunities to create understanding about the project
among those it will likely affect or interest, and to learn how these external parties view
the project and its attendant risks, impacts, opportunities, and mitigation measures.
Listening to stakeholder concerns and feedback can be a valuable source of information
that can improve project design and outcomes and help a company to identify and
control external risks. It can also form the basis for future collaboration and
partnerships. For stakeholders, a company’s consultation process is an opportunity to
get information, as well as to educate company staff about the local context in which a
project will take place, to raise issues and concerns, ask questions, and potentially help
shape the project by making suggestions for the company to consider and respond to.
Through the public consultation process, AISL hopes to:

 Promote better understanding of the project, its objective, and its likely impact;

 Identify and address concerns of all interested and affected parties of project area;

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 Provide a means to identify and resolve issues before plans are finalized and
development commences, thus avoiding public anger and resentment and
potentially costly delays;

 Encourage transparency and inculcate trust among various stakeholders to promote

cooperation and partnership with the communities and local leadership;

10.2 Consultation Process

Primary stakeholders were consulted during informal and formal meetings held in the
project area. The consultation process was carried out in the Bangla languages. During
these meetings a simple, non-technical, description of the project was given, with an
overview of the project’s likely human and environmental impact. This was followed by
an open discussion allowing participants to voice their concerns and opinions. In
addition to providing communities with information on the proposed project, their feedback
was documented during the primary stakeholder consultation. The issues and
suggestions raised were recorded in field notes for analysis, and interpretation.

By reaching out to a wider segment of the population and using various communication
tools—such as participatory needs assessment, community consultation meetings,
focus group discussions, in-depth interviews, and participatory rural appraisal—EIA
involved the community in active decision-making. This process will continue even after
this EIA has been submitted, as well as during future EIAs in which similar tools will be
used to create consensus among stakeholders on specific environmental and social
issues in the context of a proposed project.

Secondary stakeholder consultations were more formal as they involved government

representatives and local welfare organizations consulted during face-to-face meetings
and through telephonic conversations. They were briefed on the EIA process, the
project design, and the potential negative and positive impact of the project on the
area’s environment and communities.

It was important not to raise community expectations unnecessarily or unrealistically

during the stakeholder consultation meetings in order to avoid undue conflict with local
leaders or local administrators. The issues recorded in the consultation process were
examined, validated, and addressed in the EIA report.

10.3 Stakeholder Consultation Technique

In recognition of the diversity of views within any community, it is very important to

obtain a clear understanding of the different stakeholders and to analyze their capacity
and willingness to be involved in some or all of the project and its planning process. It is
important to be aware of how different power relations can distort participation. It is also

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important to examine how community skills, resources, and ‘local knowledge’ can be
applied to improve project design and implementation. All of this can be achieved by
careful use of the various tools of Stakeholder Consultation. Therefore, the following
participatory techniques were employed during stakeholder consultations:

 Informal meetings with communities in surrounding areas. Men and local elders
attended these meeting.

 Focus Groups with women participants in Jhulda.

10.4 Stakeholders Consulted

In the consultation process for EIA, following key stakeholders were consulted:

 Local communities, Men, women and local elders attended meetings.

 Local Government representatives

Meetings with stakeholders consisted of community consultation meetings, focus group

discussions, and in-depth interviews with men and limited focus-group discussions with
women. The location of the meetings, the process followed, and the outcomes are
discussed in this section. The list of the areas where public consultation was carried out
is given in Table 10.1while the photographs of consultations are included as Figure
10.1.

10.5 Stakeholder Concerns and Recommendations

The findings of the Community consultations are given in Table 10.2. All these have been
addressed in various sections of the EIA, and the mitigation plans have been incorporated
into the EMP. The summary of the various stakeholder consultations is given below.

10.5.1 Community Concerns

Project Approval

The community consultations demonstrated that goodwill towards the project

proponents indeed exists; approval for project activities by the communities was
evident. The consultations were considered a good gesture and appreciated, especially
by the men and women. The poverty level is such that communities are looking to any
project proponent to improve their financial well-being to a great extent. AISL
recognizes that benefits from the project should be distributed judiciously and equitably

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especially among primary stakeholders in the project area, and will continue to ensure
that this principle is followed in its projects and community development program.

Resettlement/ Relocation

The proposed site of 50 MW HFO Fired Power Plant is located at Jhulda, Chittagong near
the Shah Amanat International Airport. AISL purchased the land from the land owners
compensating the current value for the lands. Most of the part of the land is vacant low
land and the rest of the part is fallow and watery low land. There was no household inside
the land. Therefore, resettlement issue is not applicable for the proposed project.

Local Employment

Communities in the project area emphasized that local people should be given priority
when employing people for various project-related works and activities according to
their skills.

Compensation

Compensation for the land has been paid to the landowners. Other compensations shall
be paid e.g. trees and any damage to the crop. The compensation process shall be
transparent.

Interaction with Local Community

Non-Local work force coming in the project area that will not be aware of the local customs
and norms, may result in conflicts with the local community, keeping in mind the
sensitive law and order situation and culture of the area.

Impact on Livelihood

The communities also expressed some fear that construction process would disturb
their cattle and that their livestock might get hurt or run away or die accidental death
due to construction process.

Impact on Accessibility of the Surrounding Households

The communities also expressed some concerns about the access routes to the main
road. Especially the households nearby the access road emphasized about repairing
the damaged road. The access road to the proposed project as well as the culvert
adjoining should be repaired to avoid any difficulty of the surrounding local people.

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10.5.2 Local Government Representatives

The consultations were considered a good gesture and appreciated. They also expressed
the jobs and business opportunities for the local community will be increased due to
project activities. They also expressed the concern that most of the unskilled and skill
jobs should be reserved for the local communities.

Table 10.1: Stakeholder Consultations Conducted During EIA Study

a) Local Community:

Date Location Name Age Occupation

Md. Delwar 38 Service Holder
Md. Nurul Alam 40 Service Holder
Monoara Begum 30 Housewife
Md. Biplob 40 Agricultural Labourer
Sahida 20 Housewife
Rumana 24 Housewife
Md. Abdul Matin 44 Service Holder
Josnara 26 Housewife
Mr. Omor Faruk 17 Service Holder
Md. Osman 22 Agricultural Labourer
Md. Minhaz 25 Businessman
Md. Shahidul Islam 30 Agricultural Labourer
Md. Atikur Rahman 41 Agricultural Labourer
Newton 28 Agricultural Labourer
22.12.2017 Nearby
Md. Josim 30 Service Holder
AISL Plant
Ripon Borua 22 Businessman
Sujon Borua 34 Service Holder
Md. Abdullah 28 Businessman
Md. Nasiruddin 23 Businessman
Md. Abdul Latif 44 Service Holder
Md. Jasimuddin 27 Service Holder
Md. Belal 28 Service Holder
Md. Saber 29 Service Holder
Kulchuma Khatun 36 Businessman
Md. Usuf 28 Businessman
Md. Absar 22 Service Holder
Ali Azam 30 Businessman
Hasina 50 Housewife

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 Nargis 23 Housewife
Akter Hossain 18 Service Holder
Ikram 25 Student
Md. Alamgir 30 Shopkeeper

b) Local Government:

Date Location Participants

Md. Abdullah Al Faruk
Station Air Traffic Officer
Shah Amanat International
Airport
Civil Aviation Office
23.12.2017 Shaikh Shahjahan Alam
at Patenga
Meteorologist
Bangladesh Meteorological
Department,
Ministry of Defence

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Table 10.2: Concerns Raised by the Communities during Stakeholder Consultations

Issues Concern Raised by the Communities’ Remarks

Community

Employment Provision of semi-skilled and Maximum unskilled jobs

unskilled jobs for the local labor should be allocated to the
locals.

Livelihood Restriction of livestock grazing Grazing and vegetation

and accidental killings of areas should be protected
livestock and speed of vehicles should
be limited to avoid accidents

Access to the Difficulty to access to the The access road should be

household households from the main road repaired by AISL or initiative
need to be taken in repairing
the access road after
completion of the project

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Figure 10.1: Photographs of Public Consultations during Field Visit

Consultation nearby AISL Consultation nearby AISL

Consultation at nearby AISL Consultation at nearby AISL

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Figure 10.2: Photographs of Consultations with Government Officers

Consultation at Civil Aviation with Md. Abdullah Al Faruk,

Station Air Traffic Officer (SATO), Shah Amanat International Airport

Consultation at Civil Aviation with Shaikh Shahjahan Alam

Meteorologist, Bangladesh Meteorological Department, Ministry of Defence

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 Chapter – 11
Grievance Redress
Mechanism

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 Chapter 11: Grievance Redress Mechanism

11.0: Grievance Redress Mechanism

Public participation, consultation and information disclosure undertaken as part of the

local EIA process have discussed and addressed major community environmental
concerns. Continued public participation and consultation has been emphasized as a
key component of successful project implementation. As a result of this public
participation during the initial stages of the project, major issues of grievance are not
expected. During the operational phase of the project, the complaints that may be
anticipated are mostly related to noise & vibration of the engines. However, unforeseen
issues may occur. To settle such issues effectively, an effective and transparent
channel for lodging complaints and grievances will be established. The grievance redress
mechanism should be scaled to the risks and adverse impacts of the project. It should
address affected people’s concerns and complaints promptly, using an understandable
and transparent process. It should also be readily accessible to all sections of the
community at no cost and without retribution.

The Grievance Mechanism will be implemented during both the construction and
operational period of the project to ensure that all complaints from local communities
are dealt with appropriately, with corrective actions being implemented, and the
complainant being informed of the outcome. It will be applied to all complaints from
affected parties.

The mechanism will be accessible to diverse members of the community, including

more vulnerable groups such as women and youth. Multiple means of using this
mechanism, including face-to-face meetings, written complaints, telephone conversations
should be available. Confidentiality and privacy for complainants should be honored
where this is seen as necessary or important.

A grievance redress mechanism and procedures is setup to provide opportunity for

project affected persons to settle their complaints and grievances amicably. The
established grievances redress procedures and mechanism ensures that project
affected persons are provided with the appropriate compensations and that all
administrative measures are in line with the law. It also allows project affected persons
not to lose time and resources from going through lengthy administrative and legal
procedures. Grievances are first preferred to be settled amicably.

AISL shall set-up a grievance redress committee that will address any complaints
during both the construction and operational period of the project.

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Figure 11.1 - Flowchart of Complaints/Grievance Procedure:

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The representation in the committee makes project affected persons to have trust and
build confidence in the system. The grievance redress committee reports its plan and
activities to the Implementation committee. The following list presents members of the
committee.

Table 11.1: Members of the Committee of Grievance Redress (GRC)

No. List of Member Organizations Responsibility

1 Saleh Ahmed Chowdhury Chair Person
Ex Commissioner
Ward# 31, Chittagong City Corporation
2 Anil Kumar Gupta Executive Member
Project Manager
AISL
3 Julfiquer Huda Member
Head of Admin
AISL
4 Shahabuddin Chowdhury Member
Local Businessman (Representative of PAPs)
5 Ayub Rana Member
Local Businessman (Representative of PAPs)

GRC will maintain a Complaints Database, which will contain all the information on
complaints or grievances received from the communities or other stakeholders. This
would include: the type of complaint, location, time, actions to address these
complaints, and final outcome.

The procedures to be followed and adopted by the grievance redress should be

transparent and simple to understand or uniform process for registering complaints
provide project affected persons with free access to the procedures. The response time
between activating the procedure and reaching a resolution should be as short as
possible. An effective monitoring system will inform project management about the
frequency and nature of grievances. GRC will arrange half yearly meetings where the
activities and the outcomes/measures taken according to the Complaints Database are
to be monitored and reviewed by third party consultant to ensure the required
transparency. In addition to the above, if there are any grievances related to
environmental management issues in the project area, the GRC will record these
grievances and suggestions and pass it on to the relevant consultant for necessary action
and follow-up.

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In case a dispute is not resolved by arbitrational tribunal, then if any of the Party
disagrees, the aggrieved party has the right to appeal to the ordinary courts of law.
However, the preferred option of dispute settlement ought to be the option of settling the
dispute amicably because recourse to courts may take a very long time even years before
a final decision is made and therefore, should not be the preferred option for both parties
concerned.

A grievance form is presented below and hard copies of both English and Bangla will be
made available at the AISL project office.

Table 11.2 : Sample Grievance Reporting Form

Contact Details Name:

Address:

Telephone Number/ Cell Phone Number:

Email:

How would you prefer to be By Phone

contacted
(please tick box) By Email

Details of your Grievance

(Please describe the

problems, how it happened,
when , where, and how many
times, as relevant)

What is your suggested

resolution for the grievance?

Signature: Date:

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 Chapter – 12
Conclusion
&
Recommendations

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 Chapter 12: Conclusion

CONCLUSION AND RECOMMENDATIONS

12.0 CONCLUSION AND RECOMMENDATIONS

12.1 Conclusions

AISL Unit-3, a Bangladeshi private company intends to build and operate a 100 MW HFO
fired power plant at Jhulda area of the Chittagong district. An EIA has been prepared for
the project according to the requirement of DoE for necessary environmental clearances
as it is made mandatory in ECA’95 for any new industrial set up. The EIA has been prepared
through identifying the potential impacts, assessing them and recommendation of possible
mitigating and enhancing measures for negative and positive impacts, respectively.

The environmental analysis has revealed that the project can be set-up according to the
proposed design and configuration in the proposed site and location. The environmental
impacts are of limited nature, whereas the benefits of the project are many.

The primary reason why the environmental impact from the plant is minimal is that the project
proponent is abide by Bangladesh/World Bank Standards and build a plant, which will meet
the emission standards of Bangladesh and the World Bank. The excellent characteristics
of the fuel used, equipment and machinery, which conform to international standard and good
operation practices all combine to make the proposed power plant project acceptable one.

The main potential environmental problems, which may arise as a result of construction of
power plant, can be grouped as follows-

o Atmospheric emissions and Air quality

o Water pollution and waste water disposal
o Noise

All these aspects have been examined and the findings are as follows:

Atmospheric Emission and Air Quality: Emission of sulfur dioxide, Nitrogen Oxides,
carbon dioxides and particulates would be the major concern of air pollution for the project.
The plant will have 8 Caterpillar engines, each of capacity 13.201MW. The final rated
capacity of the power plant would be 100 MW. Thus the exhaust heat temperature will be
reduced from 315 0C to 174 0C. In addition to that, the project authority will also install a
Flue gas de-sulpharisation (FGD) plant to reduce the sulpher content from the exhaust
which will remove approximately 90% sulpher from the exhaust. So, after taking all
those mitigation measures, it is expected that the final exhaust from power plant
project should comply all the standards parameters of IFC/WHO and as well as
Bangladesh. To assess the ambient air quality from the stack emission, a dispersion

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modeling has been done by using USEPA approved AERMOD model and the result shows
that all emission would be within the Bangladesh limit.

Liquid Discharge: The power plant will not produce any wastewater since it has mainly
air cooling and close looped water cooling system. The steam turbine will have a
condensation cooling system by a close loop cooling tower. Only small amount of make-
up water will be needed in the system. The domestic liquid wastes would be disposed
through septic tank. The surface drainage network would be connected with an interceptor
prior to discharge through natural water. The interceptor will trap all oily matter present in
the water.

Noise: The noise impact generated by operation of the plant has been predicted by means
of noise impact modeling. The results will be used to specify noise abatement measurers.
Appropriate noise controls will be installed to keep the neighborhood impact due to noise
emissions within the limit of DoE and international standards.

12.2 Recommendations

Having reviewed all the potential environmental impacts, and following our proposed
mitigation measures the project is expected to proceed without having unacceptable
environment. Electricity supplies could be provided to the area without much of load
shedding. In this context, the proposed power station, 50 MW HFO Fired Power Plant, would
be a welcome relief for the people in that area. However, the following recommendation may
be outlined for the project:

1. Follow the Mitigation measures suggested in the chap-6 during the construction and
operation of the project
2. Follow the Environmental Management Plan (EMP) suggested in chap-7 properly.
3. Develop an Environment Management System (EMS) for the project.
4. Conduct a post operational environmental study to evaluate the environmental impacts
from the project and compare these with the EIA.

However no development can be expected without any adverse impact on the

environment. The beneficial impacts on the nation as well as human beings would only be
meaningful and sustainable development would only be possible if adverse impacts are
minimized through strict maintenance and control measures as mentioned for this project.
All this would need vigilant care and cost money, and the project authority should take these
into consideration.

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References

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 References

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2. Peavy & Rowe (1985), “Environmental Engineering”, McGraw-Hill Inc., Singapore.

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5. S.S Dara (1995), “Environmental Chemistry and Pollution Control”, S. Chand &
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6. A.K De (1989), “Environmental Chemistry”, Wiley Eastern Ltd., New Delhi, India.

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