Bangladesh Case Study on

ENVIRONMENTAL IMPACT ASSESSMENT OF

Gas Engine Power Project
1. INTRODUCTION

1.1 Project Location

The Project area is located about 25 Km from Dhaka (capital city of Bangladesh)
by the eastern side of Ashulia-Savar road, at Ashulia, Savar, Dhaka. The site is on
the west side of vast wetland of Ashulia. REB (Rural electrification Board) has
leased out the designated land for the project of USPCL (United Summit Power
Company Limited).

Access to the site by road from Dhaka is possible through two major routes, one
via Uttara and then Ashulia and the other via Aminbazar and then Savar.

1.2 Project History

The Pally Biddut Samitis (Rural Electric Societies) or PBSs are non-government
autonomous cooperative institutions in the power sector registered with the Rural
Electrification Board (REB). The creation of the PBSs, construction of their
facilities, initial financing of their assets, training of their personnel and monitoring
of their performances are done by the REB of the Government established under
Rural Electrification Board ordinance, 1977.

The peak power demand in Bangladesh is between 2400 MW to 2600 MW,

according to mid 2000 estimates. The load forecast as per the latest estimate
provided by PDB shows that the demand is expected to increase up to 250-300
MW by end 2000. At present PDB can meet about 2000-2200 MW of power.
That’s why there is always a shortage of about 400 to 600 MW of power during
peak demand. Generally REB and subsequently PBS suffer due to this shortage of
load. The electricity distributed through the PBSs is about 15 per cent of combined
countrywide sales of power by the Bangladesh Power Development Board (BPDB)
and Dhaka Electric Supply Authority (DESA). Government considers this to be
insufficient and wishes to extend the share of the PBSs. There are at present 54
PBSs under REB in the country and their daily demand are 400 MW of power,
which PDB is constrained to meet during peak time.

It is observed from the daily load curve that the load management has not been
very effective and there is predominant peak during the evening hours. Bangladesh
is gradually shifting to industrialization and this growth is certain, if security of

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 supplies and load shedding can he avoided. In this context, the installation of I0
MW power plants becomes necessary. Such a power station near load center would
minimize transmission losses and would also improve voltage conditions.

To meet the national requirement in the power generation REB solicited invitations
to interested Bidders for Pre-Qualification of sponsors to develop around 10 MW
(± 10%) gas fired power stations at Ashulia, Savar, on a Build, Operate and Own
(BOO) basis. After Pre-Qualification, a Request for Proposals (RFP) was issued to
interested bidders. They were asked to submit the proposals for the right to develop
10 MW (± 10%) net at Guarantee Point natural gas fired, conventional
reciprocating or combustion turbine electric power stations along with all support
facilities at the Dhaka PBS on a BOO basis. Being the most competitive bidder
REB issued Letter of Intent (LOI) in favor of United Summit Power Co. Ltd.
(USPCL), a private limited company. The International Finance Corporation (IFC)
and EXIM Bank of USA are involved in financing the project along with USPCL.
IFC is a member of the World Bank Group, which also includes the International
Bank for Reconstruction and Development (IBRD), the International Development
Association (IDA), and the Multilateral Investment Guarantee Agency (MIGA).
IFC’s business is investment in private sector projects through loans, equity
investment, and other financial instruments. It is IFC policy that all its operations
are carried out in an environmentally and socially responsible manner. To this end,
IFC projects must comply with applicable IFC environmental, social and
disclosure policies. Furthermore, the project sponsor must ensure compliance with
Bangladesh requirement. IFC does not finance project activities that would
contravene country (here in Bangladesh) obligations under relevant international
environmental treaties and agreements, as identified during the Environmental
Impact Assessment (EIA).

1.3 Need of the Project

Thrust of population increase makes Bangladesh the most densely populated

country in the world, and the task of sustainable resource management difficult but
very urgent. With the increase in population as well as industrialization the demand
of electricity increased day by day. The worsening gap between demand and
supply of electricity as manifested by frequent load shedding throughout the
country has prompted the government to take urgent measures to tackle the
situation. The government has decided to set up Barge Mounted Power Plants and
along with that different capacities of other power plants(particularly small power
plants of 10 MW or around capacity) to quickly add a few hundred megawatts of
generation capacity. The present project is in response to the power requirement

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 and attempts to perform in a manner so that through contributing to the power
sector need and operating in an environmentally and socially responsive manner,
this contributes towards overall development of the country.

1.4 Project Features

This is a gas engine type power generation project of 10 MW electricity at base

load. The raw material is local natural gas. Total number of employees during
operation is 22 and the project cost US $ 6.2 million. Total land requirement 1.2
acres, water requirement 18 cubic meter per day and natural gas requirement 125
MSCF per hour. The gas engines drive the electric generators to produce electricity
at 11 kV and 50Hz. The plant was supposed to go into production by end 2000 or
early 2001.

1.5 Extent and scope of EIA

The present EIA is focused on, and is limited to, preparation of the EIA for the
Plant, and carried out by Protech Engineering, a Bangladeshi Environmental
Consulting Firm.

This EIA identifies the major potential environmental impact/issues due to the
plant location and operation along with suggestion of effective measures to
mitigate the adverse impacts and enhance the positive environment potential. 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 biological
aspect, but also the human dimension.

The report has the following specific scope:

• Present a brief discussion on the EIA process and its role in the planning
and
• Implementation of development projects
• Present a brief discussion of the legal, policy and institutional requirement
• Present a description of the project/program and the activities involved and
evaluate the proposed area of exploration activities from the environmental
point of view
• Delineate the significant environmental issues / impacts found / identified
and believed to be involved

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 • Suggest certain recommended measures to be undertaken during the
Planning, construction and operation stages so that the performance al
through remains in an environment friendly manner.

1.6 Environmental setting

The site is located about 25 km from Dhaka City by the eastside of Ashulia-Savar
road. On the eastside of the site there is a semi-pucca house and all other sides are
surrounded by vacant lands and scattered homesteads. There is garments industry
named MST Fashion and a proposed washing plant named Laundry Industries Ltd.
on the southwest side and a poultry farm named SA. Rahman on the west side of
the proposed site. There is also a garments factory at the northwest side of the
project. A gas substation is about half kilometer northwest and the transmission
grid line is about five-kilometer from the site.
The topography of the area is flat land and sparsely populated. The surrounding
areas of the site have mixed use as for seasonal crop production, scattered
homestead, fallow lands and industries. Also there are some lands demarcated for
industrial uses and there is an Export Processing Zone (EPZ) situated about 5 km
from the site. The site for the proposed power plant has been purchased about two
years back by REB from its owner at market value and no homestead acquisition
was involved for the proposed site. The past history of the site, as mentioned by the
local people, suggests that it was a fallow land without crop production. Since the
proposed land is more or less flat and at road level so there no land development is
required. However, half kilometer of gas pipeline from sub station to the proposed
site and five-kilometer long electric transmission grid line for the transmission of
generated electricity to PBS would be constructed along the side of the Ashulia-
Savar road. From the field visit to the site and its surroundings it is confirmed that
the proponent would construct the above-mentioned lines without the need of
resettlement of people, as because the construction would be done by the side of
the Ashulia-Savar road. During the EIA study the construction of the power plant
was going on.

It is obvious that in future the area would be mostly used for industrial, commercial
and related activities only. Some of the notable features of the surroundings are:

• Like other pans of Bangladesh, only domestic animals and a few common
birds were observed around the plant site.
• No high rise building; monuments or sites of historic and of archaeological
interest were observed near the site.
• Features of scientific interest on and around the plant site are absent

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 • There is no development of scenic or recreation facility on and around the
plant site.
• There is no wildlife, natural reserved forest and vegetation, fishery
resources, endangered species present in and around the plant site

From the above discussion, it is dear that the land use of the area is mixed
(commercial and mixed) in nature. So, the area falls under category ‘B’ as per area
classification by DOE.

1.7 Purpose of the EIA

The purpose of the EIA, which has been carried out (not as an integral part of the
overall project planning, but as a separate document to obtain environmental
clearance) are to:

• Evaluate the Project's anticipated effects on environmental resources in the

region to be affected by the Project, in order to identify any significant
environmental impacts (SEIs) of the Project
• Describe any of these SEIs for present and anticipated future conditions, for
both with-project and without-project conditions
• Evaluate feasible ways by which each SEI can be suitably managed by use
of Environmental Protection Measures (EPMs). This includes mitigation/
offsetting/ enhancement measures, and work with the overall project team,
to incorporate needed EPMs into the overall project plan, so that the
adjusted project plan will be both economically and environmentally sound
to the extent feasible. This will allow Decision Makers to be clearly
appraised of the economic and environmental consequences if the decision
is made to proceed or not to proceed with the project.
• Assist to prepare technical monitoring programs for monitoring the
project's effects on environment during both the construction and
operation phases
• Guide to prepare a recommended Environmental Management Plan which
presents the institutional plan, including management, tasks, benefits, to
ensure that the proposed EPMs and monitoring will actually be carried out
as proposed in the EIA

The objective of the EIA report is also to comply with the requirement of the
Government regulatory requirement and in contributing to the process of
obtaining the required environmental clearance from the Department of
Environment (DOE).

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2. NATURE AND SCOPE OF ISSUES

The major issues related to the EIA was

• The plant’s location suitability from an environmental point of view

• Pollution aspects due to the plant, particularly air pollution
• Social issues particularly resettlement and public consultation

Pollution management
Air pollution aspect was duly considered and the anticipated impacts studied and
documented. Similarly other potential sources of pollution were also considered.

Resettlement

No resettlement was necessary, as there was no human habitation on the selected

land.

Consultation with affected people

The EIA's Public Consultation Team conducted a series of formal and informal
meetings, arranged Focus Group Discussions and Key Informants’ Interviews with
the community members and stakeholders.

Based on results of the consultations, it had been obvious that people want project
like this and they welcome such efforts. At the same time they like to see that the
plant performs in an environmentally and socially responsive manner. As the plant
is a small one, natural gas based, with few people working, the land being a
purchased land without any displacement of people, there had not been any major
concern from any corner.

Site alternatives
The sites for the installation of the power plant were selected by NRECA
International Ltd. (REB’s rural electrification consultant) about a year back from
the time of conducting the EIA. Site was selected on the basis of proximity to load
centers within the PBS, distance to gas pipelines and distance to electrical inter
connection sub stations and also a site good enough to construct the plant, easy to
develop and available for purchase. As the project site was finalized on the above-
mentioned criteria, alternate sites were not looked into.

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3. PROCESS AND PROCEDURAL CONTEXT

The concept of Environmental Impact Assessment was introduced in Bangladesh

in the late 1980s. However it was formally introduced in the 1992 Environment
Policy and subsequently legalized through the Environment Conservation Act 1995
and Environment Conservation Rules 1997.

Environmental policy requires “conducting Environmental Impact Assessments

(EIAs) for all new public and private industries”. Section 5 of the Policy
"Institutional arrangement" requires that “Department of Environment will review
and approve all environmental Impact Assessments”.

The Energy Policy 1995 highlights the importance of protecting the environment
by requiring EIA for any new energy development project, introduction of
economically viable and environment friendly technology. Out of seven
recommendations of the Energy Policy, one says ‘Environmental impact
assessment should be made mandatory and should constitute an integral part of any
new energy development project’

The Power Policy 1997 suggests, “Development of power sub-sector shall be

such that it is sustainable environmentally and cost-effective at the same time”.

Policy guideline for small power plants in private sector, 1997 is to promote small
power plants (SPP) of not more than 10 MW in private sector. According to this
policy guideline, “the SPPs can be located in any part of Bangladesh”. “As per
electricity Act 1910, the sponsors will be required to obtain license from the
GOB”. The good thing is, “SPP will need to comply will all laws of Bangladesh
including environmental standards” as per the requirement of the policy guideline.
The present plant under consideration is a SPP.

3.1 Compliance with DOE EIA guidelines

As DOE has its own EIA guidelines for industries 1997, the Project Proponent
while conducting EIA is expected to consult and follow the DOE EIA guidelines.

The Guidelines under consideration however tend to address the three categories of
industries and other projects (Green, Orange and Red) as scheduled in the
Environment Conservation Rules 1997 (ECR'97) and `Power Generation Plants’
fall under the Red category (item 6, schedule-1, page 3120 of Bangladesh Gazette

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 of 28 August 1997 and of ECR'97 and page-49 of the 'EIA Guidelines for
Industries). [Red List Industries 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 initial site clearance on the basis of an
IEE report, and subsequently submit an EIA report for obtaining environmental
clearance along with other necessary papers, like the feasibility study report, no
objection from local authority].

The present study and the preparation of the report took due cognizance of these
Guidelines to remain consistent with and the structure and contents tried to
comprehensively address these guidelines.

4.0 APPROACHES TAKEN

Scoping was done carefully so that the focus is made concretely in a limited time
and with limited resources without wasting efforts.

The present report has been prepared based on the information supplied by the
project proponent and undertaking site visits to the proposed area with a view to
reconnaissance survey of the area and its surrounding areas. Relevant secondary
and primary information regarding such exploration program and other
environmental information was collected, samples were collected and analyzed,
and field surveys were undertaken. This was followed by evaluation of the
information to delineate the major environmental issues relating to the proposed
program.

During this process, the following steps were followed:

• Collection of information relating to the project by requesting and meeting

with the Project Proponent
• Collection and review of pertinent reports and other references
• Undertake field visits to the project site
• Survey the neighborhood
• Gather information from various government and other agencies, etc.
• Critical analysis of the project document and other information
• Understanding the program, process involved and the surrounding
environment
• Undertake surveys

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 • Collect, analyze samples
• Identification of possible environmental impacts and evaluation of their
significance and consequences
• Identification of sources of pollution and other causes of degradation of
significance
• Undertake public consultations
• Presentation of a brief outline/components of an environmental
management plan, which is pragmatic and reasonable, to handle
environmental issues

The IEE methodology involved basically is of that described in EIA guidelines

published by DOE for industries and ADB manuals of IEE/REIA/EIA guidelines
and the World Bank EA Source Book, but not really limited to those.

Particular focus was on air pollution and water pollution aspects, social impacts,
public health and safety, construction impacts, changes on landscape, impacts on
both flora and fauna. Some of these were studied carefully and in depth, however
as the plant is a small one and a gas based one in an area, which is not very
sensitive in terms of floral and faunal resources and also not densely inhabited,
detailed special studies were not conducted on these.

5.0 RESULTS AND IMPLICATIONS

5.1 Anticipated Environmental Impacts

5.1.1 Impacts on Air Quality

Impact Origin
Emission from the engine stack and unburned gases from the engine operation may
affect the ambient air quality. The situation aggravates when gas 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
fossil fuels for power generation inevitably results in emission of gaseous
pollutants to the atmosphere. As the proposed power plant would be fired with gas,
the pollutants of potential concern are sulfur dioxide (SO2), oxides of nitrogen
(NOx), carbon monoxide (CO) and carbon dioxide (CO). Each of these pollutants
is examined below to ensure the Bangladesh emission limits and, where
appropriate, the required emission control techniques would be incorporated into
the mitigation measures. Since the location of the proposed power plant is in near

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rural area so it is expected that the site would be away from major pollution
sources. Further ambient air qualities of rural areas of Bangladesh are relatively
good and also the emissions from the proposed power plant are expected to have
only minor impacts.

Sulfur dioxide (SO2)

The emissions of sulfur dioxide are dependent on the sulfur content of the gas.
Typically, this is extremely low and, in comparison to coal and oil fired plant, is
considered insignificant. For this assessment the sulfur content of the gas is
assumed to be 0.002%. The emission rates can be compared to and be seen to
comply with all the relevant Bangladesh standards.

Nitrogen Oxides (NOx)

The combustion of fossil fuels generally produces two forms of nitrogen oxides,
commonly referred to as nitrogen oxides (NOx). The two oxides are: NO - nitric
oxide and NO2 - nitrogen dioxide.

The proportion varies depending on the combustion technology, and in the case of
gas engines approximately 90% of the NOx is present as NO with the remainder
being NO2. Once NO enters the atmosphere, it reacts with ozone and other
chemicals in the air and oxidizes to NO2 with time. The health effects of nitrogen
dioxide are far greater than that of nitric oxide. For these reasons, when
atmospheric emissions are discussed, this is referred to nitrogen oxides and air
quality is discussed, nitrogen dioxide is referred to.

The NOx produced will originate from both the fuel and the air. NOx from the fuel
is usually referred to as ‘Fuel NOx’ and NOx from the air is generally referred to
as ‘Thermal NOx’. The proportion of fuel NOx to thermal NOx depends cm the
temperature of combustion. With an increase in combustion temperature, there is
an increase in thermal NOx emissions, and hence overall NOx emissions. As per
designed standard the maximum emission of NOx from the engines would be 45
ppm at 15% 02. On the basis of the above emission level, ground level
concentration (GLC) at various distances for a proposed stack height of I 5.Om can
be calculated using air quality model.

By superimposing the calculated ground level concentrations from sources over

background concentration then, only conclusion can be drawn whether the
proposed project will create any negative impact on air quality or not.

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Dispersion modeling techniques have been used to calculate maximum ground
level concentration of nitrogen-di-oxide for a stack height of 15.0 m. The model
used for this assessment was SCREEN 3. This model is approved by the United
States Environmental Protection Agency (USEPA) for the calculation of maximum
short term concentration of non-reactive pollutants emitted from a single point
source Short term concentrations generally represent peak I-hr, 8-hr or 24-hr
ground level concentrations. The SCREEN 3 model includes subroutines to
estimate the effect of building wash, rural or urban dispersion, complex or simple
terrain, inversion breakup and shoreline fumigation. SCREEN 3 is an optimized
version of the USEPA reference Industrial Source Complex (ISC) model.
Maximum concentrations are calculated on a screening set of 54 meteorological
conditions for distance downwind of the source. No account is made for wind
direction.

SCREEN 3 assumes that pollutants are conserved (i.e. no atmospheric reactions

take place). The combined concentration of NO and NO2 are therefore expressed
as NOx. Emissions of NOx from combustion plants generally include l0-25%NO2
and 75-90% NO. As the exhaust passes into the atmosphere, the NO is oxidized to
NO2. The conversion rate is determined by a number of factors including time,
temperature, ozone and hydrocarbon concentration. For short term modeling a
conversion rate of 50% is accepted.

The result of using SCREEN 3 is presented in Amnex-6.l. It is found that

maximum I-hr concentration of NOx would be 14.98 µg /m3 at a distance of 380 m
from the stack. This means, at present ambient condition, after operation of
proposed plant, maximum NOx concentration would be 39.38 µg/ m3. This value
will comply with the Bangladesh standard of 100 µg/ m3 for Category —B area.

Mitigation measures
The discussion confirms that, the proposed stack height of 15.0 m will able to keep
the emission level of NOx within the allowable limit of Bangladesh, so no extra
mitigation measure would be needed for combating the NOx emission level from
the plant in question.

Carbon monoxide
Carbon monoxide (CO) is generated when incomplete combustion takes place. As
per designed standard the maximum emission of CO from the engines would be
1314 mg/Nm3 (dry at 5% O2). No Bangladesh emission limits for carbon
monoxide are available. But it can safely be presumed that, as the proposed project

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would be set up mostly in the rural areas, the ambient air quality of those areas
would significantly be less than the Bangladesh standards of 2000 µg/ m3. So the
impact due to emission of CO would not be significant for the proposed power
stations.

Carbon dioxide
The emission of carbon dioxide (C02) depends on the fuel burn and the carbon
content of the fuel. The fuels that would be fired contain about 75% carbon, which
reacts with oxygen to produce carbon dioxide and heat.
CO2 emissions to the atmosphere are associated with ‘global warming’. Any
reduction in emissions of CO2 is therefore beneficial but need to be weighed up
against the need for production of electricity. The proposed power station would be
of modem design with optimum designed cycle efficiency in order to maximize the
MW output and hence, the CO2 emission, per unit of fuel burnt.

5.1.2 Pollution from Solid Waste

Impact Origin
The operation of the plant by itself would not generate any solid waste. Solid waste
generated by people working at the proposed power station is paper, bags, boxes,
office wastes, pallets, empty drums etc. along with negligible quantity of domestic
waste. All these materials would be non-toxic and therefore does not require
specialist disposal requirements. These materials could be delivered to the nearby
landfill safely.

Mitigation Measures
The solid wastes would first be scavenges to screen the saleable wastes and
remaining portion would be collected at a convenient point and disposed safely to
designated landfill sites. There are low lying areas surrounding the site so these
solid materials could be safely disposed to the nearby landfill.

Residual Impact
Provided that the mitigation measure indicated above is fully implemented,
residual impact will be insignificant

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5.1.3 Impact due to Lubricating Oil

Impact Origin
Insignificant amount of used lubricating oil would be generated from 10 MW
power plant. The generated waste oil would be stored in a sealed tank constructed
on the site. This oil is generally used in the brick kilns and has other secondary
uses. The proponent mentioned that they would sell this waste oil to the secondary
users

Mitigation Measures
As there is no chance of mixing and disposal of lubricating oil on to land or water,
so there are no mitigating measures suggested for the project.

5.1.4 Noise and vibration impacts

Impact Origin
There would be moderate noise and vibration from the power station. The
proposed power plant would generate significant noise during operation. The level
of noise would be about 65 dB (A) at a distance lOO. O m and 60dB (A) at a
distance of 150.0 m from engines. For the proposed site the distance from the
engine to the boundary of plant would exceed the Bangladesh standards for mixed
area (60 dB (A) at day time and 50 dB (A) at night time). So, careful acoustic
design is to be done to reduce the noise level within the allowable limit

Mitigation Measures
After getting the site clearance the proponent has purchased more lands to increase
the boundary for the project. The engine manufacturer are supplying separate
silencer for each engine to reduce the noise in operation. Moreover, the proponent
has imported pre-fabricated powerhouse building with sufficient acoustic design,
which might reduce the noise to allowable limit of Bangladesh. Since, there are
very few scattered homesteads within the close proximity of the proposed site, so
the impact from noise and vibration would not create significant effect. In addition
to control measures, creating buffer zones surrounding the power station by
planting trees will reduce noise level to some extent. However, it is understood that
the project proponent would take measures (e.g. installation of noise barrier), if
necessary in future, in their plant to reduce the noise level to an acceptable limit

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5.1.5 Impact on Socio-economic Environment

Impact on Employment and Family Finance

The project envisages providing permanent employment of about a total of 22
skilled and unskilled personnel during its operation phase. This would obviously
help to present unemployment burden of the country to some extent. Employment
will definitely provide an opportunity to improve his basic living standard. Apart
from this direct benefit, there would other indirect beneficial impacts on national
economy through foreign investment.

Benefit Enhancement Measures

Although labor recruitment is a matter of the proponent who has the right to
determine whom he shall and shall not employ, but still, the project proponent shall
employ local people wherever possible and to give preference to employment of
the land less and jobless people. This will ensure the real benefit for the poorest of
the poor.

5.1.6 Impact On Health and Safety

Impact Origin
As there might be hazards to the plant workers, employees and technical personnel,
provisions need to be made by the project for protecting occupational health,
including protection of workers from hazards/fire/spillage etc. as well as protection
of workers, health and assurance of safe drinking water supply and sanitation. The
workers who work inside the factory face occupational health hazard due to
different operation processes.

Mitigating Measures
Safe and good occupational health status of the employees and workers is
important for not only the persons working in the plant; but also for the better plant
operation and maintenance. Protective clothing and accessories should be provided
to the workers, who would be subjected to exposure to hazardous substances and
situation. Regular medical check-up is to be done to ensure the soundness of health
of the employees and workers. Pollution control measures are to be duly adopted
as necessary, including noise and emission control, so that there would not be any
negative occupational health impact. Insurance for all employees should be taken
out. A senior Medical officer with sufficient background and experience in
occupational health problems should coordinate this issue and would be

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 responsible for drawing up and implementing a detailed and regular program for
ensuring health safety for all the workers in the industrial unit.

5.1.8 Other Safety Provisions

Beyond the above measures, the project would also have full provision for fire
fighting and first aid medical services. The proponent also will construct an
underground water reservoir for fire fighting. The project has provision in its
recurring annual expenditure for purchasing safety items such as aprons, hand
gloves, ear protector etc.

5.1.9 Religious, Cultural and Archaeological Sites/Objects

No sites or objects of religious, cultural, archaeological significance are expected

to be affected by the project. There are no tribal or indigenous people.

5.2 Environment protection measures

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
gas, the pollutants of potential concern are sulfur dioxide (SO2), oxides of nitrogen
(NOx), carbon monoxide (CO) and carbon dioxide (C02). Each of these pollutants
is examined to ensure the Bangladesh limits will be complied with and, where
appropriate, the required emission control techniques are incorporated into the
rehabilitation program. When the plant goes into operation, gaseous emissions will
be released to the atmosphere through the stacks. The emission will contain NOx,
CO and CO2. Since, the proponent will take necessary step to minimize the
emission level to meet the national standards of Bangladesh. Natural gas will be
burned as fuel, particulate matter emission wilt not occur.

Fuel Management

The fuel will be transported to the site by a pipeline. Prior to being fed to a gas
engine, it will be treated in a gas compound to adjust its pressure to a value suitable
for engine firing.

Management of Solid Wastes

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 Recycling will be adopted wherever possible and only small quantities will require
disposal to landfill. 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.

Aqueous Management

Ground water will be used for all purposes and the impact of any abstraction on
local water bodies would be minimal It is worth pointing out that this power plant
is not a steam thermal plant. Therefore, there is no requirement of large volume of
cooling water (small amount of water will be needed only for make up water in
cooling system). As close loop cooling system will be used, so there will be no
question of discharging any cooling water.

Domestic Sewage Management

All domestic sewage along with occasional floor and machine wash will be treated
in a septic tank. The treated water will be discharged through soak pit.

Noise 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.

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 area. Soil in
and around the plan site is fertile and plenty of water is available. Hence, the green
belt can be created in a short time.

5.3 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-

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 • To check on whether mitigation and benefit enhancement measures are
actually being adopted and are providing effective in practice
• 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.
• 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:

• Visual observation or checking, coupled with inquiries

• 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.

5.3.1 Monitoring Indicators

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. Monitoring parameters suggested are Sox and
NOx for air quality (near and away to the stack, four samples each a year, on a
quarterly basis) and Noise level (near the boundary, four samples a year, on a
quarterly basis)

5.4 Evaluation of the project and granting approval

As per the regulatory requirement of the Department of Environment, the Project

Proponent submitted its application for environmental clearance to the DOE Dhaka
Divisional Office in a prescribed format along with all necessary papers. This
included the EIA Report. After review by the divisional (regional office), the
application along with EIA was forwarded to the Head Quarter, to the Environment

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 Clearance Committee. This committee in its weekly review meeting reviewed the
EIA and then asked the Proponent and Consultant to present the EIA in a special
meeting of the Clearance Committee at a later date. Once this was presented to a
wider group of Committee Members, which included specialists from outside of
DOE, there had been discussion, observations, questions and answers. The EIA
report was recommended to be approved by the Committee and then was approved
by the Department of Environment. Then the application was considered favorably
and the decision was taken to issue Environmental Clearance in favor of the Power
Plant.

6.0 LESSONS LEARNED

• EIA contributed to obtain Environmental Clearance for the Power Plant

• EIA undertaken had been a positive initiative and appreciated overall
• If EIA could have been undertaken as an integral part of the Feasibility
Study, that would have been better
• EIA is an useful tool to delineate environmental issues, impacts and
mitigation measures
• Emission and noise are two major sources of problem for power plants
• Bangladesh natural gas is a ‘sweet’ gas and not much problem is
anticipated
• Presentation of EIA at DOE in presence of both DOE officials and external
experts is a good idea
• EIA reports should be widely disseminated
• All EIAs are prepared in English in country, it would be good to have those
prepared in local language too (in Bengali)
• The Plant authority can use the EIA report as a guiding tool for its response
towards environmental compatibility
• Some other Power Plant proponents/Power Plants use this EIA as a
reference/support document

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7. Key references and information sources

7.1 Key references

ADB, 1998. “Environmental Guidelines for Selected Industrial and Power Development
Projects”, Asian Development Bank, Manila, The Philippines.

ADB, 2000. ‘Bangladesh: Environment Operational Strategy (Draft)’, Asian

Development Bank, Manila, The Philippines

AE, 2000. ‘EIA of United Summit Power Company Limited’, Protech Engineering,
Dhaka, Bangladesh

BBS, 1999. “1999 Statistical Yearbook of Bangladesh”, Bangladesh Bureau of Statistics,

Dhaka, Bangladesh.

BBS, 2001. “Population Census 2001 Preliminary Report”, Bangladesh Bureau of

Statistics, Dhaka, Bangladesh.

DE A.K., 1989. ‘Environmental Chemistry”, Wiley Eastern Limited, New Delhi, India.

DOE, 1997. EIA Guidelines for Industries, Department of Environment, Dhaka,

Bangladesh.

ESCAP, 1985. “Environmental Impact Assessment – Guidelines for Planners and

Decision-makers”, Economic and Social Commission for Asia and the Pacific, Bangkok,
Thailand.

Farooque M and Hasan S.R., 1996. Laws regulating environment in Bangladesh,

Bangladesh Environmental Lawyers Association and Food Foundation, Dhaka,
Bangladesh.

GOI/ADB/ESCAP, 1988. “Training Workshop on Environmental Impact Assessment

and Evaluation: Proceedings and Training Manual. (Vol. I &II)”, Asian Development
Bank, Manila, The Philippines.

IUCN, 2000. ‘Review of laws and policies concerning natural resource management in
Bangladesh’, IUCN- The World Conservation Union, Dhaka, Bangladesh

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Kannan K., 1991. “Fundamentals of Environmental Pollution”, S. Chand and Company
Limited, New Delhi, India.

Ludwig H.F., et al, 1988. “Environmental Technology in Developing Countries (Vol.

I&II)”, SEATEC International, Bangkok, Thailand.

MOEF, 1992. Environment Policy 1992 and Environmental Action Plan, Ministry of
Environment and Forest, Dhaka, Bangladesh.

MOEF, 1995. National Environmental Management Plan, Ministry of Environment and

Forest, Dhaka, Bangladesh.

MOEF, 1997. Bangladesh Environment Conservation Rules, Ministry of Environment

and Forest, Dhaka, Bangladesh.

MOEF, 1995. Bangladesh Environment Conservation Act, Ministry of Environment and

Forest, Dhaka, Bangladesh.

MOEF/IUCN, 1992. Towards Sustainable Development – National Conservation

Strategy, Ministry of Environment and Forest and IUCN The World Conservation Union,
Dhaka, Bangladesh.

MOP, 1998. “The Fifth five year plan 1997-2002’, Ministry of Planning, Dhaka,
Bangladesh

WB, 1992. ‘Environmental assessment source book, Volume III Guidelines for
environmental assessment of energy and industry projects’, Environment Department of
the World Bank, Washington, USA

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7.2 Person preparing the case study

Name : M.Anwarul Islam

Organization : N/A

Position : Independent EIA Practitioner/Environment & Development

Adviser

Contact Address : House-5, Road-6, Sector-6, Uttara, Dhaka-1230,

Bangladesh

Phone : 880-2-8914803,8956708

Fax : 880-2-9885248

Email : anwarsi@citechco.net

Date of preparation of case study: 12 October 2003

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