EIA Bp Exploration

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Environmental Impact Assessment:Coal Bed Methane (CBM) ProjectBirbhum District, West Bengal

Executive Summary

June 2008

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EXECUTIVE SUMMARY

A) I NTRODUCTION

BP has been awarded a CBM exploration concession for a 250 square

kilometre CBM Block located in Birbhum District in the State of West Bengal,India. The awarded CBM Block is referred to as BB-CBM-2005/III. Theexploration licence was awarded through an international bidding processunder the CBM Exploration Policy formulated by Ministry of Petroleum andNatural Gas (MoPNG) on behalf of the Government of India (GoI). As per theContract agreement with GoI, BP will undertake to execute the CBM Project inthe following four phases, with the option to relinquish the CBM Block at endof Phase 1 and 2 should BP deem the Project to be commercially unviable.

Phase I Appraisal or exploration stage which is anticipated to last 2years from the effective date of the Petroleum Exploration License PEL(Nov 2007).

Phase II - Pilot Testing to assess the fields sustainable producibility. Theduration of this phase is 2.5 years after completion of Phase I.

Phase III Implementation of a Development Plan. The duration of thisphase is 5 years after completion of Phase II.

Phase IV Production and Operation Stage which is planned to lasttwenty five years or more.

Currently, physical exploratory activity or drilling operations have notcommenced at the CBM Block; these will be initiated upon receipt of allnecessary regulatory clearances.

B) CBM B LOCK LOCATION

The BP CBM Block is located in Birbhum District of the State of West Bengal.The Birbhum District is bounded by Murshidabad and Burdwan Districts tothe east and Burdwan District to the south and Dumka district of JharkhandState to the west and north. The CBM Block is located about 35 km fromnorth-east of Siuri (the administrative headquarters of Birbhum) and about250 km from Kolkata (the capital of the State of West Bengal). It covers parts ofthe three administrative blocks of Mohammad Bazar, Rampurhaat 1 andMayureshwar 1.


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Figure 0.1 CBM Block setting map

C) P RIOR E NVIRONMENTAL C LEARANCE

As per the EIA Notification, September 2006, a Coal Bed Methane (CBM) Projectis classified as a Category A type project requiring prior environmentalclearance (EC) from the Ministry of Environment and Forests (MoEF). Thefinal Terms of Reference (ToR) for the EIA was agreed in April 2008 with theMoEF and covers Phase I and II activities only.

D) A PPROACH AND M ETHODOLOGY

While the primary object was to follow the MoEF guidelines on conductingEIAs, a phased approach was adopted in the environmental impact


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assessment of the Project. The approach allowed the environmental impactassessment related studies to benefit from critical inputs from initialpreparatory studies while giving inputs to the Project planning and design.

The EIA followed a five stage approach: Stage 1: Initial studies including field reconnaissance of the site and desk

based studies to identify and evaluate potential risks to the Project. Stage 2: Satellite data acquisition and related studies were used to

identify initial constraints to development (forests, settlements, waterbodies and access roads) and the initial identification of potentialissues such as ground and surface water, air, flora, fauna, livestock,land, agriculture and local communities.

Stage 3: Regulatory considerations involving the submission of Form 1and the subsequent agreement of the Terms of Reference (ToR).

Stage 4: Environment and Social Baseline (ESB) which was completed inApril 2008, and became the basis for predicting the potential

environmental and social impacts, providing inputs to the Projectdesign and a benchmark to measure change during and after theProject activities.

Stage 5: Environmental and Social Impact Assessment (termed EIA)

A key output from the constraints mapping process (Stage 2) was theidentification of ten Initial Drilling Areas (IDAs), within which wellsites willbe located for the purposes of developing core holes and in some cases, testwells. These IDAs helped focus the environmental and social baseline surveys,and, along with a network of preliminary access roads, formed the basis of the

EIA.


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Figure 0.2 IDA locations in the CBM Block


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Figure 0.3 One of the Initial Drilling Areas (IDA) and existing features

The well-site locations within the IDAs will be selected based on theidentification and understanding of numerous issues associated with bothminimizing environmental and social impacts associated with the wellsites aswell as access routes to the wellsite locations. Issues considered include: floodpotential; ecologically sensitive sites such as forest, community disturbance,areas of cultural / religious significance, land holdings and physical

constraints such as power lines.

The impact assessment considered the significance of a range of potentialimpacts following the implementation of various mitigation measures, wheresignificance is determined by its context (geographic extent), duration (short,medium, long term), intensity (magnitude) and type (adverse or beneficial)

Figure 0.4 A typical satellite imagery of IDA and its digitized equivalent


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E) P ROJECT D ESCRIPTION

E-1) Drilling and Testing of Wells

The project will involve the drilling and testing of wells for methaneproduction. Eight IDAs will have a corehole and some will also have atestwell. IDAs have been identified through detailed geological studies.

During Phases I and II, 8 exploration coreholes are planned. The average timeto complete each corehole is approximately 22 30 days. Coreholes will bedrilled with a combination of rotary/percussion and high speed diamondcoring technologies. The drilling rigs will be truck mounted.

Five testwells are planned during Phase I and up to 15 test wells in Phase II.The average time to complete each well is approximately 16-30 days. Testwellswill be drilled with a combination of percussion and rotary drillingtechnologies. In addition to the drilling rig, a service rig will also be deployedto conduct the well testing program for evaluating the CBM flow potential. Anumber of tests will be conducted by injecting water and nitrogen into thetestwells followed by production testing of these wells, with the aim ofassessing the gas producibility of the coal bed.

Corehole sites (wellsites) will be approximately 75m x 60m in dimension, andthe testwell well pad site will be approximately 115m x 85m.

Figure 0.5 Typical truck mounted drilling rig to be used


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E-1.1) Facilities and Resources Required

Access to the wellsites within the IDAs will require the use of existing networkof roads and where no road exists, new temporary access roads will beconstructed.

Water will be required both during construction of the wellsites (about 400m3/well) and access roads and during drilling operations (about 45 m 3 and570 m3 for core hole and test well, respectively). Water will be sourced eitherfrom existing surface water, or new tube wells.

Chemicals and other substances (such as fuel oil etc) required for drilling andtesting of wells will be safely stored at wellsites.

E-1.2) Waste Generation

Water from the coal horizons will be extracted to liberate the coal bedmethane. It is estimated that the extracted water known as Produced Watermay be approximately 30 - 80 m 3/day/well.

Liquid and solid wastes will be generated during the drilling and testing ofwells. An inventory of all wastes will be developed and treatment anddisposal options will be followed that meet the regulatory requirements.

E-1.3) Project Investment

The investment during Phase 1 and Phase 2 of the Project is approximately USDollars 100 million.

E-1.4) Project Schedule

Phase I of the Project is expected to be completed in two years from the Projectcommencement date and Phase II is expected to be completed in two and ahalf years from the completion date of Phase I.

E-1.5) Expected Project Benefits

BP has several options to market the methane derived from a successfulexploration programme in the production phase of the Project, as it isanticipated that the demand for gas will grow significantly in India. As thephased exploration programme is undertaken, BP will assess the feasibility ofa number of options to supply potential markets for the gas.


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F) P RIOR P ERMITS R EQUIRED FOR THE P ROPOSED P ROJECT

The relevant regulatory approval/permit requirements for the CBM IndiaProject have been assessed as part of a Project regulatory review. A ProjectPermits register has been developed and is currently being implemented.

G) E NVIRONMENTAL AND SOCIAL B ASELINE

G-1) Environmental Baseline

G-1.1) Physical environmentThe western part of the CBM Block comprises low hills, gradually descendingto the alluvial plains in the eastern part of the CBM Block. The eastern part ismore suitable for agriculture. The geology of the region shows the occurrenceof diverse rock units ranging from Archaean hard rocks, Gondwana sediments(Permian to Jurassic in age) to sub-recent laterites and recent to sub-recentalluvium. Coal is found in the Permian Barakar Formation.

The CBM Block area is largely drained by Dwarka and Brahmini Rivers. TheDwarka flows close to the southern boundary of the CBM Block and brieflyenters in to the CBM Block at the south east corner. The CBM Block area has anetwork of irrigation canals in form of main and branch canals. These canalsare linked to the Dwarka and Brahmini Barrages.

Approximately 70% of the land in the Project area is classified as agriculturalland, which supports the main crops such as rice (paddy), wheat, and maize.Designated forest covers 3.5% of the CBM Block area. The remainingproportion is covered by settlements, stone mining and crushing areas andwater bodies.

Soil within the CBM Block is mostly sandy clay loam and loamy sand.Samples have been analysed across the CBM Block.

Surface water quality of the major rivers and water bodies has been observedto be moderate to good (at the sampling point). COD and BOD were wellwithin the desirable limits (IS Limits).

Groundwater quality at some places in the CBM Block is slightly alkaline.Total Dissolved Solids (TDS) in the groundwater was observed within thedesirable limit of 500mg/l at all the sampled locations except in an open welllocated in middle of the CBM Block. Fluoride in the CBM Block area wasobserved below 1.0mg/l (IS Limit for Drinking) except in an artesian wellwhich reported elevated fluoride concentrations of 1.81mg/l. Ironconcentration at some of the locations (middle and north of the CBM Block)was observed to be elevated above the desirable limit of 0.3 mg/l. All heavymetals, except zinc were observed below detection limits.


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Figure 0.6 A typical rice field

Figure 0.7 A stone crusher in the block

G-1.2) Ecology

No national parks or wildlife sanctuaries exist within the CBM Block.

The forest within the CBM Block and surrounding region are mainlyidentified as Dry Deciduous Forest (Sal dominated) type. The CBM Block hasboth the Reserved Forests (RF) and Protected Forests (PF). Masra, Jatla,

Bhatina, Ghaga are the reserve forests and Ganpur, Damra, Chandpur,Ranipur, Kasthagora, Chanda, Chandpur, Radipur, Kalaipahari, Maubelia arethe protected forests In the entire study area there were no records of rare and


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endangered plant species. Most of the observed plants were widelydistributed.

Most of the fauna species are common. Some of the mammalian fauna speciesare included in endangered and rare categories but none of them belonged toendemic categories. Of these three species belong to endangered category, andeight species to threatened category.

Figure 0.8 Sal forest in the CBM Block

G-1.3) Climate, air and noiseThe temperature of the area ranges from a minimum of 5.6C in December to

47.8C in May and June.

The average annual rainfall observed is 1388 mm. About 92% of the rainfall isreceived during the south-west monsoon from May to October.

Ambient air quality monitoring within the CBM Block was carried out ateleven locations during December March 2008. The results showed that mostparameters were within the National Ambient Air Quality Standards exceptSuspended Particulate Matter (SPM), Respirable Particulate Matter (RPM),and NOx. SPM was high at all sampling locations, while NOx was observed tobe high in areas close to stone crushing units.

Day and night noise level measurements were taken at locations within theCBM Block. Ambient noise levels in the CBM Block are within the prescribedlimits, which is 55 dB (A) for day time and 45 dB (A) for night time.

G-1.4) TrafficThe main NH-60 crossing the CBM Block carries heavy traffic mainlycomprised of heavy motor vehicles (HMV). HMVs comprised over 60% of allvehicles on the Rampurhaat Dumka road and a similar trend was observedon the road connecting Pachami stone crusher area. Trucks primarily carryingcrushed stone material use this road. Non-motorised vehicles also ply in


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G-2) Socio-economic Baseline

The District of Birbhum accounts for about 5 percent of the total area andabout 15 percent of the total population of the state of West Bengal. There are19 Community Development blocks in the district covering 2478 villages, fivestatutory towns and one census town. As per the Backward DistrictInitiative in the 10 th five year plan prepared by the Planning Commission ofIndia, the District of Birbhum has been classified as a Backward Area.

Most (more than 95 percent) of the population in the CBM Block is rural andlives in settlements located close to water bodies and agricultural fields. TheProject area has an average household size of five and an average populationdensity of around 530 individuals per square kilometer. This populationdensity however is mostly concentrated in nucleated and densely populatedpockets in villages/ areas close to administrative block headquarters/markets. There are approximately 70 revenue 1 villages within the CBM Block.

The Project area has a diverse religion profile, though Hindus are in amajority. The three administrative blocks have a high percentage of ScheduledCastes (SCs) and Schedule Tribes (STs) population. These groups comprise atleast 35-45 percent of the total population in the area.

In terms of gender development, the district/area is a poor performer, beingranked 14 out of 17 districts on GDI. The primary survey came across very fewwomen who hold influential positions in the villages of the Project area, likeelected leaders, teachers, and medical staff etc.

G-2.1) Land

Land holding patterns in the Project area are fairly similar across themouza/ villages. Large landowners are very few, and most households ownless than one hectare of land and fall in the marginal land holding category.

Typically the villages in the Project area are spread over an area ranging from80 to 700 hectares. Most of this area is dominated by privately ownedagricultural practices. The actual habitation area is small, constituting aboutfive to ten per cent of the total village area and is usually located in the centreclose to the paddy fields or water bodies.

The Project area has a complex pattern of land ownership and use. The systemof sharecropping referred to as bargadari2 exists in the area. There are bothregistered as well as unregistered bargadars.

1 The census uses the term village in regard to 'revenue village'. According to the census definition a village represents aparcel of land, the boundaries of which are defined and settled by revenue survey or by cadastral survey. A revenue villagemay consist of one compact habitation ( distinct cluster of houses with a local name where people live in compact and contiguousmanner ) or a number of habitations. One of the habitations may bear the name of the village itself. These habitations may beseparated from each other by a long distance ( sometimes over a number of kilometres).(1) 2 A Bargdar is a person who cultivates the land of other person (generally an absentee landlord) and in lieu gives acertain proportion of yield to the land owner (move this note to next page)


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G-1.3) Occupation and Livelihoods

Agriculture is the mainstay of the economy of the Project area, the threeadministrative blocks as well as the district. The farm sector employsapproximately 80 percent of the active and productive work force. The overallWork Participation Rate 1 (WPR) is around 50 percent. The WPR was found to

be higher among males as compared to the females.

In terms of primary occupation, the majority of the households is engaged inagriculture and related activities. A typical family in the Project area growsone/ two rice crops during the year and has one/two members who areengaged in other activities (farm and non farm for example agriculturallabour, work in mines/ quarry either in Chanda/Pachami or inMasra/Salbhadra area or in some local business unit for example shops orother business enterprise).

The average yield of rice is estimated at approximately 24 to 36 quintal (1quintal = 100 kilograms) per hectare for winter rice (paddy) and 48-60 quintalper hectare for summer rice (paddy) depending upon the quality of land,availability of water, cost and labour inputs etc.

Non farm-based livelihoods primarily consists of work in the stone crushingand quarrying sector with other employment being provided by governmentand temporary, seasonal or permanent employment in garages, shops, ricemills etc. Fishing is practiced on a small scale either in the small fish ponds/water bodies (locally termed daab, pukur ) in the village area or in the nearbyriver/ streams/ canals and was reportedly used mostly for householdconsumption.

Rearing livestock plays a very important role in the rural economy and isanother subsidiary source of household income in the Project area. A typicalhousehold in the Project villages has livestock including cow, ox, goat, pigs,buffalo and poultry which are used both for generating subsidiary income andto a lesser extent for household consumption. Forest based livelihood exits,though it is largely limited to collecting fuelwood and fodder.

G-1.4) Infrastructure

The health facilities in the villages in the Project area are thinly spread andeven the existing facilities suffer from poor equipment, accommodation, staffand medicines. Malaria had the highest prevalence across all the villagessurveyed. Other diseases reported from the survey villages (in decreasingorder) include tuberculosis, kala azar (black fever), respiratory diseases(including Asthma), jaundice and occupation linked diseases like skin

(2) 1 Workers Participation Rate (WPR) depicts the engagement of main and marginal workers in different occupations athousehold, commercial or agricultural level.


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ailments. Tuberculosis continues to be the major health problem in the areadespite attempts to limit its spread for over four decades.

Most villages have a primary school or a Sishu Shiksha Kendra (pre-primaryschool). Secondary schools are located in Gram Panchayats or larger villages,while colleges are concentrated in towns.

Generally brick and mud paved/unpaved road connects the villages to themain road. Many of these roads are not accessible by motor vehicle in themonsoon season.

The study area and the surrounding villages have inadequate infrastructureavailable for sanitation and no sewerage system is present. None of thevillages covered as a part of the field visit had a proper interconnectingdrainage/ sewer network.

Household electricity connections are common in the main village especiallyon the dense, nucleated and concentration settlements. Tube well, handpumps, ponds and open wells serve mostly to the needs of household waterconsumption.

There are no designated archaeological and heritage sites within the CBMBlock. However as is typical of rural Indian settlements, each village in theCBM Block has a number of cultural sites or sites of religious significance, liketemples, mosques, cremation ground, graveyard, revered trees etc. that arescattered across the CBM Block.

H) STAKEHOLDER MAPPING

The EIA process identified, mapped and consulted with a range ofstakeholders on which the Project could possibly have impacts, and who inturn could influence the Project. The objective was to understand stakeholderconcerns and opinions and, , to the extent possible, address this feedback inthe EIA as well as the relevant management plans. Key stakeholders identifiedand consulted with included:

Land owners, sharecroppers and other formal and informal users. Vulnerable groups including women, marginal farmers and landless

families; Village institutional stakeholders like the Gram Panchayat; Sansad;

Gram Unnayan Samiti; Panchayat Samiti, Political parties and others; Administrative district and block level officials; Other influential groups like NGOs, media, local business groups like

the stone crusher owners etc.

A detailed stakeholder consultation log is attached as Annex B of the EIAreport.


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Figure 0.9 Consultation with the stakeholder groups

I) I MPACT ASSESSMENT AND M ITIGATION

The EIA report presents an assessment of potential environmental and socialimpacts due to the proposed CBM Project. The CBM Project is separated intothe following four stages: a) Site Preparation, b) Construction, c) Drilling, andd) Decommissioning. The identified potential impacts then formed the basisfor the development of mitigations and management plans.

I-1) Air Quality

Potential emission sources include fugitive dust from earth works associatedwith site preparation and wellsite construction activities as well as fromconstruction traffic using local roads for site access; other sources include airemissions from power generators, flaring of gases and other activities duringdrilling and well testing; air emissions from vehicles; and heat radiation due totest flaring. All the anticipated air emissions other than fugitive dust would befrom the combustion of hydrocarbons. The parameters of concern are NO x,SO2, CO, particulates and non-methane hydrocarbons.

Owing to prevailing high particulate matter concentrations associated withstone quarrying and crushing operations (mainly in the western half of theCBM Block), potential impacts to ambient air quality include particulatematter.

A number of mitigation measures will be employed to minimize the effects ofthe Project on ambient air quality. Water sprinkling will be used wherenecessary to minimize the generation of dust along the access roads to thewellsites as well as at the wellsites themselves. This effort will concentrate onareas near settlements, isolated yet occupied dwellings, and areas holdinglivestock. Other proposed measures will include appropriate stack heights foremissions-emitting equipment, as prescribed by regulatory requirements.Equipment will only be used on an as-needed basis and will not be left idling

unnecessarily. All vehicles will be maintained properly and compliance withPollution Under Control (PUC) certificate will be observed.


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With the implementation of the above mitigations the impact of the Project onambient air quality is predicted to be minor in the vicinity of the wellsites. Forminimizing impact along the access roads, vehicle speeds will be restrictedand dust suppression measures will be followed.

I-2) Noise Quality

Activities that have a potential impact on noise quality include operations ofconstruction equipment, vehicular movement to and from the wellsite sites,and drilling activities.

It is expected that site preparation and wellsite construction activities willgenerate elevated noise levels locally for short durations. Also, drillingoperations include the routine running of equipment that will generateelevated noise levels locally. In addition, the passage of construction trafficthrough local villages will also contribute to noise levels in the vicinity. Thiswill be minimised by imposing speed restrictions on all project vehicles.

Mitigations such as acoustic enclosures on equipment and the use of soilberms to help attenuate noise sources will be implemented at wellsites toreduce the impact.

With the mitigations measures proposed, the impact significance on noisequality due to site preparation and wellsite construction and drilling activitiesis considered to be minor and no significant adverse environmental effectsdue to noise are expected .

I-3) Land and soil

Activities that impact land and soil include site preparation and wellsiteconstruction, off site road movement of project vehicles, drilling activities anddecommissioning of the Project site.

Potential impacts related to the above activities include soil compaction, soilerosion and run-off, and the local alteration of flood plain hydrodynamics;overflow and runoff of drilling mud from the containment pits over thewellsite to adjacent land.

Mitigation measures such as avoidance or minimization to the extent possibleof project activities during monsoon season (to the extent possible), forestareas, flood plains and sites near water bodies, provision of drains along theselected sites and proper management of construction and drilling wastes atsites will be implemented to minimise these potential impacts.

The significance of impacts on soil compaction and soil erosion have beenassessed to be minor, mainly due to the short term and localised nature of thedisturbances, as well as the fact that if any adverse effects do materialise, theycan be reversed. The impact of site preparation activities on flood plainhydrodynamics is predicted to be insignificant due to the small size of the


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construction footprint and the preferred timing of the construction activities(during the dry season). Equally, the nature and quantities of waste generatedare such viable options for safe disposal are available and hence the residualimpacts of waste disposal are predicted to be insignificant.

I-4) Groundwater

Potential impacts that could affect groundwater include drilling throughshallow and deep aquifers, pumping of produced water from coal seams,onsite storage and disposal of wastes, disposal of produced water and closingof wells and decommissioning.

Mitigations such as operational control and monitoring of Project activitieswill be executed to ensure impacts are minimised.

The impact of site preparation and construction activities on groundwaterquality and quantity is assessed to be insignificant due to the proposal to onlyuse sustainable sources of supply and the very low likelihood that siteactivities will lead to any uncontained, subsurface contamination. The impactof drilling on local water quality is predicted to be insignificant due to thenature and quantities of materials that will be used on site, the proposedstorage and handling procedures, and spill response measures that will beenforced. The effects on water availability are predicted to be minor for thereasons noted above for site preparation. Owing to the deep-seated origin ofproduced water, it is considered unlikely that surface aquifer sources will beaffected as a result of well testing. Proposed monitoring activities will ensurethat any unexpected variations to this prediction will be detected and actionsmodified accordingly.

I-5) Surface Water

Potential impacts on surface water include change in local drainage patternand hydrology and deterioration of quality due to disturbance to soil layers,mobilising of heavy vehicles, onsite spillage and disposal of waste andproduced water.

Mitigations such as operational control and monitoring of Project activitieswill be executed to ensure impacts are minimised.

Impacts on surface water quality are predicted to be minor and changes indrainage pattern and hydrology to be insignificant. This is due to the initialsite considerations, including the design and operation of on-site wastestorage , the use of disposal facilities such as mud pits and waste watertreatment systems, and to maximise beneficial use of the water wherepossible.


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I-6) Ecology

Potential impacts on ecology include clearing ground cover at wellsitelocations and construction of new access roads, air and noise emissions at locallevels, construction traffic and restoration of sites.

The proposed project activities are planned to be kept outside the identifiedreserve and protected forests, therefore, loss of forest by virtue of conversionof forest land for non forest purposes is not envisaged.

Predicted impacts from site preparation and construction activities as well asdrilling are assessed to be insignificant.

J-1- Land and land use

Land will be either temporarily accessed or purchased from willing owners.For phase I and II, up to approx 20 hectares of land will be required for all

project activities.

Potential impacts on land may arise out of a temporary change in land use,loss of land for landowners and reduction of land value in the long term.Some of these could potentially have impacts on livelihoods. The scale of theseimpacts is however limited as the duration of project activities will be shortand area of land required is small.

Compensation to land owners and users will take into account loss of incomedue to CBM operations.

Impacts on land use and holding patterns are assessed to be of minorsignificance.

J-2) Livelihoods

Potential impacts on livelihood due to loss of land and crops (even thoughtemporary) during the drilling period, may arise. In the case of testwellsbecoming viable for future phases of the Project the potential impacts on theland owners could be long term. Compensation to land owners and existing

users will then be made on the basis of replacement value.

J-3) Community

The rural communities living in and around the construction and wellsitesmay face the impacts of an influx of outsiders looking for employment andbetter wages. This can have socio-cultural impacts as well as communityhealth impacts. However the scale of the Phase I and II operation is relativelysmall and is unlikely to result in significant immigration. Additionally, theProject will encourage contractors to deploy local staff where practicable.

Information on the Project feedback mechanism will be disseminated in thel l i i


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K) R ISK ASSESSMENT

The risk assessment associated with initial planning of CBM Project identifiedwell blow out during drilling/coring operations to be a potential majorhazard. However, the well blow out frequency was determined to be low andthe event out come is confined to within the wellsite (as established bymodelling) and would not therefore impact the community (outside thefenceline). Other hazards are associated with lifting equipment and vehicleand driving safety. The risks from these events will be mitigated by strictadherence to safety rules and procedures.

The key principles of emergency response and disaster management areoutlined.

A fully developed emergency response plan and disaster management planwill be available prior to start of the Project for necessary actions in case of anyemergency.

L) M ANAGEMENT AND M ONITORING

The purpose of developing and implementing an E&S management system isto ensure that the principles, standards and requirements (collectively referredto as project E&S commitments) are met.

The impacts and associated mitigation measures identified through the EIAprocess will be implemented and managed through two distinct phases:

Design Findings and recommendations from the EIA process (andassociated assessments) are captured in the design process. Wherepossible, identified mitigation measures are incorporated directly into thedesign plans. Where it is not possible to design out impacts, therequirements for mitigating the impacts are carried through to the Projectmanagement plans. For the CBM Project this primarily consists ofoptimising the wellsite location and access road route selection tominimise overall environmental and social impact

Project Execution BP will develop a HSE management system andContractor(s) will develop HSE plan(s) that incorporates the mitigationmeasures required to manage the impacts of their activities. Mitigationmeasures will be taken from the Management Plans included in thisdocument.

A set of eleven specific Management Plans (MPs) have been developed tomanage key issues that have been identified through the environmental and

social assessment process: pollution prevention, waste


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produced water, traffic, cultural heritage and chance finds, construction and decommissioning, ecology, land,

employment and procurement, community feedback, stakeholder engagement

The overall responsibilities for the proposed CBM project will be with BP (theProject proponent). BP will ensure that all project personnel and contractorsrepresentatives understand BPs policies, programmes and contractual terms,management and monitoring requirements and ERP (emergency responseplan) and DMP (disaster management plan).

Environmental and social awareness programmes will be implemented toensure that personnel are aware of environmental and social issues and theirresponsibilities related to these issues.

Coordination of project activities will be undertaken as required withauthorities such as Birbhum district authority, CBM Block and VillageAdministration, Land and Land Reforms department, Irrigation department,Ground water authority, Department of Forest and Environment, West BengalPollution Control Board, Ministry of Environment and Forests, DirectorateGeneral of Hydrocarbon (DGH), and Director General of Mines and Safety

(DGMS).

The Project will implement a monitoring plan to ensure that all sites willcomply with the commitments in accordance with the MPs. Monitoring of theenvironmental and social effects of the Project will enable the effectiveness ofthe mitigation measures to be determined by identifying the gap and takingpreventative and corrective action.

Project reporting will be undertaken to agencies like WBPCB and MoEF as perthe regulatory requirements.

BP will ensure that the CBM Project is operated in a manner that conforms tothe legal, regulatory and policy objectives. All the necessary permits andlicenses will be taken prior to Project operations.

CONCLUSION

The draft EIA study has concluded that the main issues are related to groundand surface water quality, air quality and vehicular movement. These issueshave been appropriately addressed in the various management plans. In

addition, input from the public consultation exercise will be taken intoaccount in the preparation of the final EIA report. Upon finalization of EIA

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