EIA Kotri North Block F01 - epasindh.gov.pk tech/EIA Kotri North Block.pdf · OCTOBER 2019 ES-5 HPK development well. Each proposed well will be drilled using a conventional land

Halcrow Pakistan (Pvt) Limited 3rd Floor, Nawa-e-Waqt House, Mauve Area

Sector G-7/1, Zero Point, Islamabad, Pakistan tel + 92 51 220 3451 fax + 92 51 220 3462

www.halcrowpk.com

Environmental Impact Assessment for Exploration and Associated Development Activities in Kotri North Block (E.L. 2568-21), Sindh

Document: 500024.BZ.EIA.F01 October 2019

EIA for Exploration and Associated Development Activities in Kotri North Block, Sindh

OCTOBER 2019 HPK

Document History

‘Environmental Impact Assessment for Exploration and Associated Development Activities in Kotri

North Block (E.L. 2568‐21), Sindh’

This document has been issued and amended as follows:

Version Date Description Created by Verified by Approved by

01 17/10/19 1st Draft AAA AQA AQA

02 23/10/19 Final AAA AQA AQA

AAA: Arslan A. Asghar

AQA: Abdul Qayyum Aslam


OCTOBER 2019 ES-1 HPK

Executive Summary

ES.1 Introduction

This report presents the findings of an Environmental Impact Assessment (EIA)

carried out by Halcrow Pakistan (Pvt) Limited for the proposed exploration and

associated development activities in Kotri North Block (E.L. 2568‐21) by United

Energy Pakistan Limited (UEPL) which lies within geographical jurisdiction of Sindh

province. A key map showing the location of Kotri North Block is presented as Figure

ES‐1. This EIA has been prepared in conformance to the requirements of the Sindh

Environmental Protection Act 2014, the Sindh Initial Environmental Examination and

Environmental Impact Assessment Review Regulations, 2014 and the Pakistan

Environmental Assessment Procedures, 1997.

The EIA report explicitly covers exploration and associated development activities in

the entire spread of Kotri North Block. These activities range from 2D/3D seismic

surveys, drilling of exploration/development wells, laying of flow line/s from

producing wells to the hydrocarbons gathering system/processing facility,

establishment of processing facilities e.g. EWT or CPP, up‐gradation/modification of

existing facilities with associated civil and engineering works e.g. construction of

access track/s, residential camp/s, construction of well site/s etc. and finally

decommissioning and site restorations. Proposed project activities will be commenced

with 2D/3D seismic survey and based upon the aforementioned seismic data

acquisition and its interpretations, UEPL will plan to drill wells at the most certain

perspective locations as part of exploration/development plan. After the successfully

drilling at any proposed well location and in case of discovery, flow line/pipeline will

be laid from each well to the new/existing hydrocarbons gathering and production

system.

The proposed 2D/3D seismic surveys will be carried out in the entire spread of Kotri

North Block (hereafter also referred as the ‘project area’ in the later sections of the

report) however, location of the seismic survey/s is not finalized yet. Similarly, the

exact location of exploratory/development wells and alignment of flow line/s is not

available at this stage either. The exact location of wells will only be made available

after proposed seismic data acquisition and its interpretations by United Energy

Pakistan Limited. Furthermore, depending on the drilling results, alignment of flow

line/s will be finalized. Likewise depending on the need basis, location of

hydrocarbons processing facility will be finalized and executed accordingly. Therefore,

this EIA report is based on the fact that United Energy Pakistan Limited will submit

the Project Initiation Report (PIR) or Activity Initiation Report (AIR) for each planned

activity to Sindh Environmental Protection Agency (for information) prior to the start

of each aforementioned activity in the project area.



The objective of exploration and associated development activities is to explore for

potential hydrocarbons reserves in the prospective formations identified during

previous Oil & Gas exploration activities in the region particularly in the leased area.

ES.2 Objectives of the EIA

The objectives of the Environmental Impact Assessment (EIA) are to:

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

identification of environmental sensitive areas and develop a baseline of its

existing environmental and socioeconomic conditions;

Identify and investigate all impacts of the proposed exploration and associated

development activities on the physical, biological and socioeconomic environment

of the project area;

To propose mitigation measures that would help UEPL in conducting the

exploration and development activities in an environmentally sustainable manner;

To uncover the construction and operational phase impacts up to

microenvironment levels in which project is proposed to be sited; and

To develop an Environmental Management Plan (EMP) that would assist UEPL in

the effective implementation of the recommendations of the EIA.

ES.3 The Project Proponent

United Energy Pakistan Limited, UEP Alpha Limited and UEP Beta GmbH collectively

known as UEP (UEP Alpha and UEP Beta were previously known as OMV Maurice

Energy Limited and OMV (Pakistan) Exploration GmbH) are subsidiaries of United

Energy Group (UEG), an energy company listed on the Hong Kong Stock Exchange.

UEP is the largest foreign oil & gas exploration and production (E&P) company in

Pakistan, and have been contributing significantly in reducing Pakistan’s dependency

on oil & gas imports through indigenous hydrocarbon production.

UEG’s asset has a rich heritage, starting nearly four decades ago when an American

E&P company, Union Texas Pakistan, initiated operations in Khaskeli, Badin. Since

then, this asset has undergone several changes and a shift in ownership a number of

times. Acquisition of British Petroleum’s assets by UEG was the first venture in

Pakistan and since then UEG has made significant investments in the business,

resulting in rapid growth. UEG’s onshore concessions span across 20,000 square

kilometers and are spread across Sindh and Balochistan provinces.

UEP is conscious of environmental footprint and work diligently to ensure that no

harm is caused to anyone involved in or impacted by their activities. UEP not only

comply with all applicable laws related to Health, Safety and the Environment (HSE)

but also have a set of internal policies in place to minimize the environmental impact

of their operations.

In coordination with the government, communities and non‐governmental

organizations, UEP has invested in sustainable social investment projects in the areas



where operating. CSR interventions have brought a positive impact in the lives of local

communities by enhancing access to technical training, creating opportunities for

sustainable income generation and providing quality education and healthcare

services. UEP has invested in the alternative energy sector. UEG (parent company) has

also invested in a wind energy project located in the Jhimpir wind corridor in the

Sindh province. This project was one of the 14 top priority projects of the China

Pakistan Economic Corridor (CPEC).

ES.4 Kotri North Block (E.L. 2568-21) & Project Area

Kotri North Block (E.L. 2568‐21) is located in geographical jurisdiction of Jamshoro,

Matiari and Hyderabad districts of Sindh province with a total area coverage of

approximately 1,397 square kilometers (km2). Out of total covered area of the block

district Jamshoro contributes the major part i.e. 1,133.5 km2 whereas, district Matiari

shares approx. 257 km2 and district Hyderabad contributes about 6.6 km2 (see Figure

ES‐2). Taluka wise distribution of abovementioned districts is provided in table below:

No. District Taluka Area Coverage (km2)

1. Jamshoro Kotri 442

Manjhand 691.5

2. Hyderabad Hyderabad 6.5

3. Matiari

Hala 210

Matiari 4

Saeedabad 43

United Energy Pakistan is operator of the block and holds 50% working interest. Other

joint venture (JV) partners include Pakistan Petroleum Limited (PPL) and Asia

Resources Oil Limited (AROL). PPL and AROL holds 40% and 10% working interest

in the block respectively.

Kotri North Block (E.L. 2568‐21) encompass several forest protected areas. There are

about 28 reserve forests (all of them are small sized) are falling in the geographical

jurisdiction of the Block (E.L. 2568‐21). These reserve forests includes; Kunar Rishal,

Keti Dallu, Nur Keti, Drabo, Manjhand, Keti Khasai, Unarpur, Rudhapur, Rishal,

Nural Abad, Racho Khanot, Pako Bhanot, Butho, Ranno, Rajri, Salaro Ghotana, Lakha,

Khasai, Ghotana, Murid Rais, Sekhat, Matiari, Miana, Hatri, Muhammad Khan, Bada,

Shah Bukhari and Railo Bada. These reserve forests which were once pristine riverine

forests, now mostly are under cultivation. Location of forest protected areas is also

shown in Figure ES‐2.

ES.5 The Proposed Project

The entire leased area spreads over approximately 1,397 km2 and lies in Jamshoro,

Matiari and Hyderabad districts of Sindh province. The EIA report explicitly covers

exploration and associated development activities in the entire spread of Kotri North

Block. These activities range from 2D/3D seismic surveys, drilling of exploration/

development wells, laying of flow line/s from producing wells to the existing

hydrocarbons gathering system/processing facility, establishment of processing



facilities e.g. EWT or CPP, up‐gradation/modification of existing facilities with

associated civil and engineering works e.g. construction of access track/s, residential

camp/s, construction of well site/s etc. and finally decommissioning and site

restorations.

Proposed project activities will be commenced with 2D/3D seismic survey and based

upon the aforementioned seismic data acquisition and its interpretations, UEPL will

plan to drill wells as part of exploration/development plan. After the successfully

drilling at proposed well location and in case of discovery, flow line/pipeline will be

laid from each well to the new/existing hydrocarbons gathering and production

system over the period of three years. Detailed proposed project activities will include

but not limited to be are listed below:

Seismic activities (2D and 3D);

Well sites preparation & construction activities;

Drilling of exploration, development and water injection wells (no new water

injection well will be drilled only plugged & abandoned (P&A) well will be used

for the purpose);

Surface facilities development at drilled well sites including EWT;

Laying of flow lines from producing wells to CPP/Gathering hub;

Laying of flow lines from CPP/Gathering hub to Point of Delivery (POD);

Development of early production, production and testing facilities which will

include plant construction and operations;

Development of remote facilities;

Up‐gradation/Modification of existing facilities;

Relocation of existing facilities e.g. decommissioning of plant equipment and

relocation to other location within project area;

Construction of access roads & residential camps;

Decommissioning of surface facilities (well sites/plant sites); and

Sites restoration.

The proposed 2D & 3D seismic data acquisition will be carried out using a

combination of vibroseis and dynamite technologies. The objective of the seismic

survey is to explore the subsurface in the area to identify hydrocarbon laden

formations. For seismic survey a base camp with fly camp (if required) will be

established to house the seismic crew followed by seismic activity and finally

restoration of seismic lines and base camp/fly camp upon completion of survey area to

original conditions.

Drilling of each well will start with the construction of the access road, rig camp and

well site for each proposed location. This will be followed by drilling of exploratory or



development well. Each proposed well will be drilled using a conventional land

drilling rig. A specialized waste management system using Hi‐G dryers and

centrifuges will be installed on the land drilling rig for better management and

disposal of drilling wastes. This will also help in reducing the water requirements

during drilling and managing the size of wastes pits at each proposed well location.

Depending on the drilling results (success or failure), abandonment, completion or

suspension of the well and site restoration. Furthermore, in case of discovery of

hydrocarbons at any of the proposed well locations, laying of flow line/pipeline from

wells to the hydrocarbons gathering/processing facilities and tie‐in/wellhead works

will be carried out.


North Block however, location of the seismic survey/s is not finalized yet. Similarly,

the exact location of exploratory/development wells and alignment of flow line/s is not









of each aforementioned activity in the leased area of Kotri North Block.

ES.6 The EIA Methodology

Various steps undertaken in the EIA preparation included sharing of ToRs with key

stakeholders; understanding of the proposed operation/s; review of legislations and

guidelines; EIA scope and methodology; collection of secondary data including

physical, biological & socioeconomic environment and heritage aspects; field data

collection; stakeholder consultations; review of alternatives; impact identification;

recommendations for mitigation and monitoring measures; development of

environmental management plan (EMP) and reporting.

Field survey for EIA study was carried out by a team of environmentalist, wildlife

expert, botanist and sociologist/gender specialist in last week of August, 2019. Field

data collection also included ground trusting of available secondary information.

Secondary information was collected from UEPL, in‐house sources like previous

environmental studies in the region in addition to respective District Census Reports

(DCRs). Applicable environmental assessment procedures prepared by the Pakistan

EPA were followed in the preparation of this EIA.

ES.7 Biological Resources

Kotri North Block (E.L. 2568‐21) is predominantly located in hilly, stony and sandy

plains followed by cultivable land & agricultural fields. Apart from them, there are



two other important biological habitats which includes Indus River, irrigation network

& associated marshes and wasteland/fallow lands. During the field visit for EIA a total

of 128 floral species belonging to 37 families, 101 birds, 20 mammals and 20 reptiles

were recorded from entire stretch of Kotri North Block.

Out of total 101 recorded birds, 18 species have protected status under the provision of

Sindh Wildlife Protection Ordinance, 1972 which include some ducks, raptors, egrets

and herons. Out of total recorded species 3 are on IUCN Red List, 12 migratory species

are on CMS and 20 included on CITES appendices having international demand for

trade. Out of total recorded mammals, three species are of global significance

including Fishing cat, Hog deer and Indian pangolin.

ES.8 Impacts and Mitigations

The EIA covers potential effects of the proposed project activities in the Kotri North

Block. Potential impacts on the physical, biological, socioeconomic, archaeological and

cultural environment that may arise from exploration and associated development

operation and the mitigation measures that will be adopted to reduce or minimize the

impact have been assessed and are summarized in Table ES‐1. Overall, the proposed

exploration activities will have positive impacts on the local communities of the area.

ES.9 Environmental Management Plan

For the effective implementation and management of mitigation measures, an

Environmental Management Plan (EMP) has been prepared which meets the

requirement of the Sindh Initial Environmental Examination and Environmental

Impact Assessment Review Regulations, 2014 and the Pakistan Initial Environmental

Examination and Environmental Impact Assessment Review Procedures, 2000.

The EMP provides a delivery mechanism to address potential impacts of proposed

project activities, to enhance project benefits and to introduce standards of good

practices in all project related activities. The EMP has been prepared with the objective

of:

Defining legislative requirements, guidelines and best industry practices that

apply to the proposed project activities;

Defining mitigation measures required for avoiding or minimizing potential

impacts assessed by the EIA;

Defining roles and responsibilities of the project proponent and the execution

contractors; and

Defining requirements for environmental monitoring and reporting.

ES.10 Conclusion

The EIA has fully examined the proposed project activities, the background

environmental conditions of the project area and the environmental impacts likely to

arise from the proposed exploration and associated development activities. Overall,

the EIA report for exploration and associated development activities in Kotri North



Block (E.L. 2568‐21) has predicted that the project will comply with all applicable

environmental standards and legislations before and during the proposed exploration

and associated activities. This EIA has also demonstrated the acceptability of the

residual impacts from the project and the protection of the identified environmentally

sensitive resources. Environmental monitoring mechanism have been recommended

before and during the proposed operation, where necessary, to verify the accuracy of

the EIA predictions and the effectiveness of recommended mitigation measures.

Based on the above, this report concludes that there are no potential adverse

environmental impacts from proposed exploration and associated development

activities in Kotri North Block. Impacts of less significance can be mitigated to an

acceptable level by adequate implementation of the mitigation measures identified

and suggested, hence, no significant or unacceptable change in the baseline

environmental conditions will occur. Similarly, the operation will have a visible

positive impact on the socioeconomic conditions of the local residents and

significantly boost the economy of the area. Mitigation measures to help alleviating

potential identified impacts have been recommended and a project specific EMP has

been provided for implementation of these mitigation measures.



Table ES‐1: Summary of Potential Impacts and Mitigation

Potential Impact Sources Recommended Mitigation Measures

Changes in

landscape,

topography and

soil erosion

Land uptake &

clearing

Off‐road travel

Over‐speeding

Use of existing dirt

tracks

Poor compaction of

working sites

Total land uptake by the project facilities e.g.

operational camps, well sites, processing facility

and access roads will be kept to the minimum

required

All project facilities will be located in existing

clearings and on levelled land

Clearing of vegetation and disturbance to the

natural soils will be minimized

Cuttings of trees/bushes will be avoided

Access tracks to project locations will be gravel

topped and properly compacted

Land area requirements for new construction

camp/s (if required) and RoW of flow lines will be

kept to the minimum required

Topsoil of the RoW will be separately stored and

will be backfilled after proper compaction

Existing access roads shall be used as much as

possible and off‐road travel will be avoided

Vehicles speed will be maintained and monitored

Periodic trainings will be provided to drivers on

environmental sensitivity

Movement of equipment will be restricted to

work areas only

Seismic lines and access tracks in the undulating

plains and higher elevations will follow natural

contours as much as possible

Uncontrolled and unnecessary clearing, dozing,

excavations or quarrying, storage of construction

material etc. will be avoided

Photographs will be taken at the begning and on

regular intervals throughout the project activities

to monitor any changes in the landscape and

topography

Topography will not be altered by taking all

appropriate measures

Soil and water

contamination

Domestic wastes

Oily wastes

Clinical waste

Construction wastes

Produced water

Drilling mud and

cuttings

Cleaning and hydro‐

testing of flow lines

Sewage Treatment Plant (STP) shall be the most

preferred option for handling of black/grey water

under BATNEEC/BAT, but in case of

unavailability of STP, septic tank and soak pits

shall be provided

Project related facilities will be setup at an

appropriate distance from the nearby settlements

Septic tanks and soak pits at 300 m from water

resources e.g. local water wells or hand pumps




Disposal of wastes according to waste disposal

procedure on regular and strict basis

Soak pits to be properly covered to avoid surface

runoff water

Sprinkling of untreated wastewater will not be

allowed

No solid waste will be disposed of in the field

Burning of waste will not be allowed

Municipal combustible, non‐combustible and

hazardous wastes will be handed over to

approved contractor

Restoration of sites including septic and soak

system according to restoration protocols

Temporarily store clinical wastes at site and hand

it over to approved waste contractor for safe

disposal

Washing of vehicles in designated areas within

the campsites

Checking of vehicles and fuel tanks for fuel or oil

leaks

Concrete pad, bunded area and proper marking

for all fuel tanks

Disposal of all spills including contaminated soil

according to waste management protocol

At the time of seismic restoration all pin flags,

signs and refuse from seismic lines will be

removed

The drill cuttings and water based mud will be

disposed into a pit lined with an impermeable

HDPE liner

Produced formation fluids during testing will be

flared along with the gas or collected inside the

lined waste pit at the well sites or processing

facility

Waste pits at the well sites will be lined with an

HDPE liner

Drill cuttings and mud pits at the well sites will

be at a minimum distance of 300 m from local

water resource

All other waste pits or enclosures at least 300 m

from local settlements and local water resources

Proper fuel and oil transfer operations

Evaporation pit will be built at a distance of 300 m

(HDPE lined) from local water sources




Spill prevention and contingency plan will be

developed and implemented

Storage of chemicals on brick masonry pads with

periphery drains

Hydro‐testing of flow line will be performed

following approved procedures, a purpose built

pit will be used for collection of wastewater from

the activity

Climate and

ambient air

quality

Equipment

Machinery

Vehicles

Maintenance of generators, equipment and

vehicles to keep them in good working condition

Adopt best management practices to minimize

the course of any segment of the proposed project

Regulation and monitoring of vehicles speed

Locate rig site and campsites 300 m away from

the community

Minimize dust emissions due to road travel by

regulating vehicles speed and watering of the

access track (where required)

While selecting routes of access track maintain a

reasonable distance from communities. Preferably

access tracks passing through communities will

be avoided

If unavoidable a speed limit of less than 30 km/hr

will be observed on the section of the road

passing through the community

Emissions should comply national and provincial

standards wherever applicable

Construction of burn pits will not be allowed

Flare pit will be kept downwind at the well site

and processing facility and at least 300 m from the

nearest community

The duration of flaring during well testing and

production phase will be kept to the minimum

required

Sand blasting will be carried out under contorlled

condition to avoid any dust emission

Noise pollution Equipment,

machinery and

vehicles

It shall be ensured that generators, vehicles and

other potentially noisy equipment used are in

good working condition

Well sites, campsites and production facility will

be located 300 m away from nearest communities

The use of horns by project vehicles shall be

minimized. The use of pressure horns shall not be

allowed




Movement of all project vehicles and personnel

shall be restricted to within work areas only

Preferably, generators will be kept within

enclosures to minimize dispersion of noise

Water

abstraction

All activities

requiring water

Water from wetlands/dhands or other surface

water bodies e.g. canals etc. will not be used for

the proposed project

Water to be used only from local wells or UEPL

may install its own water wells after ensuring the

available capacity at the local tube well/water

well (safe yield minus local demand) is at least

50% greater than the project demand

Record water consumption for each project

component

Adaptation of water conservation policy and

avoid water losses

The use of brackish water will be maximized

wherever possible

Install new water well at 300 m from existing local

wells and designed to abstract water from deep

aquifer

Utilization of water resources that are in

possession of local owners shall be compensated

as per mutual agreed terms

Abstract water from sources recommended in the

EIA report

Blockage of

natural drainage

Construction

activities

Area around the well sites and all campsites shall

be landscaped to avoid blocking of natural

drainage

Causeway crossings and pipe culverts will be

provided at all stream crossings to avoid blocking

of natural drainage

Uncontrolled clearing, dozing, excavations or

quarrying, storage of construction material etc.

will be avoided

Clearing of

vegetation and

loss of habitat

Land uptake and

clearing

Off‐road travel

Minimize land uptake for proposed project

activities

Access tracks will be properly compacted at the

time of construction and afterwards

Periodic training to drivers on sensitivity of

environment

Avoid unnecessary damage to vegetation

All operation based camp/s will be setup in

existing clearings and levelled land outside the

boundary of forest protected area




Apply good management practices

Movement of project personnel will be restricted

to working areas only

Avoid clearing of trees or even tall shrubs

Prohibit use of local wood for cooking or heating

purposes

Minimize off‐road travel

Vehicles speed will be regulated and monitored

During proposed seismic operation clearing of

vegetation will be minimized by minimizing the

width of the vibroseis tracks, minimizing the

preparation of new access tracks and keeping the

width of new access tracks to the minimum

required

Blasting, construction or drilling activities will not

be performed in Indus River

Crew personnel while working along seismic

lines will concentrate within a corridor of 4.5 m

Topsoil of the RoW for flow lines will be

separately stored

This topsoil of the RoW will be backfilled after

proper compaction ensuring regeneration of

vegetation

Disturbance to

wildlife

Noise generated from

project activities

Movement of

personnel and

vehicles

Lights used at the

project facilities

Clearing of vegetation

Prohibit hunting, killing, fishing, trapping,

feeding or harassment to wildlife

Activities in the core habitats of protected species

shall be avoided as much as possible

Proposed activities in the protected areas shall be

completed in the shortest possible time

Awareness trainings for contractors and crew

personnel prior to engagement in the operation

Minimize vegetation clearing and land uptake

Movement of project personal will be restricted

Do not dispose of food waste in open

Maintain vehicles speed on access road to avoid

incidental mortalities of reptiles

Lights used at the campsites will be kept to the

minimum required

Adhere with minimum distances specified in the

EIA and EMP for entire course of the operation

All mitigation measures listed in the EIA/EMP to

minimize noise levels, dust emissions, exhaust

emissions and waste generation will be adhered

to




Construction activities during night hours will be

prohibited. However, in case of urgency, night

activities will be allowed after reassessing the

impact of activity on the environment through a

risk assessment or change mangement statement

and specifying additional mitigation measures if

required

Blasting, construction or drilling activities will not

be performed in Indus River

Night traveling will only be allowed when

absolutely necessary or in case of emergency only

Impacts of the individual projects on wildlife will

be monitored by independent monitoring teams

Socioeconomic,

archaeological

and cultural

environment

Acquisition of lands

for project facilities

Exploitation of local

water sources

Improper disposal of

wastes

Dust and exhaust

emissions

Noise from project

facilities

Movement of vehicles

on access tracks close

to the communities

Protect local sources of drinking water

Sprinkling of water to avoid dust emission

wherever required

Re‐routing or bypass to all major settlement

Training will be given to drivers on safe driving

Strict compliance on UEPL’s HSE guidelines

Priority in employment to local residents living

close to the project location as per the local

regulations and company’s competency criteria

Regulation and monitoring of vehicles speed

The rig sites and campsites will be located at a

minimum distance of 300 m from communities

Land acquisition and distribution of

compensation must be transparent and on fast

pace

Apply best management practice in the entire

course of operation

During project, links with local community will

be maintained

Use of local wood as fuel will be prohibited

Maintain community complaints register

Cultural norms will be respected

Pay proper and justified compensation for land

and water being utilized in the entire operation

Dispose of all wastes following the requirements

of the EIA

Use local water sources only after complying with

the relevant EIA/EMP requirements

Maintain appropriate offsets from sites of

religious, cultural or archaeological significance if

encountered

Lat :25° 27' 32.436" NLong:68° 36' 29.484" E

Lat :25° 41' 38.688" NLong:68° 33' 20.196" EKotri

Hala

Thatta

Matiari

Hyderabad

Latifabad

Qasimabad

Tando Adam

Jamshoro

Matiari

Thatta

Hyderabad

Sanghar

68°32'0"E

68°32'0"E

68°24'0"E

68°24'0"E

68°16'0"E

68°16'0"E

68°8'0"E

68°8'0"E

68°0'0"E

68°0'0"E26

°0'0

"N

26°0

'0"N

25°5

2'0

"N

25°5

2'0

"N

25°4

4'0

"N

25°4

4'0

"N

25°3

6'0

"N

25°3

6'0

"N

25°2

8'0

"N

25°2

8'0

"N

25°2

0'0

"N

25°2

0'0

"N

LegendBlock Boundary Reserve Forest (SOP) Tehsil Boundaries

District Boundaries

·0 2.5 5 7.5 10 12.5 15 17.5 Km

Halcrow Pakistan (Pvt) LimitedUnited Energy

Pakistan

Fig ES-1: Key Map of Kotri North Block

Project:EIA for Exploration and Associated Development Activities in Kotri North Block (E.L. 2568-21)

h

h

h

h

h

Goth Rais Ghulam Ali Mari

Goth Tando Syed Khan Mitho

Graveyard / Shrine

Sindh Agriculture University

Graveyard

Graveyard

Goth Akro

Graveyard

Graveyard

Graveyard

Goth Tajpur

Goth Salaro

Goth Jaitharo

Goth Aliabad

Goth Haji Ishaq

Goth Karim Deno

Goth Tadri Mori

Goth Haji Shabu

Goth Khuda baksh

Goth Sufan Bacho

Goth Hayat Bhatti

Goth Bachal Dehta

Goth Bakhshia Marri

Goth Suleman Barejo

Graveyard on Highway

Goth Bego Khan Mirjat

Goth Sayen Dino Malah

Goth Mehram Khazkheli

Goth Gulshan e Shahbaz

Goth Darya Baig Mughal

Dargah Dado Khamiso Fakir

Shrine Baba Allah Bakhsh Jilani

Dargah Syed Muhammad Shah Bukhari

Goth Wadero Misri

Kotri

Hala

Matiari

Hyderabad

Thatta Latifabad

Tando Adam

Qasimabad

Tando Allahyar

Jamshoro

Matiari

HyderabadThatta

Sanghar

68°30'0"E

68°30'0"E

68°20'0"E

68°20'0"E

68°10'0"E

68°10'0"E26

°0'0

"N

26°0

'0"N

25°5

0'0

"N

25°5

0'0

"N

25°4

0'0

"N

25°4

0'0

"N

25°3

0'0

"N

25°3

0'0

"N

25°2

0'0

"N

25°2

0'0

"N

·0 2.5 5 7.5 10 12.5 15 17.5 Km

Halcrow Pakistan (Pvt) Limited

Fig ES-2: Project Area MapProject:EIA for Exploration and Associated Development Activities in Kotri North Block (E.L. 2568-21)

LegendBlockBoundary/ProjectArea

!C Existing Well Site

×[

Gas CompressionFacility

"" Community

×k Graveyard

!a Power Plant

Shrine

¥B¢ University

hWater SamplingLocation

Nationla HighwayReserve Forest(SOP)

Tehsil BoundariesDistrictBoundaries United Energy

Pakistan


OCTOBER 2019 i HPK

Contents

Executive Summary .......................................................................................................... ES-1

1 Introduction ................................................................................................................1

Environmental Impact Assessment ................................................................................... 1

The Project Proponent ........................................................................................................ 2

Kotri North Block (E.L. 2568-21) & Project Area ............................................................... 2

The Proposed Project .......................................................................................................... 3

Proposed Environmental Approval and Management System ....................................... 5

EIA Consultants ................................................................................................................... 6

Reporting .............................................................................................................................. 6

Contact Details ..................................................................................................................... 7

2 EIA Scope and Methodology ................................................................................. 10

2.1.1 Scope of the EIA .................................................................................................................. 10

The EIA Team ..................................................................................................................... 10

The EIA Methodology ........................................................................................................ 10

2.3.1 Understanding of the Proposed Project and Review of Alternatives ................................... 10

2.3.2 Review of Policies, Legislation and Guidelines ................................................................... 10

2.3.3 Secondary Data Collection .................................................................................................. 10

2.3.4 Field Data Collection ............................................................................................................ 11

2.3.5 Community/Public Consultation ........................................................................................... 11

2.3.6 Impact Identification and Assessment ................................................................................. 11

2.3.7 Recommendations for Mitigation & Monitoring Measures ................................................... 12

2.3.8 Development of Environmental Management Plan (EMP) .................................................. 12

3 Legal Framework .................................................................................................... 15

Introduction ........................................................................................................................ 15

United Energy Pakistan Limited’s Corporate HSE Policy .............................................. 15

National Environmental Policy, Legislation and Guidelines ......................................... 15

3.3.1 National Environmental Policy, 2005 ................................................................................... 15

3.3.2 National Conservation Strategy, 1992 ................................................................................. 16

3.3.3 The Biodiversity Action Plan, 2000 ...................................................................................... 17

3.3.4 Provincial & National Environmental Legislations ................................................................ 17

3.3.5 National Environmental Guidelines ...................................................................................... 23

International Treaties and Guidelines .............................................................................. 24

3.4.1 International Treaties ........................................................................................................... 24

3.4.2 Relevant International Guidelines ........................................................................................ 27

International and National Environment & Conservation Organizations ..................... 29

3.5.1 International and National NGOs ......................................................................................... 29

3.5.2 Pakistan Petroleum Exploration and Production Companies Association (PPEPCA) ......... 30

4 Project Description ................................................................................................. 42

The Proposed Project ........................................................................................................ 42

Seismic Operation ............................................................................................................. 43

4.2.1 Line Permitting ..................................................................................................................... 43


OCTOBER 2019 ii HPK

4.2.2 Line Survey and Preparation ............................................................................................... 44

4.2.3 Data Acquisition ................................................................................................................... 44

4.2.4 Camps, Staffing and Supplies ............................................................................................. 46

4.2.5 Access and Transport .......................................................................................................... 46

4.2.6 Restoration and Waste Management .................................................................................. 47

Drilling Operation .............................................................................................................. 47

4.3.1 Proposed Project Activities .................................................................................................. 47

4.3.2 Project Schedule .................................................................................................................. 48

4.3.3 Construction ......................................................................................................................... 48

4.3.4 Rig Mobilization ................................................................................................................... 49

4.3.5 Drilling .................................................................................................................................. 50

4.3.6 Demobilization & Site Restoration ....................................................................................... 53

4.3.7 Produced Water Injection Well ............................................................................................ 53

Flow Line Laying & Tie-in/Wellhead Works ..................................................................... 53

4.4.1 Flow Line Laying Activities ................................................................................................... 53

4.4.2 Development of Surface Facilities ....................................................................................... 59

Hydrocarbon Processing Facility (GPF/CPP) ................................................................. 59

4.5.1 Construction/Establishment of Gas Processing Facility ...................................................... 60

Associated Development Activities ................................................................................. 64

Noise, Wastes and Emissions .......................................................................................... 65

4.7.1 Noise .................................................................................................................................... 65

4.7.2 Wastes and Effluents ........................................................................................................... 65

4.7.3 Emissions ............................................................................................................................ 66

5 Analysis of Alternatives ......................................................................................... 77

Introduction ........................................................................................................................ 77

Management Alternatives ................................................................................................. 77

5.2.1 No Project Option ................................................................................................................ 77

5.2.2 Alternative Site Option ......................................................................................................... 79

5.2.3 Timing of the Operation ....................................................................................................... 79

Technological Alternatives ............................................................................................... 79

5.3.1 Seismic Data Acquisition Technologies ............................................................................... 79

5.3.2 Drilling Technique ................................................................................................................ 80

5.3.3 Drilling Mud .......................................................................................................................... 81

5.3.4 Disposal of Drilling Wastes .................................................................................................. 81

5.3.5 Alternative to Flow Lines ...................................................................................................... 82

5.3.6 Gas Processing Facility ....................................................................................................... 82

5.3.7 Water Abstraction ................................................................................................................ 83

6 Background Environment ...................................................................................... 88

Physical Environment ....................................................................................................... 88

6.1.1 Physiography ....................................................................................................................... 88

6.1.2 Geology & Geomorphology ................................................................................................. 89

6.1.3 Stratigraphy ......................................................................................................................... 89

6.1.4 Soils ..................................................................................................................................... 90

6.1.5 Land Capability .................................................................................................................... 90


OCTOBER 2019 iii HPK

6.1.6 Petroleum Play .................................................................................................................... 91

6.1.7 Seismicity ............................................................................................................................. 91

6.1.8 Climate and Meteorology ..................................................................................................... 91

6.1.9 Ambient Noise & Air Quality ................................................................................................ 93

6.1.10 Water Resources ................................................................................................................. 94

Biological Environment ................................................................................................... 114

6.2.1 Data Sources ..................................................................................................................... 114

6.2.2 Protected/Sensitive Areas ................................................................................................. 114

6.2.3 Biological Habitats ............................................................................................................. 115

6.2.4 Baseline Conditions ........................................................................................................... 117

Socioeconomic Environment ......................................................................................... 147

6.3.1 Study Objectives ................................................................................................................ 147

6.3.2 Study Methodology ............................................................................................................ 147

6.3.3 Administrative Boundaries ................................................................................................. 148

6.3.4 Demographic Profile .......................................................................................................... 148

6.3.5 Economy of the Project Area ............................................................................................. 150

6.3.6 Gender Profile .................................................................................................................... 152

6.3.7 Development Needs .......................................................................................................... 153

6.3.8 Archaeological and Religious Sites ................................................................................... 153

7 Potential Environmental Impacts and Mitigations ............................................ 163

Physical Environment ..................................................................................................... 163

7.1.1 Changes in Landscape & Soil Erosion .............................................................................. 163

7.1.2 Soil and Water Contamination ........................................................................................... 167

7.1.3 Climate and Ambient Air Quality ........................................................................................ 174

7.1.4 Noise Pollution ................................................................................................................... 177

7.1.5 Use of Water ...................................................................................................................... 178

7.1.6 Blockage of Natural Drainage ............................................................................................ 181

7.1.7 Site Restoration ................................................................................................................. 181

Biological Environment ................................................................................................... 183

7.2.1 Clearing of Vegetation & Loss of Habitat ........................................................................... 183

7.2.2 Disturbance to Wildlife ....................................................................................................... 185

Socioeconomic, Cultural and Archaeological Environment ....................................... 189

8 Stakeholders Consultation .................................................................................. 194

Objectives of Stakeholders Consultation ...................................................................... 194

Community Consultations .............................................................................................. 195

Community’s Concerns & Reservations ....................................................................... 195

Other Stakeholders .......................................................................................................... 196

8.4.1 Deputy Director, Sindh Environmental Protection Agency, Karachi .................................. 196

8.4.2 Range Forest Officer, Sindh Forest Department, Hyderabad ............................................ 197

8.4.3 Deputy Director, Sindh Environmental Protection Agency, Hyderabad ............................. 198

8.4.4 Technical Officer, Directorate of Animal Husbandry, Hyderabad ...................................... 198

8.4.5 Chief Engineer, Irrigation Department, Hyderabad ............................................................ 199

8.4.6 Institute of Environmental Studies, Karachi University ...................................................... 200

8.4.7 Regional Chair, Commission on Ecosystem Management, IUCN ..................................... 201


OCTOBER 2019 iv HPK

8.4.8 Coordinator Marine Program, Worldwide Fund for Nature, Karachi .................................. 201

8.4.9 Other meetings .................................................................................................................. 202

Key Findings and Issues ................................................................................................. 202

9 Conclusion ............................................................................................................ 207

Appendices

Appendix A Environmental Management Plan A-1 Appendix B Environmental Monitoring Checklists B-1 Appendix C Environmental Aspects Register C-1


OCTOBER 2019 v HPK

List of Tables

Table 2-1: Impact Characteristics Criteria ................................................................................... 13

Table 3-1: SEQS for Municipal and Industrial Effluentsa ............................................................ 31

Table 3-2: SEQS for Industrial Gaseous Emissiona ................................................................... 33

Table 3-3: SEQS for Motor Vehicle Exhaust and Noisea............................................................ 35

Table 3-4: Sindh Environmental Quality Standards for Noise ..................................................... 35

Table 3-5: Sindh Standards for Drinking Water Quality .............................................................. 36

Table 3-6: SEQS for Ambient Air ................................................................................................ 38

Table 3-7: API Standard for On-site Burial of E&P Wastes in Unlined Pitsa, b, c ....................... 39

Table 3-8: LSO 29B Criteria for On-site Burial in Unlined Pits .................................................... 40

Table 4-1: Summary of Water Usage during Various O&G Project Activities ............................. 68

Table 4-2: Summary of Approximate Domestic Wastewater and Solid Waste ........................... 69

Table 6-1: Meteorological Data of Hyderabad District, 2009 – 2018 .......................................... 96

Table 6-2: Water Quality within Project Area ............................................................................ 102

Table 6-3: Ambient Noise Levels Monitoring ............................................................................ 103

Table 6-4: List of Vegetation Species found in the Project Area ............................................... 124

Table 6-5: List of Vegetation Species of Riparian Habitat (20 x 20m Quadrate) ...................... 131

Table 6-6: List of Vegetation Species of Riparian Habitat (2 x 2m Quadrate) .......................... 131

Table 6-7: List of Vegetation Species of Marshy/Wetland Habitat (20 x 20m Quadrate) .......... 132

Table 6-8: List of Vegetation Species of Marshy/Wetland Habitat (2 x 2m Quadrate) .............. 132

Table 6-9: List of Vegetation Species of Rocky Calcareous Plain Habitat (20 x 20m Quadrate)133

Table 6-10: List of Vegetation Species of Calcareous Plain Habitat (2 x 2m Quadrate) ........... 134

Table 6-11: Vegetation Species with Medicinal and Economical Use found in the Project Area135

Table 6-12: List of Birds Observed/Reported in the Project Area ............................................. 136

Table 6-13: List of Mammals Observed/Reported in the Project Area ...................................... 141

Table 6-14: List of Reptiles Observed/Reported in the Project Area ........................................ 142

Table 6-15: Households and Population Data of Goths/Villages/Towns ................................... 155

Table 6-16: Tribal Distribution ................................................................................................... 156

Table 6-17: Development Priorities of the Communities of Suveyed Villagees ........................ 157

Table 8-1: List of Stakeholders Consulted during EIA .............................................................. 203


OCTOBER 2019 vi HPK

List of Figures

Figure 1-1: Key Map of Kotri North Block ...................................................................................... 8

Figure 1-2: Project Area Map ........................................................................................................ 9

Figure 3-1: United Energy Pakistan Limited’s HSE Policy .......................................................... 41

Figure 4-1: Anatomy of a Rotary Land Drilling Rig ...................................................................... 70

Figure 5-1: Primary Energy Supplies by Source with ACGR ...................................................... 84

Figure 5-2: Primary Energy Supplies by Source ......................................................................... 84

Figure 5-3: Final Energy Consumption by Source ...................................................................... 85

Figure 5-4: Final Energy Consumption by Sector ....................................................................... 85

Figure 5-5: Natural Gas Production by Type/Province ................................................................ 86

Figure 5-6: Natural Gas Consumption by Sector ........................................................................ 87

Figure 6-1: Graphical Representation of Average Temperatures in Hyderabad, 2009 – 2018 . 106

Figure 6-2: Graphical Representation of Hyderabad Climatic Data, 2009 – 2018 .................... 107

Figure 6-3: Seismic Zoning Map of Pakistan ............................................................................ 108

Figure 6-4: Water Resources Map of the Project Area ............................................................. 109

Figure 6-5: Ambient Noise Sampling Locations Map of the Project Area ................................. 110

Figure 6-6: Communities, Infrastructure and Archaeological Resources Map .......................... 158


OCTOBER 2019 vii HPK

List of Photographs

Photograph 4-1: A view of typical seismic base camp ................................................................ 71

Photograph 4-2: A veiw of seismic support camp ....................................................................... 71

Photograph 4-3: Uphole drilling by vehicle mounted rig.............................................................. 71

Photograph 4-4: Vibroseis moving on a seismic line .................................................................. 71

Photograph 4-5: Drilling of deep hole through buggy in progress ............................................... 71

Photograph 4-6: Jackrob drilling ................................................................................................. 71

Photograph 4-7: Loading of explosives in a shot hole ................................................................ 72

Photograph 4-8: A loaded shot hole ........................................................................................... 72

Photograph 4-9: Seismic base camp parking area ..................................................................... 72

Photograph 4-10: A veiw of explosive magazine ........................................................................ 72

Photograph 4-11: Seismic cable crossing on a road................................................................... 72

Photograph 4-12: Recording truck .............................................................................................. 72

Photograph 4-13: A view of land drilling rig in operation ............................................................. 73

Photograph 4-14: A view of typical drilling rig camp ................................................................... 73

Photograph 4-15: Dozer at work on access track ....................................................................... 73

Photograph 4-16: Gravel leveling with grader on well site .......................................................... 73

Photograph 4-17: Generators at well site.................................................................................... 73

Photograph 4-18: Water storage pit on well site ......................................................................... 73

Photograph 4-19: A view of lined drill cutting pit at well site ....................................................... 74

Photograph 4-20: Properly bunded diesel storage area with loading and unloading pad ........... 74

Photograph 4-21: Properly barricaded food burial pit ................................................................. 74

Photograph 4-22: Construction of septic tank at well site ........................................................... 74

Photograph 4-23: Installation of conductor pipe at well site ........................................................ 74

Photograph 4-24: Installation of BOP in progress ....................................................................... 74

Photograph 4-25: Dozer working on RoW .................................................................................. 75

Photograph 4-26: Offloading of pipes on RoW ........................................................................... 75

Photograph 4-27: Flow line placed along RoW ........................................................................... 75

Photograph 4-28: Clamping of flow line before welding .............................................................. 75

Photograph 4-29: Burial of flow line in trench ............................................................................. 75

Photograph 4-30: Working on flow line at wellhead .................................................................... 75

Photograph 4-31: Typical view of CPP ....................................................................................... 76

Photograph 4-32: Typical styled condensate storage at GPF..................................................... 76

Photograph 4-33: Typical lined evaporation pond....................................................................... 76

Photograph 4-34: Typical pipe yard at GPF ................................................................................ 76

Photograph 6-1: A view of Indus River ..................................................................................... 111

Photograph 6-2: A view of Kotri Barrage .................................................................................. 111

Photograph 6-3: Agriculture field – dominant habitat of the project area .................................. 111

Photograph 6-4: Barani agriculture field ................................................................................... 111

Photograph 6-5: A patch of waste land & fallow land................................................................ 111

Photograph 6-6: Stony plain of the project area ....................................................................... 111

Photograph 6-7: A view Matiari RF ........................................................................................... 112

Photograph 6-8: A view of Salaro Ghotana RF ......................................................................... 112


OCTOBER 2019 viii HPK

Photograph 6-9: Marshy wetland near Goth Suleman Barejo ................................................... 112

Photograph 6-10: A view of Khasino Canal (wah) .................................................................... 112

Photograph 6-11: A view of Pannu wah .................................................................................... 112

Photograph 6-12: Cemented watercourse – Tadri Mori ............................................................ 112

Photograph 6-13: Tube well found in the project area .............................................................. 113

Photograph 6-14: A view of Rajani-7 well site........................................................................... 113

Photograph 6-15: Gas Compression Facility near Rajani-12 well site ...................................... 113

Photograph 6-16: A view of M9 motorway entering into project area ....................................... 113

Photograph 6-17: Salvadora persecia ...................................................................................... 143

Photograph 6-18: Ficus religiosa .............................................................................................. 143

Photograph 6-19: Acacia nilotica .............................................................................................. 143

Photograph 6-20: Bombax ceiba .............................................................................................. 143

Photograph 6-21: Capparis Spinosa ......................................................................................... 143

Photograph 6-22: Cordia myxa ................................................................................................. 143

Photograph 6-23: Cassia holosericeai ...................................................................................... 144

Photograph 6-24: Dalbergia sissoo ........................................................................................... 144

Photograph 6-25: Crested lark .................................................................................................. 144

Photograph 6-26: Egyptian vulture ........................................................................................... 144

Photograph 6-27: Glossy ibis .................................................................................................... 144

Photograph 6-28: Indian robin .................................................................................................. 144

Photograph 6-29: Large cormorant ........................................................................................... 145

Photograph 6-30: Pied bushchat .............................................................................................. 145

Photograph 6-31: Redshank ..................................................................................................... 145

Photograph 6-32: Sindh pied woodpecker ................................................................................ 145

Photograph 6-33: White browed fantail ..................................................................................... 145

Photograph 6-34: Indian desert monitor lizard .......................................................................... 145

Photograph 6-35: Indian garden lizard ...................................................................................... 146

Photograph 6-36: Asiatic jackal ................................................................................................ 146

Photograph 6-37: Botanist during the EIA field survey ............................................................. 146

Photograph 6-38: Wildlife specialist during the EIA field survey ............................................... 146

Photograph 6-39: A view of Goth Sufan Bacho ........................................................................ 159

Photograph 6-40: Primary school of Goth Salaro ..................................................................... 159

Photograph 6-41: Graveyard of Goth Salaro ............................................................................ 159

Photograph 6-42: Graveyard of Goth Sufan Bacho .................................................................. 159

Photograph 6-43: Primary school in Goth Bachal Dehta .......................................................... 159

Photograph 6-44: A view of Shahpur ........................................................................................ 159

Photograph 6-45: Boys’ primary school in Goth Tajpur ............................................................ 160

Photograph 6-46: Girls’ primary school in Goth Tajpur ............................................................. 160

Photograph 6-47: Dargah Wali Muhammad in Goth Tajpur ...................................................... 160

Photograph 6-48: Sindh Agriculture University ......................................................................... 160

Photograph 6-49: Primary school in Goth Tando Syed Khan Mitho ......................................... 160

Photograph 6-50: DHQ Matiari ................................................................................................. 160

Photograph 6-51: Dargah Syed Muhammad Shah Bukhari ...................................................... 161

Photograph 6-52: A view of Goth Bakhshia Mari ...................................................................... 161


OCTOBER 2019 ix HPK

Photograph 6-53: A view of Goth Karim Deno .......................................................................... 161

Photograph 6-54: A view of Goth Jaitharo ................................................................................ 161

Photograph 6-55: Dargah Baba Allah Baksh Jilani ................................................................... 161

Photograph 6-56: A view of Goth Haji Ishaq ............................................................................. 161

Photograph 6-57: A view of Goth Gulshan-e-Shahbaz ............................................................. 162

Photograph 6-58: A view of Goth Wadero Misri ........................................................................ 162

Photograph 6-59: BHU Hyderabad ........................................................................................... 162

Photograph 6-60: High tension electric poles crossing through the project area ...................... 162

Photograph 8-1: Consultation at Goth Sufan Bacho ................................................................. 204

Photograph 8-2: Consultation with Mr. Imran Sabir, Sindh EPA ............................................... 204

Photograph 8-3: Consultation with Representatives of Sindh EPA, Hyderabad ....................... 204

Photograph 8-4: Community consultation at Goth Haji Shabu.................................................. 204

Photograph 8-5: Consultation with locals at Goth Khuda Baksh ............................................... 204

Photograph 8-6: Consultation session with RFO, Hyderabad ................................................... 204

Photograph 8-7: Consultation with Chief Engineer, Irrigation Department, Hyderabad ............ 205

Photograph 8-8: Community consultation at Goth Bachal Dehta.............................................. 205

Photograph 8-9: Consultation at Goth Bakhshia Mari ............................................................... 205

Photograph 8-10: Consultation with Dr. Abdul Manan .............................................................. 205

Photograph 8-11: Consultation session with Prof. Dr. Moazzam Ali Khan ............................... 205

Photograph 8-12: Community consultation at Goth Aliabad ..................................................... 205

Photograph 8-13: Locals are being consulted at Goth Karim Deno .......................................... 206

Photograph 8-14: Consultation session with Prof. Dr. Muhammad Zaheer Khan ..................... 206

Photograph 8-15: Consultation session Mr. Jawad Umer Khan (WWF Pakistan) .................... 206

Photograph 8-16: Community consultation at Goth Jaitharo .................................................... 206

Photograph 8-17: Community consultation at Goth Haji Ishaq ................................................. 206

Photograph 8-18: Consultation with locals at Goth Gulshan-e-Shahbaz .................................. 206


OCTOBER 2019 x HPK

List of Acronyms

2D Two Dimensional

3D Three Dimensional

ACGR Annual Compound Growth Rate

BAP Biodiversity Action Plan

BAT Best Available Technology

BATNEEC Best Available Technology Not Entailing Excessive Cost

BOD Biological Oxygen Demand

CC Civil Contractor

CFC Chlorofluorocarbon

CITES Convention on International Trade in Endangered Species of Wild Fauna and Flora

CMS Convention on the Conservation of Migratory Species of Wild Animals

COD Chemical Oxygen Demand

CPP Central Processing Plant

DCR District Census Report

DGPC Director General Petroleum Concessions

E.L. Exploration Lease

E&P Exploration and Production

EIA Environmental Impact Assessment

EMP Environmental Management Plan

EPA Environmental Protection Agency

EWT Extending Well Testing

GCA Gross Command Area

GoP Government of Pakistan

GoS Government of Sindh

GPF Gas Processing Facility

H2S Hydrogen Sulfide

HDPE High Density Polyethylene

HPK Halcrow Pakistan (Pvt) Ltd

HSE Health, Safety and Environment

HSEO Health, Safety and Environment Officer

IAGC International Association of Geophysical Contractors

IEE Initial Environmental Examination

IMC Independent Monitoring Consultant

IUCN International Union for Conservation of Nature and Natural Resources

LNG Liquefied Natural Gas

LPG Liquefied Petroleum Gas

LSO Louisiana State Order

MMCFD Million Cubic Feet per Day

MTOE Million Tonnes of Oil Equivalent

NCS National Conservation Strategy

NEQS National Environment Quality Standards


OCTOBER 2019 xi HPK

NGO Non-Government Organization

NOC No Objection Certificate

O&G Oil and Gas

PEPA 97 Pakistan Environmental Protection Act, 1997

PIR Project Initiation Report

PVC Poly Vinyl Chloride

RoW Right of Way

SEQS Sindh Environmental Quality Standards

SFD Sindh Forest Department

STP Sewage Treatment Plant

SWD Sindh Wildlife Department

SWPO Sindh Wildlife Protection Ordinance

TSS Total Suspended Solids

TDS Total Dissolved Solids

UEPL United Energy Pakistan Limited

UTC Universal Time Coordinated

WBM Water Based Mud

WWF Worldwide Fund for Nature


OCTOBER 2019 xii HPK

List of Units

cusecs cubic feet per second

dB decibels

gph gallons per hour

ha hectares

hr hour

km kilometres

m meter

mg/l milligram per litre

mg/Nm3 milligram per Normal Cubic meter

m3 cubic meter

m2 square meter

mm millimetre

m/s meter/second

°C Degree Celsius

% Percent

ppb parts per billion

ppm parts per million

sq. square

tcf Trillion cubic feet


OCTOBER 2019 1 HPK

1 Introduction

Environmental Impact Assessment

This report presents the findings of an Environmental Impact Assessment (EIA)

carried out by Halcrow Pakistan (Pvt) Limited for the proposed exploration and

associated development activities in Kotri North Block (E.L. 2568‐21) by United

Energy Pakistan Limited (UEPL) which lies within geographical jurisdiction of Sindh

province. A key map showing the location of Kotri North Block is presented as Figure

1‐1. This EIA has been prepared in conformance to the requirements of the Sindh

Environmental Protection Act 2014, the Sindh Initial Environmental Examination and

Environmental Impact Assessment Review Regulations, 2014 and the Pakistan

Environmental Assessment Procedures, 1997.

The EIA report explicitly covers exploration and associated development activities in

the entire spread of Kotri North Block. These activities range from 2D/3D seismic

surveys, drilling of exploration/development wells, laying of flow line/s from

producing wells to the hydrocarbons gathering system/processing facility,




decommissioning and site restorations. Proposed project activities will be commenced

with 2D/3D seismic survey and based upon the aforementioned seismic data

acquisition and its interpretations, UEPL will plan to drill wells at the most certain

perspective locations as part of exploration/development plan. After the successfully

drilling at any proposed well location and in case of discovery, flow line/pipeline will

be laid from each well to the new/existing hydrocarbons gathering and production

system.


North Block (hereafter also referred as the ‘project area’ in the later sections of the

report) however, location of the seismic survey/s is not finalized yet. Similarly, the

exact location of exploratory/development wells and alignment of flow line/s is not









of each aforementioned activity in the project area.


OCTOBER 2019 2 HPK

The objective of exploration and associated development activities is to explore for

potential hydrocarbons reserves in the prospective formations identified during

previous Oil & Gas exploration activities in the region particularly in the leased area.

The Project Proponent

United Energy Pakistan Limited, UEP Alpha Limited and UEP Beta GmbH collectively

known as UEP (UEP Alpha and UEP Beta were previously known as OMV Maurice

Energy Limited and OMV (Pakistan) Exploration GmbH) are subsidiaries of United

Energy Group (UEG), an energy company listed on the Hong Kong Stock Exchange.

UEP is the largest foreign oil & gas exploration and production (E&P) company in

Pakistan, and have been contributing significantly in reducing Pakistan’s dependency

on oil & gas imports through indigenous hydrocarbon production.

UEG’s asset has a rich heritage, starting nearly four decades ago when an American

E&P company, Union Texas Pakistan, initiated operations in Khaskeli, Badin. Since

then, this asset has undergone several changes and a shift in ownership a number of

times. Acquisition of British Petroleum’s assets by UEG was the first venture in

Pakistan and since then UEG has made significant investments in the business,

resulting in rapid growth. UEG’s onshore concessions span across 20,000 square

kilometers and are spread across Sindh and Balochistan provinces.

UEP is conscious of environmental footprint and work diligently to ensure that no

harm is caused to anyone involved in or impacted by their activities. UEP not only

comply with all applicable laws related to Health, Safety and the Environment (HSE)

but also have a set of internal policies in place to minimize the environmental impact

of their operations.

In coordination with the government, communities and non‐governmental

organizations, UEP has invested in sustainable social investment projects in the areas

where operating. CSR interventions have brought a positive impact in the lives of local

communities by enhancing access to technical training, creating opportunities for

sustainable income generation and providing quality education and healthcare

services. UEP has invested in the alternative energy sector. UEG (parent company) has

also invested in a wind energy project located in the Jhimpir wind corridor in the

Sindh province. This project was one of the 14 top priority projects of the China

Pakistan Economic Corridor (CPEC).

Kotri North Block (E.L. 2568-21) & Project Area





shares approx. 257 km2 and district Hyderabad contributes about 6.6 km2. Taluka wise

distribution of abovementioned districts is provided in table below:


OCTOBER 2019 3 HPK

No. District Taluka Area Coverage (km2)

4. Jamshoro Kotri 442

Manjhand 691.5

5. Hyderabad Hyderabad 6.5

6. Matiari

Hala 210

Matiari 4

Saeedabad 43

United Energy Pakistan is operator of the block and holds 50% working interest. Other

joint venture (JV) partners include Pakistan Petroleum Limited (PPL) and Asia

Resources Oil Limited (AROL). PPL and AROL holds 40% and 10% working interest

in the block respectively.








forests, now mostly are under cultivation. Location of forest protected areas is also

shown in Figure 1‐2.

The Proposed Project

The entire leased area spreads over approximately 1,397 km2 and lies in Jamshoro,

Matiari and Hyderabad districts of Sindh province. The EIA report explicitly covers

exploration and associated development activities in the entire spread of Kotri North

Block. These activities range from 2D/3D seismic surveys, drilling of exploration/

development wells, laying of flow line/s from producing wells to the existing



associated civil and engineering works e.g. construction of access track/s, residential

camp/s, construction of well site/s etc. and finally decommissioning and site

restorations.

Proposed project activities will be commenced with 2D/3D seismic survey and based

upon the aforementioned seismic data acquisition and its interpretations, UEPL will

plan to drill wells as part of exploration/development plan. After the successfully

drilling at proposed well location and in case of discovery, flow line/pipeline will be

laid from each well to the new/existing hydrocarbons gathering and production

system over the period of three years. Detailed proposed project activities will include

but not limited to be are listed below:




OCTOBER 2019 4 HPK



for the purpose);












Sites restoration.

The proposed 2D & 3D seismic data acquisition will be carried out using a

combination of vibroseis and dynamite technologies. The objective of the seismic

survey is to explore the subsurface in the area to identify hydrocarbon laden

formations. For seismic survey a base camp with fly camp (if required) will be

established to house the seismic crew followed by seismic activity and finally

restoration of seismic lines and base camp/fly camp upon completion of survey area to

original conditions.

Drilling of each well will start with the construction of the access road, rig camp and

well site for each proposed location. This will be followed by drilling of exploratory or

development well. Each proposed well will be drilled using a conventional land

drilling rig. A specialized waste management system using Hi‐G dryers and

centrifuges will be installed on the land drilling rig for better management and

disposal of drilling wastes. This will also help in reducing the water requirements

during drilling and managing the size of wastes pits at each proposed well location.

Depending on the drilling results (success or failure), abandonment, completion or

suspension of the well and site restoration. Furthermore, in case of discovery of

hydrocarbons at any of the proposed well locations, laying of flow line/pipeline from

wells to the hydrocarbons gathering/processing facilities and tie‐in/wellhead works

will be carried out.


North Block however, location of the seismic survey/s is not finalized yet. Similarly,

the exact location of exploratory/development wells and alignment of flow line/s is not



OCTOBER 2019 5 HPK








of each aforementioned activity in the leased area of Kotri North Block.

Proposed Environmental Approval and Management System

Preparation and approval of environmental assessments that covers more than one

exploration or production activity is not a new precedence, however, the following

needs to be ensured in such assessments:

Sufficient data collection and assessment of impacts to cover all environmental

sensitivities;

A mechanism that would require a site specific short study prior to start of each

activity to incorporate any additional impacts and mitigation measures that were

not addressed in the EIA; and

A mechanism by which Sindh Environmental Protection Agency (Sindh EPA) can

continue to exercise its control over the proponent’s activities and follow up on the

environmental performance of the operations.

United Energy Pakistan Limited and Halcrow Pakistan have been fully cognizant of

the above listed issues and have addressed them in the EIA by undertaking or

proposing the following:

The EIA is based on primary as well as secondary data. Primary data is collected

on all physical, biological and socioeconomic aspects;

Assessment of all generic potentially significant impacts on the physical, biological

and socioeconomic receptors due to proposed project activities has been addressed

in the EIA. Relevant mitigation measures have also been discussed in detail.

However, following methodology shall be adopted to consider the project specific

impacts, since at this conceptual design stage exact locations for project facilities

are not available; and

In order to ensure that Sindh EPA continues to regulate and oversee the

environmental performance of activities within the leased areas, the EIA has

recommended the following environmental approval, monitoring and

management protocol:

o Prior to commence of any proposed project activity as defined in Section 1.4,

United Energy Pakistan Limited will prepare and submit a Project Initiation

Report (PIR) or Activity Initiation Report to the Sindh EPA. The report will be

submitted at least fifteen days prior to initiation of any physical work related to


OCTOBER 2019 6 HPK

that particular activity. The PIR or AIR will provide details on the proposed

activity, site specific information on the physical, biological and socioeconomic

environment, waste management procedures and any environmental issues

and mitigation measures additional to the EIA;

o If required, Sindh EPA can forward any comments that it might have on the

PIR/AIR within fifteen days of the submissions of the PIR/AIR after which the

activity will automatically stand as approved;

o Once any activity is initiated, United Energy Pakistan Limited will undertake

environmental monitoring according to the requirements of the project specific

EMP and any additional requirements specified by the Sindh EPA; and

o United Energy Pakistan Limited will accommodate any visits by Sindh EPA,

Sindh Wildlife Department and Forest Department officials for the purpose of

external audits or on‐site inspections.

EIA Consultants

This EIA study was carried out by Halcrow Pakistan (HPK) comprising of

Environmental Specialists, Social Experts, Wildlife Specialists, Botanist and Water

Resources Expert having sound technical expertise to perform assignments particular

to the oil & gas sector. The details of the project team members appointed on this

study are provided below:

No. Name Expertise

1. Abdul Qayyum Aslam Team Lead – HSE

2. Arslan A. Asghar Environmental Specialist

3. Abdur Razzaq Khan Wildlife Expert

4. Ahmed Salman Qureshi Environmentalist

5. Ghulam Sakina Memon Social/Gender Expert

6. Shakeel Ahmed Botanist

7. Syed Jawad GIS Expert

8. Ahsan Ullah CAD Operator

Reporting

The EIA study has been compiled in a report form. The format of the EIA report

conforms to the guidelines provided in the Pakistan Environmental Assessment

Procedures, 1997.

The EIA report is presented as one volume and describes the proposed project,

environment of the project area, relevant legislations and guidelines, assessment of the

project impacts, recommendations for mitigation measures and environmental

management plan (Appendix A). The photographic records have been provided in the

relevant sections of the EIA report.


OCTOBER 2019 7 HPK

Contact Details

In case of further details or clarifications regarding this EIA please do not hesitate to

contact the Proponent or the Consultant at the addresses provided below:

Proponent Consultant

Amjad Shaikh

Senior HSE Manager

United Energy Pakistan Limited

1st Floor, Bahria Complex‐1,

24 M.T. Khan Road

Karachi

Pakistan

Tel : +92 21 3561 1194

Fax: +92 21 3561 0634

Abdul Qayyum Aslam

Team Lead – HSE


3rd Floor, Nawa‐e‐Waqt House,

Mauve Area

Sector G‐7/1

Islamabad

Tel: +92 51 220 3451‐55

Fax: +92 51 220 3462

Lat :25° 27' 32.436" NLong:68° 36' 29.484" E

Lat :25° 41' 38.688" NLong:68° 33' 20.196" EKotri

Hala

Thatta

Matiari

Hyderabad

Latifabad

Qasimabad

Tando Adam

Jamshoro

Matiari

Thatta

Hyderabad

Sanghar

68°32'0"E

68°32'0"E

68°24'0"E

68°24'0"E

68°16'0"E

68°16'0"E

68°8'0"E

68°8'0"E

68°0'0"E

68°0'0"E26

°0'0

"N

26°0

'0"N

25°5

2'0

"N

25°5

2'0

"N

25°4

4'0

"N

25°4

4'0

"N

25°3

6'0

"N

25°3

6'0

"N

25°2

8'0

"N

25°2

8'0

"N

25°2

0'0

"N

25°2

0'0

"N

LegendBlock Boundary Reserve Forest (SOP) Tehsil Boundaries

District Boundaries

·0 2.5 5 7.5 10 12.5 15 17.5 Km

Halcrow Pakistan (Pvt) LimitedUnited Energy

Pakistan

Fig 1-1: Key Map of Kotri North Block


h

h

h

h

h



Graveyard / Shrine


Graveyard

Graveyard

Goth Akro

Graveyard

Graveyard

Graveyard

Goth Tajpur

Goth Salaro

Goth Jaitharo

Goth Aliabad

Goth Haji Ishaq

Goth Karim Deno

Goth Tadri Mori

Goth Haji Shabu

Goth Khuda baksh

Goth Sufan Bacho

Goth Hayat Bhatti

Goth Bachal Dehta

Goth Bakhshia Marri

Goth Suleman Barejo

Graveyard on Highway





Goth Darya Baig Mughal


Shrine Baba Allah Bakhsh Jilani

Dargah Syed Muhammad Shah Bukhari

Goth Wadero Misri

Kotri

Hala

Matiari

Hyderabad

Thatta Latifabad

Tando Adam

Qasimabad

Tando Allahyar

Jamshoro

Matiari

HyderabadThatta

Sanghar

68°30'0"E

68°30'0"E

68°20'0"E

68°20'0"E

68°10'0"E

68°10'0"E26

°0'0

"N

26°0

'0"N

25°5

0'0

"N

25°5

0'0

"N

25°4

0'0

"N

25°4

0'0

"N

25°3

0'0

"N

25°3

0'0

"N

25°2

0'0

"N

25°2

0'0

"N

·0 2.5 5 7.5 10 12.5 15 17.5 Km


Fig 1-2: Project Area MapProject:EIA for Exploration and Associated Development Activities in Kotri North Block (E.L. 2568-21)



×[

Gas CompressionFacility

"" Community

×k Graveyard

!a Power Plant

Shrine

¥B¢ University

hWater SamplingLocation

Nationla HighwayReserve Forest(SOP)

Tehsil BoundariesDistrictBoundaries United Energy

Pakistan


OCTOBER 2019 10 HPK

2 EIA Scope and Methodology

2.1.1 Scope of the EIA

This EIA investigates the impacts likely to arise from the proposed exploration and

associated development activities by United Energy Pakistan Limited (UEPL) which

predominantly covers 2D/3D seismic surveys, drilling of exploration/development

wells, laying of flow line/s from producing wells to the existing hydrocarbons

gathering system/processing facility, establishment of surface facilities e.g. EWT or

CPP, up‐gradation/modification of existing facilities with associated civil and

engineering works e.g. construction of access track/s, residential camp/s, construction

of well site/s etc. and finally decommissioning and site restorations.

These activities have been further discussed in detail in Chapter 4 of this report. Any

exploration or production activity carried out by UEPL, other than those specified in

this report will be the subject of a separate Environmental Assessment (EIA/IEE) study

of the area.

The EIA Team

The EIA has been prepared by a team of environmental specialists, wildlife specialists,

botanist and sociologist/gender specialist. Relevant departments/stakeholders were

also consulted during the EIA process. Project specific details and particulars were

provided to HPK by United Energy Pakistan Limited.

The EIA Methodology

The various steps undertaken in the EIA preparation are summarized below:

2.3.1 Understanding of the Proposed Project and Review of Alternatives

Details of the proposed project activities were collected from United Energy Pakistan

Limited and understood by the EIA Consultant. All alternatives to the proposed

operations were reviewed including; no project option, alternative site selection,

timing and alternative technologies to establish the context that proposed operations

will not depreciate the environmental quality/soundness of the project area. Details of

the proposed project and a review of alternatives have been provided in Chapter 4

and Chapter 5 respectively of this EIA.

2.3.2 Review of Policies, Legislation and Guidelines

National & provincial legislations, international agreements, environmental

guidelines, best industry practices and UEPL’s environmental policy were reviewed to

set environmental standards that UEPL would be required to adhere to during the

project. A synopsis of these is provided in Chapter 3 of the EIA.

2.3.3 Secondary Data Collection

Previous environmental assessments for exploration and development projects in the

area and other published and un‐published information was collected in order to


OCTOBER 2019 11 HPK

gain a complete understanding of existing environmental conditions in the area

including the following:

Physical environment – topography, geology, geomorphology, soils, surface &

groundwater resources and climate;

Biological environment – habitat types, flora and fauna (particularly rare or

endangered species), critical habitats and vegetation communities particularly

within the forest protected areas;

Socioeconomic environment – settlements, socioeconomic conditions,

infrastructure and land use; and

Heritage aspects – sites of cultural, archaeological or historical significance.

2.3.4 Field Data Collection

The EIA field team including environmentalist, wildlife specialist, botanist and

sociologist/gender expert visited the Block (E.L. 2568‐21) in August, 2019. During the

site visit primary information on the physical, biological and socioeconomic

environment of the project area was gathered. Discussions were also held with the

members of community in the project area as well as in closer vicinities to collect

primary information about the project area and their view and concerns regarding the

proposed project activities.

A description of baseline physical, biological and socioeconomic conditions of the

project area, impacts due to proposed project activities and their mitigation

measures are provided in Chapters 6 and Chapter 7 of the EIA report

respectively.

The project area for EIA contains four major habitats i.e. Agriculture Fields, Farmlands

& Human Settlements; Indus River/Irrigation Network and Associated Marshes;

Wastelands & Fallow Lands; and Hilly, Stony and Sandy Plains. All sampling

locations were randomly selected, ensuring that sufficient locations are sampled for

each identified habitat.

2.3.5 Community/Public Consultation

Local residents of Kotri North Block were also consulted to promote better

understanding of the proposed exploration and development activities through

explaining its objectives and its potential positive and negative impacts during the

fieldwork of EIA. Locals seemed positive and optimistic about the proposed project

activities. The biggest aspiration of locals is getting only one thing i.e. employment.

Land related issues were also highlighted during the consultation process. The

outcomes of the consultation are detailed in Chapter 8 of the EIA report.

2.3.6 Impact Identification and Assessment

Potential impacts arising from each phase of the proposed project activity were

identified. These include effects of the proposed project activities on the physical,

biological, socioeconomic, archaeological and cultural environments of the area. These


OCTOBER 2019 12 HPK

are detailed in Chapter 7 of the EIA. Impacts were identified and assessed on the basis

of field data, secondary data, experts’ opinion and monitoring results of previous oil

and gas exploration projects in Pakistan, particularly in Sindh region.

2.3.7 Recommendations for Mitigation & Monitoring Measures

Mitigation measures to prevent or minimize all potential adverse environmental

impacts of the project were identified based on a range of options including

management and monitoring practices, alternative technologies and physical controls.

The proposed mitigation measures are based on an appreciation of the sensitivity and

behavior of environmental receptors within the project area, past experience, case

studies, legislative controls, environmental guidelines and experts’ advices.

Monitoring measures have been recommended for residual impacts (impacts

remaining after applying the recommended mitigation measures) or for impacts that

cannot be accurately predicted at the EIA stage. In such cases advice on requisite

monitoring measures was sought from experts involved in the EIA and case studies of

similar monitoring exercises carried out in wildlife or forest protected areas elsewhere.

The impacts identified were characterised following the criteria provided in Table 2‐1.

2.3.8 Development of Environmental Management Plan (EMP)

An Environmental Management Plan (EMP) for the proposed project activities has

been prepared and provided in Appendix A of this EIA report. The EMP provides a

framework for implementing and managing the mitigation and monitoring measures

recommended in the EIA. The EMP includes the following:

A mitigation and monitoring plan;

Definition of roles and responsibilities of the proponent, project contractors and

monitoring teams;

Requirements for communication, documentation and trainings during the

proposed exploration and associated development project;

Restrictions on design, timing and conduct of the project; and

Change Management Plan to cover unforeseen events/environmental conditions

during the entire course of the project.


OCTOBER 2019 13 HPK

Table 2‐1: Impact Characteristics Criteria

Impact Characteristics Categories

Duration of the impact Short term – lasting only till the duration of the project such as

noise from the drilling or seismic operations.

Medium term – lasting for a period of few months to a year after

the project before naturally reverting to the original condition such

as loss of vegetation due to clearing of well site, contamination of

soil or water by fuels or oil.

Long term – lasting for a period much greater than medium term

impacts before naturally reverting to the original condition such as

loss of soil due to soil erosion.

Geographical location of

the impact

Local – within the area of project i.e. well site, campsite and access

road etc.

Regional – within the boundaries of the project area.

National – within the boundaries of the country.

Likelihood of the impact Qualitatively measured on a scale of:

Almost certain

Likely

Possible

Unlikely

Rare

Reversibility of the impact Defined as:

Reversible – when a receptor resumes its pre‐project condition.

Irreversible – when a receptor does not or cannot resume its pre‐

project condition.

Consequence severity of

impact

Rated as:

Major – when an activity causes irreversible damage to a unique

environmental feature; effects entire population or species of flora

or fauna in sufficient magnitude so as to cause a decline in species

abundance or change in distribution over more than one

generation; has long term effects (period of years) on socio‐cultural

or economic activities of regional significance.

Moderate – when an activity causes long term (period of years)

reversible damage to a unique environmental feature; effects a

portion of a population of flora or fauna causing reversible damage

or change in abundance or distribution over one generation; has

short term effects (period of months) on socio‐cultural or economic

activities of regional significance.

Minor – when an activity causes short term (period of few months)

reversible damage to an environmental feature; slight reversible

damage to a few species of flora or fauna within a population over

a short period of time; has short term (period of months) effects on

socio‐cultural or economic activities of local significance.

Negligible – when no measurable damage to physical,

socioeconomic or biological environment above the existing level of

impacts occurs.


OCTOBER 2019 14 HPK

Impact Characteristics Categories

Significance of the impact Categorized as:

High

Medium

Low

Based on the consequence, likelihood, reversibility, geographical

extent, duration, level of public concern and conformance with

legislative or statutory requirements.


OCTOBER 2019 15 HPK

3 Legal Framework

Introduction

This chapter provides a synopsis of local land environmental laws, policies,

legislations and guidelines that may have relevance to the proposed exploration and

associated development project within Kotri North Block (E.L. 2568‐21). These include:

United Energy Pakistan Limited’s corporate policy on Health, Safety and

Environment (HSE);

National and provincial environmental policies, acts, legislations and guidelines;

and

International conventions and guidelines.

UEPL will be required to adhere to the relevant requirements of the acts, policies,

legislations and recommendations of the guidelines during the proposed exploration

and associated development activities, which have also been incorporated in the

mitigation measures and the EMP provided in the EIA.

United Energy Pakistan Limited’s Corporate HSE Policy

United Energy Pakistan Limited has a corporate HSE Policy in place. Under this policy

UEPL is committed to make all workplaces and processes safe and secure for UEPL

and its stakeholders, environment with continuous improvement, actively strive to

minimize impacts on environment, participate in climate protection measures and

support alternative energy resources. Moreover, UEPL constantly strives to drive

down the environmental impacts through responsible use of natural resources and

reduction of waste, emissions and discharges.

The Health, Safety, and Environmental (HSE) Policy has been attached at the end of

this chapter as Figure 3‐1.

National Environmental Policy, Legislation and Guidelines

The enactment of comprehensive legislation on the environment, covering multiple

areas of concern is a relatively new and ongoing phenomenon in Pakistan. Whereas, a

basic policy and legislative framework for the protection of the environment and

overall biodiversity in the country is now in place, detailed rules, regulations and

guidelines required for the implementation of the policies and enforcement of

legislations are still in various stages of formulation and discussion. The following

section presents a brief overview of the existing national policies, legislations and

guidelines.

3.3.1 National Environmental Policy, 2005

The National Environmental Policy (NEP) is the primary policy of Government of

Pakistan that addresses the environmental issues of the country. The broad goal of


OCTOBER 2019 16 HPK

NEP is, “to protect, conserve and restore Pakistan’s environment in order to improve

the quality of life of the citizens through sustainable development”. The NEP identifies

the following set of sectoral and cross‐sectoral guidelines to achieve its goal of

sustainable development.

a. Sectoral Guidelines

Water and sanitation, air quality and noise, waste management, forestry, biodiversity

and protected areas, climate change and ozone depletion, energy efficiency and

renewable, agriculture and livestock, and multilateral environmental agreements.

b. Cross‐sectoral Guidelines

Poverty, population, gender, health, trade and environment, environment and local

governance, and natural disaster management.

The NEP suggests the following policy instruments to overcome the environmental

problems throughout the country:

Integration of environment into development planning;

Legislation and regulatory framework;

Capacity development;

Economic and market based instrument;

Public awareness and education; and

Public private civil society partnership.

NEP is a policy document and does not apply to proposed exploration or associated

development project. However, UEPL shall ensure that the project activities should

not add to the aggravation of the environmental issues identified in NEP and

mitigation measures shall be adopted to minimize or avoid any contribution of the

project impacts in these areas.

3.3.2 National Conservation Strategy, 1992

Before the approval of National Environmental Policy (NEP), the National

Conservation Strategy (NCS) was considered as the Government’s primary policy

document on national environmental issues. At the moment this strategy just exists as

a national conservation program. The NCS identifies 14 core areas including

conservation of biodiversity, pollution prevention and abatement, soil and water

conservation, preservation of cultural heritage and recommends immediate attention

to these core areas in order to preserve the country’s environment.

NCS does not directly apply to oil and gas E&P projects. However, UEPL shall ensure

that proposed project should not add to the aggravation of the 14 core environmental

issues identified in the NCS and mitigation measures shall be adopted to minimize or

avoid any contribution of the project impacts in these areas.


OCTOBER 2019 17 HPK

3.3.3 The Biodiversity Action Plan, 2000

The Biodiversity Action Plan (BAP), which was designed to complement the NCS and

the provincial conservation strategies, identifies the causes of biodiversity loss in

Pakistan and suggests a series of proposals for action to conserve biodiversity in the

country.

The BAP recognizes that an environmental assessment is used as a tool at a project

level to identify environmental effects of a proposed project activities and to plan for

reducing adverse effects. The BAP further stipulates that an environmental assessment

needs to be initiated at an early stage of project development and that public

participation in the review of potential effects is important.

3.3.4 Provincial & National Environmental Legislations

a. Sindh Environmental Protection Act, 2014

After passage of 18th amendment by the parliament in April 2010, Government of

Sindh has enacted its own environmental law. The Sindh Environmental Protection

Bill, 2014 having been passed by the Provincial Assembly of Sindh on 24th February,

2014 and assented to by the Governor of Sindh on 19th March, 2014 as an Act of

Legislature of Sindh.

According to Part‐VI, Environmental Examinations and Assessments; no proponent of a

project shall commence construction or operation unless he has filed with the Agency

an Initial Environmental Examination (IEE) or Environmental Impact Assessment

(EIA) and has obtained from the Agency approval in respect thereof. This EIA is being

submitted by United Energy Pakistan Limited to Sindh Environmental Protection

Agency to fulfil the requirements of the Act.

b. Sindh Environmental Protection Agency Review of IEE and EIA Regulations, 2014

In exercise of the powers conferred by Section 37 of the Sindh Environmental

Protection Act, 2014, the Sindh Environmental Protection Agency, with the approval

of Government, issued the following regulations, namely ‘Review of Initial

Environmental Examination and Environmental Impact Assessment Regulations, 2014’

which came into force at once.

Under these regulations a new provision for submittal of ‘Environmental Checklist’

was also introduced in addition to IEEs and EIAs. A proponent of a project falling in

any category listed in Schedule‐III of these Regulations shall file ‘Environmental

Checklist’ with the Agency and the provisions of Section 17 shall apply to such

projects.

Other important features of the Sindh EPA IEE‐EIA Regulations, 2014 relevant to the

proposed project activities are listed below:

A fee is payable to the Sindh EPA for review of the EIA;

The EIA submittal is to be accompanied by an application in the format prescribed

in Schedule V of the Sindh EPA IEE‐EIA Regulations, 2014;


OCTOBER 2019 18 HPK

The Sindh EPA is bound to conduct a preliminary scrutiny and reply within 15

days of the submittal of the report; a) confirming completeness, or b) asking for

additional information, if needed, or c) returning the report requiring additional

studies, if necessary;

The Sindh EPA is required to make every effort to complete the EIA review

process within 4 months (120 days) of the issue of confirmation of completeness

under Regulation 9; and

If Sindh EPA accords approval, it will be valid for three years from the date of

accord.

This EIA falls under Regulation‐4 of these Regulation i.e. Projects requiring an EIA,

Schedule‐II, Category‐J ‘Environmentally Sensitive Areas’.

c. Sindh Environmental Quality Standards, 2016

In exercise of the powers conferred under Clause (g) of Sub‐section (1) of Section 6,

Sindh Environmental Protection Act 2014, the Sindh EPA, with the approval of the

Sindh Environmental Protection Council, has established the environmental

standards for Industrial wastewater, Effluents, Domestic sewage, Industrial air

emissions and ambient airs, Noise for vehicles and Drinking water quality standards,

2015. These standards came into force on 28th January, 2016 and are provided in Table

3‐1 to Table 3‐6.

UEPL will be required to comply with all applicable standards as prescribed in the law

and report to Sindh Environmental Protection Agency as per their requirements or

bindings.

d. Self‐Monitoring and Reporting Rules, 2014


Protection Act, 2014, Sindh Environmental Protection Agency with the approval of

Government of Sindh has established the rules which are called ‘Sindh Environmental

Quality Standards (Self‐Monitoring and Reporting by Industry) Rules, 2014’ which came

into force at once.

As per rules set by this system, provincial industries have to monitor effluents and

emissions in compliance with the SEQS and report it to Provincial EPA. This system

classifies industry into three categories A, B and C each corresponding to a specified

reporting frequency. Proposed exploration and associated development activities in

Kotri North Block lies under ‘Category A & B’ for both liquid effluent and gaseous

emissions (priority parameters provided in Table A & B of Schedule‐IV of these Rules,

2014) and thus shall submit Environmental Monitoring Reports to Sindh EPA on

monthly and quarterly basis as per categories defined in the Rules e.g. for oil & gas

production, priority parameters need to be submitted to the Sindh EPA on monthly

basis.


OCTOBER 2019 19 HPK

e. The Sindh Occupational Safety and Health Act, 2017

The Sindh Occupational Safety and Health Bill, 2017 having been passed by the

Provincial Assembly of Sindh on 17th November, 2017 and assented to by the Governor

of Sindh on 26th December, 2017 as an Act of the Legislature of Sindh which came into

force at once.

The Sindh Occupational Safety and Health Act 2017, Sindh Act No. I of 2018 is an act

to make provision for occupational safety and health conditions at all workplaces for

the protection of persons at work against risk of injury arising out of the activities at

work places and for the promotion of safe, healthy and decent working environment

adapted to the physical, physiological and psychological needs of all persons at work.

After enforcement of this Act, United Energy Pakistan Limited and all proposed

project execution contractors will be bound to abide all provisions defined in the act.

f. Hazardous Substances Rules, 2014


Protection Act, 2014, the Sindh EPA, with the approval of the Sindh Government

announced comprehensive rules in 2014, namely ‘Hazardous Substances Rules, 2014’

which came into force at once.

As per Hazardous Substances Rules, 2014, United Energy Pakistan Limited is bound to

obtain a license from Sindh EPA for transportation, usage, handling, storage and

disposal of hazardous substances as prescribed in Sub‐clause (b) of Clause (xxv) of

Section 2, Schedule‐I of Hazardous Substances Rules, 2014 in exploration & production

operations being carried out by the Company.

g. Sindh Wildlife Protection Ordinance, 1972 and Amendments, 2001

This ordinance provides for the preservation, protection and conservation of wildlife

by the formation and management of protected areas and prohibition of hunting of

wildlife species declared protected, under this Ordinance.

The ordinance also specifies three broad classifications of the protected areas i.e.

national parks, wildlife sanctuaries and game reserves. Activities such as hunting and

breaking of land for mining are prohibited in national parks, as are removing

vegetation or polluting water flowing through the park. Wildlife sanctuaries are areas

that have been set aside as undisturbed breeding grounds and cultivation and grazing

is prohibited in the demarcated areas. Nobody is allowed to reside in a wildlife

sanctuary and entrance for the general public is by special dispensation. However,

these restrictions may be relaxed for scientific purpose or betterment of the respective

area on the discretion of the governing authority in exceptional circumstances. Game

reserves are designated as areas where hunting or shooting is not allowed except

under special permits.

Two amendments to the Ordinance were issued in January and June, 2001 respectively

pertaining to oil and gas activities within national parks and wildlife sanctuaries. The

first amendment allowed the Government to authorise the laying of an underground


OCTOBER 2019 20 HPK

pipeline through protected areas. The second amendment allowed exploration and

production activities within national parks and wildlife sanctuaries.

As the planned project activities will be carried out far away from wildlife protected

areas therefore, the project will not contravene with any provisions of the Act.

However, UEPL shall ensure that the mitigation measures suggested in the EIA are

being adhered with to preserve, protect and conserve the existing wildlife of the area.

h. Sindh Irrigation Act, 1987 with Amendments in 2011

The Sindh Irrigation Act (1987) is the main enactment relating to irrigation in the

province of Sindh, under this Act the entire task of irrigation has been entrusted to the

Provincial Government, Canal Officers, the Revenue Department and Judicial Officers.

The main features of the Act are as under:

Important policy aspects of Irrigation, like the appointment of the Canal Officers,

acquisition of water for public use, payment of compensation, water rates,

drainage schemes, canal crossing and framing the rules, have been entrusted to the

Provincial Government;

Operational functions are entrusted to the Canal Officers but the Act does not

specify which Canal Officers are empowered to act under any of its provisions.

Therefore, a Canal Officer must by duly authorized by the Provincial Government

to act under any provision of the Act;

The Revenue Administration helps the Irrigation Department to acquire land,

determine compensation and collect water dues. Moreover, the Commissioner and

Collector have substantial power to settle disputes among irrigators and can

decide appeals against the decisions of the Canal Officers. Thus, the Canal Officers

are substantially subservient to the Revenue Department; and

The offences under the Act can be tried before the Magistrate.

The canals and associated irrigation network exists in the project area and provisions

of this acts applies to certain activities like water abstraction by project contractors etc.

There is no project activity planned near the canal and associated network which

could directly cause physical damage to the canal or alteration in water quality. Any

abstraction of water from the canal shall be only done after getting formal approval

from the concerned Irrigation Department.

i. The Forest Act, 1927

This act is applicable to all regions of Pakistan. It includes procedures for constituting

and managing various types of forests, such as reserved forests and protected forests.

The act empowers the provincial forest departments to declare any forest area as

reserved or protected and also prohibit the breaking up or clearing of forest for

cultivation, grazing, hunting, removing forest produce, quarrying and felling, lopping

and topping of trees’ branches in reserved and protected forests.


OCTOBER 2019 21 HPK

It also defines the duties and roles of forest related public servants and penalties for

any infringement of the rules. As per information collected from secondary sources,

SOP maps and from consultation with Sindh Forest Department, the project area is

also located within the forest plantation or on forest land therefore provisions of this

act applies to all project activities. Thus, United Energy Pakistan Limited shall ensure

that all mitigation measures suggested in this EIA are being adhered with to protect

the natural vegetation cover of the area and to avoid habitat loss and degradation of

biodiversity.

j. Antiquities Act, 1975

The protection of cultural resources in Pakistan is ensured by the Antiquities Act of

1975. Antiquities have been defined in the Act as ancient products of human activity,

historical sites, or sites of anthropological or cultural interest, national monuments etc.

The act is designed to protect antiquities from destruction, theft, negligence, unlawful

excavation, trade and export. The law prohibits new construction in the proximity of a

protected antiquity and empowers the Government of Pakistan to prohibit excavation

in any area which may contain articles of archaeological significance. Under the Act,

the project proponent is obligated to:

Ensure that no activity is undertaken in the proximity of a protected antiquity, and

If during the course of the project an archaeological discovery is made, it shall be

reported to the Department of Archaeology, Government of Pakistan.

No surface archaeological sites (protected) were identified in the project area during

the fieldwork for EIA however, there is a possibility of existence of sites with historical

significance within the leased area due to its location therefore, UEPL shall ensure that

all proposed mitigation measures suggested in EIA shall be adhered with during the

execution of the proposed exploration and development project to protect the

archaeological, heritage and cultural environment of the area. As per authentication

measure, SOP maps and secondary data were also consulted for verification purposes

and no protected archaeological site falls within jurisdiction of Kotri North Block.

k. Legislation on Oil & Gas Exploration and Production

The various regulations related to oil & gas exploration and production include:

The Mines Act, 1923

The Regulation of Mines and Oilfields and Mineral Development (Government

Control) Act, 1948

The Pakistan Petroleum (Production) Rules, 1949

The Oil and Gas (Safety in Drilling and Production) Regulations, 1974

The Pakistan Petroleum (Exploration and Production) Rules, 1986

The Model Petroleum Concessions Agreement, 1994


OCTOBER 2019 22 HPK

The Regulation of Mines and Oilfields and Mineral Development (Government

Control) Act, 1948 and the Pakistan Petroleum (Production) Rules, 1949 and Pakistan

Petroleum (Exploration and Production) Rules, 1986 empowers the Ministry of

Petroleum to oversee the petroleum exploration, development and production

operations. The 1986 Exploration and Production Rules address environmental

concerns and require operators to “prevent pollution, avoid accumulation of trash and

prevent damage to the environment and surroundings”.

As for safety, the Model Petroleum Concession Agreement (July, 1994) implementing

the 1986 Exploration and Production Rules, specifically requires observance of the

1974 Safety Regulations. The penalties imposed in the 1986 Exploration and

Production Rules allow the Director General Petroleum Concessions (DGPC) to revoke

a license if the Rules are not satisfied by the operator. The Mines and Oil Fields Act

also specifies penalties including imposition of fines and/or imprisonment.

The 1923 Mines Act through the Oil and Gas (Safety in Drilling and Production)

Regulations, 1974 controls the full range of safety issues in exploration and production

from seismic operations to construction, drilling and production.

The 1974 Safety Regulations requires operators to send to the Chief Inspector of Mines,

Ministry of Labour and Manpower information on safety issues including provisions

of protective equipment and identification of safety personnel and emergency

measures, designation of safety personnel including a Welfare and Safety Officer and

accident reporting.

l. The Explosive Act, 1884 and Explosive Rules, 2010

This Act and Rules provide regulations for the handling, transportation and use of

explosives during quarrying, blasting and other purposes. The proposed seismic

surveys will be performed using combination of dynamite and vibroseis therefore,

strict compliance to the provisions/guidelines should be ensured while using the

explosives. However, subsequent drilling of wells and other associated development

activities e.g. construction of well site or campsite sometimes needs blasting at

rocky/mountainous areas. Same rule applies on the construction/establishment of

processing facilities or necessary surface support facilities e.g. EWT etc. It is pertinent

to mention that for the purpose, no such blasting is envisaged. If unavoidable the

activity should be performed in such a manner that no contravention with any

provisions of the Act or Rules is occurred.

m. Pakistan Penal Code, 1860

The Pakistan Penal Code, 1860 authorizes fines, imprisonment or both for voluntary

corruption or fouling of public springs or reservoirs so as to make them less fit for

ordinary use.


OCTOBER 2019 23 HPK

3.3.5 National Environmental Guidelines

a. The Pakistan Environmental Assessment Procedures, 1997

The Pakistan Environmental Protection Agency (Pak EPA) prepared the Pakistan

Environmental Assessment Procedures in 1997. The guidelines pertaining to the

review process of EIAs and IEEs was given regulatory status in the Review of IEE and

EIA Regulations, 2000. They are based on much of the existing work done by

international donor agencies and Non‐Governmental Organizations (NGOs). The

package of regulations prepared by Pak EPA includes:

Policy and procedures for filing, review and approval of environmental

assessments;

Guidelines for the preparation and review of environmental reports;

Guidelines for public consultation;

Guidelines for sensitive and critical areas; and

Sectoral guidelines – O&G exploration and production.

The guidelines on policy and procedures define the policy context and the

administrative procedures that will govern the environmental assessment process,

from the project pre‐feasibility stage, to the approval of the environmental report.

According to the procedures laid out in the policy guidelines, IEEs or EIAs are to be

filed with the Provincial EPA where the project is to be implemented. The Federal EPA

has, however, been given the right to review any environmental report at any time and

the power to revoke the decision of the Provincial EPA, if it deems this to be necessary.

Projects have been classified in the policy guidelines by expected degree of adverse

environmental impacts. All projects proposed in environmentally sensitive areas

(including Game Reserves and Wildlife Sanctuaries) require an EIA.

The procedures require proponents to prepare terms of reference for the

environmental assessment reports. They require that all environmental assessment

studies shall contain baseline data on the area and must contain a detailed assessment

of the potential environmental impacts and the recommended mitigation measures.

Consultations with the communities that are most likely to be affected as well as

relevant NGOs are to be an integral part of the environmental impact assessment

process.

The guidelines on public consultation deals with possible approaches to public

consultation and techniques for designing an effective program of consultation that

reaches out to all major stakeholders and ensures the incorporation of their concerns in

any impact assessment study. The guidelines on sensitive areas are more specific in

that they identify the officially notified protected areas in Pakistan, including critical

ecosystems and archaeological sites.

Lastly, there are guidelines for oil & gas exploration and production operations. The

guidelines state that onshore exploration activities can be carried out without having


OCTOBER 2019 24 HPK

to submit either an IEE or an EIA. This is subject to the project proponent’s adherence

to the provisions of the guidelines and provided that such exploration is not taking

place within or adjacent to a sensitive or critical area/s. Possible adverse impacts that

may arise in due to proposed project activities include damage to flora and fauna and

to crops and livestock as well as the production of waste. Project proponents are

required to take measures to mitigate such effects.

b. Guidelines for Operational Safety, Health and Environmental Management,

December, 1996

These guidelines are the outcome of a study commissioned by the Directorate General

Petroleum Concessions (DGPC), Ministry of Petroleum and Natural Resources,

Government of Pakistan. The guidelines list down the relevant laws related to the

operational/occupational health, safety and environment and also recommends

environmental controls and management practices to be adopted in O&G exploration

and production projects.

International Treaties and Guidelines

3.4.1 International Treaties

Pakistan is a signatory to various international treaties and conventions on the

conservation of the environment and wildlife protection. The country is thus obliged

to adhere to the commitments specified in these treaties. A brief of these prime treaties

is provided hereunder.

a. The Convention on Biological Diversity, 1992

The Convention on Biological Diversity was adopted during the Earth Summit of 1992

at Rio de Janeiro, Brazil. The Convention requires parties to develop national plans for

the conservation and sustainable use of biodiversity, and to integrate these plans into

national development programs and policies. Parties are also required to identify

components of biodiversity that are important for conservation, and to develop

systems to monitor the use of such components with a view to promoting their

sustainable use. Moreover, in accordance with the Article 26 of the convention, parties

are also required to prepare national reports on the status of implementation of the

convention.

b. The Convention on Conservation of Migratory Species of Wild Animals, 1979

(Bonn Convention)

The Convention requires countries to take action to avoid endangering migratory

species. The term ʺmigratory speciesʺ refers to the species of wild animals, a significant

proportion of whose members cyclically and predictably cross one or more national

jurisdictional boundaries. The parties are also required to promote or cooperate with

other countries in matters of research on migratory species.


OCTOBER 2019 25 HPK

The Convention contains two appendices. Appendix I contain the list of migratory

species that are endangered according to the best scientific evidence available. For

these species, the member states to the Convention are required endeavour to:

Conserve and restore their habitats;

Prohibit their hunting, fishing, capturing, harassing and deliberate killing;

Remove obstacles and minimize activities that seriously hinder their migration;

and

Control other factors that might endanger them, including control of introduced

exotic species.

Appendix II lists the migratory species, or groups of species, that have an

unfavourable conservation status as well as those that would benefit significantly from

the international cooperation that could be achieved through intergovernmental

agreements. See Table 6‐12, Table 6‐13, and Table 6‐14 for list of recorded wildlife

species covered under this convention.

c. The Convention on Wetlands of International Importance, Ramsar, 1971

Pakistan is a signatory to the said Convention. The principal obligations of contracting

parties to the Convention are:

To designate wetlands for the List of Wetlands of International Importance;

To formulate and implement planning so as to promote wise use of wetlands, to

make EIA before transformations of wetlands, and to make national wetland

inventories;

To establish nature reserves on wetlands and provide adequately for their

wardening and through management to increase waterfowl populations on

appropriate wetlands;

To train personnel competent in wetland research, management and wardening;

To promote conservation of wetlands by combining far‐sighted national policies

with coordinated international action, to consult with other contracting parties

about implementing obligations arising from the Convention, especially about

shared wetlands and water system;

To promote wetland conservation concerns with development aid agencies; and

To encourage research and exchange of data.

So far 19 sites in Pakistan have been declared as wetlands of International Importance

or Ramsar Sites but none of these lies within or in the close proximity of the Kotri

North Block. The nearest Ramsar site is Keenjhar which is also known Kalri Lake at an

approx. distance of 33 km in southern direction. Kalri is one the largest freshwater

lakes in Pakistan. It has length of about 24 km, width 6 km and capacity of 0.53 million

acre feet. It is located at a distance of about 122 km east from Karachi and 19 km north‐

east of Thatta town. Indus provides Keenjhar, the required water through Kalri Baghar


OCTOBER 2019 26 HPK

(KB) Feeder. KB Feeder starts from Kotri Barrage. Since, the area is arid and receives

less than 200 mm annual rainfall, hence Indus is the only source of water for this lake.

d. Convention on International Trade in Endangered Species of Wild Fauna and Flora

(CITES)

This Convention came into effect on 3rd March, 1973 in Washington. In all, 130

countries are signatory to this convention with Pakistan signed the convention in 1976.

The convention requires the signatories to impose strict regulation (including

penalization, confiscation of the specimen etc.) regarding trade of all species

threatened with extinction or that may become so, in order not to endanger further

their survival.

The Convention contains three appendices. Appendix I includes all species threatened

with extinction which are or may be affected by trade. The Convention requires that

trade in these species should be subject to strict regulation. Appendix II includes

species that are not necessarily threatened presently but may become so unless trade

in specimens of these species is subject to strict regulation. Appendix III includes

species which any contracting party identifies as subject to regulations in trade and

requires other parties to cooperate in this matter. See Table 6‐12, Table 6‐13 and Table

6‐14 for list of recorded wildlife species covered under CITES appendices.

e. International Union for Conservation of Nature and Natural Resources (IUCN)

Red List

The Red List is published by IUCN and includes those species that are under potential

threat of extinction. These species have been categorized as:

Endangered – Species that are seen to be facing a very high risk of extinction in the

wild in the near future, reduction of 50% or more either in the last 10 years or over

the last three generations, survive only in small numbers, or have very small

populations.

Vulnerable in decline – Species that are seen to be facing a risk of extinction in the

wild, having apparent reductions of 20% or more in the last 10 years or three

generations.

Vulnerable – Species that are seen to be facing a high risk of extinction in the wild,

but not necessarily experiencing recent reductions in population size.

Lower risk – Species that are seen to be facing a risk of extinction that is lesser in

extent that for any of the above categories.

Data deficient – Species that may be at risk of extinction in the wild but at the

present time there is insufficient information available to make a firm decision

about its status.


OCTOBER 2019 27 HPK

3.4.2 Relevant International Guidelines

a. World Bank Guidelines on Environment

The principal World Bank publications that contain environmental guidelines are

listed below:

Environmental Assessment – Operational Policy 4.01. Washington, USA. World

Bank 1999;

Environmental Assessment Sourcebook, Volume I: Policies, Procedures and Cross‐

Sectoral Issues. World Bank Technical Paper Number 139, Environment

Department, World Bank, 1991;

Environmental Assessment Sourcebook, Volume III: Guidelines for Environmental

Assessment of Energy and Industry Projects. World Bank Technical Paper No. 154,

Environment Department, World Bank, 1991;

Pollution Prevention and Abatement Handbook: Towards Cleaner Production,

Environment Department, the World Bank, United Nations Industrial

Development Organization and the United Nations Environment Program, 1998;

and

Environmental, Health and Safety (EHS) Guidelines, International Finance

Corporation (IFC) World Bank Group, 2007.

The first two publications listed here provide general guidelines for the conduct of an

EIA and address the EIA practitioners themselves as well as project designers. While

the Sourcebook in particular has been designed with Bank’s projects in mind and is

especially relevant for the impact assessment of large‐scale infrastructure projects. It

contains a wealth of information which is useful to environmentalists and project

proponents.

The Sourcebook identifies a number of areas of concern, which should be addressed

during impact assessment. It sets out guidelines for the determination of impacts,

provides a checklist of tools to identify possible biodiversity issues and suggests

possible mitigation measures. Possible development project impacts on wild lands,

wetlands and forests etc. are also identified and mitigation measures suggested. The

Sourcebook also highlights concerns in social impact assessment and emphasizes the

need to incorporate socioeconomic issues in EIA exercises.

The Sourcebook dealing with the assessment of industry and energy projects is more

specific. It contains a section on onshore development of O&G and identifies the

potential environmental impacts of E&P activities. These include surface disturbance

from the building of access roads in undisturbed areas, disturbance from explosive

charges and possible damage to cultural resources. Possible socio‐cultural issues that

may arise as a result of an influx of non‐locals are also identified in the Sourcebook.

The Pollution Handbook provides general waste management policies with specific

techniques for the prevention of air and water pollution. Project guidelines are


OCTOBER 2019 28 HPK

presented for major pollutants as well as typical emissions from industry sector

including oil and gas.

As of 30th April, 2007, the documents published in Volume III of the Pollution

Prevention and Abatement Handbook have been replaced by the new versions of EHS

Guidelines published by IFC. The EHS Guidelines are technical reference documents

that address IFCʹs expectations regarding the industrial pollution management

performance of its projects. They are designed to assist managers and decision makers

with relevant industry background and technical information. This information

supports actions aimed at avoiding, minimizing, and controlling EHS impacts during

the construction, operation and decommissioning phase of a project or facility. The

EHS Guidelines have become globally applied references for private sector

development with their use extending well beyond World Bank Group operations to a

diverse external community, such as other international financial institutions,

regulators, industry, academics and commercial banks, including the international

banks that have adopted the Equator Principles. Separate sets of guidelines have been

prepared addressing general EHS issues as well as guidelines specific to various

industrial sectors including onshore O&G development projects.

The EHS Guidelines for onshore O&G development include information relevant to

seismic exploration, exploration and production drilling, development and production

activities, transportation activities including pipelines, other facilities including

pumping, metering, pigging & compressor stations and storage facilities, ancillary and

support operations and decommissioning. A full description of industry activities for

this sector is also provided in the guidelines.

b. Environmental Management in Oil & Gas Exploration and Production, IOGP

This document provides an overview of environmental issues in the oil & gas

exploration and production processes and discusses potential environmental impacts

on the physical, biological and socioeconomic environment.

The document also recommends environmental management practices and

environmental protection measures such as waste treatment and disposal techniques,

pollution prevention and cleaner production, oil spill contingency planning,

decommissioning etc. for oil & gas exploration and production operations.

c. International Regulations and Guidelines for the Disposal of E&P Wastes

These include the following:

The Resource Conservation and Recovery Act of the United States, 1976 (hereafter

referred to as RCRA)

Environmental Guidance Document – Waste Management in Exploration and

Production Operations, American Petroleum Institute, API E5, 1997 (hereafter

referred to as API Guidelines)

Statewide Order 29‐B, State of Louisiana, Department of Natural Resources, 1990

(hereafter referred to as LSO 29‐B Regulations)


OCTOBER 2019 29 HPK

Colorado Oil and Gas Conservation Commission, Rules and Regulations (hereafter

referred to as COGCC Regulations)

The Interstate Oil and Gas Compact Commission guidelines on disposal of E&P

wastes (hereafter referred to as IOGCC Guidelines)

The United States Environmental Protection Agency (USEPA) under the RCRA

classifies all drilling fluids, produce water and drill cuttings as non‐hazardous. The

API and IOGCC Guidelines and LSO 29‐B and COGCC Regulations present various

options for the disposal of drilling fluids, produced water and drill cuttings including

land treatment, road spreading, on site burial and solidification, and recommend

maximum concentration levels for pH, metals, oil and grease and other inorganic

parameters to be met by each option. The most stringent limits of concentrations for

burial have been provided in API Environmental Guidance Document E5 ʺWaste

Management in Exploration and Production Operationsʺ provided in Table 3‐7, if the

waste exceeds these limits then the disposal should be in lined pits. Table 3‐8 provides

the less stringent criteria in terms of concentrations set by LSO 29‐B.

d. Environmental Guidelines for Worldwide Geophysical Operations, International

Association of Geophysical Contractors (IAGC); April, 1995

The IAGC guidelines provide guidance for the management of impacts from

geophysical operations related to:

Physical environment including water, air and soil;

Biological environment including vegetation and wildlife; and

Socioeconomic environment including archaeological sites, cultural practices and

commercial and recreational activities.

The guidelines require project operators to:

Plan and conduct operations in a manner that conserves the environment;

Train personnel in environmental matters;

Consult appropriate stakeholders at all stages of the operation; and

Evaluate environmental performance of operations and adopt restoration

measures.

International and National Environment & Conservation Organizations

3.5.1 International and National NGOs

International environmental and conservation organizations such as International

Union for Conservation of Nature (IUCN) and the Worldwide Fund for Nature

(WWF) have been active in Pakistan for some time now. Both these organizations have

worked closely with government and act in an advisory role with regard to the

formulation of environmental and conservation policies. Since, the convening of the

Rio Summit, a number of national environmental NGOs have also been formed and


OCTOBER 2019 30 HPK

have been engaged in advocacy and in some cases, research. Most prominent national

environmental NGOs, such as the Sustainable Development Policy Institute (SDPI),

Strengthening Participatory Organization (SPO), Shehri, Lead and Shirkatgah are

members of the Pakistan National Committee (PNC) of IUCN.

As mentioned earlier, environmental NGOs have been particularly active in advocacy,

as proponents of sustainable development approaches. Much of the governmentʹs

environmental and conservation policy has been formulated in consultation with

leading NGOs, who have also been involved in drafting new legislation on

conservation.

3.5.2 Pakistan Petroleum Exploration and Production Companies Association

(PPEPCA)

PPEPCA is an association of private sector companies and semi‐autonomous

departments concerned with exploration and production of O&G. It provides a forum

for such companies to discuss issues, formulate common strategies and convey

concerns and demands to the government and to other stakeholders in the O&G

business. PPEPCA has also been particularly effective in collecting and disseminating

information on current trends in exploration and production to its members and has

been instrumental in informing members of changes in government policy and in

formulating a response to such policy changes.


OCTOBER 2019 31 HPK

Table 3‐1: SEQS for Municipal and Industrial Effluentsa

Parameters Into Inland

Water

Into Sewage

Treatment5 Into Sea6

Temperature 40°C or temperature increase* ≤3°C ≤3°C ≤3°C

pH 6‐9 6‐9 6‐9

Biochemical Oxygen Demand (BOD5) at 20°C 1 80 250 80**

Chemical Oxygen Demand (COD)1 150 400 400

Total Suspended Solids (TSS) 200 400 200

Total Dissolved Solids (TDS) 3,500 3,500 3,500

Grease and oil 10 10 10

Phenolic compounds (as phenol) 0.1 0.3 0.3

Chloride (as Cl‐) 1,000 1,000 SC***

Fluoride (as F) 10 10 10

Total cyanide (as CN‐) 1.0 1.0 1.0

An‐ionic detergents (as MBAS)2 20 20 20

Sulphate (SO4) 600 1000 SC***

Sulphide (S‐) 1.0 1.0 1.0

Ammonia (NH3) 40 40 40

Pesticides3 0.15 0.15 0.15

Cadmium4 0.1 0.1 0.1

Chromium (trivalent & hexavalent)4 1.0 1.0 1.0

Copper4 1.0 1.0 1.0

Lead4 0.5 0.5 0.5

Mercury4 0.01 0.01 0.01

Selenium4 0.5 0.5 0.5

Nickel4 1.0 1.0 1.0

Silver4 1.0 1.0 1.0

Total Toxic metals 2.0 2.0 2.0

Zinc 5.0 5.0 5.0

Arsenic4 1.0 1.0 1.0

Barium4 1.5 1.5 1.5

Iron 8.0 8.0 8.0

Manganese 1.5 1.5 1.5

Boron4 6.0 6.0 6.0

Chlorine 1.0 1.0 1.0

Source: The Sindh Government Gazette, January 28, 2016

Notes: a All values are in mg/l, unless otherwise defined. 1 Assuming minimum dilution 1:10 on discharge, lower ratio would attract progressively stringent standards to be

determined by the Sindh Environmental Protection Agency. By 1:10 dilution means, for example that for each one

cubic meter of water for dilution of this effluent. 2 Methylene Blue Active Substance; assuming surfactant as biodegradable. 3 Pesticides include herbicides, fungicides and insecticides. 4 Subject to total toxic metals discharge should not exceed level given at S.N. 25.


OCTOBER 2019 32 HPK

5 Applicable only when and where sewage treatment is operational and BOD5=80mg/l is achieved by the sewage

treatment system.

6 Provided discharge is not at shore and not within 10 miles of mangrove or other important estuaries.

* The effluent should not result in temperature increase of more than 3°C at the edge of the zone where initial mixing

and dilution take place in the receiving body. In case zone is not defined, use 100 meters from the point of discharge.

** The value for industry is 200mg/l.

*** Discharge concentration at or below sea concentration (SC).


OCTOBER 2019 33 HPK

Table 3‐2: SEQS for Industrial Gaseous Emissiona

Parameter Source of Emission Standard

Smoke Any

40% or 2 on Ringlemann

scale or equivalent smoke

number

Particulate matterb

Boilers and Furnaces:

Oil fired 300

Coal fired 500

Cement kilns 300

Grinding, crushing, clinker

coolers and related processes,

metallurgical processes,

converter blast furnaces and

cupolas

500

Hydrogen chloride Any 400

Chlorine Any 150

Hydrogen fluoride Any 150

Hydrogen sulfide Any 10

Sulfur oxidesc

Sulfuric acid/Sulfonic acid

plants 5,000

Other plants except power

plants operating on oil and

coal

1,700

Carbon monoxide Any 800

Lead Any 50

Mercury Any 10

Cadmium Any 20

Arsenic Any 20

Copper Any 50

Antimony Any 20

Zinc Any 200

Oxides of nitrogend

Nitric acid manufacturing unit

3,000 Other plants except power

plants operating on oil or coal

Oil Fired 400

Coal fired 600

Cement kilns 1,200


Notes: a All values are in mg/Nm3, unless otherwise defined. b Based on the assumption that the size of the particulates is 10 micron or more. c Based on 1% sulphur content in fuel oil. Higher content of sulphur will cause standards to be pro‐rated.


OCTOBER 2019 34 HPK

d In respect of the emissions of the sulfur dioxide and nitrogen oxides, the power plants operating on oil or coal as

fuel shall, in addition to standard specified above, comply with the following standards.


OCTOBER 2019 35 HPK

Table 3‐3: SEQS for Motor Vehicle Exhaust and Noisea

Parameter Standard Measuring Method

Smoke

40% or 2 on the Ringlemann

scale during engine

acceleration mode

To be compared with Ringlemann

Chart at a distance of 6 meters or

more

Carbon Monoxide New vehicles: 4.5%

Used vehicles: 6%

Under idling conditions, non‐

dispersive infrared detection

through gas analyzer

Noise 85 dB (A) Sound‐meter at 7.5 meters from the

source


Notes: a For in‐use vehicles

Table 3‐4: Sindh Environmental Quality Standards for Noise

No. Category of Area/ Zone

Effective from

1st January, 2015

Effective from

1st January, 2015

Limit in dB(A) Leq

Day Time Night Time Day Time Night time

1. Residential area (A) 65 50 55 45

2. Commercial area (B) 70 60 65 55

3. Industrial area (C) 80 75 75 65

4. Silence zone (D) 55 45 50 45


Notes:

1. Day time hours: 6.00 am to 10.00 pm

2. Night time hours: 10.00 pm to 6.00 am

3. Silence zone: Zones which are declared as such by the competent authority. An area comprising not less than 100

meters around hospitals, educational institutions and courts.

4. Mixed categories of areas may be declared as one of the four above mentioned categories by the competent

authority.

5. dB(A) Leq: Time weighted average of the level of sound in decibels on scale A which is relatable to human

hearing.


OCTOBER 2019 36 HPK

Table 3‐5: Sindh Standards for Drinking Water Quality

No. Properties/Parameters Proposed Standard Values for Pakistan

Bacterial

1.

All water intended for drinking

(E.Coli or thermotolerant coliform

bacteria)

Must not be detectable in any 100 ml

sample

2.

Treated water entering the

distribution system (E.Coli or

thermotolerant coliform and total

coliform bacteria)


sample

3.

Treated water in the distribution

system (E.Coli or thermotolerant

coliform and total coliform bacteria)


sample. In case of large supplies, where

sufficient samples are examined, must not

be present in 95% of the sample taken

throughout any 12‐month period.

Physical

4. Colour < 15 TCU

5. Taste Non objectionable/Acceptable

6. Odour Non objectionable/Acceptable

7. Turbidity < 5 NTU

8. Total hardness as CaCO3 < 500 mg/L

9. TDS < 1000

10. pH 6.5‐8.5

Radioactive

11. Alpha Emitters bq/L or pCi 0.1

12. Beta emitters 1

Chemical

Essential Inorganics mg/L

13. Aluminium (Al) < 0.2

14. Antimony (Sb) < 0.005

15. Arsenic (As) < 0.05

16. Barium (Ba) 0.7

17. Boron (B) 0.3

18. Cadmium (Cd) 0.01

19. Chloride (Cl‐1) < 250

20. Chromium (Cr) < 0.05

21. Copper (Cu) 2

Toxic Inorganics mg/L

22. Cyanide (CN) < 0.05

23. Fluoride (F)* < 1.5

24. Lead (Pb) < 0.05

25. Manganese (Mn) < 0.5

26. Mercury (Hg) < 0.001

27. Nickel (Ni) < 0.02


OCTOBER 2019 37 HPK

No. Properties/Parameters Proposed Standard Values for Pakistan

28. Nitrate (NO3)* < 50

29. Nitrite (NO2)* < 3

30. Selenium (Se) 0.01

31. Residual chlorine 0.2‐0.5 at consumer end 0.5‐1.5 at source

32. Zinc (Zn) 5.0


* Indicates priority health related inorganic constituents which need regular monitoring.


OCTOBER 2019 38 HPK

Table 3‐6: SEQS for Ambient Air

No. Pollutants

Time‐

weighted

Average

Concentration in Ambient

Air Method of

Measurement Effective

from 1st Jan,

2009

Effective from

1st Jan, 2012

1. Sulfur Dioxide

(SO2)

Annual

Average* 80 μg/m3 80 μg/m3 Ultraviolet

Fluorescence method 24 hours** 120 μg/m3 120 μg/m3

2. Oxide of Nitrogen

as (NO)

Annual

Average* 40 μg/m3 40 μg/m3 Gas Phase

Chemiluminescence 24 hours** 40 μg/m3 40 μg/m3

3. Oxides of

Nitrogen as (NO2)

Annual

Average* 40 μg/m3 40 μg/m3 Gas Phase

Chemiluminescence 24 hours** 80 μg/m3 80 μg/m3

4. O3 1 hour 180 μg/m3 130 μg/m3 Non dispersive UV

absorption method

5.

Suspended

Particulate Matter

(SPM)

Annual

Average* 400 μg/m3 360 μg/m3

High Volume

Sampling, (Average

flow rate not less

than 1.1 m3/minute) 24 hours** 550 μg/m3 500 μg/m3

6.

Respirable

Particulate Matter.

PM10

Annual

Average* 200 μg/m3 120 μg/m3 ß Ray absorption

method 24 hours** 250 μg/m3 150 μg/m3

7.

Respirable

Particulate Matter.

PM2.5

Annual

Average* 25 μg/m3 15 μg/m3

ß Ray absorption

method

24 hours** 40 μg/m3 35 μg/m3

1 hour 25 μg/m3 15 μg/m3

8. Lead (Pb)

Annual

Average* 1.5 μg/m3 1 μg/m3

ASS method after

sampling using EPM

2000 or equivalent

filter paper 24 hours** 2 μg/m3 1.5 μg/m3

9. Carbon Monoxide

(CO)

8 hours** 5 μg/m3 5 μg/m3 Non Dispersive Infra

Red (NDIR) method 1 hour 10 μg/m3 10 μg/m3


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

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

days.


OCTOBER 2019 39 HPK

Table 3‐7: API Standard for On‐site Burial of E&P Wastes in Unlined Pitsa, b, c

No. Parameter Standard

1. pH 6‐9

2. Total Petroleum Hydrocarbons < 1% (dry weight)d

3. Arsenic 41

4. Barium 180,000

5. Cadmium 26

6. Chromium 1,500

7. Copper 750

8. Lead 300

9. Mercury 17

10. Molybdenum 37

11. Nickel 210

12. Selenium 100

13. Zinc 1,400

14. Boron 2 mg/Le

15. Sodium adsorption ratio (solution phase) < 12

16. Exchangeable sodium percentage (solid phase) < 15%

17. Electrical conductivity < 4 mmho/cm

Source: API E5 Second Edition of Environmental Guidance Document, Waste Management in Exploration and

Production Operations (February 1997), Section 5.5.4

Notes:

a All values in mg/kg unless otherwise stated

b Waste exceeding the following limits should be buried or land‐filled in lined pits (provided the limits of pH, TPH

and EC are complied with)

c The standards also require that the top of the burial cell must be at least five feet below ground level and the

bottom of the burial cells must be five feet above seasonal high water table

d Dry weight

e Based on the soluble concentration with units of mg/L rather than total concentration


OCTOBER 2019 40 HPK

Table 3‐8: LSO 29B Criteria for On‐site Burial in Unlined Pits

No. Parameter Standard

1. pH 6‐9

2. Oil and Grease < 3% (dry weight)

3. Arsenic 10 ppm

4. Barium (Upland area) 40,000 ppm

5. Cadmium 10 ppm

6. Chromium 500 ppm

7. Lead 500 ppm

8. Mercury 10 ppm

9. Selenium 10 ppm

10. Silver 200 ppm

11. Zinc 500 ppm

12. Electrical Conductivity < 12 mmho/cm

13. Moisture Content < 50 % by weight

Source: State wide order No. 29‐B (June, 2010)

Notes:

1‐ The top of the burial cell must be at least five feet below ground level.

2‐ The bottom of the burial cells must be five feet above seasonal high water table.


OCTOBER 2019 42 HPK

4 Project Description

The Proposed Project

United Energy Pakistan Limited (UEPL) intends to carry out exploration and

associated development activities in Kotri North Block (E.L. 2568‐21). These

activities range from 2D/3D seismic surveys, drilling of exploration/

development wells, laying of flow line/s from producing wells to the



associated civil and engineering works e.g. construction of access track/s,

residential camp/s, construction of well site/s etc. and finally decommissioning

and site restorations. Proposed project activities will be commenced with 2D/3D

seismic survey and based upon the aforementioned seismic data acquisition and

its interpretations, UEPL will plan to drill wells as part of exploration/

development plan. After the successfully drilling at any proposed well location

and in case of discovery, flow line/pipeline will be laid from each well to the

new/existing hydrocarbons gathering and production system over the period of

three years. Detailed proposed project activities will include but not limited to

be are listed below:





for the purpose);












Sites restoration.


OCTOBER 2019 43 HPK

The details of core activities i.e. seismic, drilling, laying of flow line and establishment

of processing facility are provided in following sections of this chapter.

Seismic Operation

The objective of the seismic survey is to delineate the subsurface geological structure

beneath the area in order to investigate the potential for oil & gas reserves and to

identify a suitable surface location for the drilling of wells. The principle of seismic

survey is to cause shock waves in the ground which reflect from geological strata. By

measuring the time taken to receive the shock waves at detectors at the ground surface

(called “geophones”), a picture of the subsurface geology can be developed.

There are two basic types of seismic data acquisition techniques are being used in

Pakistan i.e. two dimensional (2D) and three dimensional (3D). The seismic operation

proposed by UEPL comprise of both 2D and 3D seismic data acquisition within the

project area. Two dimensional seismic data collection occurs along a line of receivers

therefore, the resultant image represents only a section below the line. A three

dimensional seismic survey utilizes multiple points of observation. This is

accomplished by deploying a grid of geophones and seismic source impact points

along the surface of the area being studied. The result is a volume or cube of seismic

data sampled from a range of different angles and distances. In a typical 2D survey,

seismic lines can be many kilometres apart, whereas in a 3D survey, they are generally

a few hundred meters apart.

Two types of techniques will be used for data acquisition; vibroseis in the terrain with

gentle slopes and flat areas; dynamite within agricultural lands and all other areas

where access or working of the vibroseis will be difficult. Upholes may be drilled at

selected locations within the area of the seismic survey.

Each seismic operation will involve housing about 800 – 1,000 people in a seismic

campsite (depending upon the technique being used). In terms of resource utilization,

water will be used for domestic and operational purposes. Earth fill material may be

required for the construction and operational purposes. Local labour will also be

employed during the operation. A description of activities involved in proposed

seismic program is provided in sections below.

4.2.1 Line Permitting

Before commencement of work, a permitting team headed by a Chief Permit Man will

arrive in the area. The teamʹs early arrival will facilitate activities such as liaising with

local landowners and authorities to inform them of the operation and make necessary

arrangements. The permitting team will identify the ownership of the land areas over

which the seismic operation will be undertaken. In consultation with the respective

district administration and following agreed rates, compensation will be given to the

landowners. During the seismic survey the Chief Permit Man will be the focal point

for communication between local inhabitants and seismic survey personnel.


OCTOBER 2019 44 HPK

4.2.2 Line Survey and Preparation

In this activity the seismic lines will be marked on the ground by survey teams, each

team comprising of 4 to 5 people. The survey teams will use a Global Positioning

System (GPS) to mark shot points on the seismic lines at every 20 – 50 m intervals with

whitewashed stones or wooden pegs.

In plain areas, for laying of seismic lines, area may be cleared (if required) to a width

of 3 m and at a depth of a few inches with a bulldozer. This will allow the movement

of vibroseis over the cleared strip of land along the line. Clearing of trees and dense

patches of vegetation will be avoided. Seismic lines passing through agricultural fields

will not be cleared, as dynamite will be used as the energy source in these areas.

4.2.3 Data Acquisition

a. Dynamite

In this technique, 1 – 20 meters deep and 10 cm diameter holes, called shot holes, will

be drilled every 20 – 50 m along sections of the seismic lines passing through

agricultural lands or areas where access or working of vibroseis will be difficult. These

holes will be drilled using portable hand driven drills. Each drill will be operated by a

team of 6 to 8 drillers headed by a foreman. A total of 5 to 10 drilling teams will be

employed on each line. It is expected that each team will be able to drill 6 to 8 holes

per day depending on the geological and environmental conditions of the area. If

required each drilled hole will be cased with a Polyvinyl Chloride (PVC) pipe to

prevent the hole from collapsing. If a shot point cannot be drilled at a specified

location because of any environmental restriction, a replacement point will be located

as close to the original shot point as possible. Seismic drilling activity will not be

carried out at stream beds. However, cables and geophones will be laid across the

surface water bodies for data acquisition purposes.

Due to loose soil material wherever expected in the area the holes during drilling will

be flushed with bentonite mud. The bentonite mud will be prepared near the shot

point in a 2 m square and 0.5 m deep earthen pit. Water tankers will transport water

required for the preparation of the mud. These water tankers will travel only on

existing and approved tracks. In case an existing track does not reach to a shot point,

the tanker will stop on the track at a position nearest to the shot point, from thereon

water will be transported by means of hose pipes connected to the tanker. The spent

drilling mud and cuttings will be stored inside a similar earthen pit. The spent mud

and cuttings will be allowed to dry after which the pit will be backfilled with at least

15 cm of top soil cover. The pits will be clearly marked until restored. Since, bentonite

is a type of clay and a non‐hazardous material, burial of the mud and cuttings on site

will not contaminate soil or groundwater.

After completion of drilling, each shot hole will be loaded with approximately 0.5 – 3

kg of dynamite and 1 or 2 detonators. Explosives will be handled by a loading crew

who will be specially trained in the handling, storage, transportation, charging, firing


OCTOBER 2019 45 HPK

and safety of dynamite. The charges will be carefully inserted into each hole before the

cylindrical PVC casing is removed. Each hole will then be backfilled with sand/mud.

Approximately 70 labourers divided into six teams including front crew, back crew,

shooting crew, recording crew and green crew will carry out shooting, recording and

restoration along the seismic lines. These teams will operate several days behind the

drilling team.

The front cable crew will layout the cables and plant geophones along the seismic line.

The cables and geophones will be symmetrically laid out 3 – 4 km along the seismic

line on either side of a shot point. The geophones connected together in groups of 24

or more will be planted along the line at intervals of 1 to 5 meter. Each string of

geophones will be connected to a cable, which will be connected to a station unit. The

station units will be connected to a recording unit through the same cable. The points

along which cables and geophones will be laid are termed receiver array.

The shooting crew will be responsible for the detonation of charges. Once the cables

and geophones have been symmetrically laid out along the line, the charge is

detonated by a crew comprising of 4 men. At the surface the sound of the detonation

will be no more than a muffled thud. The process is repeated along the line, cables and

geophones being removed from the back of the line and placed at the front of the line

as the shooting crew progresses.

The recording crew will monitor the ground electronics equipment and recording of

the seismic data. The back cable crew will be responsible for picking up the cables,

geophones and station units. The green crew will follow the back cable crew and

remove any wastes from the seismic lines and restore the shot holes as close to their

original condition as possible.

b. Upholes

Upholes will be drilled with the help of truck mounted drilling rig. These holes will be

drilled to a depth of up to 150 m and will be 150 mm in diameter. To ensure stability of

the borehole, a water based bentonite mud will be circulated through the hole. It is

estimated that for each hole approximately 5,000 to 8,000 litres of water will be

required for the preparation of the bentonite mud. The mud will be prepared in an

earthen pit near the hole. A similar pit will be used to store the used mud. After

drying the pits along with their contents (bentonite mud and cuttings) will be

backfilled. Data from upholes will be collected either by a hammer source at the

surface and a string of geophones suspended inside the hole or by using detonators

inside the hole to receiver at the surface.

c. Vibroseis

This technique will make use of vibrators as an energy source. The vibrator consists of

a heavy mass (up to 50 tons) attached to a steel plate mounted on a truck. The truck

will lower the steel plate to rest on the ground while lifting the body of the truck in air

by means of hydraulic jacks. The steel plate will be made to vibrate, creating energy


OCTOBER 2019 46 HPK

waves that will travel downwards into the earth’s surface. The reflected waves will be

received on the ground by cables and geophones laid along the seismic line.

The arrangement of cables, geophones and station units will be similar to the

arrangement adopted for dynamite. A series of four vibrators will follow each other

along the line. All 4 vibrators will stop at a point called vibroseis point and produce

energy waves in the manner described above. With this technique approximately 5 – 8

km of line can be recorded each day again depending on the topography of the area.

4.2.4 Camps, Staffing and Supplies

One base camp and a fly camp (if required) will be prepared to house around 800 –

1,000 crewmembers depending on the technique being used for the seismic data

acquisition during each seismic survey. The camps will be located and constructed

such that minimum clearing of vegetation or land is involved land maintaining a safe

distance from the communities and sensitive environmental habitats. The approximate

area for the seismic base camp will be 40,000 square meters (m2) and will include

accommodation area including tents and porta‐cabins, senior and junior kitchens and

mess, laundry area, toilets, workshops, vehicles parking area, equipment storage

areas, fuel and oil storage areas, generators area, septic tanks, soak pits and a garbage

pit. The camps will be fenced for security reasons. An advance party will prepare the

base camp. Survey work will start only after satisfactory set up of the base camp.

Approximately 40,000 litres of water would be required per day for the seismic

operation, which will be primarily used for domestic purposes. Flush and uphole

drilling consumes approx. 4~5,000 litres and 8,000 litres of water per hole respectively.

Except flush and uphole drilling, use of jackrobs drilling (if required) and vibroseis

operation will not require water.

A bulk stock of dynamite will be transported to the project area. This will be stored in

a purpose built explosive storage area ‘magazine’ located at a safe distance from

communities and the seismic camps (base & fly). The explosives will be stored in an

excavated pit lined with concrete blocks and covered with tarpaulins. The area will be

fenced and guarded for security reasons.

4.2.5 Access and Transport

Access to seismic lines will mostly be through existing tracks. As 4WD vehicles will be

used by the project, these tracks can be used without any improvement. Short reaches

of new tracks may have to be prepared in areas where there is no existing access

however, the preparation of new tracks will be minimized. Vehicles and equipment

likely to be used during seismic operation will include Dozers, Trucks, Unimog

Recorder Truck, Cranes, Uphole Rigs, Jackrobs, Air Compressors, Water Tankers, 4x4

Pick‐ups/Jeeps, Explosive Vehicles, Fuel Tankers, Vibrators, Tents, Porta‐cabins,

Ambulances and Generators.


OCTOBER 2019 47 HPK

4.2.6 Restoration and Waste Management

After completion of the every seismic operation, the campsites (base & fly) will be

restored to as close to its original condition as possible. For reference purposes a

photographic record of the campsites prior to setup will be taken. The following

activities will be carried out for site restoration:

Demobilization of all equipment and machinery;

Disposal of any waste material remaining at the time of completion of the

operation;

Backfilling of all soak pits and septic tanks;

Dismantling and removal of fence or barriers surrounding the camp area; and

General restoration of the site area including landscaping and restoration of

drainage where required.

Restoration of seismic lines will include removal of all cables, geophones, station units,

flags, stakes and wastes from the lines and backfilling of all mud pits. For reference

purposes a photographic record of selected sections of seismic lines will be taken

before and after the operation.

Drilling Operation

4.3.1 Proposed Project Activities

This operation will comprise of drilling of exploratory/development wells within

prospective areas based on the 2D & 3D seismic data interpretations. The proposed

drilling project will entail the following activities:

Phase I – Construction

o Civil contractor’s mobilization

o Development of access road

o Rig camp construction

o Security camp construction

o Well site construction

o Civil contractor’s demobilization

Phase II – Well Drilling

o Rig mobilization and rig camp establishment

o Well drilling and testing

o Vertical Seismic Profiling (VSP)

o Rig demobilization

Phase III − Site Restoration (depending on the failure or success of the well)


OCTOBER 2019 48 HPK

4.3.2 Project Schedule

The drilling operation of each well, from civil works to plugging and abandonment is

expected to take about 4~5 months. The drilling of wells is planned after the

acquisition of 2D & 3D seismic data and its interpretation by United Energy Pakistan

Limited. The tentative duration of key activities is provided below:

Mobilization 15 days

Civil works 60 days

Drilling 60 days

Testing 15 days

4.3.3 Construction

In this phase of the operation, a well site, rig camp, security camp and access track will

be developed for each proposed well. The construction contractor will develop its own

camp for construction purposes. The camp will house a maximum of 200 people. The

contractor will also hire local people for unskilled jobs. The construction works will

take approximately 60 days to complete.

The well site and rig camp will cover an area of approximately 32,400 and 8,000 m2

respectively. Well site construction will involve the following:

Clearing, leveling and compaction;

Construction of the concrete drilling rig pad and cellar;

Construction of cutting pit, water pit and wastewater pits;

Construction of septic tanks and soak pits;

Construction of flare pit;

Construction of platform for fuel storage tank with sump and loading/un‐loading

pad; and

Installation of a chain link fence around the well site along with snake protection

and ditch.

The rig campsite will consist of porta‐cabins, kitchens, mess rooms, bathrooms,

laundry area etc. for which limited construction works including levelling, grading,

filling and compaction will be required. Development of campsite includes, but not

limited to the following:

Leveling and compaction of area for the campsite;

Provision of drainage works in and around the campsite;

Laying and compaction of the gravel or rock topping in the campsite;

Construction of fuel storage tank with sump and loading/un‐loading pad;

Provision of fence, access and emergency gates;


OCTOBER 2019 49 HPK

Construction of septic tank and soak pits;

Installation of security guard wooden cabins; and

Installation of sewerage flow line with manholes for the septic system.

Construction works to develop the access road will include, but not limited to the

following:

Cutting and filling;

Leveling, grading and compaction of subgrade;

Laying of gravel and compaction;

Construction of culverts and causeway crossings (if required);

Provision of earthen catch drains;

Provision of pass points at every 1,000 m; and

Provision of milestones, road and safety signs.

Existing tracks will be used as much as possible to access the selected drilling

locations. Due to the network of existing tracks in the area, development of new tracks

may be limited to short reaches of a few kilometers only. The existing tracks will be

upgraded (if required) to a standard that is suitable for movement of 40 ft. trailers. The

road will be 6 m wide, consisting of 5 m gravel top and 0.5 m of earthen shoulder on

either side.

Water required during construction will be obtained from either local tube wells, or

new water wells installed by UEPL in the area of operation. Approximately 80,000

liters of water would be required per day during construction phase. After completion

of construction activities, all except for a few machinery, equipment and personnel

required for maintenance of the access road will be demobilized from the area.

4.3.4 Rig Mobilization

Following the construction of the each well site, campsite and access road mobilization

of the rig and related machinery and equipment will commence. Mobilization will

involve the transportation of the following to the designated drilling location:

The drilling rig;

Ancillary equipment such as power generators, mud pumps, mud tanks, shale

shakers, cementing unit, drill pipe and collars;

Porta‐cabin style camp, complete with all catering, power generation, laundry and

other facilities;

Drilling and other necessary support personnel; and

Drilling materials such as casing and associated accessories, wellheads, drill bits,

drilling fluid chemicals and liner hanger equipment etc.


OCTOBER 2019 50 HPK

The drilling rig will be transported to the site using 40 ft. long trailers. Depending on

the type of rig, approximately 80 to 150 truckloads of equipment will be transported

during mobilization. The rig will be assembled and erected over the well location.

4.3.5 Drilling

Drilling will be carried out using conventional equipment, techniques and practices

for drilling operation. A rotary drilling rig will be used in this operation. The derrick

will be mounted on a steel platform known as the rig floor. The rig floor will provide

working area for the drilling operations and personnel. A hoisting drum called draw

works will be mounted on the rig floor at the base of the derrick. A wire rope called

the drilling line will pass from the draw works to the top of the derrick through a

system of pulleys called the crown block and will be attached to a further system of

pulleys known as the hook and block. The whole system of wire rope and pulleys will

operate like a crane. A drill string made up of uniform lengths of hollow steel pipes

will be suspended from the hooks. Suspended from the drill string will be the drill bit.

The drill bit will drill through the formations by the combined effect of the weight of

the drill collar and the rotary action provided to the bit by a rotary table mounted on

the rig floor. Rotation of the drilling bit and string is achieved by means of powerful

electric motors on the surface.

Based on the sections of the well, drill bits with diameter 26, 171/2, 121/4, 81/2 and 6 inches

are expected to be used. As drilling progresses in a given section of the well the length

of the drill string will be increased by the addition of new lengths of pipes. Steel pipes

known as casing will be lowered into the hole to line the sides of the well and prevent

the hole from collapsing. At the end of drilling each section, these steel casings will be

cemented into place by pumping cement into the space between the casing and the

surrounding strata. The sections of the well will be drilled in this manner until the

desired target depth is achieved. Anatomy of a generic rotary drilling rig is shown in

Figure 4‐1. The drilling operation will be undertaken on a round‐the‐clock basis with

two 12 hours shifts.

a. Drilling Mud

A water based drilling mud will be used during the operation to serve the following

functions.

Flushing out drilled solids from the bottom of the hole and their transport to the

surface;

Lubrication and cooling of the drill bit and string;

Deposition of an impermeable layer on the wall of the wellbore so as to seal the

drilled formations; and

Countering the natural formation pressures and preventing uncontrolled flow of

fluid from the formations.


OCTOBER 2019 51 HPK

The drilling mud will consist of slurry of formation cuttings suspended in a liquid

phase. Fresh water spud mud will comprise of Bentonite, Sodium hydroxide (NaOH),

Sodium carbonate (Na2CO4) and lime (CaO) in water. The additives such as bentonite,

barite and salts will be used for initial mud formulation and subsequent changes as

required during the operation. The exact constituents and concentrations will be

finalized before the drilling operation. The quantity & composition of drilling mud

used and the cuttings generated will depend upon the well geology, depth of the well

and other operating factors.

b. Management of Drilling Wastes

Conventional drilling waste management involves discharging the mud and cuttings

into a lined waste pit. However, UEPL may use a cuttings segregation and fluid

recovery unit in which the cuttings segregated by the shakers are processed through

centrifuges and Hi‐G dryer. This will further allow:

Additional drying of the cuttings making their disposal into the lined waste pit

easier;

Recovery of the excess mud associated with the cuttings. The mud can be re‐used

thereby reducing the overall water consumption and chemical usage for mud

formulation; and

Reduction in the size of the waste pit due to the reduction in the mud content

associated with the cuttings and due to less water consumption and mud

formulation.

This waste management system is considered to be technologically and

environmentally the most preferred option. After completion of drilling, the cuttings

remaining in the waste pit will be allowed to dry out. The cuttings will then be

encapsulated within the HDPE liner and the waste pit will be backfilled leaving a top

soil cover over the pit at the time of site restoration.

c. Coring & Well Logging

In the potential reservoir section, cores of rock may be taken from the borehole and a

number of well logs performed. Cores and well logs will be used to confirm the

geology of the structures being bored through and assess the accuracy of the seismic

survey data interpretation carried out before drilling operation. Coring and well

logging will also help identify possible hydrocarbons.

d. Well Evaluation

After having drilled to the specified depth, a number of logs for hydrocarbon bearing

strata will be taken to accurately measure the pressure and fluid content of the zone.

The main objectives of the logs will be to determine the fluid composition (gas, oil or

water), whether or not it will flow and its pressure regime.


OCTOBER 2019 52 HPK

If test results show that gas has been encountered, it becomes necessary to conduct

further tests to determine whether it is feasible to develop the well. Tests are

conducted to determine the gas composition and the reservoirʹs permeability.

Once the temporary or permanent valves are in place, it is ensured that the mud

column is more than adequate to counteract any formation pressures that could be

released. After that, a mechanical plug is used to plug off the area of the formation

being tested, and tubing is run through the plug. A Blowout Preventer (BOP) is kept in

place throughout the test.

Once these steps have been taken, gas is allowed to flow to the surface and is passed

through a 3‐phase separator that segregates the fluid into water, gas and oil or

condensate. Metering devices and valves are used to estimate the gas production rate,

after which the gas and associated condensate are flared and water discharged into the

mud pit.

e. Well Completion

If data collected from coring, logging and well testing shows that the well can be used

as a producing well then a completion string together with a few items of subsurface

equipment (such as a down hole plug) to enable production from the well will be

installed just above the producing formation. The mud in the well will be displaced by

completion fluid, which is expected to consist of potassium chloride brine, containing

small volumes of chemicals designed to protect the well. These chemicals will include

a corrosion inhibitor, an oxygen scavenger, biocide and a chemical for pH control. The

final design of the completion equipment will depend on the subsurface geology.

f. Well Control & Blowout Prevention

In addition to careful monitoring and control of the mud system and the installation of

casing in each section of the well, a surface wellhead consisting of a series of BOPs will

be installed at the top of the casing. The function of the BOP is to prevent uncontrolled

flow from the well by positively closing in the wellbore as and when required. The

BOP is made up of a series of hydraulically operated rams and is designed to

withstand pressures well in excess of those expected to be encountered.

g. Staffing and Supplies for Drilling

It is expected that around 160 – 180 people will be required for each drilling operation.

Local people will be hired for unskilled jobs. During the drilling program the supplies,

with the exception of casing will be transported to the rig in smaller trucks. Casing

will be carried to the rig in 40 ft. flatbed trucks. General supplies transported will

include camp supplies (food etc.), fuels, oils and chemicals and equipment

maintenance parts. Project personnel will travel to and from the rig in smaller vehicles,

mostly four‐wheel drive pickups.

Water for rig and rig camp operation will be transported to the project facilities from

local water wells or to be installed by UEPL in the project area in consultation with

local communities and by following the requirements of the EIA. A maximum of


OCTOBER 2019 53 HPK

80,000 litres of water will be required per day during the drilling operation, which

may exceed to 150,000 litres during peak drilling activity. The surface water resources

will not be used during drilling phase. Average water consumption during the camp

operation for different O&G operations is shown in Table 4‐1.

4.3.6 Demobilization & Site Restoration

After completion of the drilling and testing operations, the rig will be dismantled and

demobilized off the site. The wellhead will remain in situ, but all other equipment and

materials including empty drums used and unused chemicals, fuels and lubricants

will be removed from the well site by their respective suppliers.

After well evaluation, a decision on whether to abandon or further develop the well

will be taken. If it is decided that the well is to be abandoned, the site will be restored,

as far as possible, to its original condition. All the concrete structures will be broken

up and removed, the fencing will be removed and the area levelled. All the broken

concrete may be taken outside of the project area for disposal, reused for backfilling of

pits or provided to locals for re‐use. All waste products, solid and liquid will be

disposed of in accordance with the requirements of the EIA. All pits will be backfilled.

Drill cuttings will be disposed of within the lined cuttings pit at the well site. Drilling

mud and other liquids will be allowed to evaporate inside the lined pit after which the

pits will be backfilled. The access tracks may be left intact if local people desire to use

them. If not, they too will be restored and the land returned to its original use.

4.3.7 Produced Water Injection Well

Produced water injection wells are also part of the proposed exploration and

development project. Produced water from the producing wells will be re‐injected into

deep subsurface formations wherever feasible. Drilling will not be carried out and

only plugged and abandoned well/s will be used for the safe disposal of produced

water from the nearby producing wells which will be connected through a nominal

diameter of pipeline.

Flow Line Laying & Tie-in/Wellhead Works

In case of discovery at any proposed drilling location, a flow line will be laid to

connect it to gathering hub and ultimately to the gas processing facility. Pipelines used

for this purpose will be dependent on specifications of fluid properties. Shortest

possible route will be selected for laying of flow line.

4.4.1 Flow Line Laying Activities

Flow lines will be laid to connect the well site to the existing/new processing plant by

carbon steel NACE flow line which will be dependent on flow rate/production. Laying

of proposed flow lines will primarily be done along the existing and proposed access

tracks to the well sites. Flow line laying activities will include the following:

Land survey;

Right of way (RoW) preparation;


OCTOBER 2019 54 HPK

Transportation of pipes, construction materials, construction machinery and

personnel;

Installation (trenching, laying and backfilling);

Cleaning, testing and commissioning;

Operation and maintenance;

Site Restoration; and

Flow line decommissioning.

A brief description of these activities is as follows:

a. Land Survey

Land survey for demarcating the pipeline route will be undertaken by a team of about

5 to 6 persons equipped with computers, survey stations, GPS handsets, levelling

instruments, steel measuring tapes and worktables. The following activities are carried

out as part of the survey:

Route reconnaissance;

Traverse line survey and installation of wooden pegs;

Topographic survey of pipelines, RoW and terminals;

Excavation and re‐filling of pits for classification and record of soil encountered;

Determination of subsoil water table in the area and land type classification e.g.

fallow land or cultivated areas;

Survey of pipeline crossings at roads or water channel etc.;

Installation of RoW markers; and

Installation of permanent benchmarks.

b. Right of Way (RoW) Preparation

A 50 ft. RoW along the proposed alignment will be leased from the local landowners.

RoW for the proposed gas flow line will be cleared of vegetation and levelled before

the trenching operation is started.

The RoW route will be selected with the following considerations:

Selection of the shortest possible route;

Maximum usage of existing RoW of access route and flow line laid thereby,

minimizing access requirements during the construction period and avoiding

acquisition of private land;

Minimum disruption to the local population, in particular avoidance of any

population resettlement;

Maintaining a safe distance from cultural resources (typically a distance of 50 m

from shrines, graveyards and mosques); and


OCTOBER 2019 55 HPK

Minimum disruption to the natural environment.

c. Transportation and Construction Activities

The laying of pipeline will be done by a construction contractor. The construction

contractor will employ a crew of around 150 – 200 people for pipeline laying. Local

people will be hired for unskilled jobs as and when required during the project subject

to company’s competency criteria and in accordance to all local applicable laws. The

construction equipment required during the pipeline laying typically includes:

Bulldozer

Excavator

Forklift

Pipe layer

Grader

Compressor

Welding machine

Radiography

Sand blasting machine

Pumps; and

Pipe‐bending machines.

The crew may work in separate teams and may reside in one or two fly camps

established at different locations. The camp will consist of tented accommodation,

kitchens, mess rooms, bathrooms, laundries, septic tanks and soak pits etc. for which

limited construction work will be required. At campsite the contractor may also utilize

levelled areas for storage of pipes and other materials and machinery. The pipes will

be transported to the site in up to 40 ft. sections over flatbed trucks. The construction

material and construction machinery will be transported to the site on trucks. Trucks

or pick‐ups will transport all other supplies to the camps. This will include

construction material and consumables, fuel, oil, water and food. At campsite fuel, oil

and chemicals will be unloaded in designated areas with impermeable floors and

dykes to prevent soil and water contamination from spills. Water consumed during

pipeline laying (cleaning and hydro‐testing) will be transported to the site from the

nearest local wells or from UEPL’s existing or new wells (if required) to be installed by

the company according to the requirements of EIA.

d. Flow Line Installation

A trench approximately 3 ft. wide by 5 ft. deep for laying of pipeline (to connect

producing well to the storage or processing facility) will be excavated. The pipeline

will be laid along the side of the trench and welded together. Welded sections of the

line will then be placed at the bottom of the trench by pipe layers or/and cranes


OCTOBER 2019 56 HPK

moving along the line. The pipeline will be below the ground along its entire route

and will be installed in a trench with a minimum depth of one meter, which will be

backfilled to be flushed with the surrounding ground level, with the top soil replaced.

e. Flow Line Cleaning, Testing and Commissioning

Once a section of a pipeline has been installed, it will be cleaned by sending a traceable

brushing pig down the section. This will remove some of the debris and water that has

accumulated in the pipeline during construction. The line will then be flushed with

clean water for further cleaning. The cleansing water may contain some oil, grease and

suspended solids. The water will be collected in earthen pits where it will evaporate

with time or drained into the nearest drainage channel. Disposal of the residual sludge

or solids and the liner will be done following best industrial practices.

The pipeline will then be non‐destructive tested by radiography, ultrasonic and

magnetic particle inspection and hydro‐testing to check its integrity. Hydro‐testing

involves filling the line with clean water (no chemicals added) and pressurizing the

line to 1.25 times the operating pressure. Makeup water will also be required during

testing. After final use, wastewater produced during hydro‐testing will be collected in

lined pits at the main production facilities and evaporated or disposed of into nearby

drainage channels with the prior approval of the concerned municipality. After the

testing phase is over, the pipeline will be commissioned.

As steel pipes are being used, these will be buried at a depth of 3 ft. from the natural

surface level and a 1 ft. sand cushion underneath the pipes for added support. At

water crossings the pipeline will be normally laid 4 ft. below its bed level. However, in

certain cases where this is not practical due to HSE or other reasons the pipeline may

be laid above grade. Inter‐visible white washed concrete posts or markers will be

provided to indicate the pipeline alignment.

Existing dirt tracks or roads will be used to access work areas along the pipeline

alignment. The development of new tracks may be limited to short reaches only. The

dirt tracks used may also need to be upgraded to a standard that is suitable for

movement of flatbed trucks carrying pipelines.

f. Well Sites Control System

Each well will be provided with a local wellhead control panel (WHP) for equipment

status and for local manual control of the wing valve. The Surface Safety Valve (SSV)

and Upper Master Safety Valve (UMSV) will have self‐contained manual hydraulic

systems for opening and closing of the valve.

Each well will be provided with a Remote Terminal Unit (RTU) to provide status,

control and shutdown facilities at the Gas Processing Facility (GPF) via fiber optic

cable.


OCTOBER 2019 57 HPK

g. Methanol Injection

Requirement for Methanol Injection will be reconfirmed upon completion of flow

assurance studies to be carried out during conceptual engineering design. If it is

required, methanol injection skid will be made available at the wellhead. Methanol

will be injected into the wellhead via the service wing valve and it will be used to

prevent hydrate formation in the wellhead piping, downstream of choke valve and in

the flow line.

h. Corrosion Inhibitor

Corrosion Inhibitor skid and injection facility will also be installed at each wellhead

area. Corrosion inhibitor will be injected into the flow lines (unless CRA material is

used) to protect these and associated downstream piping systems from internal

corrosion.

i. Flow Line Operation and Maintenance

Following commissioning, pipeline during operation will be continuously monitored

for corrosion, leakages and faulty instrumentation.

Cathodic Protection System

For proposed steel pipelines Cathodic Protection (CP) will be done. Impressed current

system will be provided for underground pipeline protection. With a CP system a

direct electric current will be induced into the pipe at intervals to maintain a pipe to

soil potential in the range of ‐0.85 to ‐1.5 volts. The normal corrosion of steel is a

process where the electron flows from the steel surfaces towards the surrounding

medium (ground). With a CP system this process will be reversed and will result in

corrosion prevention. Base plates protection of tanks and sacrificial anodes to be

provided for pipeline during construction and internal cathodic protection of tanks.

Pipeline Coating

Pipeline will be protected against external corrosion by a 3 layer fusion bonded epoxy

polyethylene factory‐applied coating system. The field joint and bends will be coated

with heat‐shrink sleeves at the site. The above‐ground section of pipeline and block

valves will be painted.

Isolation Valve Stations

Keeping in view applicable codes & standards’ requirements, four isolation valve

stations on the pipeline shall be developed.

j. Site Restoration

On completion of the construction phase, the temporary infrastructure will be

decommissioned and sites restored. This will involve:

Removing the temporary construction camp;

Reinstating the flow line route back to the original condition as close as possible;


OCTOBER 2019 58 HPK

Closing all the temporary waste pits;

Leveling and restoration of borrow areas; and

Site restoration also involves reinstatement of vegetation and topography.

k. Flow Line Decommissioning

Decommissioning of flow lines will be carried out when required according to best

industrial practices and standards. There may be three potential options for pipeline

decommissioning:

Suspension – pipelines are not depressurised but are physically isolated from the

pipeline system;

Abandonment in place – pipelines are physically disconnected from the pipe

system, purged and cleaned with water or inert material and sealed (capped) at the

ends; or

Removal – pipelines are entirely removed from the pipeline easement.

Abandonment in place is usually environmentally most favourable option. One of the

objectives of decommissioning will be to return the leased land to the landowners in a

condition that poses no adverse risk to human health or to the environment.

l. Staffing and Supplies during Flow Line/s Construction

It is expected that around 150 – 200 people will be required for the construction of flow

line and tie‐in works/wellhead works. These included technical, skilled and un‐skilled

staff.

General supplies transported will include camp supplies (food items etc.), fuels, oils,

chemicals and equipment maintenance parts. All supplies, both for construction

activity and for the camp, will be transported by trucks and pick‐ups. This will include

construction material and consumables, water and food. Diesel will only be purchased

locally from the nearest diesel filling station and will not be stored at campsite in the

form of storage tanks. The average daily consumption of diesel would be less than

1,000 litres. The requirement of water during construction would include water for

construction camps, sprinkling of roads and general construction activities. Water

required for construction purposes will be procured from local tube well or newly

installed tube wells by UEPL and in case of a shortfall, from other groundwater

sources as per the requirements prescribed in EIA.

During the construction activity, material such as steel, cement, sand and aggregates

for road and pavement construction may also be required. Earth fill will be obtained

from selected sites where material meeting the required specifications is available.

These sites will be selected with consideration to environmental mitigations. Pavement

material will be obtained from regional quarries.


OCTOBER 2019 59 HPK

4.4.2 Development of Surface Facilities

After the successful drilling of at any proposed well location, development of surface

facilities will also be carried out as part of exploration and development plan. This will

include development of EWT (Extending Well Testing) in case if laying of flow line to

the processing facility is not a feasible option at initial development phase. If any

new/existing hydrocarbon processing facility exists in nearby areas, flow line will be

laid from producing wells to the processing facility/gathering hub. Furthermore, flow

line will also be laid from processing facility to the POD (Point of Delivery) i.e. SSGC

Hub which are usually installed near Gas Processing Plant/s.

Extended Well Testing (EWT)

The Extended Well Test (EWT) operations are required in order to gain an

understanding of the dynamic characteristics of the reservoir to support any future

development of the well and are essential to determine reservoir connectivity on a

large scale and to demonstrate sufficient reserves in place to justify any future

development.

Fluids produced during the EWT operations will be processed through a well test

based process system. The intended test shall help in acquiring the dynamic data for

further evaluation and firming up the:

Original hydrocarbon reserves;

Stabilized reservoir pressure;

Depletion trend;

Well deliverability;

Drainage radius; and

Strategy for field development.

During the EWT operations, all the gas produced would be sent for flaring after

passing through filtration unit. Thus the use of flaring will be very limited and

intermittent.

The proposed operation will consist of the following main activities:

Installation and operation of EWT facilities including, but not limited to wellhead

production and control system, de‐emulsifier injection system, line heaters, 3‐

phase separation and crude stabilization system etc.;

Boiler/Hot oil system (optional); and

Storage tanks and decanting facility.

Hydrocarbon Processing Facility (GPF/CPP)

The Hydrocarbons Processing Facility i.e. Gas Processing Facility or Central

Processing Plant (GPF/CPP) will be designed and constructed to treat the raw gas and

meet the gas sales specifications. The GPF/CPP will also be capable of handling waxy


OCTOBER 2019 60 HPK

well fluids. The wax content is expected to be present in condensate which may cause

wax formation especially during winter. The wax mitigation strategies will be further

explored during the Front End Engineering Design Phase. The construction/

establishment activities of the GPF/CPP are provided in the following sections of the

report.

4.5.1 Construction/Establishment of Gas Processing Facility

The construction of the facility will be undertaken in two phases, selection and

preparation of the site and installation of the equipment. These are described below:

a. Site Selection and Preparation

The land will be acquired/leased by United Energy Pakistan Limited. The land for the

GPF/CPP will be cleared and temporary campsite will be constructed. A blacktop road

will be constructed by converting the already existing track into a metalled track.

However, some small new stretches of metalled track might also have to be developed

to approach the CPP/GPF.

Earthworks will be carried out to provide a raised platform for the processing plant

area and to avoid inundation during floods. Appropriately sized and lined drainage

ditches will be provided to direct rainwater away from the GPF/CPP.

Once the site sub‐base has been prepared, the underground infrastructure will be

installed and foundations laid for the process equipment and supporting

infrastructure. The sealed site roads and paved areas will also be constructed.

Typical activities that are conducted during the civil construction are:

Excavation for foundations;

Laying of foundations;

Masonry work;

Concrete work;

Asphalt work (pavement and roads etc.); and

Finishing (plastering and painting etc.).

b. GPF/CPP Installation

The gas processing and ancillary equipment, brought to site by road in sections, will

be erected on site and hooked‐up. After completion of erection, the facility will be

hydro‐tested to 1.5 times design pressure.

Typical activities that are conducted during plant erection are:

Site fabrication (equipment/pipe supports, equipment assemblies etc.);

Placement of the vessels and equipment on the foundations;

Laying of pipes;

Welding and joining etc.;


OCTOBER 2019 61 HPK

Electrical installation (cabling, switchgears and transformers etc.);

Instrument installation (field instruments, control room instruments and

instrument cabling etc.);

Painting; and

Testing and commissioning.

c. Main Facilities at GPF/CPP

Main facilities at GPF/CPP include:

Three Phase Separator (Production Separator);

CO2 Removal Unit (CRU);

Gas Dehydration Unit (DHU);

Nitrogen Removal Unit (NRU);

Sales Gas Compressors;

Evaporative Cooler;

Sales Gas Metering;

Closed Drain System;

Flare System;

Fuel Gas System;

Instrument Air System;

Nitrogen Generation System;

Fire Water & Pumps;

Hot Oil System;

Demineralized Water System; and

CPI Separator and Pump.

Condensate and produced water from processing trains are directed to condensate

and produced water handling system. The produced water is disposed to Evaporation

Ponds from Produced Water Tank or CPI Separator via Pump.

GPF inlet header is provided with a connection to direct well fluid to processing train.

Production Separator receives gas from the inlet header. The gas, condensates and

produced water are separated in the Production Separator. The separated condensate

and produced water will be routed to the Condensate System and Produced Water

System for further treatment and disposal.

The separated/produced gas from the Production Separator is routed to the CO2

Removal Unit (CRU). Here the CO2 is reduced/removed to meet the CO2 specification.

This gas is then processed to the Gas Dehydration Unit (DHU) to remove or minimize


OCTOBER 2019 62 HPK

the water content in the gas. After the water content removal, the gas is then routed to

the Nitrogen Rejection Unit (NRU). NRU removes/reduces the Nitrogen content in the

gas to meet the Sales Gas specification for Nitrogen.

The gas from the NRU outlet is then routed to the Sales Gas Compressors. The Sales

Gas Compressors boost the sales gas pressure to transport the sales gas to the Buyer

network. After cooling the compressed gas up to the desired temperature, it is then

routed to the Sales Gas Pipeline via Sales Gas Metering Skid.

d. Construction Camps

The construction camp will be set up for the construction of the GPF/CPP. The

construction camp for plant construction is expected to be set up at an appropriate

location and will be fully fenced, sign‐posted and secured to restrict access.

The campsite will include the following facilities:

Camp fencing and security setup;

Offices;

Communications base;

Mechanical workshop;

Maintenance workshop;

Warehouse and stores;

Fuel storage;

Water treatment plant;

Power generation plant;

Water storage;

First‐aid unit;

Firefighting equipment;

Supervisory staff and workers accommodation;

Diners;

Recreation unit;

Laundry unit;

Prayer hall;

Walkways;

Fully contained sewage management system and surface water drain system;

Solid waste collection and disposal system; and

Parking areas.


OCTOBER 2019 63 HPK

A separate liquid sewage disposal will be established for the construction campsite.

Power will be supplied to the site via diesel generators. All contractor’s solid waste

materials will be treated/disposed in on site waste disposal facilities or at an

appropriate off‐site facility which must be approved from Sindh EPA.

After the completion of construction the construction campsite will be rehabilitated to

the original conditions as far as possible.

e. Equipment

The equipment typically used during construction of GPF/CPP will be:

Survey sets;

Dozers, loaders, dump trucks, cranes and trailers;

Concrete mixers and asphalt plants;

Pipe‐bending machines, cutting outfits, beveling machines, grinders, welding

units, radiography equipment, sand‐blasting units, coating units and painting

equipment;

Excavators, thrust‐bore equipment and ditch pumps;

Pipe‐layers, tractors, fuel trucks, service trucks, water tankers with sprinklers and

crew vehicles;

A water‐treatment plant, strainers, fill‐up pumps, hydrostatic testing equipment,

temperature and pressure recorders, and air compressors;

Generators;

Communication equipment;

Mobile maintenance units; and

Warehouse storage units.

f. Staffing

The construction crew during the plant construction will comprise about 500 – 600

personnel, out of which between 60 – 70 may be sourced from local communities

depending upon their experience and skill levels particularly meeting Company’s

competency criteria.

g. Supplies

The estimate includes water required for construction camps, sprinkling of roads and

general construction activities. Water will be procured from existing groundwater

wells and, in case of a shortfall, from other groundwater sources or UEPL’s newly

installed water wells.

Diesel will be the primary fuel during the construction phase, required for power

generation, vehicles and equipment. The estimated average daily consumption of


OCTOBER 2019 64 HPK

diesel is 3,000 litres. Diesel will be procured locally and a tanker will be used to deliver

it to the site.

h. Construction Material Sourcing

During the construction of GPF/CPP, material such as the steel, cement, sand and

aggregates for road and pavement construction will be required. Pavement material

will be obtained from regional quarries.

i. Waste Streams

The primary source of emissions to air during construction activities will be diesel

engine‐driven generators’ exhaust. Other emission sources include construction

machinery and vehicles exhaust emissions. Dust from the construction activities and

movement of vehicles will be the other main source of air emissions.

Black and grey water will be first sent to septic tank (made of concrete/impermeable

material) and then to soaking pit. Whereas, recycling or reuse of waste material is the

preferred option. However, where that is not possible, waste will be treated and

appropriately disposed of as per UEPL’s policy and other legal and contractual

obligations.

j. Site Restoration

On completion of the construction phase, the temporary infrastructure will be

decommissioned and sites restored. This will involve:

Removing the temporary construction camp;

Reinstating the pipeline route back to the original condition;

Closing all the temporary waste pits; and

Leveling and restoration of borrow areas.

The average water requirement during construction is estimated to be 150 m3.

Associated Development Activities

Other associated development activities proposed may include but not limited to:





Construction of additional residential camps; and

Decommissioning and site restoration of surface facilities.

Where the category of the proposed activity is same, mitigation measures suggested

for the broader category will be applicable.


OCTOBER 2019 65 HPK

Noise, Wastes and Emissions

4.7.1 Noise

Sources of noise during core activities i.e. seismic, drilling, construction and operation

of flow line and establishment of processing facility i.e. GPF/CPP are listed below:

a. Seismic

Operation of generator at seismic base camp;

Movement of light and heavy vehicles;

Noise and vibration due to operation of vibroseis; and

Drilling activity especially with Jackrobs (only if used).

b. Construction (all activities including GPF/CPP)

Operation of generator at construction camps;

Movement of light and heavy vehicles; and

Construction works at the well site and rig camp, along access road and RoW of

flow line/s.

c. Drilling

Operations of generators at the rig camp;

Drilling and operation of generators at the well site;

Movement of vehicles; and

Operation of generator at the maintenance/construction base camp.

d. Laying of Flow Line/s

Operations of generators at the base camp;

Sand blasting; and

Movement of light and heavy vehicles for the operation.

Noise from generators will be minimized by regular maintenance and keeping them

within enclosures. Noise from vehicles, dozers and vibroseis will be minimized by

regular maintenance and reducing effects of project activities on environmental

receptors by maintaining minimum safe distances. Regular monitoring will also be

carried out in accordance to all applicable laws.

4.7.2 Wastes and Effluents

Categories of wastes generated during proposed exploration and associated

development activities in Kotri North Block and their proposed methods of disposal

are discussed below:

Clinical wastes – These will be stored separately from other wastes and sent to an

offsite commercial or provided to a Sindh EPA’s approved waste contractor.


OCTOBER 2019 66 HPK

Combustible wastes – Combustible wastes will include kitchen wastes, paper,

packaging material etc. It will be stored separately in waste segregation containers.

Thereafter all combustible wastes will be provided to the approved waste

contractor for appropriate disposal. All kind of food waste will be buried properly.

Composting can also be exercised for leftover food.

Recyclable or re‐usable wastes – These will include used oil, glass, tin, metals,

workshop wastes etc. It will also be stored separately in waste segregation

containers. All recyclable wastes will be collected by an approved waste contractor

for recycling or re‐use.

Drill cuttings and mud – A Water Based Mud (WBM) will be used during drilling.

The drill cuttings and WBM will be stored at the well site in lined pits. The drilling

mud will be allowed to evaporate inside the mud pit. The drill cuttings will also be

allowed to dry out. After that, the mud pit and the cuttings pit will be backfilled.

Sprinkling of untreated excess wastewater used for drilling purposes will not be

allowed. Sprinkling of treated wastewater will only be done if meeting

NEQS/SEQS.

Sewage Treatment Plant (STP) shall be preferred for handling of black/grey water

under BATNEEC/BAT, but in case of unavailability of STP, septic tank and soak

will be provided. Septic tank and soak pit will be covered properly to avoid any

obnoxious smell or environmental nuisance in surrounding areas.

In case if septic tank gets filled with sludge, septic tank shall be emptied through

vacuum truck and material shall be transferred to treatment facility or approved

municipal drain.

The wastewater and the amount of solid waste expected to be generated as a result of

the proposed project activities is provided in Table 4‐2.

4.7.3 Emissions

Emissions during seismic, construction including GPF/CPP, drilling and flow line

laying/tie‐in/wellhead works will include:

Dust emissions during seismic operation – Clearing of seismic lines with the use of

dozer may result in dust emissions within the area of operation. Dust will not be

generated due to use of vibroseis and flush or uphole drilling. However, use of

Jackrobs (if used) will generate dust, but its extent will be limited to its immediate

surrounding and fairly occupational in nature. Use of proper PPEs by the workers

(dust masks and safety goggles etc.) will be ensured.

Dust emissions during construction (all activities including GPF/CPP) – These will

be controlled by proper water sprinkling and good construction management.

Dust emissions during road travel (all activities) – These will be controlled by

avoiding off‐road travel, observing speed limits and tracks maintenance on regular

basis.


OCTOBER 2019 67 HPK

Exhaust emissions from light and heavy vehicles, construction equipment and

machinery and generators – These will be controlled by proper maintenance

(exhaust emissions from these sources generally meet the NEQS/SEQS).

Emissions during flaring and H2S release during drilling and testing – The effects

of these emissions will be controlled by maintaining a safe distance of 300 m from

communities and adhering to emergency response plans in case of H2S release.

Fugitive emissions – The effects of these volatile organic content (VOC) emissions

will be controlled by maintaining safe distances. High concentration levels will be

regularly checked/monitored as part of safety program. During operation, areas

with higher concentration levels will be identified and appropriately mitigated.


OCTOBER 2019 68 HPK

Table 4‐1: Summary of Water Usage during Various O&G Project Activities

Parameter Ratea

Seismic Operation

Domestic water usage Approximatley 200 liters per capita

per day

Upholes 8,000 liters per hole

Flush drilling 4,000 – 5,000 liters per hole

Flush drilling (shallow waters) None

Construction of well site 80,000 b liters per day

Drilling Operation

Domestic and Drilling 150,000c liters per day

Laying of Flow Line/Tie‐ins

Domestic water usage Approximatley 150 liters per capita

per day

Hydrocarbons Processing Facility

Construction and domestic 150 m3

Notes:

a: The values have been taken from various seismic, construction and drilling operations

b: The values are for total consumption of water for domestic and construction purposes. Usually construction and

domestic activities takes up to 80%, and 10% respectively of the total water consumption with the remaining

amount of water being used for sprinkling purposes.

c: The values are for total consumption of water for domestic and drilling purposes. Usually drilling and domestic

activities takes up to 60%, and 40% respectively of the total water consumption.


OCTOBER 2019 69 HPK

Table 4‐2: Summary of Approximate Domestic Wastewater and Solid Waste

Parameter Generation

Domestic Wastewatera

Seismic operation (litres per capita per day) 160

Construction of well site (litres per day) 6,400

Drilling operation (litres per day) 32,000

Laying of flow line (litres per day) 5,400

Construction of GPF/CPP (m3) 20

Other Wastes (per month)a

Seismic Operation

Recyclable solid waste generation (kg) 308

Oil waste produced (litres) 104

Food waste generation (kg) 150

Others/Hazardous waste (kg) 18.2

Construction Phase (Well Site)




Others/Hazardous waste (kg) 3

Drilling Phase

Recyclable solid waste generation (kg) 2,585




Wellhead Surface Facility/Flow Line Construction





Construction of Processing Facility

Recyclable solid waste generation (kg) 5,690

Oil waste produced (litres) 1,700

Food waste generation (kg) 1,350


Notes:

a: Values have been calculated based on HPK environmental monitoring record for various O&G project activities.


OCTOBER 2019 70 HPK

Figure 4‐1: Anatomy of a Rotary Land Drilling Rig


OCTOBER 2019 71 HPK

Photographs: Proposed 2D & 3D Seismic Operation (HPK Library)

Photograph 4‐1: A view of typical seismic base

camp Photograph 4‐2: A veiw of seismic support

camp

Photograph 4‐3: Uphole drilling by vehicle

mounted rig Photograph 4‐4: Vibroseis moving on a seismic

line

Photograph 4‐5: Drilling of deep hole through

buggy in progress Photograph 4‐6: Jackrob drilling


OCTOBER 2019 72 HPK

Photograph 4‐7: Loading of explosives in a shot

hole Photograph 4‐8: A loaded shot hole

Photograph 4‐9: Seismic base camp parking

area Photograph 4‐10: A veiw of explosive magazine

Photograph 4‐11: Seismic cable crossing on a

road Photograph 4‐12: Recording truck


OCTOBER 2019 73 HPK

Photographs: Proposed Drilling & Associated Construction Activities

(HPK Library)

Photograph 4‐13: A view of land drilling rig in

operation

Photograph 4‐14: A view of typical drilling rig

camp

Photograph 4‐15: Dozer at work on access track Photograph 4‐16: Gravel leveling with grader

on well site

Photograph 4‐17: Generators at well site Photograph 4‐18: Water storage pit on well site


OCTOBER 2019 74 HPK

Photograph 4‐19: A view of lined drill cutting

pit at well site

Photograph 4‐20: Properly bunded diesel

storage area with loading and unloading pad

Photograph 4‐21: Properly barricaded food

burial pit

Photograph 4‐22: Construction of septic tank at

well site

Photograph 4‐23: Installation of conductor pipe

at well site

Photograph 4‐24: Installation of BOP in

progress


OCTOBER 2019 75 HPK

Photographs: Lying of Flow Line/Tie‐in Works and GPF (HPK Library)

Photograph 4‐25: Dozer working on RoW Photograph 4‐26: Offloading of pipes on RoW

Photograph 4‐27: Flow line placed along RoW Photograph 4‐28: Clamping of flow line before

welding

Photograph 4‐29: Burial of flow line in trench Photograph 4‐30: Working on flow line at

wellhead


OCTOBER 2019 76 HPK

Photograph 4‐31: Typical view of CPP Photograph 4‐32: Typical styled condensate

storage at GPF

Photograph 4‐33: Typical lined evaporation

pond

Photograph 4‐34: Typical pipe yard at GPF


OCTOBER 2019 77 HPK

5 Analysis of Alternatives

Introduction

An analysis of available alternatives to the proposed exploration and associated

development activities as described in Chapter 4 of this EIA have been carried out in

this section to ensure that the best possible management and technological options are

going to be employed during proposed project implementation. The analysis of

alternatives has been discussed under two separate headings, management

alternatives and technological alternatives.

Management Alternatives

5.2.1 No Project Option

Energy is the prime mover of current day economies and is vital to the sustenance of

economic growth, which depends crucially on the long‐term availability of energy

from sources that are accessible, sustainable, affordable, and environment friendly.

The energy sector plays a key role in the development and growth of Pakistanʹs

economy. Through its history, Pakistan’s economy has paced an unsteady path with

extended phases of low growth following moderate stints of high growth. If one looks

at the pattern of energy supplies, Pakistan has remained an energy deficit country,

dependent upon imports, mostly oil & oil products.

During the Fiscal Year (FY) 2017‐18, the primary commercial energy supplies have

increased from 80 to 86 million tonnes of oil equivalent (MTOE). The increase was in

coal (68.5%), LNG (68.2%), renewable electricity (44.6%), nuclear electricity (41.2%),

imported electricity (11.9%) and LPG (4.5%) as compared to last year. Consequently,

the overall primary commercial energy supply mix during 2017‐18 was increased by

8.4% than the previous year (2016‐17). The share of each energy commodity in primary

energy supplies for 2017‐18 was: Oil – 31.2%, Gas – 34.6%, LNG import – 8.7%, LPG –

1.2%, Coal – 12.7%, hydro‐electricity – 7.7%, nuclear electricity – 2.7%, renewable

electricity sources – 1.1% and imported electricity – 0.1%. Primary energy supplies by

source are provided in Figure 5‐1 & 5‐2.

The annual growth rate of final energy consumption was enhanced considerably by

9.7% and reached to 55 million tonnes of oil equivalent during 2017‐18 due to major

increase in consumption of industry, agriculture and transport sectors. Final energy

consumption by source & sector are shown in Figure 5‐3 & 5‐4 respectively.

Local crude oil production moved up slightly by 0.9% from 88,409 barrels per day in

2016‐17 to 89,197 barrels per day in 2017‐18, while the natural gas production

decreased slightly by 0.9% from 4,032 MMCFD in 2016‐17 to 3,997 MMCFD in 2017‐18.

Extensive activity was seen in the upstream sector where 45 exploratory and 36

development/appraisal wells were drilled. The drilling efforts resulted in 14

discoveries mostly of gas/condensate which needs to be continued.


OCTOBER 2019 78 HPK

The overall import of petroleum products was decreased by 11.9% as compared to the

last year. Import of crude oil by the refineries was, however, increased significantly by

19.3%. The import to aviation fuel (98.3%), motor spirit (8.1%) and HSD (1.3%) was

increased. The import of petroleum products is decreased while the oil import bill

increased from US $ 9.1 billion in 2016‐17 to US $ 11.9 billion in 2017‐18 due to increase

in prices and increase in import of crude oil.

The overall oil consumption during 2017‐18 decreased by 3.5% from 25.56 million

tonnes to 24.68 million tonnes. Consumption of furnace oil decreased to 23.0% and

kerosene 5.4%. However, consumption of HSD increased from 8.48 million tonnes to

9.04 million tonnes (6.5%) and gasoline from 6.74 million tonnes to 7.51 million tonnes

(11.5%). Whereas, natural gas consumption increased from 1,377,307 MMCft to

1,454,697 MMCft (5.6%). Similarly, RLNG import also increased from 186,672,977

MMBtu to 313,902,345 MMBtu (68.2%). Gas consumption in power sector increased

from 446,941 MMCft to 544,654 MMCft (21.9%). As per available information, Kotri

North Block is conducive to natural gas production hence, sharing the accumulative

gas production of the Sindh province. Natural gas production by type/province is

provided as Figure 5‐5 and consumption of natural gas is by sector is shown as Figure

5‐6.

Pakistan’s economy has been growing at an average growth rate of almost 5.5% and

demand of energy is increasing rapidly. A number of contemporary studies indicate

that Pakistan’s primary energy demand is expected to grow at an ACGR of between

4.37 to 6.09 percent over the next 15 years, depending upon the projected GDP growth,

and is likely to be in the range of 116 to 148 MTOE by FY 2022.

As indicated above, Pakistan spends billions of dollars on the import of crude oil and

other petroleum products and as a result total import bill is rising for every

consecutive fiscal year. To reduce this loss of foreign exchange the government is

committed to maximum replacement of imported furnace oil and diesel oil with

indigenous natural gas.

In view of Pakistanʹs current balance of payment difficulties, it has become imperative

for the country to explore indigenous resources in the energy sector, as a reliable

supply of energy is crucial to the achievement of national development targets in the

commodity producing sectors. Natural gas is a particularly attractive option as the

environmental effects associated with its usage are also minimal in comparison to

other fossil fuels.

An oil or gas discovery in the area of operation will augment the present oil & gas

supplies of the country and reduce Pakistanʹs reliance on imported fuel. In view of the

above and high energy demand of the country ‘No Project Option’ seems to be a

highly unfavorable option.


OCTOBER 2019 79 HPK

5.2.2 Alternative Site Option

Several concession areas and exploration sites exist on Pakistanʹs map and a number of

national and international companies are actively engaged in oil & gas exploration and

production in the country in addition to the public sector agencies.

As exploration activities involve large investments, the area of the operation is

carefully selected after assessing that the geological characteristics conducive to the

presence of hydrocarbon reserves are present in the area. Kotri North Block seems to

be an attractive area for hydrocarbon exploration in Pakistan due to the fact that

various successes of discovering hydrocarbon reserves during past drilling operations

e.g. Unarpur‐1 ST‐1 in 2018. Adjacent concession e.g. Kotri Block (2468‐12) also have

potential for hydrocarbon reserves. A recent discovery at exploratory well Yasar X‐1 is

made in 2018. In addition to above, there are also operational hydrocarbon processing

facilities in the nearby areas i.e. Shahdadpur (PPL), Tando Adam (PPL) and Badin

(UEPL). In the above context, an operation in any other area may not be fruitful.

Furthermore, strict adherence to the mitigation measures proposed by the EIA will

ensure that any residual impacts on the forest protected areas are reversible, short

term and insignificant.

Proposed seismic survey in the region will verify and authenticate the potential for oil

and gas reserves and to rightly identify suitable surface locations for drilling of wells

in the subsequent phase of exploration and development phase. Moreover, in case of

discovery/success, flow line will be laid to existing or newly established processing

facility further to distribution network.

5.2.3 Timing of the Operation

The proposed exploration and associated development project have to follow strict

project schedule in order to meet production targets and to reduce national gas

shortage for supporting the countryʹs economy. Restrictions on the timing of the

proposed operation may be deemed necessary if the operations are significantly

affecting the breeding of key wildlife species in the area. On the basis of assessment of

the impacts done in the EIA any restrictions on timing should necessarily be

considered as significant core habitats for the breeding of key species were also

identified in the project area. Wetlands of the project area are visited by migratory

birds and in addition to core habitats of some famous mammals i.e. Hog deer, Fishing

cat, Smooth coated otter, Desert cat, Indian/Bengal fox and Indian pangolin. Famous

game birds i.e. Grey partridge and Black partridge are also key species of the area.

Therefore, the EIA has recommended measures to minimize the duration of activities

within key wildlife areas/habitats and maintain minimum safe distance from sensitive

& fragile environmental receptors.

Technological Alternatives

5.3.1 Seismic Data Acquisition Technologies

Proposed seismic data can be acquired using the following methods:


OCTOBER 2019 80 HPK

Upholes;

Deep shot hole survey;

Shallow shot hole survey;

Surface shots; and

Vibrating energy sources.

The selection of any of these sources is dependent on the quality of data, time, cost,

land type and environmental sensitivity of the area. Care has to be exercised in

selecting the method to ensure that geophysical data of the highest possible quality is

collected with least possible impacts on the environment. It is important to mention

that major part of Kotri North Block is already covered under 2D/3D seismic coverage

however, to be more certain for selection of a well drilling, seismic activities including

2D/3D are also proposed for the project.

Only cables and geophones will be laid across the surface water bodies for data

acquisition. For the rocky and sandy plains the technological options are vibroseis and

shallow holes. In agricultural lands there is a choice between the use of dynamite and

vibroseis as an energy source. The use of vibroseis in agricultural lands was not

considered as a preferred option as it would involve land clearing along the seismic

lines.

Whereas, upholes provide highest data quality, they may pose greater environmental

impacts if used as the only technology due to operation of heavy drilling rigs, use of

water and the need to develop access track. Deep holes and shallow holes required for

dynamite acquisition have comparable environmental acceptability, though deep

holes outrank shallow holes in terms of quality of data obtained, staffing requirements

and the total time required to complete the operation. In order to obtain high quality

data keeping due regard for the environment, a combination of vibroseis and

dynamite has been selected for the operation. The location of upholes will be carefully

selected to minimize the preparation of new tracks and the location of deep holes has

been set at every 50 m to minimize the amount of drilling in the area. Combination of

vibroseis and dynamite sources will enable UEPL to obtain the desired quality of data

with the least possible impacts on the existing environment.

5.3.2 Drilling Technique

Conventional rotary drilling proposed by United Energy Pakistan Limited has been

historically used for the drilling of oil and gas wells. Other drilling techniques include:

Coiled tubing; and

Slim holes.

Despite some environmental gains in the use of coiled tubing and slim holes (reduced

well site area and reduced waste volumes etc.) both techniques seem to share a

number of technical disadvantages and operational limitations. Moreover, the rigs are

not available in Pakistan and in case of a breakdown required backup and service


OCTOBER 2019 81 HPK

facilities may not be available as readily as for conventional rigs. Advantages of the

two techniques therefore, do not outweigh their disadvantages. Conventional drilling

technique proposed by UEPL is therefore evaluated to be the best alternative.

5.3.3 Drilling Mud

Generally, two broad categories of mud are used for drilling of oil or gas wells i.e. oil

based and water based. Oil based mud is formulated by mixing chemicals with diesel.

This mud is not considered to be environment friendly due to the risk of

contamination of subsurface formations during drilling and the generation of oily

drilled cuttings which require specialized handling and treatment. A water based mud

system will be used which due to the abovementioned reasons has environmental

preference over oil based mud and is therefore considered to be the preferred

alternative.

For proposed seismic activity, as highlighted in Section 4.1.3 of Chapter 4, due to

loose soil material wherever, expected in the area the holes during drilling will be

flushed with bentonite mud. The bentonite mud will be prepared near the shot point

in a 2 m square and 0.5 m deep earthen pit. Water tankers will transport water

required for the preparation of the mud. These water tankers will travel only on

existing tracks. In case an existing track does not reach to a shot point, the tanker will

stop on the track at a position nearest to the shot point, from thereon water will be

transported by means of hose pipes connected to the tanker.

The spent drilling mud and cuttings will be stored inside a similar earthen pit. The

spent mud and cuttings will be allowed to dry after which the pit will be backfilled

with at least 15 cm of top soil cover. The pits will be clearly marked until restored.

Since, bentonite is a type of clay and a non‐hazardous material, burial of the mud and

cuttings on site will not contaminate soil or groundwater. No other type of mud is

planned to be used by UEPL during the proposed seismic operation in project area.

5.3.4 Disposal of Drilling Wastes

Conventional drilling waste management involves discharging the mud and cuttings

into a lined waste pit (HDPE lined). UEPL after a review of various waste

management alternatives has started using a cuttings segregation and fluid recovery

unit in which the cuttings segregated by the shale shakers and processed through

centrifuges and Hi‐G dryers. This allows:

Additional drying of the cuttings making their disposal into the lined waste pit

easier;

Recovery of the excess mud associated with the cuttings. The mud can be re‐used

thereby reducing the overall water consumption and chemical usage for mud

formulation; and

Reduction in the size of the waste pit due to the reduction in the mud content

associated with the cuttings and due to less water consumption and mud

formulation.


OCTOBER 2019 82 HPK

The waste management system is considered to be technologically and

environmentally the most preferred option. The drill cuttings and mud will be

disposed of at the well site within lined waste pits. Other options such as

bioremediation, incineration, re‐injection or landfill are either not applicable to the

type of waste or their cost or technical and management disadvantages outweigh the

little benefits that they may have.

5.3.5 Alternative to Flow Lines

After the successful drilling of well and discovery of hydrocarbons, hydrocarbons

need to be processed before it enters into distribution network for ultimate

consumption. Pipelines are the best available option however, transmission pipeline

safety regulators and operators have expressed mutual interest in demonstrating the

effectiveness of In‐Line Inspection methods for better risk evaluation and management

of pipeline safety as an alternative to hydrostatic testing in the cases where safety can

be verifiably maintained. Hydrostatic testing can result in substantial costs, occasional

disruptions in service, and substantial emissions due to the routine evacuation of

natural gas from pipelines prior to tests. Allowing alternatives to hydrostatic testing

(including In‐Line Inspection technologies), combined with research and

development, could help to drive innovation in pipeline integrity testing technologies

and eventually lead to improved safety and system reliability.

5.3.6 Gas Processing Facility

Natural gas (also called fossil gas) is naturally occurring hydrocarbon gas mixture

consisting primarily of methane, but commonly including varying amounts of other

higher alkanes and sometimes a small percentage of carbon dioxide, nitrogen,

hydrogen sulphide or helium. It is formed when layers decomposing plant and animal

matter are exposed to intense heat and pressure under the surface of earth over

millions of years. The energy that the plants originally obtained from the sun is stored

in the form of chemical bonds in the gas.

In petroleum production gas is sometimes burned as flare gas. Before natural gas can

be used as a fuel, most, but not all, must be processed to remove impurities, including

water, to meet the specifications of marketable natural gas. The by‐products of this

processing include ethane, propane, butanes, pentanes and higher molecular weight

hydrocarbons, hydrogen sulfide (which may be converted into pure sulfur), carbon

dioxide, water vapours and sometimes helium & nitrogen. Because of these properties,

natural gas is receiving attention as low‐carbon, eco‐friendly alternative fuels.

It is the major energy source of our country for both domestic and industrial

operations. Natural gas processing plant converts gas reservoirʹs raw natural gases to

produce sales gas, which is highly demanded commodity in the market. Sales gas

specification typically required processed gas with small amount of water to avoid

pipelines corrosion, avoid hydrates formation in the gas and for their immediate

industry consumption. The plant is equipped with gas dehydration system facilities to

absorb water from raw gas and most of the gas dehydration processes are using tri‐


OCTOBER 2019 83 HPK

ethylene glycol (TEG) process unit. Therefore, gas processing plant with appropriate

capacity is the best solution for the purpose.

5.3.7 Water Abstraction

Water is without any doubt one of the most undervalued resources on earth. Globally,

there is increasing pressures on water resources. In particular, population growth and

economic development are putting pressure on available freshwater resources. Water

quality is inextricably linked to human health in many ways and poor water quality

can lead to diseases, reduced food availability and malnutrition. Improved access

to fresh water has a direct positive impact on people and communities leading to

significant social, economic and environmental benefits.

The two primary options for obtaining water for project needs are:

Surface water

Groundwater

Existing local wells – Existing local wells may be used during proposed exploration

and associated development project activities, if these show sufficient capacity to meet

the project water requirements. Only those local wells will be used which show an

excess capacity of water above the local requirements (domestic and irrigation) and

flow rate from these wells will be monitored during the operation to monitor any

effect. The local wells located close to the existing irrigation network have sufficient

quantity of water and does not show any significant drawdown.

New water wells – There is also a possibility that depending on the requirement for

proposed exploration and associated development activities, United Energy Pakistan

Limited may install new water wells in an area where availability of groundwater is

confirmed. However, this option will be considered if taking water from the existing

water wells in project area is not feasible due to long haul distance or constraints. Use

of brackish water for proposed project activities should be maximized wherever

possible and feasible.

During proposed exploration and associated development, under unavoidable

conditions like long haul distances, unavailability of tube wells in the proximity of

project area etc. limited water abstraction from seasonal watercourses will be allowed

after getting a formal approval from the concerned department and conditional

approval in the form of third order Change Management Statement (CMS) from IMC.


OCTOBER 2019 84 HPK

Source: HDIP Year Energy Book, 2017‐18

Figure 5‐1: Primary Energy Supplies by Source with ACGR


Figure 5‐2: Primary Energy Supplies by Source


OCTOBER 2019 85 HPK


Figure 5‐3: Final Energy Consumption by Source


Figure 5‐4: Final Energy Consumption by Sector


OCTOBER 2019 86 HPK


Figure 5‐5: Natural Gas Production by Type/Province


OCTOBER 2019 87 HPK


Figure 5‐6: Natural Gas Consumption by Sector


OCTOBER 2019 88 HPK

6 Background Environment

In order to assess the potential environmental impacts of proposed exploration and

associated development activities (details are provided in Chapter 4) may have on the

environment of the area and to propose mitigation measures a detailed understanding

of the background environment of Kotri North Block (E.L. 2568‐21) including physical,

biological and socioeconomic environment has been established and provided in this

chapter.

Physical Environment

In this sub‐section, physical environment including the physiography, geology & soils,

seismicity, climate, water resources (surface & groundwater), noise and air quality of

the project area and its surroundings is discussed in detail.

6.1.1 Physiography

The Kotri North Block lies in the southern part of the Sindh province and is mostly

covered in the Indus Delta covering parts of Jamshoro, Hyderabad and Matiari

districts. District Jamshoro contributes the major part followed by district Matiari and

Hyderabad.

As a whole, Jamshoro district may be divided into three parts which are entirely

dissimilar in character namely:

The Kohistan or hilly area;

The barrage zone; and

The low lands riverine area.

For instance, taluka Kotri of Jamshoro district has a major part within Kotri North

Block. Overall, taluka Kotri has sandy plains and a barren rocky terrain to traverse.

Small hills, nais and dhoros (perennial rivers) add beauty to the landscape. Collectively,

the Kohistan region consists of a range of limestone hills, known as Kirthar Range. It

extends along the whole western boundary of the district. In Sehwan taluka it spread

out and approach Lakhi hills, which start near Sehwan and run south along the

western boundary of the district therefore most of the Sehwan taluka area is hilly in

general.

Hyderabad district is the part of the lower Indus plain conformed of vast alluvial

along the course of the Indus River. The Indus bifurcates the district of Jamshoro from

Hyderabad and stretches the western flanks of the district and is surrounded by

riverine forests. There are no mountains or hills anywhere in the districts except some

small hillocks and off shoot of Kirthar limestone (of middle Eocene) range known as

Ganjo Takkar located in Hyderabad district. They run parallel to the river Indus for

about 22 km south of Hyderabad city. The highest point in these hillocks is known as

“Gaho” which is about 75 m above mean sea level (msl). There are also two small


OCTOBER 2019 89 HPK

hillocks on the north of Tando M. Khan town. They are named Budhaka Takkar. The

rest of the district is a fertile plain with an average elevation of about 50 m above msl.

Overall, the north western area of the Kotri North Block is a hilly tract known as

Kohistan tract. These hills are the extension of the Kirthar Range. It has been described

as succession of broad valleys laying between ranges of hills running generally north

and south. The valleys are more or less level and fairly covered with grass or

brushwood. The hills are bare and mostly composed of limestone. Southwards the

area degenerates into sandy formations, uncultivated and almost devoid of vegetation,

but much broken up by short ranges of low, stony hills and intersected by nais (locally

called meaning torrent beds) which carry the drainage of the Kohistan to the Indus.

6.1.2 Geology & Geomorphology

The Indus Delta is formed as a result of sediment trapping of the river Indus into the

Arabian Sea for millions of years. The geological history of the river Indus is

associated with the rapid tectonic uplift in the region which has led to the formation of

Himalayan Mountains. The geology of Hyderabad district comprises of sedimentary

and volcanic rocks which is quaternary in nature. The district has loamy and clayey

part saline floodplain soils of the arid zone.

Kotri North Block is majorly covered under the Eocene sedimentary and

unconsolidated surfical deposits of silt, sand and gravel geologic formations belonging

to the Tertiary and Quaternary ages respectively. The area is also rich in coal deposits

with the coal field being explored currently for coal reservoirs. Coal is associated with

basal part of laterite where a sequence of lateritic clay and shale with beds of

arenaceous sandstone of Laki Formation, named as Sonhari member of early Eocene

age is found. Laki formation attains a thickness of 55 m near Thatta however, the later

sequence of Laki Formation is mainly composed of nodular limestone with shale and

sandstone. The Sonhari coal is of poor quality lignite with high Sulphur. Sonhari

member varies in thickness from 10 – 30 m. The meting limestone and Shale member

consists mainly of creamy white nodular limestone with subordinate sandstone in the

upper part. The shale is grey, greenish yellow, weathering dark rusty brown

ferruginous and gypsiferous. The limestone is thin bedded and arenaceous whereas

the sandstone is commonly ferruginous. Meting member is about 70 m thick at the

type locality (Siddiqui, 2007).

6.1.3 Stratigraphy

The Kotri North Block is located in southern Indus basin and over lower Indus trough

and Nabisar slope. The project area under consideration for EIA is predominantly

located over the lower Indus trough. The general stratigraphy of the lower Indus basin

is comprised of Pliocene Swaliks up to Jurassic carbonates. The stratigraphic sequence

change drastically from the west to the east. The Pub, Mughal Kot and Parh formation

of the Cretaceous age pinch out in the eastern lower Indus basin.


OCTOBER 2019 90 HPK

6.1.4 Soils

Clay and sand are principal ingredients of the soil of Kotri North Block and one of the

two factors by which the composition of the various soils is differentiated is the extent

to which the clay or the sand predominates.

The soil of Kotri North Block is mostly loamy and clayey soil with patches of gravely

land and salt as well as seasonally affected soil. In some places of the block, the soil of

is mostly loamy with seasonally flooded soil. According to Soil Map of Sindh, Survey

of Pakistan, soil types in Kotri North Block is provided below:

Rough mountain land;

Gravelly land and rock land;

Loamy soil;

Clayey soil;

Seasonally flooded soil; and

Salt affected soil.

The texture of soils in the project area ranges from loamy saline, silty to gravely,

mainly loamy and clayey soils in the inland areas. The soil in the project area,

especially those areas covered under the lower Indus basin consists mainly of loamy

and clayey soils.

These soils have little or no salinity (0 to 4dSm‐1) and are moderately alkaline (pH of

7.9 to 8.4). The soils are generally non‐saline, non‐sodic except local saline patches in

inter‐dunal valleys and some parts of the alluvial plain.

6.1.5 Land Capability

Different land use potentials were identified on the basis of their characteristics or on

the basis of other external limiting factors such as aridity and erosion etc. The potential

land use for the soil regimes within the Kotri North Block has been identified in this

study using the map of Land Capability for Sindh, Survey of Pakistan. This

classification is expected to help in the management of soils in the area and for further

planning on land use within the project area. Classes of land capability in Kotri North

Block falls in Class I, II, III, VII and VIII. Description of these classification of land

capability is presented below:

Class I – Very good (loamy) irrigated crop land;

Class II – Good (predominantly clayey) irrigated crop land;

Class III & VII – Complex of mainly moderate flood‐watered crop land and some

poor (sandy) grazing land;

Class VIII – Agricultural unproductive open water and marsh. Agricultural

unproductive (mountainous) land; and


OCTOBER 2019 91 HPK

Class VIII & VII – Complex of agricultural unproductive (rock) land and some

poor grazing (gravely) land.

6.1.6 Petroleum Play

The early Cretaceous shale of the Sembar Formation are the source rocks which

charged the hydrocarbon pools on the Thar slope and the Karachi trough. The close

vicinity of the block to the petroleum producing province and the lateral continuity of

the early Cretaceous Lower Goru clastics ensure the presence of good quality reservoir

horizons in this basin. The prospective play types comprise the tilted fault blocks and

associated rollovers.

6.1.7 Seismicity

Based on the seismic zoning map of Pakistan issued by the Geophysical Centre Quetta,

the entire Kotri North Block falls under Zone 2A with minor to moderate damage

category of earthquakes and a ground acceleration level of 0.08 to 0.16 g. Seismic map

of the Kotri North Block with respect to other seismic zones of Pakistan is shown in

Figure 6‐3.

6.1.8 Climate and Meteorology

a. Climatic Classification

The climate of the entire Kotri North Block is intensively hot in summer and cold

enough in winter. The salient feature of climate is the high variability in temperature

in different areas within the project area. Shamshad (1956) has classified the climate of

Pakistan on the basis of characteristic seasons found in the country. Taking into

account topography, proximity to the sea, rainfall, temperature and winds, Shamshad

has defined eleven climatic zones for Pakistan. Under his scheme, the climate of the

project area is classified as ‘Subtropical Double Season”, which may further be

subdivided into hot land and coast land. The characteristic features of hot land

climatic zone is low rainfall, (less than 250 millimeters per annum) absence of a well‐

defined rainy season, and high temperatures that increase from east to west. Whereas,

features of the coast land climatic zone include occurrence of afternoon sea breeze, low

rainfall (less than 250 mm per annum) with moderate and high temperatures in coastal

and inland areas respectively.

Rasul and Chaudhry (2004) classified the climate of Pakistan on the basis of moisture

index. They reported that two third of the country has arid to semiarid climate type.

According to them most of the southern half lies under arid climate thus Kotri North

Block as well which falls into Jamshoro, Hyderabad and Matiari districts of Sindh

province. Average secondary meteorological data of Hyderabad district for last decade

(2009 – 2018), which is broadly applicable to the entire stretch of Kotri North Block

(E.L. 2568‐21) is presented in Table 6‐1 whereas, graphically shown in Figure 6‐1 and

Figure 6‐2. Figure 6‐1 represents the average temperature in °C including minimum,

maximum and average whereas Figure 6‐2 shows the average rainfall in mm, average

humidity in % and average windspeed in kmph.


OCTOBER 2019 92 HPK

b. Temperature

Interpretation of the available meteorological data shows that the Kotri North Block

experiences extreme hot temperatures where mean daily maximum temperatures can

go up to 48°C and even beyond due to the direction of sea breeze from west to east.

According to available meteorological information, hottest months of the year are

May, June and July. Coldest months of the year are December, January and February.

The climate of the project area is extreme and is characterized by hot summers and

moderately cold winters. The average temperature for the year stands at 29°C

whereas, mean annual maximum and minimum temperatures remain above 42°C in

June and above 13°C in January respectively. Table 6‐1 shows average monthly

maximum and minimum temperature recorded during past decade i.e. 2009 – 2018 at

PBO Hyderabad.

c. Rainfall

Available meteorological information shows that the average annual rainfall in the

project area is only about 6 millimetres. Complete record of average monthly

precipitation for last ten years (2009 – 2018) is also presented in the Table 6‐1. Project

area is situated in arid and semiarid zone of Pakistan and hence, prone to drought.

Careful analysis of met data shows that the wind in the project area during the past

era was blowing from all four directions, but it now blows from one side only, which

shows climatic change. Now the rains occur from the sea. These rains contain salt

concentration that impairs the soil fertility/quality and cause water‐logging in

agricultural zones of the project area. Due to lot of precipitation from oceanic origin,

the land gets degraded which ultimately affects the crop yield in the area of influence.

d. Relative Humidity

Interpretation of available meteorological data shows that the area experiences

relatively medium humidity. The average minimum humidity for last decade (2009 –

2018) at Hyderabad was recorded during month of December which is 25.3% at 0000

UTC and maximum humidity was recorded in month of May was 58.7% at 1200 UTC.

e. Wind Speed

Average wind speed in entire project area is very erratic. According to available

information, wind speed of the project area could reach up to averagely 25 kmph in

the hotter months of the years which ultimately generate high speed gusts however, in

winter months the average wind speed remain in‐between 8 – 13 kmph.

f. Sun Hours

Available meteorological data (2009 – 2018) of Hyderabad district shows that average

sun hours in January are around 258 hours whereas, during the peak summer time are

around 387.2 hours (in May). Average sun hours of Hyderabad district is also

presented in Table 6‐1.


OCTOBER 2019 93 HPK

g. Climatic Change

Careful analysis of climatic conditions of the area reveals that annual rainfall may

continue to increase during the coming years with a rate of 5% per decade subjecting

this region to flooding risks. Various studies show that the winter rainfall is

continuously decreasing with a significant rate by every passing year. However, the

spring rainfall is continuously increasing while the summer (monsoon) rainfall rates

show increasing trend while, the fall season indicates a continuous decreasing trend.

As a whole, rainfall in winter and fall is on a decreasing trend, whereas spring and

summer rains are increasing.

From the temperature perspective it was revealed that annual average temperature is

increasing globally by about 0.8° Celsius due to global warming and other

contributing environmental factors. The duration of winters is decreasing slightly

shaping a longer span for summers.

6.1.9 Ambient Noise & Air Quality

a. Ambient Noise

Sources of noise during proposed exploration and associated development activities

will be generators, vehicles, drilling rig, flaring during well testing and construction

equipment and machinery. These sources of noise can be categorized as short term

and intermittent arising from proposed project activities. Increased noise levels during

the operations although will not accumulate but can individually be a source of

nuisance for locals and a source of disturbance to the existing wildlife.

There are no continuous major sources of noise in the project area. Existing sources of

noise in the project area are farm tractors & related equipment and vehicles.

Considering the intermittent nature of these noise sources, it can be presumed that the

noise pollution in the area is low.

Ambient noise levels were monitored through Sound Meter 840029 and Garmin GPS

etrex 10 and their results are shown in the Table 6‐3. Figure 6‐5 shows the sampling

locations to record ambient noise levels in the project area. Noise monitoring locations

were randomly selected during the field visit of the area in different habitats. On the

basis of the investigation/results, it is concluded that ambient noise level in the project

area is of low level.

b. Ambient Air Quality

Due to the absence of typical sources like industrial and heavy vehicular emissions of

air pollution within Kotri North Block, the ambient air quality of the area may be

regarded as pristine with respect to the presence of air borne pollutants. Dust storms

or strong winds during summer generate limited dust emissions, vehicles travelling

on existing road network in and adjacent areas also generate limited amounts of dust.

These dust emissions, however, apart from being a nuisance, do not pose any threat to

human health. Proposed exploration and associated development activities may be a

source of dust emission but activities will be well planned/designed and every effort


OCTOBER 2019 94 HPK

will be made as recommended in this EIA to alleviate the adverse impact on

environment, thus not significantly deteriorating ambient air quality.

6.1.10 Water Resources

a. Surface Water Resources

The Kotri North Block lies in the Lower Indus Basin of Sindh province where surface

hydrology is predominantly influenced by the Indus River. The lower Indus basin is

drained mainly by the Indus River and its tributaries including various hill torrents

from the west which flow only in the period of heavy rain from north to south‐west

direction.

Indus River & Associated Irrigation Network

The Indus provides the key water resources for the economy of the area– especially

the Breadbasket of Punjab province, which accounts for most of the nationʹs

agricultural production and Sindh. The river also supports many heavy industries and

provides the main supply of potable water in Sindh. The Indus is one of the few rivers

in the world that exhibit a tidal bore. The Indus system is largely fed by the snows and

glaciers of the Himalayas, Karakoram and the Hindu Kush ranges of Tibet, the state of

Jammu and Kashmir and the Northern Areas of Pakistan respectively. The flow of the

river is also determined by the seasons – It diminishes greatly in the winter, while

flooding its banks in the monsoon months from July to September. There is also

evidence of a steady shift in the course of the river since prehistoric times – It deviated

westwards from flowing into the Runn of Kutch and adjoining Banni grasslands after

the 1816 earthquake (wikipedia).

The irrigation system of Sindh is entirely dependent on the Indus River for supplies of

water downstream of the area. Riverine tract of the Indus River occupies a special

significance in the ecology of Sindh. Expansion of agriculture and subsequent

industrial development led to the need for conserving water for agriculture purpose

and power generation through construction of reservoirs on the river Indus and its

tributaries with associated irrigation canal networks. A number of dams, head works,

barrages and diversion canals have been constructed on Indus River and its tributaries

from 1886 to 1993.

The first barrage on the river Indus was commissioned in 1932 (Sukkur Barrage)

followed by Kotri (Ghulam Muhammad Barrage) and Guddu in 1955 and 1962

respectively (Osmani, 2003). Irrigation canals from mainly Kotri Barrage (Ghulam

Muhammad Barrage, 1955) and partly from Sukkur Barrage (1932) irrigate the project

area.

There are four feeders which originate from Kotri Barrage including Akram Wah, New

Fuleli, Old Fuleli and Kalri Baghar (KB) feeder. KB feeder with command area 637,041

square miles serves irrigation network in and near the project area. The water channels

exist within the project area and close vicinities are Pannu canal, Khasino wah,

Budhapur minor, Buhara distributary, Jam wah, Qubi minor and Sonda distributary.


OCTOBER 2019 95 HPK

b. Groundwater

Generally, groundwater becomes saline downstream of Hyderabad. This is because of

the recent shift (in terms of geological times) of the Arabian Sea which used to be

further southwards until Hyderabad some 12,000 years ago. The areas with saline

groundwater show higher concentration of chlorine compared to carbonates and

bicarbonates suggesting that some millennia ago the area was submerged into

seawater.

Though meandering of the river Indus had diluted the brackish water, but 800 years of

deserting by the Indus River had allowed saline water down below to displace fresh

water of Indus River by various processes including seawater encroachment, surface

water evaporation and dilution. Hydro‐geological investigations carried out by the

Water and Power Development Authority (WAPDA) on the eastern side of the Indus

River reveals that freshwater is available at shallow depths in Hyderabad district up to

60 m. It becomes saline to highly saline as one moves south to the coastal areas.

Groundwater occurs under water table condition at depths varying from 3 m to 10 m.

Water resources map of Kotri North Block is provided in Figure 6‐4.

c. Water quality

Water quality analysis was carried out in the project area as part of the EIA study. For

this purpose five water samples were taken from various sources being used by locals

for drinking purposes. These sources include three hand pumps and two surface water

samples. Out of these two surface water samples, one was taken from Indus River

crossing the project area and water of the river is being consumed for drinking

purposes by the local communities residing on the banks of the river. Sixteen (16)

parameters were analysed in each sample and thereafter compared with Sindh

Standards for Drinking Water Quality (SSDWQ). All these parameters of water play

an important role, especially in determining its quality and suitability for intended

use. The lab results are provided in Table 6‐2 and sampling location of water samples

are also marked in Figure 6‐4. Based upon chemical analysis test results it may be

concluded that water quality is not satisfactory for drinking purposes.

At present, sources of water contamination are open defecation, uncontrolled disposal

of domestic and livestock wastes, uncontrolled use of pesticides and chemicals in

agricultural fields by local communities however, no quantitative analysis of the

extent of this contamination is available.


OCTOBER 2019 96 HPK

Table 6‐1: Meteorological Data of Hyderabad District, 2009 – 2018

Month/Year

Parameters

Average Temperature (°C) Avg. Rainfall in

mm

Humidity in

%

Avg. Wind in

kmph

Avg. Sun

hours Maximum Minimum Average

2009

Jan 25 14 19 1.32 38 11.3 252.5

Feb 32 17 24 0 32 9.4 280

Mar 37 21 29 0.51 29 10.1 308.5

Apr 41 24 32 0.02 22 12.4 327.5

May 46 28 36 0 36 15.1 387.5

Jun 44 29 35 5.43 44 15.5 364.5

Jul 42 30 35 5.51 51 15.9 371

Aug 40 28 33 0.45 54 15.7 318.5

Sep 41 27 33 0 47 14.5 300

Oct 40 22 30 0 27 8.2 265

Nov 33 18 24 0 23 8.9 225

Dec 28 14 19 0 27 10.2 229.5

2010

Jan 27 12 19 0.34 32 9.3 265

Feb 30 15 22 2.13 30 9.9 276

Mar 40 22 30 0 31 11.3 310

Apr 43 25 34 0 30 14.8 319.5

May 45 28 36 0 35 16.5 387.5

Jun 43 29 35 7.04 44 17 369

Jul 40 29 34 36.36 56 12.7 347

Aug 38 28 32 48.26 64 11.6 300

Sep 39 26 32 13.71 51 10.1 288

Oct 40 23 30 0.05 37 8.8 265


OCTOBER 2019 97 HPK

Month/Year

Parameters


mm

Humidity in

%

Avg. Wind in

kmph

Avg. Sun


Nov 32 18 24 0.04 27 9.9 225

Dec 27 11 17 0 24 10.1 232.5

2011

Jan 26 11 17 0.07 26 10.3 262.5

Feb 29 15 21 0.22 39 10.3 276

Mar 37 20 28 0.05 28 10.9 302.5

Apr 41 23 31 0.14 27 11.1 323.5

May 43 27 34 0.07 47 21.6 387.5

Jun 42 29 35 1.69 48 24.7 373.5

Jul 39 29 34 21.38 53 22.2 377

Aug 36 28 31 139.07 65 17.2 282

Sep 34 27 30 108.85 68 16.1 250.5

Oct 36 24 29 0 40 12.1 267.5

Nov 33 23 27 0.16 38 10.2 219.5

Dec 27 15 20 0 24 12.3 232.5

2012

Jan 24 12 17 0.01 34 12.1 256.5

Feb 26 13 19 0 22 13 290

Mar 35 20 27 0 26 13.3 308.5

Apr 40 26 33 1.88 29 14.7 326

May 43 28 35 2.77 39 19.7 386

Jun 42 28 34 0.67 52 27.2 373.5

Jul 40 28 33 0.92 56 28.1 386

Aug 38 28 32 7.77 57 22.9 339

Sep 37 28 32 17.45 55 16 270


OCTOBER 2019 98 HPK

Month/Year

Parameters


mm

Humidity in

%

Avg. Wind in

kmph

Avg. Sun


Oct 37 24 30 0.28 32 10.6 265

Nov 32 20 26 0 27 9 225

Dec 27 15 20 0.47 27 12.5 232.5

2013

Jan 26 13 18 0 25 11.7 260

Feb 28 16 21 4.93 33 14.8 275.5

Mar 35 22 28 0.05 24 13 306

Apr 39 26 32 1.72 32 15.8 326

May 43 28 35 0 35 23.7 387.5

Jun 41 30 35 2.38 47 22.7 369

Jul 40 30 34 0.45 54 24.9 372

Aug 37 28 32 34.57 60 21.6 312

Sep 39 27 33 0.43 48 17.8 300

Oct 38 20 32 0.28 39 11.5 265

Nov 32 15 25 0 27 9.9 225

Dec 27 11 20 0 31 11.1 232.5

2014

Jan 24 11 17 0 28 12.9 257.5

Feb 28 15 21 0 29 13.2 280

Mar 34 21 27 2.18 26 12.8 306

Apr 40 26 33 2.11 30 16.2 325

May 42 29 35 0.71 37 22.1 387.5

Jun 43 30 36 0.13 47 29.1 370.5

Jul 40 29 34 3.89 55 27 381.5

Aug 38 28 32 1.52 55 22.8 336


OCTOBER 2019 99 HPK

Month/Year

Parameters


mm

Humidity in

%

Avg. Wind in

kmph

Avg. Sun


Sep 38 27 32 1.21 55 20.8 297

Oct 38 25 31 0.55 31 11.6 265

Nov 33 21 26 0 30 10.7 225

Dec 27 15 20 0 23 11.4 231

2015

Jan 26 14 19 0.19 35 10.8 262.5

Feb 30 19 24 1.45 34 13.4 269.5

Mar 35 23 28 0.27 28 13.4 308.5

Apr 41 28 34 0.68 29 18 320.5

May 44 30 36 1.12 37 24.8 387.5

Jun 42 32 36 21.53 43 21.1 364.5

Jul 37 29 33 54.3 61 30 347.5

Aug 37 28 31 1.85 60 28 331

Sep 38 27 32 2.28 50 19.2 291

Oct 38 27 32 0.32 35 14.7 276.5

Nov 32 22 26 0 22 12.2 225

Dec 27 16 21 0.55 22 10.2 229.5

2016

Jan 27 16 21 0 34 10 262.5

Feb 30 18 23 0 18 10.8 290

Mar 36 25 30 2.27 30 15.2 307

Apr 40 27 33 0.38 29 17.7 314

May 42 29 35 1.24 42 27.4 387.5

Jun 43 30 36 0 45 24.8 372

Jul 39 30 34 9.77 57 25.2 341


OCTOBER 2019 100 HPK

Month/Year

Parameters


mm

Humidity in

%

Avg. Wind in

kmph

Avg. Sun


Aug 38 29 33 9.42 57 20.8 319.5

Sep 39 27 32 0 54 24.1 300

Oct 38 26 31 0 44 14.4 262.5

Nov 34 21 26 0 25 8.7 225

Dec 31 19 24 0 28 8.8 232.5

2017

Jan 25 15 19 1.31 32 11.7 263.5

Feb 30 18 23 1.23 19 11.3 275.5

Mar 36 23 29 0.2 25 12.7 308.5

Apr 42 27 34 1.16 28 19.6 327.5

May 44 30 36 0 38 23.4 387.5

Jun 41 30 35 0.41 51 26.5 351

Jul 37 30 33 12.48 58 25.4 362

Aug 37 29 33 17.04 55 24.5 321

Sep 38 28 32 9.25 50 18.4 295.5

Oct 38 27 32 0 32 12.2 265

Nov 32 21 26 0 23 9 225

Dec 27 17 21 0.01 21 12.4 231

2018

Jan 28 17 21 0 28 8.7 265

Feb 31 20 25 0 26 10.1 278.5

Mar 36 24 30 0 27 13.8 306

Apr 41 28 34 0.13 25 16.9 320.5

May 44 31 37 0 27 19.6 386

Jun 41 30 35 0.05 49 28 368



Month/Year

Parameters


mm

Humidity in

%

Avg. Wind in

kmph

Avg. Sun


Jul 38 29 33 0.27 57 28.6 375.5

Aug 36 28 31 3.84 60 27.8 326

Sep 37 26 31 0.06 54 22.9 298.5

Oct 40 31 37 0.1 25 12.4 262

Nov 35 27 32 0 22 8.9 217.5

Dec 29 20 26 0 26 9.7 232.5

Source: https://www.worldweatheronline.com/hyderabad‐weather‐averages/sindh/pk.aspx



Table 6‐2: Water Quality within Project Area

No. Water Parameters Units LOD Concentration

Sample 1 (HP) Sample 2 (HP) Sample 3 (HP) Sample 4 (SW)* Sample 5 (SW)

1. pH … … 7.52 7.22 6.81 7.31 7.28

1. TDS mg/l 1.0 5 17 9 46 54

2. TSS mg/l 0.5 802 538 7675 226 171

3. Chloride (Cl‐1) mg/l 2.0 30.25 49.54 1162.75 20.36 9.69

4. T. Hardness μg/ml … 266.23 459.13 2269.51 156.18 124.02

5. Calcium μg/ml … 45.53 129.78 421.15 45.30 35.53

6. Magnesium μg/ml … 35.35 32.86 296.74 10.47 8.58

7. Fluoride (F)* mg/l 0.05 0.41 0.33 2.86 0.57 0.55

8. Sulphate μg/ml … 188.76 107.22 1660.20 45.48 30.05

9. Lead (Pb) μg/ml 0.04 ND ND ND ND ND

10. Arsenic (As) ppb 0.75 ND 14.20 ND ND 1.73

11. Cadmium (Cd) μg/ml 0.01 ND ND ND ND ND

12. Nickel (Ni) μg/ml 0.01 ND ND ND ND ND

13. Phenolic compounds mg/l 0.1 ND 0.33 ND ND 0.55

14. Nitrate (NO3)* mg/l 3.0 ND ND ND ND ND

15. Iron μg/ml 0.02 0.09 0.16 ND 0.08 0.52

Notes:

*: Surface water from Indus River

HP: Hand pump

SW: Surface water

ND: Not detected

LOD: Limit of determination



Table 6‐3: Ambient Noise Levels Monitoring

No. Location

Noise Level (dB) Latitude Longitude

1. 22° 24ʹ 21.1ʹʹ 68° 29ʹ 20.8ʹʹ 53.7

2. 25° 45ʹ 11.1ʹʹ 68° 28ʹ 40.3ʹʹ 54.1

3. 25° 45ʹ 10.9ʹʹ 68° 28ʹ 21.0ʹʹ 75.4

4. 25° 45ʹ 08.4ʹʹ 68° 27ʹ 45.1ʹʹ 54.8

5. 25° 45ʹ 07.7ʹʹ 68° 27ʹ 19.3ʹʹ 52.5

6. 25° 44ʹ 48.9ʹʹ 68° 26ʹ 31.8ʹʹ 56.8

7. 25° 45ʹ 29.0ʹʹ 68° 23ʹ 48.4ʹʹ 59.8

8. 25° 46ʹ 02.2ʹʹ 68° 23ʹ 28.1ʹʹ 53.2

9. 25° 37ʹ 51.2ʹʹ 68° 32ʹ 36.4ʹʹ 54.1

10. 25° 34ʹ 54.6ʹʹ 68° 29ʹ 22.6ʹʹ 63.8

11. 25° 33ʹ 58.9ʹʹ 68° 30ʹ 58.4ʹʹ 55.6

12. 25° 32ʹ 50.6ʹʹ 68° 32ʹ 50.4ʹʹ 56.2

13. 25° 31ʹ 05.9ʹʹ 68° 33ʹ 12.3ʹʹ 60.7

14. 25° 30ʹ 03.9ʹʹ 68° 35ʹ 15.9ʹʹ 55.7

15. 25° 28ʹ 16.2ʹʹ 68° 35ʹ 21.8ʹʹ 60.1

16. 25° 26ʹ 51.2ʹʹ 68° 35ʹ 38.2ʹʹ 56.2

17. 25° 25ʹ 41.0ʹʹ 68° 32ʹ 21.8ʹʹ 66.5

18. 25° 28ʹ 15.3ʹʹ 68° 27ʹ 43.7ʹʹ 55.7

19. 25° 28ʹ 29.6ʹʹ 68° 26ʹ 32.9ʹʹ 53.5

20. 25° 28ʹ 16.4ʹʹ 68° 26ʹ 37.5ʹʹ 53.7

21. 25° 28ʹ 59.4ʹʹ 68° 25ʹ 58.7ʹʹ 53.1

22. 25° 29ʹ 01.9ʹʹ 68° 25ʹ 56.0ʹʹ 58.8

23. 25° 29ʹ 20.4ʹʹ 68° 25ʹ 20.6ʹʹ 63.2

24. 25° 36ʹ 23.8ʹʹ 68° 26ʹ 01.2ʹʹ 62.7

25. 25° 36ʹ 25.0ʹʹ 68° 25ʹ 47.3ʹʹ 54.8

26. 25° 36ʹ 15.0ʹʹ 68° 26ʹ 11.0ʹʹ 56.8

27. 25° 28ʹ 47.1ʹʹ 68° 26ʹ 19.8ʹʹ 55.3

28. 25° 27ʹ 41.5ʹʹ 68° 28ʹ 14.1ʹʹ 54.7

29. 25° 26ʹ 13.9ʹʹ 68° 18ʹ 10.5ʹʹ 53.9

30. 25° 28ʹ 16.6ʹʹ 68° 22ʹ 45.1ʹʹ 52.5

31. 25° 25ʹ 52.3ʹʹ 68° 18ʹ 04.6ʹʹ 51.6

32. 25° 26ʹ 42.2ʹʹ 68° 18ʹ 42.1ʹʹ 50.9

33. 25° 33ʹ 29.2ʹʹ 68° 15ʹ 38.9ʹʹ 55.3

34. 25° 33ʹ 42.9ʹʹ 68° 14ʹ 51.3ʹʹ 51.8

35. 25° 34ʹ 45.3ʹʹ 68° 18ʹ 46.8ʹʹ 68.6

36. 25° 37ʹ 51.1ʹʹ 68° 18ʹ 06.4ʹʹ 64.7

37. 25° 38ʹ 57.2ʹʹ 68° 18ʹ 07.3ʹʹ 61.3

38. 25° 38ʹ 30.1ʹʹ 68° 17ʹ 50.5ʹʹ 53.7

39. 25° 37ʹ 34.4ʹʹ 68° 18ʹ 15.2ʹʹ 58.4

40. 25° 35ʹ 04.9ʹʹ 68° 20ʹ 19.4ʹʹ 60.9

41. 25° 35ʹ 34.4ʹʹ 68° 16ʹ 37.3ʹʹ 56.6



No. Location


42. 25° 35ʹ 11.5ʹʹ 68° 16ʹ 55.2ʹʹ 53.5

43. 25° 28ʹ 45.5ʹʹ 68° 16ʹ 19.6ʹʹ 62.5

44. 25° 28ʹ 48.6ʹʹ 68° 16ʹ 54.0ʹʹ 58.8

45. 25° 29ʹ 16.8ʹʹ 68° 17ʹ 07.0ʹʹ 53.6

46. 25° 30ʹ 59.4ʹʹ 68° 17ʹ 30.9ʹʹ 52.5

47. 25° 30ʹ 58.6ʹʹ 68° 17ʹ 41.5ʹʹ 59.4

48. 25° 30ʹ 10.5ʹʹ 68° 18ʹ 37.6ʹʹ 53.7

49. 25° 30ʹ 08.2ʹʹ 68° 18ʹ 55.0ʹʹ 53.2

50. 25° 28ʹ 32.1ʹʹ 68° 16ʹ 16.8ʹʹ 64.1

51. 25° 24ʹ 04.0ʹʹ 68° 16ʹ 52.3ʹʹ 66.2

52. 25° 21ʹ 32.4ʹʹ 68° 12ʹ 09.5ʹʹ 62.4.

53. 25° 21ʹ 35.0ʹʹ 68° 12ʹ 14.2ʹʹ 59.3

54. 25° 23ʹ 12.2ʹʹ 68° 14ʹ 47.4ʹʹ 61.6

55. 25° 24ʹ 13.4ʹʹ 68° 18ʹ 24.4ʹʹ 52.6

56. 25° 24ʹ 44.1ʹʹ 68° 19ʹ 04.6ʹʹ 62.5

57. 25° 24ʹ 26.4ʹʹ 68° 16ʹ 00.9ʹʹ 65.6

58. 25° 24ʹ 46.5ʹʹ 68° 16ʹ 15.2ʹʹ 66.1

59. 25° 23ʹ 03.8ʹʹ 68° 21ʹ 18.3ʹʹ 63.6

60. 25° 23ʹ 05.8ʹʹ 68° 20ʹ 36.4ʹʹ 66.2

61. 25° 23ʹ 20.6ʹʹ 68° 20ʹ 26.1ʹʹ 67.7

62. 25° 24ʹ 13.8ʹʹ 68° 19ʹ 37.6ʹʹ 68.5

63. 25° 24ʹ 09.5ʹʹ 68° 18ʹ 39.1ʹʹ 69.3

64. 25° 42ʹ 33.9ʹʹ 68° 30ʹ 06.6ʹʹ 51.4

65. 25° 43ʹ 02.2ʹʹ 68° 29ʹ 39.3ʹʹ 53.1

66. 25° 46ʹ 03.7ʹʹ 68° 23ʹ 20.6ʹʹ 50.8

67. 25° 45ʹ 09.9ʹʹ 68° 26ʹ 20.2ʹʹ 51.7

68. 25° 37ʹ 47.9ʹʹ 68° 32ʹ 33.8ʹʹ 53.4

69. 25° 36ʹ 28.6ʹʹ 68° 31ʹ 25.7ʹʹ 52.2

70. 25° 34ʹ 54.0ʹʹ 68° 29ʹ 38.8ʹʹ 56.8

71. 25° 34ʹ 48.6ʹʹ 68° 29ʹ 51.7ʹʹ 60.8

72. 25° 34ʹ 14.1ʹʹ 68° 30ʹ 51.9ʹʹ 63.3

73. 25° 32ʹ 02.7ʹʹ 68° 33ʹ 14.3ʹʹ 55.2

74. 25° 31ʹ 05.9ʹʹ 68° 33ʹ 12.3ʹʹ 58.9

75. 25° 30ʹ 39.4ʹʹ 68° 32ʹ 58.3ʹʹ 51.5

76. 25° 25ʹ 48.6ʹʹ 68° 32ʹ 40.9ʹʹ 64.7

77. 25° 25ʹ 44.1ʹʹ 68° 27ʹ 35.9ʹʹ 52.3

78. 25° 28ʹ 45.4ʹʹ 68° 26ʹ 20.0ʹʹ 53.2

79. 25° 29ʹ 20.4ʹʹ 68° 25ʹ 20.6ʹʹ 54.4

80. 25° 32ʹ 27.7ʹʹ 68° 26ʹ 08.1ʹʹ 68.9

81. 25° 34ʹ 41.2ʹʹ 68° 28ʹ 37.6ʹʹ 55.7

82. 25° 36ʹ 16.3ʹʹ 68° 27ʹ 12.4ʹʹ 73.6

83. 25° 31ʹ 46.9ʹʹ 68° 16ʹ 52.5ʹʹ 71.8



No. Location


84. 25° 33ʹ 06.6ʹʹ 68° 16ʹ 53.5ʹʹ 52.9

85. 25° 38ʹ 07.3ʹʹ 68° 18ʹ 06.9ʹʹ 64.8

86. 25° 33ʹ 05.7ʹʹ 68° 17ʹ 58.9ʹʹ 59.7

87. 25° 29ʹ 11.5ʹʹ 68° 16ʹ 19.3ʹʹ 64.9

88. 25° 27ʹ 15.0ʹʹ 68° 16ʹ 20.7ʹʹ 63.7

89. 25° 21ʹ 48.2ʹʹ 68° 12ʹ 19.2ʹʹ 75.3

90. 25° 22ʹ 15.4ʹʹ 68° 13ʹ 11.6ʹʹ 59.6

91. 25° 24ʹ 20.0ʹʹ 68° 17ʹ 52.2ʹʹ 72.2

92. 25° 24ʹ 46.1ʹʹ 68° 16ʹ 14.7ʹʹ 73.8

93. 25° 50ʹ 15.6ʹʹ 68° 04ʹ 24.0ʹʹ 53.1

94. 25° 47ʹ 17.5ʹʹ 68° 11ʹ 02.0ʹʹ 49.4

95. 25° 43ʹ 41.7ʹʹ 68° 10ʹ 27.6ʹʹ 58.6

96. 25° 47ʹ 55.8ʹʹ 68° 15ʹ 46.0ʹʹ 54.8

97. 25° 52ʹ 05.9ʹʹ 68° 14ʹ 31.5ʹʹ 60.2

Note: All locations were randomly selected in day time within the project area.



Figure 6‐1: Graphical Representation of Average Temperatures in Hyderabad, 2009 – 2018

0

5

10

15

20

25

30

35

40

45

50

Jan, 09

Apr, 09

Jul, 09

Oct, 09

Jan, 10

Apr, 10

Jul, 10

Oct, 10

Jan, 11

Apr, 11

Jul, 11

Oct, 11

Jan, 12

Apr, 12

Jul, 12

Oct, 12

Jan, 13

Apr, 13

Jul, 13

Oct, 13

Jan, 14

Apr, 14

Jul, 14

Oct, 14

Jan, 15

Apr, 15

Jul, 15

Oct, 15

Jan, 16

Apr, 16

Jul, 16

Oct, 16

Jan, 17

Apr, 17

Jul, 17

Oct, 17

Jan, 18

Apr, 18

Jul, 18

Oct, 18

Average Temperature (°C) Maximum Average Temperature (°C) Minimum Average Temperature (°C) Average



Figure 6‐2: Graphical Representation of Hyderabad Climatic Data, 2009 – 2018

0

20

40

60

80

100

120

140Mar, 09

Jun, 09

Sep

, 09

Dec, 09

Mar, 10

Jun, 10

Sep

, 10

Dec, 10

Mar, 11

Jun, 11

Sep

, 11

Dec, 11

Mar, 12

Jun, 12

Sep

, 12

Dec, 12

Mar, 13

Jun, 13

Sep

, 13

Dec, 13

Mar, 14

Jun, 14

Sep

, 14

Dec, 14

Mar, 15

Jun, 15

Sep

, 15

Dec, 15

Mar, 16

Jun, 16

Sep

, 16

Dec, 16

Mar, 17

Jun, 17

Sep

, 17

Dec, 17

Mar, 18

Jun, 18

Sep

, 18

Dec, 18

Avg. Rainfall in mm Humidity in % Avg. Wind in kmph

0 90 180 270 360 450 540 63045Km


Fig 6-3: Seismic Zone Map of Paksitan

Halcrow Pakistan (Pvt) Limitedwww.halcrowpk.com

Zone 2B Zone 2A

Zone 3

Zone 3

Zone 2A

Zone 2B

Zone 2B

Zone 1

Zone 4

Zone 2B

Zone 2B

Zone 4

Zone 4

Zone 3

Zone 3

Zone 4

Zone 4

Zone 4Zone 4

82°0'0"E

82°0'0"E

80°0'0"E

80°0'0"E

78°0'0"E

78°0'0"E

76°0'0"E

76°0'0"E

74°0'0"E

74°0'0"E

72°0'0"E

72°0'0"E

70°0'0"E

70°0'0"E

68°0'0"E

68°0'0"E

66°0'0"E

66°0'0"E

64°0'0"E

64°0'0"E

62°0'0"E

62°0'0"E3

6°0

'0"N

36

°0'0

"N

34

°0'0

"N

34

°0'0

"N

32

°0'0

"N

32

°0'0

"N

30

°0'0

"N

30

°0'0

"N

28

°0'0

"N

28

°0'0

"N

26

°0'0

"N

26

°0'0

"N

24

°0'0

"N

24

°0'0

"N

KotriNorthBlock

;?N

LegendZone 1 (0.05 to 0.08g)Zone 2A (0.08 to 0.16g)Zone 2B (0.16 to 0.24g)Zone 3 (0.24 to 0.32g)Zone 4 (> 0.32g)

LegendKotri North Block Seismic Zones

Zone 1

Zone 2A

Zone 2B

Zone 3

Zone 4

United Energy Pakistan

h

h

h

h

h

Kotri

Hala

Matiari

Hyderabad

Thatta Latifabad

Tando Adam

Qasimabad

Tando Allahyar

Jamshoro

Matiari

Hyderabad

Thatta

Sanghar

68°30'0"E

68°30'0"E

68°20'0"E

68°20'0"E

68°10'0"E

68°10'0"E26

°0'0

"N

26°0

'0"N

25°5

0'0

"N

25°5

0'0

"N

25°4

0'0

"N

25°4

0'0

"N

25°3

0'0

"N

25°3

0'0

"N

25°2

0'0

"N

25°2

0'0

"N

·0 2.5 5 7.5 10 12.5 15 17.5 Km


Fig 6-4: Water Resources Map

Project:EIA for Exploration and AssociatedDevelopment Activities in Kotri North Block (E.L. 2568-21)

Legend

h Water_Sample h Water Sampling Location Nationla Highway

mminor and katcha tracks

Name

Canal

Indus River

Nullah

Project Boundary

District Boundaries

Block Boundary/Project Area

Tehsil Boundaries

Reserve Forest (SOP)

Legendh

Water SamplingLocationNationla HighwayCanal

Indus RiverNullah

BlockBoundary/ProjectAreaReserve Forest(SOP)

Tehsil BoundariesDistrict Boundaries

United EnergyPakistan

!

!!!!!

!!

!

!

!

!

!

!

!

!

!

!!!

!!!

!!!

!

!

!

!

!

!

!!

!

!

!!

!

!!!

! !!

!!

!!

!

!

!!

!

!!

!!

!!!

!!

!!

!

!

!

!

!!!

!

!!

!!

!!

!

!

!

!

!

!

!

!

!

!!

!!

!

!

!

!

!

Kotri

Hala

Matiari

Hyderabad

Thatta Latifabad

Tando Adam

Qasimabad

Tando Allahyar

Jamshoro

Matiari

Hyderabad

Sanghar

Thatta68°30'0"E

68°30'0"E

68°20'0"E

68°20'0"E

68°10'0"E

68°10'0"E26

°0'0

"N

26°0

'0"N

25°5

0'0

"N

25°5

0'0

"N

25°4

0'0

"N

25°4

0'0

"N

25°3

0'0

"N

25°3

0'0

"N

·0 2.5 5 7.5 10 12.5 15 17.5 Km


Fig 6-5: Ambient Noise Sampling Location Map of Project AreaProject:EIA for Exploration and Associated Development Activities in Kotri North Block (E.L. 2568-21)

Legend! new noise locations

!C Well Site

×[ Gas Plant

"" Goth

×k Graveyard

!a Power Plant

Shrine

¥B¢ University

h Water Sample

! Noise Sampling Location

Nationla Highway

mminor and katcha tracks

Project Area Boundary

District Boundaries

Block Boundary/Project Area

Tehsil Boundaries

Reserve Forest (SOP)


District BoundariesTehsil Boundaries

Reserve Forest (SOP)Nationla Highway

!Noise SamplingLocation United Energy

Pakistan



Photographs: Physical Environment and Resource of the Project Area

Photograph 6‐1: A view of Indus River Photograph 6‐2: A view of Kotri Barrage

Photograph 6‐3: Agriculture field – dominant

habitat of the project area Photograph 6‐4: Barani agriculture field

Photograph 6‐5: A patch of waste land & fallow

land

Photograph 6‐6: Stony plain of the project area



Photograph 6‐7: A view Matiari RF Photograph 6‐8: A view of Salaro Ghotana RF

Photograph 6‐9: Marshy wetland near Goth

Suleman Barejo

Photograph 6‐10: A view of Khasino Canal

(wah)

Photograph 6‐11: A view of Pannu wah Photograph 6‐12: Cemented watercourse –

Tadri Mori



Photograph 6‐13: Tube well found in the

project area Photograph 6‐14: A view of Rajani‐7 well site

Photograph 6‐15: Gas Compression Facility

near Rajani‐12 well site

Photograph 6‐16: A view of M9 motorway

entering into project area



Biological Environment

This section of the report describes the biological environment of the project area

proposed for exploration and associated development activities falls in Sindh

province. Ecologically, Kotri North Block and its immediate vicinities, is rich in

biodiversity having wide variations in physical features and climate which has

produced diverse landscape, ecosystem and habitats.

6.2.1 Data Sources

The present study of EIA contain data from both secondary and primary sources.

Primary field data of biological environment for the EIA was collected by a team of

wildlife specialist and botanist. Field survey data for the EIA was collected during

August, 2019. The faunal field data collection included traditional wildlife survey

techniques like line transects, incidental sightings and plot searches for birds, reptiles

and mammals. The vegetation survey was carried out by laying 2 x 2 m and 20 x 20 m

quadrates within the study area. The field survey methodologies followed

scientifically established and accepted wildlife and vegetation survey techniques.

Primary data for flora and fauna was collected at various sampling locations of the

project area. The sampling locations were randomly selected ensuring that sufficient

locations were sampled from each habitat and the maximum number of species

belonging to each habitat was identified.

The secondary data was also collected which provides a detailed insight in the

biological environment of the Kotri North Block. For faunal attributes, this mainly

includes work of WWF Pakistan, Sindh Wildlife Department (SWD), Zoological

Survey Department (ZSD) and IUCN Pakistan. Previously conducted IEEs and EIAs in

the region were also consulted for the purpose. For floral attributes, works of Roberts

(1967, 1991 and 1997) and Schaller (1977) were primarily consulted. Information on

other secondary data sources consulted during the current EIA study is provided in

the references section of this EIA report.

6.2.2 Protected/Sensitive Areas








forests, now mostly are under cultivation. These reserved forests mostly lie along the

bank of Indus River falling in north‐eastern side of the block. During project execution

Sindh EPA, under Regulations, 2014 and Sindh Forest Department will have the

authority to oversee the conduct of proposed project activities approved by them.



6.2.3 Biological Habitats

Kotri North Block (E.L. 2568‐21) is predominantly located in hilly, stony and sandy

plains followed by cultivable land & agricultural fields however, mosaics of micro‐

habitats are also present within and around the study area. On the basis of these main

micro‐habitats present within the project area, it can be divided into four major habitat

types, each of which have its own ecological significance and possess unique floral and

faunal attributes. These are:

Hilly, Stony and Sandy Plains;

Agriculture Fields, Farmlands & Human Settlements;

Indus River/Irrigation Network and Associated Marshes; and

Wastelands & Fallow Lands.

These habitat types will be discussed in detail in later paragraphs while describing

fauna and flora of the entire project area as a whole. During the field visit for EIA a

total of 128 floral species belonging to 37 families, 101 birds, 20 mammals and 20

reptiles were recorded. Complete list of biological attributes is provided in Table 6‐4

(flora) to Table 6‐12 to 6‐14 (fauna).

As mentioned above a total of four major habitats were identified during the field

survey for the study. Classifications of these habitats is discussed separately in the

following sections of this chapter. Information on the key species of flora and fauna

associated with each habitat type has also been discussed as part of the habitat

description.

a. Hilly, Stony and Sandy Plains

This common and most dominant type of habitat is found in the western side of the

project area which mostly falls in geographical jurisdiction of Jamshoro district. The

bottom of hills constitutes stony/sandy plains which get eroded soil and nutrients

from watershed areas. Sometimes they get flooded during heavy rains mainly during

monsoon. However, during most of the dry months, the conditions of these plains are

mainly acute dry. Suitable portions of these stony plains are cultivated and are rain fed

(wherever feasible).

The main floral species, which are stunted and sparse due to overgrazing, include,

Cassia italic, Zizyphus nummularia, Haloxylon salicornicum, Salsola imbricate, Withania

coagulan and Convolvulus spinosus. The wildlife in this arid climate is of special

significance which can survive such harsh climatic conditions.

The typical avian species of this habitat type include See see partridge, Desert

wheatear, Desert lark, Collared dove, Blue rock pigeon, Great grey shrike, Hoopoe and

Common babble. Among them game birds are liked by sport hunters. Among the

mammals, Asiatic jackal, Black napped hare, Desert cat, Indian pangolin and Long

eared desert hedgehog may be mentioned, where enough cover is available for their



food and protection. Raptors like Common kestrel and Black kite were noticed

hovering in search of small mammals and rodents.

b. Agriculture Fields, Farmlands & Human Settlements

Second commonly found habitat type comprises of agricultural fields, orchards and

villages located in entire project area except for the main Indus River. The ecology this

built environment has been altered with passage of time through different human

interventions. Most of the riverine forests have been cleared for seasonal agriculture

during the low flow season. These riverine forests were once flourishing now have

almost disappeared due to negligence of relevant authorities and most of the land is

converted into agriculture fields.

Like other such areas, a number of species of mammals, birds and reptiles have

adapted human presence in their neighbourhood and started living in agriculture

fields, planted trees and even in structures. The presence of these species was noticed

by direct sightings or through their discrete calls like doves, sparrows, mynas, bulbuls,

larks and many passeriforms living around human presence. Mammals, which are

nocturnal in nature were noticed through signs of their movement for search of food.

Asiatic jackal, Indian/Bengal fox and Desert cat were noticed through their footprints,

scats and predation on domestic birds and small animals. The small mammals/rodents

were observed through their burrow systems usually in form of colonies. Reptiles

were noticed living in their burrow system, on planted trees and even in

cracks/cavities of buildings/structures.

Besides the weed species, anthropogenic trees species like Acacia nilotica, Azardica

indica, Albizia lebbeck, Eucalyptus camaldulensis, Cordia myxa, Dalbergia sissoo and

Zizyphus mauritiana are scattered around the edges of the agricultural fields. These

planted and some natural trees and orchards are the roosting places for raptors

including Common kestrel, Brahminy kite, Black kite, Black‐winged kite, buzzards

and sometimes eagles. These raptors feed upon rodents and small mammals and play

positive role for farmers to reduce their loss.

c. Indus River/Irrigation Network and Associated Marshes

Indus River, the most critical/important ecosystem is located in the north‐eastern and

eastern part of the project area running north south. Indus River, the irrigation system

supported majorly through Kotri Barrage and associated dhands/marshes on banks

which are usually inundated during monsoon. These seasonal floods are very

important for resident wildlife. River Indus is also important for migratory birds,

mainly water‐birds as it is used for navigation and resting ground for winter migrants.

In addition, the important nearby wetlands like Kalri, Haleji and Hadero are also very

important for resident and migratory water‐birds, mainly waterfowls which use these

water bodies for staging during migration and if settled, for entire winter season. The

abundance of different invertebrates, including insects and soil biodiversity coupled

with different palatable floral species, the main source of food for resident and

migratory birds make this habitat rich and important.



The floral species were observed from this habitat, at the river banks, and riverine

areas which are usually under water during the monsoon floods. Species that grow

around the river and associated marshes include Tamarix indica, Saccharum spontaneum,

Populus euphratica, Saccharum bengalensis, Acacia nilotica and Capparis deciduas etc.

including some submerge species e.g. Phragmites karka, Typha elphentiana and Typha

domingensis.

During the EIA field visit of project area, a good number of resident and migratory

species of birds were recorded along Indus River, supporting irrigation network and

associated dhands/marshes on its both sides.

d. Wastelands & Fallow Lands

Ecologically, this is the least important habitat and was noticed in some parts of the

project area, either in highlands or in shallow lands, in form of small patches. Most of

such areas were being cultivated in the past. However, water‐logging and salinity

have reduced the productivity of these areas and now left without any potential use

by the farmers. Some higher patches were not able to command by irrigation system,

hence not productive for agriculture. The main flora includes the salt tolerant species,

grasses and mesquite, Saccharum spontaneum, Tamarix indica, Salvadora oleoides and

Saccharum bengalense.

Such areas which are in shape of islands between human habitations and agricultural

fields are also less important for wildlife. Very few species were noticed in this habitat

type including Crested lark, Desert lark, House crow, Indian roller, Little green bee‐

eater, Indian myna and some passerines. However, the tall grasses, thickets and bushes

provide habitat for Black and Grey partridges. Overall, such areas are of least

ecological importance.

6.2.4 Baseline Conditions

a. Flora

The variation in climate between upper and lower Sindh is not reflected in any

difference in the flora of the two zones. The vegetation is characteristic of edaphic

conditions of the region viz. arid climate and sandy and calcareous soil, largely

impregnated with salts. A notable feature is the predominance of plants and trees with

small leaves, or none at all, and the large proportion of thorny species. The apparent

contrast between the verdure of the riverine and irrigated tracts on the one hand, and

the hilly and desert tracts on the other, is largely a matter of its intensity and

distribution.

Overall, Sindh Forest Department controls an area of 241,198 hectares in the Riverine

tract of the province which are categorized as ʺRiverine Forestsʺ locally known as

Kacho forests. These forests are located along both the banks of River Indus in Thatta,

Hyderabad, Dadu, Larkana, Naushero Feroze, Nawabshah, Khairpur, Sukkur,

Shikarpur, Ghotki and Jacobabad districts and have been declared as “Reserved

Forests” under Forests Act, 1927. The rich alluvial soils support crops of Acacia nilotica



(Babul), Populus euphratica (Bahan), Tamarix aphylla, Tamarix dioca (Lai) and Prosopis

cineraria (Kandi). Riverine forests are the most productive forests of Sindh, producing

wood material for domestic and commercial purposes.

Existence of Riverine forests of Sindh is dependent on flooding by the river. They are

flooded by the spate of River Indus, on lands and soils over its banks. Floods occur

due to the flow of large quantities of water in the river that cannot be accommodated.

Both the land configuration and the soils in riverine tract are made by flood waters.

The spate was a common summer phenomenon in the past, until such a time that the

river water was not diverted and extracted through dams, barrages, head‐works and

link‐canals. Riverine forests are the mainstay of forestry in Sindh. They provide

products and services such as timber, firewood, pit props for mines, forage and

browse for livestock, supports biodiversity and game animals. Other non‐timber forest

products include tannin from bark, gum, honey and even fish from dhands (ponds) and

dhoros (depression of old river beds). They act as carbon sinks, moderate climate, stop

soil erosion and also protect soils and settlements from the ferocity of flood waters.

The annual inundation of the riverine areas during the monsoon season act as a lifeline

for the existence and flourishing of the Riverine forests. There has been large‐scale

degradation of riverine forests due to severe decrease in flow of freshwater down the

Guddu Barrage. The situation has been worsened by the recent drought and lowest

ever flow in Indus (0.75 MAF) downstream of Kotri Barrage. Major reason for great

depletion of Riverine forests are continuous decrease in quantum of floods due to

upper stream storage, diversion and increasing amount of take‐off for irrigation/

human consumption. Areas frequently flooded before are now flooded only every

seven or eight year interval, which is not enough to support lush floodplain forests.

High‐lying portions of these forests are the worst affected. Reduced frequency of high

floods has left these areas in an increasingly dry state. Xerophytic trees and shrubs have

replaced thick and profuse growth of Acacia nilotica, which is the main and most

important riverine specie. The common riverine forests species such as, Bahan (Populus

euphratica) and Lai (Tamarix aphylla) are gradually disappearing from the tract. Apart

from over all degradation of these forests, there occurred sizeable blanks within them

due to which the required forest density has diminished.

The Riverine forests in the past were only developed through the annual regeneration

at the time of monsoon floods. Recently, under annual development program, some

areas were developed and planted on the pattern of irrigated plantations by lift

irrigation through installation of electric/diesel operated tube wells and diesel

operated lift pumps on the river banks and depressions. The underground water in

the riverine tract is sweet, available in abundance in the aquifer and is suitable for

raising trees and agriculture crops. Following are the main factors responsible for

degradation of Riverine forests:

Severe reduction in flow of fresh water in Indus through floods;

Population pressure for meeting the local needs of the people; and



Increase in the high‐lying areas due to low floods.

Productive potential of these areas can be restored by developing artificial source of

irrigation such as installing tube wells and lift pumps and planting suitable tree

species for increasing wood production and protection of the environment. These

areas are to be developed through intensive management, land levelling and

arranging the assured supply of irrigation on high‐lying areas. In order to develop

these forests, two strategies have been proposed in various projects i.e. departmental

forestry or traditional forestry (forestry by the department) and participatory forestry

(forestry by the department and local people) with main emphasis on participation of

local people, poverty alleviation and combating desertification.

Floral Diversity

Ecologically, entire stretch of Kotri North Block is a part of the tropical thorn forest

ecozone. The area is characterized by low rainfall, high summer temperatures, high

velocity winds, poor soil and low diversity of plant species. Most of this region has

been cleared for cultivation and last remnants of the forest are heavily degraded due

to over grazing and felling of trees. Plant communities in the project area are also

faced with the threats of livestock grazing.

During field work for the EIA, 128 plant species belonging to 37 families were

identified in main habitats within the project area. Table 6‐4 provides a complete list

of the floral species along with their family name, life form and life span observed

during recent EIA site survey in the major habitats of the project area.

Out of 128 species 65 are perennial, 2 are semi‐perennial, 1 is biennial and 60 are

annual. Life forms of the identified species are as follows:

Life Form Number Life Form Number

Grass 31 Climber shrub 1

Herb 40 Subshrub 7

Tree 17 Prostrate subshrub 1

Sedge 8 Prostrate herb 1

Shrub 22 Total 128

Life form of the project area is dominated by herb (31.25%) followed by grass (24.22%),

shrub (17.19%), tree (13.28%), sedge (6.25%), subshrub (5.47%), climber shrub,

prostrate subshrub and prostrate herb (0.78%) each.

Floral Species of Medicinal or Economical Use

The species found in the project area which are of importance in terms of medicinal

and economical use include Aerva javanica, Capparis deciduas, Desmostachya bipinnata,

Salvadora oleoides and Typha elephantina. Table 6‐11 represents the plant species along

with their medicinal and economical use.



Rare or Endemic Floral Species

No endemic or rare species exist within the project area. All species have a wide range

of distribution. Some representative photographs of the flora in the project area are

presented at the end of this chapter.

Quantitative Accounts of Flora

The quantitative accounts of vegetation (i.e. Relative Cover, Relative Frequency,

Relative Density and Importance of Index Value (I.V.I) of all the species) were also

checked. The usual means of sampling of vegetation for floristic composition is the

quadrate. Traditionally, quadrates are square, although rectangular and even circular

quadrates have been used. Since, the vegetation of the project area is of different sized

components, comprised of trees/tall shrubs and tall herbs/sub‐shrubby/herbs and

grasses so Nested Quadrates method was adopted. Hence, two different sized

quadrates were laid down at every sampling site in major habitats as follows:

Measuring 20 x 20 m (Climax community for Trees/Tall shrubs)

Measuring 2 x 2 m (Underneath flora for Tall herbs/Sub‐ shrubs/Herbs and Grass)

Thereafter, the data in major habitats was analysed separately for each quadrate and

habitat as well. The quantitative analysis of floral composition (vegetation) was carried

out in calculating Relative Cover, Relative Frequency, Relative Density and

Importance of Index Value (I.V.I) of all the species.

The Relative Density of the species has been calculated with the following formula:

Relative Density =

Total number of individual of a species in all

quadrates 100

Total number of individual of all species in all

quadrates

The Relative Cover of species has been calculated with the following formula:

Relative Cover of

Species =

Total cover (sq. cm) of all plants of a species 100

Total cover (sq. cm) of plants of all species

The Relative Frequency % of the species has been determined with the help of the following formula:

Relative Frequency = Frequency of a species

100 Total frequency of all species

Importance Value Index (I.V.I) – Since the floral composition is not homogenous in

project area, so data like density, cover and frequency cannot depict clearly the

dominant species. Therefore, for each habitat measuring two separate sized quadrates

(i.e. 20 x 20m & 2 x 2m) Importance Value Index (I.V.I) of all the recorded species



calculated by adding the value of Relative Cover, Relative Frequency and Relative

Density then divided by three as follows:

I.V.I = Relative Cover + Relative Frequency + Relative Density

3

List of species found in the project area for EIA along with the I.V.I values for the three

major critical habitats identified by botanist namely Riparian habitat, Marshy/wetland

habitat and Calcareous rocky plain habitat for quadrates measuring 20 x 20m (Climax

community for Trees/Tall shrubs etc.) and 2 x 2m (Underneath flora for Tall herbs/Sub‐

shrubs/Herbs and Grass) is provided in Table 6‐5 to Table 6‐10.

Dominant Floral Species of Reserved Forests

According to the Sindh Forest Department the reserve forests comprise of five main

species of interest. These include Tamarix indica, Acacia nilotica, Prosopis juliflora,

Prosopis cineraria and Saccharum spontaneum.

b. Fauna

The faunal field data collection included line transects, incidental sightings and plot

searches for birds, ungulates, carnivores, small mammals and reptiles. On significant

wetlands, surveys were also conducted for identification of water‐birds. This involved

walking along the edges of the wetlands to select a suitable site for making

observations using binoculars and spotting scope. The survey team ensured that the

birds were observed without causing any disturbance. The sampling locations were

randomly selected, ensuring that sufficient locations are sampled for each habitat and

the maximum number of species belonging to each habitat is identified.

Birds

The project area of Kotri North Block, being blend of different habitats, supports a

variety of avifauna, both resident and migratory including migratory ducks, waders,

gulls, herons and egrets. Famous game birds including Grey and Black partridges are

also recorded almost throughout the project area. However, Black partridges are

confined to riverine areas and thick vegetative covers. The wetlands, dhands and

marshy areas will be filled with the arrival of migratory birds during the peak winter

season. The agricultural fields at the river banks and even in riverine areas provide

food and shelter to a number of species, which have adapted with the human

settlements. Houbara bustard sometimes is recorded from sandy plains but there had

been no recent sighting from the project area.

During the current EIA field visit, 101 birds’ species which includes 28 migratory and

73 resident species were recorded from the project area of Kotri North Block and its

immediate vicinity proposed for exploration and associated development activities.

Out of total 101 recorded species, 64 are common, 5 are abundant 29 are less common

and 3 are rare species. Out of total 101 recorded birds, 18 species have protected status

under the provision of Sindh Wildlife Protection Ordinance, 1972 which include some

ducks, raptors, egrets and herons. Out of total recorded species 3 are on IUCN Red



List, 12 migratory species are on CMS and 20 included on CITES appendices having

international demand for trade.

The common birds of the project area include Crested lark, Cattle egret, Chestnut

shouldered petronia, Desert lark, Ring dove, Desert wheatear, Hoopoe, Indian river

tern, Indian roller, Common moorhen, Indian pond heron, Pied kingfisher, Purple

sunbird, Red‐wattled lapwing, Sindh nightjar, Spotted owlet and White breasted

kingfisher. A complete list of the bird species observed in the project area can be seen

in Table 6‐12.

Mammals

A total of 20 mammalian species were recorded during field visit of EIA conducted

during August, 2019 through direct sightings and various signs of their presence. Out

of total 20 recorded species, 12 are common, 1 is abundant, 3 are less common and 4

are rare. Out of these 20 mammals, three species are of global significance including

Fishing cat, Hog deer and Indian pangolin.

Small mammals and rodents are quite abundant as noticed through their burrow

system. Small mammals play an important and perhaps indispensable role in the

functioning of ecosystem. They should not be viewed separately from other

components in the ecosystem. Rather, they must be viewed in terms of their

interrelationships with other components. Small mammals influence the structure and

function of ecosystems as consumers of plants and small animals, as movers of soil

and soil nutrients, and as the primary prey of raptors, snakes, hawks, eagles, owls and

carnivorous mammals. Because of their intermediate trophic position and high

dispersal abilities, small mammals may track changes in biotic and abiotic

environment that result from shifts in land‐use practices and other human activities. A

complete list of the mammalian species observed in the project area can be seen in

Table 6‐13.

Reptiles

During the present EIA field visit of project area in Kotri North Block and its

immediate vicinity, presence of 20 reptilian species was recorded through direct

sightings and signs of their presence. Out of total 20 recorded species, 10 are common,

9 are less common and one is rare.

Common reptilian species of the project area include, Brilliant agama, Indian fringe‐

toed sand lizard, Garden lizard, Indian monitor lizard, Indian sand swimmer and

Indian spiny‐tailed lizard found in the semi‐desert and loamy soil habitat for such

reptiles. Poisonous snake species of the area include, Saw scaled viper and Indian

cobra whereas, non‐poisonous are Brahminy blind snake, Checkered keelback,

Dhaman, Glossy billed racer, Indian sand boa, Royal diadem snake and Pakistan

ribbon snake. A list of reptiles observed during both field visit is provided in Table 6‐

14.



Key Faunal Species

Based on current site visit, relative abundance and sensitivity towards human

interventions and their listing in different Conventions and SWPO, there are several

species which may be categorized as key species of the project area including Hog

deer, Indian pangolin, Fishing cat and birds of prey. During the project

implementation, special care/mitigation measure is adopted while working in habitat

of these key species.



Table 6‐4: List of Vegetation Species found in the Project Area

Family Name/Plant Species Local Name Life‐Form/Habitat Life‐Span

Cyperaceae

Cyperus rotundus Linn Kabah Sedge Annual

Cyperus longus L. Kal Sedge Perennial

Bolboschoenus affinis (Roth.) Drobov. Cheho Sedge Perennial

Bolboschoenus glaucus (Lam.) S. G. Simth Cheho Sedge Perennial

Schoenoplectus littoralis (Schrad.) Palla Cheho Sedge Perennial

Fimbristylis acuminata Vahl. Kabah Sedge Perennial

Poaceae

Aeluropus lagopoides (Linn.) Trin. ex. Thw Kalar gaah Grass Perennial

Aristida adscensionis Linn. Lumb gaah Grass Annual

Aristida funiculata Trin. & Rupr. Lumb gaah Grass Annual

Brachiaria eruciformis (J. E. Simth) Griseb. Sawri Grass Annual

Brachiaria ramosa (L.) Stapf Sawri Grass Annual

Brachiaria reptans (L.) Gardner & Hubbard Sawri Grass Annual

Cenchrus bifloris Roxb. Bhorut Grass Annual

Cenchrus ciliaris L. Bhourt Grass Annual

Cymbopogon jawarancusa (Jones) Schult. Katan Grass Perennial

Cynodon dactylon (Linn.) Pers. Chhabar Grass Perennial

Chloris barbata Sw. Sawari Grass Annual

Dactyloctenium aegyptium (Linn.) P. Beauv. Gandheer gaah Grass Annual

Dactyloctenium aristatum Link. Gandheer gaah Grass Annual

Desmostachya bippinata (Linn.) Stapf. Drabh Grass Perennial

Dichanthium annulatum (Forssk.) Stapf Palwan Grass Perennial

Digitaria ciliaris (Retz.) Koel. Pachar gaah Grass Annual

Diplachne fusca (L.) P. Baeuv. ex Roem. & Schult. Jhang sari Grass Perennial




Eragrostis ciliaris (L.) R. Br. Sawri ghahh Grass Annual

Eragrostis minor Host. Sawri ghahh Grass Annual

Eragrostis tenella (L.) Bhurbhuri Grass Annual

Imperata cylindrica (L.) Reuschel Dabori Grass Annual

Ochthochloa compressa (Forssk.) Hilu. Ghander Grass Perennial

Paspalum paspaloides (Michx.) Scribner Koda Grass Perennial

Pennisetum orientale L. C. Rich. Bhurut Grass Perennial

Phragmites karka (Retz.) Trin. ex Steud. Nar/Naro Grass Perennial

Saccharum bengalense Retz. Booro Grass Perennial

Saccharum griffithii Munro ex Boiss. Kanh Grass Perennial

Saccharum spontaneum Linn. Booro/Munian Grass Perennial

Stipagrostis plumosa (Linn.) Munro ex T. Anders. Lumb gaah Grass Annual

Tragus berteronianus Schult. ….. Grass Annual

Tragus roxburghii Panigrahi ….. Grass Annual

Aizoaceae

Limeum indicum Stocks. ex T. Anders. Khir wal Herb Annual

Sesuvium sesuvioides (Fenzl.) Verdc. Kori lonak Herb Annual

Trianthema portulacastrum L. Waho Herb Annual

Zaleya pentandra (L.) Jeffrey. Waho Herb Annual

Amaranthaceae

Aerva javanica var. javanica (Burm.f.) Juss. ex. Booh Subshrub Perennial

Digera muricata (L.) Mart. Lulur Herb Annual

Anacardiaceae

Mangifera indica L. Aumb Tree Annual

Aristolochiaceae

Aristolochia bracteolata Lamk. Kinari wal Herb Annual

Asclepiadaceae




Calotropis procera (Willd.) R. Br. Ak Shrub Perennial

Leptadenia pyrotechnica (Forsk.) Decne. Khip Shrub Perennial

Oxystelma esculentum (L. f.) R. Br. Phuli Climbing shrub Perennial

Asteraceae

Launaea procumbens (Roxb) Ramayya & Rajagopal. Bhattar Herb Perennial

Eclipta alba (L.) Hassk. Daryai buti Herb Annual

Echinops echinatus Roxb. Loot Herb Annual

Iphiona grantioides (Boiss.) Anderb Gandraf Herb Annual

Pluchea lanceolata (DC.) Oliv. & Hiern. Phaar buti Shrub Perennial

Xanthium indicum Koenig ex Roxb. Bhurt Shrub Annual

Bombacaceae

Bombax ceiba L. Simbal Tree Perennial

Boraginaceae

Cordia myxa Linn. Lesuro Tree Perennial

Heliotropium crispum Desf. Kharsan Herb Annual

Heliotropium europaeum L. Kharsan Herb Annual

Caesalpiniaceae

Cassia italica (Mill.) F. W. Andr. Ghora wal Herb Annual

Cassia holosericeae Fresen. Ghora wal Herb Annual

Capparidaceae

Capparis decidua (Forssk.) Edgew. Kirar Shrub Perennial

Capparis cartilaginea Decne. Golaro Shrub Perennial

Capparis spinosa L. ….. Herb Annual

Cleome scaposa DC. Kano gah Herb Annual

Dipterygium glaucum Decne. Phair Subshrub Perennial

Chenopodiaceae

Arthrocnemum indicum (Willd.) Moq. Lano Shrub Perennial




Haloxylon salicornicum (Moq.) Lano Shrub Perennial

Haloxylon stocksii (Boiss.) Lani Shrub Perennial

Saueda fruticosa (Linn.) Forsk. Lani Subshrub Semi‐perennial

Salsola imbricata Forssk. Lano Shrub Perennial

Combretaceae

Conocarpus lancifoluis Engl. Cono Tree Perennial

Convolvulaceae

Cressa cretica Linn. Oin Herb Annual

Convolvulus arvensis L. Narro Herb Annual

Ipomoea carnea Jacquin. Narro Herb Annual

Cucurbitaceae

Citrullus colocynthis (Linn.) Schrad. Trooh Prostrate subshrub Perennial

Mukia maderaspatana (Linn.) M. J. Roem. ….. Prostrate herb Annual

Cuscutaceae

Cuscuta europaeae L. Be paari Herb Annual

Cuscuta reflexa Roxb. Be paari Herb Annual

Euphorbiaceae

Euphorbia hirta Linn. Kheer wal Herb Annual

Euphorbia granulata Forssk. Kheer wal Herb Annual

Euphorbia prostrata Aiton Kheer wal Herb Annual

Chrozophora tinctoria (L.) Raf. ….. Herb Annual

Phyllanthus reticulatus Poir. Kamohi Herb Perennial

Ricinus communis L. Heran Shrub Biennial

Fabaceae

Alhaji maurorum Medic. Kandero Subshrub Perennial

Crotolaria burhia Ham. ex Benth. Chag Subshrub Semi‐perennial

Dalbergia sissoo Roxb. Taari Tree Perennial




Indigofera cordifolia Heyne ex Roth. Mahori Herb Annual

Indigofera oblongifolia Forsk. Jhil Shrub Perennial

Rhynchosia minima (L.) DC. Wanverhi Herb Perennial

Sesbania sesban (L.) Kuntze Manjhanderi Shrub Perennial

Malvaceae

Abutilon indicum (L.) Sweet Pat‐teer Shrub Perennial

Meliaceae

Azadirachta indica A. Juss. Nim (Neem) Tree Perennial

Mimosaceae

Acacia jacquemontii Benth. Banwar Shrub Perennial

Acacia nilotica (Linn.) Delile Sindhi babur Tree Perennial

Albizia lebbeck Linn. Sarenh Tree Perennial

Prosopis cineraria (Linn.) Druce Kandi Tree Perennial

Prosopis juliflora (Swartz) DC. Devi Shrub Perennial

Prosopis glandulosa Torr. Devi Shrub Perennial

Moraceae

Ficus benghalensis L. Bar Tree Perennial

Ficus religiosa L. Pepur Tree Perennial

Myrtaceae

Eucalyptus L Her. Sufedo Tree Perennial

Syzygum cumini (L.) Skeels. Jaman/Jamu Tree Perennial

Neuradaceae

Neurada procumbens Linn. Chhapri/Chhipri Herb Annual

Nyctaginaceae

Boerhavia procumbens Banks ex Rxb. Dakhri Herb Annual

Oxalidaceae

Oxalis corniculata L. Sawari Herb Annual




Palmeae

Phoenix dactylifera Linn. Khaji Tree Perennial

Rhamnaceae

Zizyphus mauritiana Lam. Ber Tree Perennial

Zizyphus nummularia (Burm. f.) Wt. & Arn. Jhangoori ber Tree Perennial

Salvadoraceae

Salvadora oleoides Decne. Jar/Peroon Shrub Perennial

Salvadora persica L. Khabar Shrub Perennial

Scrophulariaceae

Bacopa monnieri (L.) Penn. Bhattar Herb Annual

Solanaceae

Datura metel Linn. Charyo dhatooro Herb Annual

Solanum surattense Burm. f. Kanderi wal Subshrub Annual

Solanum nigrum var. nigrum Linn. Kanwal buti Herb Annual

Withania somnifera (Linn.) Dunal Akri Shrub Perennial

Tamaricaceae

Tamarix aphylla (Linn.) Karst. Lawo Tree Perennial

Tamarix indica willd. Lawi Shrub Perennial

Tamarix dioica Roxb. ex Roth. Lawi Shrub Perennial

Tiliaceae

Corchorus depressus (Linn.) Stocks. Mundheri Herb Annual

Corchorus tridens Linn. Datehri Herb Annual

Typhaceae

Typha domingenasis Pres. Pan Sedge Perennial

Typha elephantina Roxb. Pan Sedge Perennial

Verbenaceae

Phyla nodiflora (L.) Greene Bukan Herb Perennial




Zygophyllaceae

Fagonia indica var. schweinfurthii Hadidi Dramaaho Subshrub Annual

Tribulus terrestris L. Bakhro/Bhurt Herb Annual

Tribulus longipetalus Viv. Bakhro/Bhurt Herb Annual

Zygophyllum simplex L. Pat lani Herb Annual



Table 6‐5: List of Vegetation Species of Riparian Habitat (20 x 20m Quadrate)

No. Plant Species Density Relative D* Frequency Relative F** Total Cover Relative Cover I.V.I

1. Acacia nilotica 4.75 24.05 75 16.67 1934707.68 36.80 25.84

2. Capparis decidua 1.25 6.33 50 11.11 190139.4 3.62 7.02

3. Calotropis procera 1 5.06 50 11.11 80455.68 1.53 5.90

4. Phyllanthus reticulatus 0.25 1.27 25 5.56 25456.68 0.48 2.44

5. Prosopis cineraria 1 5.06 25 5.56 282852 5.38 5.33

6. Prosopis juliflora 3.5 17.72 75 16.67 532390.32 10.13 14.84

7. Prosopis glandulosa 2.25 11.39 50 11.11 400546.7172 7.62 10.04

8. Salvadora oleoides 0.75 3.80 25 5.56 637359.84 12.12 7.16

9. Salvadora persica 1.5 7.59 25 5.56 912669.12 17.36 10.17

10. Tamarix indica 3.5 17.72 50 11.11 260871.2568 4.96 11.26

D* ‐ Density, F** ‐ Frequency

Table 6‐6: List of Vegetation Species of Riparian Habitat (2 x 2m Quadrate)


1. Abutilon indicum 1 5.80 50 16.67 11314.08 15.53 12.66

2. Alhaji maurorum 7.75 44.93 100 33.33 21921.03 120.76 66.34

3. Cynodon dactylon 3.25 18.84 75 25.00 13237.4736 72.92 38.92

4. Desmostachya bippinata 5.25 30.43 75 25.00 26399.52 145.43 66.95




Table 6‐7: List of Vegetation Species of Marshy/Wetland Habitat (20 x 20m Quadrate)


1. Acacia nilotica 0.20 0.57 10.0 3.57 277194.96 2.43 2.19

2. Capparis decidua 0.10 0.29 10.0 3.57 38722.4388 0.34 1.40

3. Prosopis cineraria 0.10 0.29 10.0 3.57 149358.4272 1.31 1.72

4. Prosopis juliflora 0.30 0.86 10.0 3.57 60341.76 0.53 1.65

5. Prosopis glandulosa 3.20 9.20 60.0 21.43 814613.76 7.14 12.59

6. Saccharum bengalense 0.30 0.86 10.0 3.57 122531.4864 1.07 1.84

7. Salvadora persica 1.40 4.02 40.0 14.29 3449537.28 30.22 16.18

8. Saueda fruticosa 17.10 49.14 50.0 17.86 4067722.897 35.64 34.21

9. Tamarix indica 12.10 34.77 80.0 28.57 2433784.32 21.32 28.22


Table 6‐8: List of Vegetation Species of Marshy/Wetland Habitat (2 x 2m Quadrate)


1. Aeluropus lagopoides 0.40 2.30 10.0 4.17 804.557 0.65 2.37

2. Alhaji maurorum 0.70 4.02 10.0 4.17 3717.932 3.00 3.73

3. Bacopa monnieri 1.00 5.75 20.0 8.33 2545.668 2.06 5.38

4. Cressa cretica 2.20 12.64 30.0 12.50 11684.930 9.44 11.53

5. Cynodon dactylon 1.20 6.90 20.0 8.33 13614.610 11.00 8.74

6. Cyperus longus 1.00 5.75 10.0 4.17 1131.408 0.91 3.61

7. Desmostachya bippinata 1.60 9.20 30.0 12.50 22175.597 17.92 13.20

8. Diplachne fusca 0.30 1.72 10.0 4.17 2121.390 1.71 2.53

9. Fimbristylis acuminata 0.70 4.02 10.0 4.17 1781.968 1.44 3.21

10. Paspalum paspaloides 2.60 14.94 20.0 8.33 2941.661 2.38 8.55

11. Phragmites karka 1.60 9.20 30.0 12.50 16292.275 13.16 11.62

12. Schoenoplectus littoralis 0.30 1.72 10.0 4.17 1847.966 1.49 2.46

13. Typha domingenasis 3.80 21.84 30.0 12.50 43112.930 34.83 23.06




Table 6‐9: List of Vegetation Species of Rocky Calcareous Plain Habitat (20 x 20m Quadrate)


1. Capparis decidua 0.71 6.17 28.57 9.09 127283.4 4.00 6.42

2. Calotropis procera 0.57 4.94 85.71 27.27 97351.3728 3.06 11.76

3. Indigofera oblongifolia 0.29 2.47 14.29 4.55 30799.44 0.97 2.66

4. Prosopis cineraria 0.14 1.23 14.29 4.55 23787.8532 0.75 2.18

5. Prosopis juliflora 1.57 13.58 28.57 9.09 86427 2.71 8.46

6. Prosopis glandulosa 3.14 27.16 57.14 18.18 301180.8096 9.45 18.27

7. Rhazia stricta 1.43 12.35 14.29 4.55 95069.7 2.98 6.63

8. Salvadora oleoides 2.14 18.52 42.86 13.64 2098808.982 65.88 32.68

9. Zizyphus nummularia 1.57 13.58 28.57 9.09 325276.6572 10.21 10.96




Table 6‐10: List of Vegetation Species of Calcareous Plain Habitat (2 x 2m Quadrate)


1. Aristida adscensionis 15.29 18.61 71.43 8.33 33627.96 11.21 12.72

2. Aristida funiculata 6.29 7.65 28.57 3.33 8850.12 2.95 4.64

3. Cassia holosericeae 0.71 0.87 28.57 3.33 4541.35 1.51 1.91

4. Cassia italica 5.14 6.26 85.71 10.00 25456.68 8.48 8.25

5. Cenchrus bifloris 8.57 10.43 85.71 10.00 12068.35 4.02 8.15

6. Cenchrus ciliaris 4.00 4.87 42.86 5.00 7127.87 2.38 4.08

7. Corchorus depressus 11.14 13.57 71.43 8.33 29661.75 9.89 10.59

8. Cymbopog jawaracusa 1.14 1.39 28.57 3.33 8146.14 2.71 2.48

9. Eragrostis ciliaris 4.43 5.39 71.43 8.33 4773.91 1.59 5.11

10. Eragrostis minor 3.14 3.83 42.86 5.00 5600.47 1.87 3.56

11. Euphorbia granulata 6.71 8.17 57.14 6.67 24963.26 8.32 7.72

12. Fagonia indica 2.43 2.96 57.14 6.67 19287.36 6.43 5.35

13. Indigofera cordifolia 0.57 0.70 14.29 1.67 3633.08 1.21 1.19

14. Iphiona grantioides 0.71 0.87 28.57 3.33 3079.94 1.03 1.74

15. Ochthochloa compressa 6.29 7.65 71.43 8.33 49920.24 16.64 10.87

16. Zygophyllum simplex 5.57 6.78 71.43 8.33 59323.49 19.77 11.63




Table 6‐11: Vegetation Species with Medicinal and Economical Use found in the Project Area

No. Scientific Name Common Name Family Medicinal or Economical Use

1. Acacia nilotica Sindhi Babur Mimosaceae Trunk used as pillars in making huts and agricultural implements, leaves and

flowers/fruits used as a fodder. The tree is also used as a fuel

2. Aerva javanica Booh Amaranthaceae Fodder and medicinal value

3. Alhagi maurorum Kandero Fabaceae Fencing around huts, medicinal value

4. Calotropis procera Ak Asclepiadaceae Medicinal value, silky floss of the seeds is used for stuffing pillows, the smoke of

the plant is used to keep away mosquitoes

5. Capparis decidua Kirar Capparidaceae Trunk is used for fuel, unripe fruit is used as vegetable, ripened food is edible,

young twigs used as fodder

6. Cressa cretica Oin Convolvulaceae Fodder and also considered as a neutralizer for acidic soils

7. Crotolaria burhia Chag Fabaceae Fodder, medicinal value, thatching of roof

8. Cynodon dactylon Chhabar Poaceae Fodder, medicine

9. Desmostachya bipinnata Drabh Poaceae Fodder, stalk used for brooms, leaves woven to make ropes

10. Euphorbia hirta Kher wal Euphorbiaceae Fodder

11. Leptadenia pyrotechnica Khip Asclepiadaceae Branches used for thatching of roof, fodder, medicinal value

12. Saccharum bengalense Booro Poaceae Stem used for making roof and chairs, leaves used for making mats, used in a

medicine for cattle

13. Saccharum spontaneum Booro/Munian Poaceae Stem used for making roof and chairs, leaves used for making mats, used in a

medicines for cattle

14. Suaeda fruticosa Lani Chenopodiaceae Ash of the plant is used for washing of clothes, the plant is also a fodder for

camels

15. Typha domingenasis Pan Typhaceae Leaves used for thatching of roof and making mats

16. Typha elephantina Pan Typhaceae Used for making jute bags, leaves used for thatching of roof and making mats



Table 6‐12: List of Birds Observed/Reported in the Project Area

No. Common Name Scientific Name

Status Occurrence Listing

Migratory

Resident

Common

Abundant

Less Common

Rare

WPO/Act

IUCN Red List

CMS Appendix

CITES Appendix

1. Ashy headed finch lark Eremopterix grisea x x

2. Bank myna Acridotheres ginginianus x x

3. Bay backed shrike Lanius vittatus x x

4. Black drongo/King crow Dicrurus macrocercus x x

5. Black kite Milvus migrans x x x II

6. Black partridge Francolinus francolinus x x

7. Black redstart Phoenicurus ochruros x x

8. Black crowned finch lark Eremopterix nigreceps x x

9. Black shouldered kite Elanus caeruleus/E.leucurus x x x II

10. Black‐winged stilt Himantopus himantopus x x II

11. Blue cheeked bee‐eater Merops superciliosus x x

12. Blue rock pigeon Columba livia x x III

13. Blue throat Luscinia svecica x x

14. Blyth’s reed warbler Acrocephalus dumetorum x x

15. Brahminy kite Haliastur indus x x x II

16. Brown tree pipit Anthus trivialis x x

17. Cattle egret Bubulcus ibis x x x III

18. Chestnut shouldered petronia Petronia xanthocollis x x

19. Chiffchaff Phylloscopos collybita x x

20. Collared dove Streptopelia decaocto x x





Migratory

Resident

Common

Abundant

Less Common

Rare

WPO/Act

IUCN Red List

CMS Appendix

CITES Appendix

21. Common/Blue kingfisher Alcedo atthis x x

22. Common babbler Turdoides caudatus x x

23. Common buzzard Buteo buteo x x x II

24. Common kestrel Falco tinnunculus x x x II II

25. Common redstart Phoenicurus phoenicurus x x

26. Common sandpiper Actitis hypoleucos x x

27. Common snipe Gallinago gallinago x x II

28. Crested honey buzzard Pernis ptilorhynchus x x x II

29. Crested lark Galerida cristata x x

30. Crow pheasant Centropus sinensis x x

31. Desert lark Ammomanes deserti x x

32. Desert wheatear Oenanthe deserti x x

33. Egyptian/Scavenger vulture Neophron percnopterus x x x II

34. Eurasian sparrow hawk Accipiter nisus x x x II II

35. Eurasian scops owl Otus scops x x II

36. Golden backed woodpecker Dinopium benghalense x x

37. Great grey shrike Lanius excubitor x x

38. Grey partridge Francolinus pondicerianus x x

39. Hoopoe Upupa epops x x

40. House crow Corvus splendens x x

41. House sparrow Passer domesticus x x





Migratory

Resident

Common

Abundant

Less Common

Rare

WPO/Act

IUCN Red List

CMS Appendix

CITES Appendix

42. House swift Apus affinis x x

43. Indian river tern Sterna aurantia x x

44. Indian robin Saxicoloides fulicata x x

45. Indian roller Coracias benghalensis x x

46. Indian sand martin Riparia paludicola x x

47. Indian tailor bird Orthotomus sutorius x x

48. Indian tree‐pie Dendrocitta vagabunda x x

49. Indian/Common moorhen Gallinula chloropus x x

50. Indian/Common myna Acridotheres tristis x x

51. Jungle babbler Turdoides striatus x x

52. Kentish/Snowy plover Charadrius alexandrinus x x II

53. Little brown dove Streptopelia senegalensis x x III

54. Little cormorant Phalacrocorax niger x x x

55. Little egret Egretta garzetta x x x

56. Little grebe Tachybaptus ruficollis x x

57. Little green Bee‐eater Merops orientalis x x

58. Little owl Athene noctua x x II

59. Little ringed plover Charadrius dubius x x II

60. Little stint Calidris minuta x x II

61. Little tern Sterna albifrons x x II

62. Long‐eared owl Asio otus x x II





Migratory

Resident

Common

Abundant

Less Common

Rare

WPO/Act

IUCN Red List

CMS Appendix

CITES Appendix

63. Long‐tailed grass warbler Prinia burnesii x x NT

64. Marsh harrier Circus aeruginosus x x x II

65. Merlin Falco columbarius x x x II II

66. Night heron Nycticorax nycticorax x x x

67. Paddy bird/Indian pond heron Ardeola grayii x x x

68. Pied bushchat Saxicola caprata x x

69. Pied kingfisher Ceryle rudis x x

70. Pied/Variable wheatear Oenanthe picata x x

71. Purple moorhen Porphyrio porphyrio x x x

72. Purple sunbird Nectarinia asiatica x x

73. Red turtle dove Streptopelia transquebarica x x

74. Redshank Tringa totanus x x II

75. Red‐vented bulbul Pycnonotus cafer x x

76. Red‐wattled lapwing Hoplopterus indicus x x

77. Richardʹs pipit Anthus novaeseelandiae x x

78. Rose‐ringed parakeet Psittacula krameri x x III

79. Ruff Philomachus pugnax x x II

80. Rufous backed shrike Lanius schach x x

81. Rufous tailed/Isabelline shrike Lanius isabellinus x x

82. Short toed eagle Circaetus gallicus x x x II

83. Sindh jungle sparrow Passer pyrrhonotus x x





Migratory

Resident

Common

Abundant

Less Common

Rare

WPO/Act

IUCN Red List

CMS Appendix

CITES Appendix

84. Shikra Accipiter badius x x LC

85. Sindh nightjar Caprimulgus mahrattensis x x

86. Sindh pied woodpecker Dendrocopos assimilis x x

87. Small Indian pratincole Glareola lactea x x

88. Small/Wandering minivet Pericrocotus cinnamomeus x x

89. Spotted little owl Athene brama x x II

90. Streaked weaver bird Ploceus manyar x x

91. White/Pied wagtail Motacilla alba x x LC

92. White breasted waterhen Amaurornis phoenicurus x x

93. White browed wagtail Motacilla maderaspatensis x x

94. White eyed buzzard Butastur teesa x x x II

95. White tailed plover Chettusia leucura x x

96. White throated munia Eodice malabarica/Lonchura malabarica x x III

97. White‐breasted kingfisher Halcyon smyrnensis x x

98. White‐browed fantail flycatcher Rhipidura aureola x x

99. White‐cheeked bulbul Pycnonotus leucogenys x x

100. Wire tailed swallow Hirundo smithii x x

101. Yellow bellied prinia Prinia flaviventris x x

Abbreviations: WPO – Wildlife Protection Ordinance; LC – Least concerned; NT – Near threatened



Table 6‐13: List of Mammals Observed/Reported in the Project Area


Occurrence Listing

Common

Abundant

Less Common

Rare

WPO/Act

IUCN Red List

CITES Appendix

1. Asiatic jackal Canis aureus x III

2. Black‐naped hare Lepus nigricollis x

3. Balochistan gerbil Gerbillus nanus x

4. Desert cat Felis silverstris x III

5. Fishing cat Prionailurus viverrinus x x VU II

6. Five stripped palm squirrel Funambulus pennantii x

7. Hog deer Axis porcinus x x

8. House mouse Mus musculus x

9. Indian/Bengal fox Vulpes bengalensis x

10. Indian bush rat Golunda ellioti x

11. Indian desert jird Meriones hurrianae x

12. Indian pangolin Manis crassicaudata x x LC

13. Indian gerbil Tatera indica x

14. Indian grey mongoose Herpestes edwardsi x III

15. Indian porcupine Hystrix indica x

16. Indian wild boar Sus scrofa x

17. Little Indian field mouse Mus booduga x

18. Long eared desert hedgehog Hemiechinus collaris x

19. Small Indian mongoose Herpestes javanicus x x III

20. Smooth coated otter Lutrogale perspicillata x x VU II

Abbreviations: WPO – Wildlife Protection Ordinance; VU – Vulnerable; LC – Least Concerned



Table 6‐14: List of Reptiles Observed/Reported in the Project Area


Occurrence Listing

Common

Less Common

Rare

WPO/Act

IUCN Red List

CITES Appendix

1. Black pond/Spotted turtle Geoclemys hamiltonii x x

2. Brahminy blind snake Typhlops braminus x x

3. Brilliant agama Trapelus agilus isolepis x

4. Brown river turtle Kachuga smithii x x II

5. Checkered keelback Xenochrophis piscator piscator x x III

6. Cobra Naja naja x DD II

7. Common ground agama Trapelus ruderata baluchiana x

8. Desert monitor Varanus griseus koniecznyi x x I

9. Dhaman/Rat snake Ptyas mucosus x x II

10. Garden lizard Calotes versicolor x

11. Glossy bellied racer Coluber vetromaculatus x

12. Indian fringe‐toed lizard Acanthodactylus cantoris cantoris x

13. Indian monitor Varanus bengalensis x x I

14. Indian sand boa Eryx johnii johnii x

15. Indian sand swimmer Ophiomorus raithmai x

16. Indian spiny‐tailed lizard Uromastyx hardwickii x II`

17. Pakistan ribbon snake Psammophis leithii x x

18. Royal diadem snake Spalerosophis diadema diadema x x

19. Saw scaled viper Echis carinatus pyramidum x

20. Yellow bellied house gecko Hemidactylus flaviviridis x

Abbreviations: WPO – Wildlife Protection Ordinance; DD – Data Deficient



Photographs: Biological Environment of the Project Area

Photograph 6‐17: Salvadora persecia Photograph 6‐18: Ficus religiosa

Photograph 6‐19: Acacia nilotica Photograph 6‐20: Bombax ceiba

Photograph 6‐21: Capparis Spinosa Photograph 6‐22: Cordia myxa



Photograph 6‐23: Cassia holosericeai Photograph 6‐24: Dalbergia sissoo

Photograph 6‐25: Crested lark Photograph 6‐26: Egyptian vulture

Photograph 6‐27: Glossy ibis Photograph 6‐28: Indian robin



Photograph 6‐29: Large cormorant Photograph 6‐30: Pied bushchat

Photograph 6‐31: Redshank Photograph 6‐32: Sindh pied woodpecker

Photograph 6‐33: White browed fantail Photograph 6‐34: Indian desert monitor lizard



Photograph 6‐35: Indian garden lizard Photograph 6‐36: Asiatic jackal

Photograph 6‐37: Botanist during the EIA field

survey

Photograph 6‐38: Wildlife specialist during the

EIA field survey



Socioeconomic Environment

A random sampling survey was carried out within Block (E.L. 2568‐21) and in its close

surroundings to collect first hand reliable and authentic socioeconomic data of the

area. For this purpose a semi‐structured interview schedule was used. The information

was collected with the objective to obtain a clear and complete understanding of the

social and economic conditions of the locals, assess the vulnerability of the local

communities and identify the concerns of locals regarding the proposed project

activities. During the socioeconomic field visit substantial information was collected

that was required to understand the socioeconomic conditions of the area and the

impacts of the proposed project on local communities. Since, the socioeconomic

assessment and recommendations for mitigation measures primarily addresses the

issue despite of individual/community. Issues related to individual/community will be

mitigated through an on‐site mechanism suggested in the EIA. The local residents will

be able to register their complaints and grievances during the project and the

individual or community not covered in this study will receive due compensation or

mitigation for its complaint. Socioeconomic environment and infrastructure of the

project area is shown in Figure 6‐6.

6.3.1 Study Objectives

The socioeconomic study undertaken for the EIA was designed and conducted to meet

the following objectives:

To assess the human environment of the area i.e. to determine the life’s quality of

communities within the region of influence;

To have an insight into the day to day activities of people especially focusing on

their income generating activities viz. agriculture, livestock and labor;

To access the vulnerabilities of the local communities and the effects of project

activities on their quality of life and;

Consultation with communities regarding the proposed project activities and to

find out their concerns and aspirations.

6.3.2 Study Methodology

Random Sampling Survey techniques were used to collect data in the project area. The

sampling locations were carefully selected for true representation of the project area.

Specific tools were used to conduct the study included informal group interviews,

focus group discussions, need assessment, participant observation, secondary data

review, village meetings and social mapping. At some places, key informants and

community activists were used as the main instruments for data collection. Focused

group discussions were conducted to assess the socioeconomic conditions, concerns

and problems of the communities.



6.3.3 Administrative Boundaries





shares approx. 257 km2 and district Hyderabad contributes about 6.5 km2. Taluka wise

distribution of abovementioned districts is provided in table below:

District Taluka Area Coverage (km2)

Jamshoro Kotri 442

Manjhand 691.5

Hyderabad Hyderabad 6.5

Matiari

Hala 210

Matiari 4

Saeedabad 43

6.3.4 Demographic Profile

During the field visit of EIA population data on 23 villages/goths was collected and this

data is presented in Table 6‐15. All villages/goths/towns were carefully selected where

exploration activities have been planned or which might be influenced by the

propsoed exploration and associated development activities.

According to the recent census of 2017, the population of the area has been

significantly increased having annual growth rate of 2 – 3% to the 1998. For instance,

the population of Hyderabad districts have annual growth rate of 2.02%. If the

population grows at the present rate, it will be doubled in next 31 years. Population of

districts where Kotri North Block falls are detailed in table below:

Kotri North Block (E.L. 2568‐21)

District Population (Census)

Year 2017 Year 1998

Jamshoro 993,142 582,094

Matiari 769,349 494,244

Hyderabad 2,199,463 1,494,866

Source: www.pbs.gov.pk

a. Major Castes

In surveyed villages it is observed that the main castes/tribes (biraderies) inhabiting the

project area are Khaskheli, Mari Bloch, Khoso, Bhambro, Mallah, Talpur, Solangi,

Bhatti, Mughal, Syed, Shaikh, and Lashari. Some other minor biraderies of the area

include Bhenchai, Nizamani, Umrani, Daito, Bheel, Kohli, Qambrani, Jamali, Hajana,

Khokar, Shar, Palari and Chandio. Other populations depending on their professions

like mistri, naaee, kumhar and lohars etc. are also inhabitants of the project area. Sunni

sect is more prevalent in the area as compared to Shias. Other minorities that exist in



the area are Christians, Hindus, Ahmadis and other schedule castes. The tribal

distribution of the surveyed villages is provided in Table 6‐16.

b. Basic Amenities

The cities and towns of the districts in the project area are inter‐connected through a

network of blacktop roads and jeepable tracks in fair weather. The access to most of

the villages of the project area is provided through katcha roads. The system of

communication in the project area is satisfactory. The project area can be accessed

through National Highway which enters the Kotri North Block from Karachi. The area

is connected to main cities of nearby districts through National Highway. Karachi –

Hyderabad motorway (M9) also enters the project area from southern side. A number

of farm to market roads also exist in the area. Brick roads are also in place connecting

villages with the main metaled road.

The main line of Pakistan railways runs through the districts. The major railway

stations exist in Hyderabad, Jungshahi and Latifabad. Besides these railway stations

there are many small railway stations located within the project area. The nearest

airports to the project area are Karachi, Nawabshah and Moenjo Daro.

Electricity and mobile facilities are present in almost every part of the project area. Out

of total 23 visited villages, electricity is available in 16 villages/towns however, the

residents complained about the load shedding. Project area has also a network of post

offices and postal facilities as well.

c. Languages

Sindhi is the mother tongue language being spoken in the project area followed by

Urdu and Punjabi etc. The locals in rural areas follow their norms and values very

rigidly/strictly than that of urban areas. But with the passage of time and development

trends, these societal values has been changed and are not followed as rigidly as it

used to be in the past.

d. Water Usage

There is a proper source of irrigation in many parts of the project area and in some

areas the land is irrigated with rainy water (mostly western and northwestern).

Drinking water supply schemes developed by Government departments also serves

the rural population. The remaining population fulfil their domestic water need from

groundwater borings, open dug wells and hand pumps. Sufficient amount of water for

drinking and domestic purposes is available in the area.

e. Pattern of Settlements

Settlements are mainly in the form of large and complex clusters/villages. At places,

these clusters are big blocks of 100 plus household while at other places small blocks

of 5 to 10 households also exist. Generally, aggregation of settlements is based on

kinship relations, with each settlement being inhabited by descendants from the same

family lineage. All the villages in the project area have usually two parts, the core and



the suburbs. Usually the core contains the bulk of population while the suburbs have

cluster of houses along the roadsides where usually one family resides. There are two

considerations for moving outside the core village. Firstly, to have easy access to the

family’s farmlands and secondly, as the population of a household grows denser, it

requires more space for living.

f. Marriages

The ideal marriage age is 18 and 25 for females and males respectively in the project

area. These early marriages result in big households, which is clear from their high

populations. Presently, the trend of early marriages is on its decline due to increase in

literacy level. The concept of dowry has taken firm roots in the population. Marriages

are occasions of festivity for everyone in the village. A three dish menu is served for

common guests while special guests get special dishes.

g. Education

People in the project area are very conscious of the educational needs of the society. In

most of the cases every child of school‐going age in the project area is getting

education in one way or another. Almost every village of the study area has primary

school either in public or private sector. Middle and high schools are also present in

some of the villages of the project area. The network of Boys and Girls Degree Colleges

both in public and private sectors at Hyderabad and Jamshoro is providing higher

educational facilities. Main medium of education in most of the local schools is Urdu.

Private schools also exist in the project area where medium of education is mostly

English.

h. Health

There are District Head Quarter (DHQ) Hospitals at Hyderabad and Matiari. There are

Basic Health Units (BHUs) and a number of Rural Health Centre (RHCs) also exist in

the project area and providing health care facilities to countless number of locals. In

addition to that, private health care facilties also exist in the project area.

During the survey, locals termed five most common diseases in the project area which

include acute respiratory infection, diarrhea, fever (clinical malaria), dysentery and

cough. Malaria tops the list of diseases, as every one out of ten patients is affected.

Serious medical cases are taken to Hyderabad and Karachi where better medical

facilities are available.

6.3.5 Economy of the Project Area

Economy of the project area is dependent on four occupations i.e. agriculture, services,

small business and livestock grazing. People are also involved in occupations such like

shopkeeping, transport, masonry and other daily wage earning occupations. However,

the bulk of workforce is working outside the village in armed forces and in large cities

such as Hyderabad and Karachi or abroad in the middle‐east.



a. Major Occupations

Agriculture

There is a proper source of irrigation in the major parts of the project area. The existing

standards and management levels of agriculture in the project area are satisfactory. As

a result, the present subsistent agriculture produces enough to meet the food and

financial requirements of the farm population. Uncertainty in precipitation in some of

the rain‐fed areas is the primary constraint on agricultural development.

Diversified cropping pattern were practiced under existing conditions due to the

irrigation supplies. Whole of the area available for cultivation is very much fertile and

possesses great potentials for agricultural production provided optimum water and

non‐water inputs are applied. However, the other non‐water inputs will remain

underutilized unless adequate irrigation water is provided which is the basic and

more important input.

Tractors and harvesters are usually used by the locals for agricultural purposes. Main

Kharif crops are Jawar, Bajra, Rice, Cotton and Sugarcane while Rabi Crops are Wheat,

Barley, Gram, Mung, Peas and fruits like Mango, Banana, Chikoo, Guava, Grapes,

Jamun, Papaya, Phalsa and others are grown. Hyderabad district is also famous for the

production of flowers particularly roses (Rosa damascena).

Livestock

The practice of livestock rearing is majorly for household dairy needs. The concept of

livestock rearing for commercial purposes is very rare. As such this particular aspect

of an agrarian economy is largely overlooked. Majority of the households keep

livestock e.g. cows, goats and sheep. Buffaloes are common in irrigated areas only,

though few were observed in the parts of project area where pasture is less available.

All the animals are of native breed and thus they can survive the local harsh

environment and drought like conditions better.

Feeding practices include free grazing and stall‐feeding. Under free grazing system,

rangelands and government lands are used. Agricultural fields after harvests are also

used for grazing. Family members usually carry out the activity of grazing their

livestock but sometimes the services of local herder are taken. Some of the tribes have

large flocks of animals.

It is estimated that 80% of the work related to livestock is carried out by women and

children. This includes watering, feeding, milking and bathing the livestock. People

also keep poultry for domestic consumption of eggs and meat. Goats outnumber any

other farm animals as it can survive on meagre water and fodder. Data reveals that on

the average, each household has 7.5 heads of farm animals with at least 10 goats.

b. Other Occupations

Apart from agriculture and livestock, the male population has to resort to some other

alternatives as well. The other major occupations in the area are government services,



shop keeping, fish farms and daily‐wagers. Some of the locals have also gone abroad

for work in the Gulf States. Poultry farming is also carried out on reasonable scale in

the area by the locals.

6.3.6 Gender Profile

Literature in gender studies suggests that poverty exacerbates gender disparities.

“Pakistan is only one of 12 countries which spends less than 2% of its GDP on

education” (HRCP, 2004). Out of this whole budget, only a tiny amount goes into the

primary education which is not enough for providing separate infrastructure for both

genders. Co‐education is not common especially after the primary education is over.

This explains a huge dropout rate amongst girls than prevalent for boys. Furthermore,

the literature also shows that inequalities between girls and boys in access to schooling

or adequate health care are more acute among the poor than among those with higher

incomes. These disparities disadvantage women and girls and limit their capacity to

participate in and benefit from development.

Siddiqui et al (2003) produces evidence that women empowerment leads to better

household consumption. “Empirical evidence showed if woman has empowerment

and control over household resources, they spend more money on basic needs such as

foods, clothing, education and health.” (Sathar and Kazi, 1997 and Siddiqui et al, 2003).

Focused group discussions separately with men and women in the area lead to the

following two generalizations:

Scarcity of resources aggravates the gender inequalities, depriving women of basic

needs, particularly education; and

Fatalistic cultural traditions/institutions work the same way as scarcity of

resources and results in women’s illiteracy.

The scarcity of resources is evident. When voice about cultural traditions and

institutions is raised, it necessarily includes religion as a guiding force. In the Sindhi

context, culture and religion are embedded deeply in social norms and behaviors.

Similarly, religion (as a variable noted in Dollar and Gatti’s analysis) may be attributed

to ‘extreme patriarchy’ a phenomenon cementing women alienation in rural

uneducated societies.

Women are not equal to men in the project area. There are various manifestations of

this phenomenon. For example, at bus stops there is neither sitting arrangements for

women nor toilet facilities. Women generally observe purdah (seclusion) from

outsiders. The purdah restrictions are more stringent for young girls. Adult women

may appear before male members of the same tribe. Restrictions on mobility vary with

the marital status, age of women, tribe affiliation and local customs. Mostly women in

Sindhi families of all ages shake hand with the male relatives. Married and relatively

older women are freer to attend marriage, death and birth ceremonies in other villages

and even go to markets with male members of the family.



A married woman has to seek permission for a social visit from her husband or

mother in law and is usually accompanied by her husband or sister in law. Married

woman also do not observe purdah from male members of the same tribe or village. In

agriculture activity women help their male members in the fields.

Females from landowning families do not work in the fields. The gender specialist

analyzed that the poverty and women mobility are directly proportional. As much as

they get rich, the females secluded to their homes and observe strict purdah or even

wear black or mostly white veils. All women take dupata on their heads even inside

their homes and during household chores. Girls before attaining the puberty are

confined to their homes. For outdoor activities of fire wood collection, agriculture or

water fetching they use the same dupatas but for visiting the relatives for marriage and

death ceremonies and doctors for health issues, women wear Ajrak or big embroidered

dupata.

Shopping or recreational visit are very uncommon for women. Shopping for

unmarried girls is carried out by brothers or father while husbands do for the married

women. Mostly communities in the project area are peaceful. Karokari or honor killing

is uncommon in the area and no cases have been heard or reported for a long time

however, there are still killings of women on different pretexts ‘accidentally’. The

brutal killing is thought to discourage women’s mobility.

Decision making inside the household resides on the male head of the household.

Women are generally not consulted in issues related to households’ major decisions on

lands, cropping, marketing and livestock etc. Eldest women in the household usually

have issues related to marriages.

6.3.7 Development Needs

The analysis of field survey data suggests that education, health, electricity, potable

water and gas rank highest amongst all priorities but their relevant weightage varies

with locality i.e. demand for drinking water is higher in the project area that falls away

from Indus River and potable sources of drinking water are not available in the area.

The top three development priorities expressed by each sampled survey is shown in

Table 6‐17. Provision of waste management facilities and others e.g. employment,

micro financing & provision of sewerage system were identified as their priorities of

lesser weightage as compared to education, health, electricity, potable water and gas.

6.3.8 Archaeological and Religious Sites

There are no reported or documented sites of archaeological significance within the

project area that are protected by either the federal government under the Antiquities

Act, 1975 or the Government of Sindh under the Sindh Cultural Heritage

(Preservation) Act, 1994.

Antiquities are protected under clause 19(1) of the Antiquities Act 1975 and this law

defines an antiquity as: “any ancient (an antiquity in existence for a period of not less

than 75 years) product of human activity, movable or immovable”. Any antiquities



found in the area that falls under the proponent’s area of operation, must be protected,

and not removed from their location. During the survey of the project area no surface

archaeological site (protected) was observed however, there are several sites of

religious and cultural interest in the entire spread of Kotri North Block.

A total 12 notified archaeological sites exist in Hyderabad district whereas, 4 in Matiari

and 8 in Jamshoro district. However, none of these falls under the geographical

jurisdication of Kotri North Block. It is important to highlight that, there are several

sites of cultural and religious significance spreading in entire stretch of Kotri North

Block in the form of shrines and graveyards. Therefore, mitigation measures suggested

for the protection of archaeological, cultural, heritage and religious environment will

be ensured.



Table 6‐15: Households and Population Data of Goths/Villages/Towns

No. Village/Town Name District No. of Household* Population*

1. Goth Sufan Bacho Matiari 75 800

2. Goth Salaro Matiari 100 900

3. Goth Haji Shabu Matiari 120 1,200

4. Goth Suleman Barejo Matiari 15 80

5. Goth Mehram Khaskheli Matiari 300 2,000

6. Goth Bachal Dehta Matiari 250 1,500

7. Shahpur Matiari 600 4,000

8. Goth Tajpur Matiari 1,200 5,500

9. Goth Tadri Mori Hyderabad 10 90

10. Goth Tando Syed Khan Mitho Hyderabad 1,500 6,500

11. Goth Raees Ghulam Ali Mari Hyderabad 60 650

12. Goth Hayat Bhatti Hyderabad 250 900

13. Goth Sayen Dino Mallah Jamshoro 400 1,500

14. Goth Darya Baig Mughal Hyderabad 1,200 9,000

15. Goth Khuda Baksh Jamshoro 8 40

16. Goth Bakhshia Mari Jamshoro 300 1,200

17. Goth Aliabad Jamshoro 2,000 15,000

18. Goth Karim Deno Jamshoro 50 500

19. Goth Jaitharo Jamshoro 20 80

20. Goth Bego Khan Mirjat Jamshoro 800 4,500

21. Goth Haji Ishaq Hyderabad 45 400

22. Goth Gulshan‐e‐Shahbaz Hyderabad 1,100 5,500

23. Goth Wadero Misri Hyderabad 90 700

Total 2,319 14,750

Notes: * Approximate numbers (information provided by the locals and best judgement during the field survey)



Table 6‐16: Tribal Distribution

No. Village/Town Name Vital Tribes

1. Goth Sufan Bacho Bhenchai

2. Goth Salaro Nizamani/Khaskheli

3. Goth Haji Shabu Mari Baloch

4. Goth Suleman Barejo Khoso

5. Goth Mehram Khaskheli Khaskheli, Bhambro, Khoso

6. Goth Bachal Dehta Mallah, Umrani, Daito

7. Shahpur Khoso, Mari, Kohli, Bheel

8. Goth Tajpur Talpur, Solangi, Khoso, Qambrani, Jamali

9. Goth Tadri Mori Khoso, Hajana, Khaloro

10. Goth Tando Syed Khan Mitho Mari, Mirbahar, Khaloro, Hajana

11. Goth Raees Ghulam Ali Mari Mari Bugti

12. Goth Hayat Bhatti Bhatti

13. Goth Sayen Dino Mallah Mirbahar, Khaloro

14. Goth Darya Baig Mughal Mughal

15. Goth Khuda Baksh Mari Bugti

16. Goth Bakhshia Mari Sheikh, Mari, Mallah, Kohli

17. Goth Aliabad Lashari, Shar, Hajana, Baloch, Khokar

18. Goth Karim Deno Mirbahar

19. Goth Jaitharo Burfat

20. Goth Bego Khan Mirjat Burfat, Khoso, Mirjat, Shora, Kanrio

21. Goth Haji Ishaq Laghari, Mari

22. Goth Gulshan‐e‐Shahbaz Baloch, Chandio, Palari, Kholro

23. Goth Wadero Misri Sheikh, Palari



Table 6‐17: Development Priorities of the Communities of Suveyed Villagees

Village/Goth Name Development Priorities

1 2 3

Goth Sufan Bacho Electricity Health ‐

Goth Salaro Health Employment ‐

Goth Haji Shabu Electricity Health Education

Goth Suleman Barejo Health Education ‐

Goth Mehram Khaskheli Health Waste Management ‐

Goth Bachal Dehta Education Health ‐

Shahpur Waste Management Employment Micro financing

Goth Tajpur Education Waste management Micro financing

Goth Tadri Mori Electricity Health Employment

Goth Tando Syed Khan Mitho Potable water Employment ‐

Goth Raees Ghulam Ali Mari Health Employment ‐

Goth Hayat Bhatti Gas Employment ‐

Goth Sayen Dino Mallah Electricity Waste management Employment

Goth Darya Baig Mughal Gas Employment ‐

Goth Khuda Baksh Electricity Potable water ‐

Goth Bakhshia Mari Electricity Potable water Education

Goth Aliabad Gas Potable water Health

Goth Karim Deno Health Education Potable water

Goth Jaitharo Electricity Gas Potable water

Goth Bego Khan Mirjat Education Health ‐

Goth Haji Ishaq Education Potable water Education

Goth Gulshan‐e‐Shahbaz Potable water Health Sewerage system

Goth Wadero Misri Health Waste management ‐

h

h

h

h

h



Sindh UniversityJamshoro

DHQ Matiari

Jamshoro Power Plant/ Water Sample 5


Goth Akro

Goth Tajpur

Goth Salaro

Goth Jaitharo

Goth Aliabad

Goth Haji Ishaq

Goth Karim Deno

Goth Tadri Mori

Goth Haji Shabu

Goth Khuda baksh

Goth Sufan Bacho

Goth Hayat Bhatti

Goth Bachal DehtaGoth Bakhshia Marri

Goth Suleman Barejo





Goth Darya Baig MughalShrine of Wali Muhammad


Shrine Baba Allah akhsh Jilani

Dargah Syed Muhammad Shah BukhariGoth Wadero Misri Water Sample 6

Kotri

Hala

Matiari

Thatta

Hyderabad

Latifabad

Tando Adam

Qasimabad

Tando Allahyar

Jamshoro

Matiari

Hyderabad

Thatta

Sanghar

68°30'0"E

68°30'0"E

68°20'0"E

68°20'0"E

68°10'0"E

68°10'0"E25

°50

'0"N

25°5

0'0

"N

25°4

0'0

"N

25°4

0'0

"N

25°3

0'0

"N

25°3

0'0

"N

25°2

0'0

"N

25°2

0'0

"N

·0 1.5 3 4.5 6 7.5 9 10.5 Km


Fig 6-6 Communities , Infrastructure & Archeaological Resource Map


LegendBlock Boundary/Project Area

"" Communties

×[ Gas Compression Facility

×k Graveyard

"' Hospital

!a Power Plant

Shrine

¥B¢ University

h Water Sampling Location


Nationla HighwayReserve Forest (SOP)

Tehsil BoundariesDistrict Boundaries

United EnergyPakistan



Photographs: Socioeconomic, Cultural & Archeaological Environment of the Project Area

Photograph 6‐39: A view of Goth Sufan Bacho Photograph 6‐40: Primary school of Goth

Salaro

Photograph 6‐41: Graveyard of Goth Salaro Photograph 6‐42: Graveyard of Goth Sufan

Bacho

Photograph 6‐43: Primary school in Goth

Bachal Dehta

Photograph 6‐44: A view of Shahpur



Photograph 6‐45: Boys’ primary school in Goth

Tajpur

Photograph 6‐46: Girls’ primary school in Goth

Tajpur

Photograph 6‐47: Dargah Wali Muhammad in

Goth Tajpur

Photograph 6‐48: Sindh Agriculture University

Photograph 6‐49: Primary school in Goth

Tando Syed Khan Mitho

Photograph 6‐50: DHQ Matiari



Photograph 6‐51: Dargah Syed Muhammad

Shah Bukhari

Photograph 6‐52: A view of Goth Bakhshia

Mari

Photograph 6‐53: A view of Goth Karim Deno Photograph 6‐54: A view of Goth Jaitharo

Photograph 6‐55: Dargah Baba Allah Baksh

Jilani

Photograph 6‐56: A view of Goth Haji Ishaq



Photograph 6‐57: A view of Goth Gulshan‐e‐

Shahbaz

Photograph 6‐58: A view of Goth Wadero

Misri

Photograph 6‐59: BHU Hyderabad Photograph 6‐60: High tension electric poles

crossing through the project area



7 Potential Environmental Impacts and Mitigations

This section discusses the potential positive and negative impacts that may arise from

the proposed exploration & development activities and the mitigation measures that

will be adopted to reduce or minimize these impacts. The impacts and mitigation

related to physical, biological and socioeconomic environment have been discussed

under three separate headings.

Physical Environment

7.1.1 Changes in Landscape & Soil Erosion

The potential sources for changes in landscape and soil erosion due to the proposed

project activities include operation of vibroseis, preparation and establishment of

campsites for seismic/drilling/flow line/GPF operations, preparation of new tracks for

seismic operations, construction of access roads for well sites, construction of well

sites, quarrying of gravel or sand, use of project access roads, off‐road travel,

development of new access tracks and earthworks at RoW/GPF for flow lines.

a. Source Specific Assessment

Seismic Operation

For seismic lines in agricultural lands, shot or deep holes will be drilled for which no

line clearing will be required. At selected locations upholes will be done which will

not require significant land clearing. Vibroseis technique will be mostly used in areas

having flat topography (not in agriculture fields).

Preparation of Campsites for Seismic Operation – For seismic operation campsites will be

developed to accommodate the seismic crew. The campsites will preferably be located

in levelled land and existing clearings to avoid any disturbance to soil or vegetation.

Preparation of Access Tracks for Seismic Operation – Due to the presence of numerous

existing access tracks, the need for preparation of new tracks will be minimal. Only

limited number of tracks might have to be prepared to access remote locations. The

mitigation measures listed at the end of the section will ensure that any impacts due to

this activity are kept to the minimum.

Drilling Operation

Construction of Access Road – The existing tracks will be upgraded and used as much as

possible, except for small stretches of new tracks that will be built to access proposed

well sites. Construction of the access tracks in the levelled sections will not involve any

major cut and fill. Since, the entire road section will be covered with compacted gravel

topping (the topping maybe of in‐situ or imported gravel) soil erosion from the road

will not occur. Because of compacted gravel topping no erosion from the road will

occur.



Mitigation measures to minimize chances of soil erosion or land slippage from the

entire length of the road have been recommended at the end of this section. This will

primarily be due to wind erosion, from earth‐fill stock piles and loose road surface

during construction.

Construction of Well Sites and Campsites – For each well site, land will have to be cleared

for the preparation of well site, rig camp, security camp and access track. Considering

the limited land area requirement for the development of a well and rig campsite

(approximately 32,400 sq. m for well site, 8,000 sq. m for rig camp and 3,900 sq. m for

security camp), no significant impacts due to this activity will occur provided the

mitigation measures listed at the end of this section are adhered with. The well site

and rig camp are proposed in levelled areas so no large earthworks would be required

for their construction. The top surface at these areas will be compacted minimizing

any chances of soil erosion.

Quarrying of Earth‐fill – During construction of well sites, rig camps and access roads

fill material may be required. Quarrying if done un‐appropriately can lead to erosion.

To minimize erosion due to quarrying, the quarry sites will be carefully selected such

that they are located in levelled areas with existing clearing and the quarry sites are

restored after use.

Laying of Flow Lines/Tie‐in/Wellhead Works

Laying of Flow Lines – Flow lines will be laid to connect producing wells to the main

processing plant/facility. For the flow lines potential sources of soil erosion may

include clearing of land along the Right of Way (RoW) which will be 40 to 50 ft. for

flow lines, use of existing tracks, development of short reaches of new tracks and

preparation of construction campsites.

The flow lines generally run along the access roads to the well sites and further to the

processing plant/facility. In the project area, the flow lines should preferably follow

the roads developed to access the individual well locations. Lying of flow lines should

avoid major cut and fill during construction/establishment.

During the laying of flow lines use of the existing local access tracks and roads should

be used. Development of new roads should be minimized. The construction camps

developed during laying of the flow lines should be located in flat terrain and existing

clearings.

A certain level of soil loss can be expected from poorly compacted backfills over

buried flow lines and the use of dirt tracks during laying of flow lines. In order to

minimize this soil loss, it is recommended that laying of flow line activities should be

planned keeping into consideration two key principles 1); to minimize disturbance to

soil by minimizing land clearing and 2); to minimize loss of soil from disturbed areas

by ensuring soil binding. Detailed mitigation measures based on these principles are

listed at the end of this section below.



Quarrying of Earth‐fill – The impacts will remain the same as discussed in the section

on drilling operation.

Construction/Establishment of GPF/CPP

Establishment/Construction of GPF/CPP – Construction/establishment of GPF/CPP will

be carried out in an already existing cleared and levelled land. Considering the limited

land area requirement for the plant and a single access road will be developed, no

significant impacts due to this activity will occur provided the mitigation measures

listed at the end of this section are adhered with. Construction will follow good

industry practices to avoid unnecessary clearing outside the work corridors and

likelihood of soil erosion along or across natural drainage paths. The access road will

be properly compacting to minimize soil erosion. Construction camps will be located

in flat area with existing clearings.

Quarrying of Earth‐fill – During construction activities fill material may be required.

Quarrying if done un‐appropriately can lead to erosion. To minimize erosion due to

quarrying, the quarry sites will be carefully selected such that they are located in

levelled areas with existing clearing and the quarry sites are properly restored after

use.

Road Travel during Project – The use of the road during the project may result in erosion

of soil from the road surface. On gravel‐topped roads, erosion is less significant due to

the compacted gravel topping. During the project, erosion from road surface will be

minimized by sprinkling of water over the project access road and compacting loose

surfaces wherever required. However, as water is a precious resource in the area there

will have to be some rationing of its use.

b. Residual Impacts

Even after application of mitigation measures the characteristics of the residual

impacts for each component of proposed project activity are tabulated below:

Characteristic Activity

Seismic Drilling GPF/CPP Flow Lines

Duration Medium Medium Medium Medium

Extent Local Local Local Local

Likelihood Certain Possible Possible Possible

Consequence Minor Minor Minor Minor

Reversibility Reversible Reversible Reversible Reversible

Significance Medium Low Low Low

c. Mitigation Measures

General

During construction movement of construction equipment will be restricted to

work areas only to avoid unnecessary disturbance to soils in the project area;



To minimize erosion due to quarrying, the quarry sites will be carefully selected

such that they are located in levelled areas with existing clearing and the quarry

sites will be restored after use;

Clearing of vegetation and the cutting of trees will be minimized as much as

possible;

Off‐road travel will be strictly prohibited and observance of this will be monitored

during the operation;

Vehicles speed will be regulated and monitored to avoid excessive dust emissions;

Total land uptake by the camps and access road will be kept to the minimum

required;

Periodic trainings will be provided to drivers on mitigation measures related to

off‐road travel and speed limits;

UEPL Rep and IMC will monitor the access tracks (other than the main access

track for the project) to be used by water tankers, dumper trucks and other

vehicles;

Stream crossings when built shall be such that the slopes of the stream bank are

properly adjusted and compacted resulting in a stabilized and sealed surface; and

The width of the new/improved track should be kept to the minimum 5 m

required, except at bends where safety considerations will dictate additional

width.

Seismic Operation

Seismic lines in the undulating plains will follow natural contours wherever

possible. However, in areas where seismic line cutting is a requirement, the

activity will be carried out in a way that would minimize disturbance to natural

topography and soils;

The width of seismic lines cleared for vibroseis will be limited to 4.5 m to minimize

clearing of vegetation and disturbance to soil;

Construction and seismic camps will be located in existing clearings and on

levelled land;

During seismic operation the number of routes used will be kept to a minimum

and road travel will be minimized; and

During seismic operation the preparation of new access tracks will be minimized.

Where improvement of existing tracks or development of short lengths of new

tracks is unavoidable the width of the access track will not exceed 5.5 m.

Drilling Operation

Total land uptake by each well site, rig camp and access road will be kept to the

minimum required;



The access track to each well site will be selected to utilize existing tracks as much

as possible;

The well site, rig camp and construction camp will preferably be located in existing

clearing and levelled land and will avoid major earthworks; and

The access track to each well site will be properly compacted at the time of

construction and thereafter properly maintained throughout the entire

construction and drilling operation.

Laying of Flow Lines/Tie‐in/Wellhead Works

Land area requirements for construction camps and RoW of flow line laying will

be kept to the minimum required;

Topsoil of the RoW will be separately stored. This topsoil will be backfilled after

proper compaction ensuring minimum loss of topsoil;

Clearing of vegetation (especially dense vegetation) will be minimized by careful

selection of construction camps and flow line alignment; and

During the laying of flow line, use of the existing local access tracks and gravel top

roads prepared should be used. Development of new tracks should be minimized.

The construction camp developed during laying of flow line should be located in

flat terrain and existing clearings.

Construction/Establishment of GPF/CPP

Land uptake for establishment of GPF/CPP and access road will be kept to the

minimum required;

Existing access tracks to the GPF/CPP will be used as much as possible;

Already cleared and levelled land will be acquired for GPF/CPP avoiding major

earthworks; and

Access track to the GPF/CPP will be properly compacted at the time of

construction and thereafter properly maintained throughout the entire operational

life.

7.1.2 Soil and Water Contamination

During seismic operations, potential sources of impact will include domestic wastes,

fuel or oil leakages or spills, bentonite mud used during drilling of shot holes and

upholes. During drilling operations potential sources may include domestic wastes,

drilling mud (WBM or may be OBM) and cuttings, produced formation fluids, and

spillage or leakage of fuel, oil or chemicals. During flow line laying, tie‐in & wellhead

works wastewater will be generated during hydro‐testing in addition to domestic

wastes generated at the campsites. Similarly, during construction/establishment of

GPF/CPP potential sources of impact will include domestic wastes (solid & liquid),

fuel or oil leakages or spills and other construction wastes.



a. Waste Generation and Disposal

Waste will be generated during the proposed exploration and development activities.

If the waste generated during the project activities is managed and disposed of in an

environmentally friendly manner then adverse impacts related to soil and water

contamination could be avoided or minimized. Moreover, if all mitigation measures

recommended in this EIA are followed, contamination of soil or water resources is not

expected to occur and hence impacts will not be cumulative. For the purpose of risk

assessment the likelihood of oil spillages during transportation has been assessed as

possible. Because any contamination that may occur will be remediated following

standard protocols, the effect of such spills will therefore not be cumulative.

A water based mud system is normally used by United Energy Pakistan Limited due

to its environmental preference over oil based mud. Generally two broad categories of

muds are used for drilling of oil or gas wells i.e. oil based and water based. Oil based

mud is formulated by mixing chemicals with diesel. This mud is not considered to be

environment friendly due to the risk of contamination of subsurface formations during

drilling and the generation of oily drilled cuttings which require specialized handling

and treatment. If cuttings not handled, stored and treated properly then it may result

in soil and water contamination. UEPL may use Mineral Oil Based Mud System

(OBM) during drilling activity where wellbore issues will be encountered. However,

the use of OBM will be limited to short reaches of section/s. In order to cool the

drilling bit and flush out rock fragments, diesel‐based drilling mud will be

continuously circulated down the drill pipe and back up the well hole. By circulating

the mud through the drill string and up out of the hole, the mud will carry oil

contaminated drilled solids (cuttings) to the surface. The separated solids (cuttings)

will be temporarily stored in a lined cuttings pit or in steel containers and will be

transported to land farming site or thermal desorption contractor site in dump trucks

with water tight containers for treatment. The final disposal of drill cuttings with OBM

will be carried out after treatment at land farming site or by thermal desorption. OBM

cuttings will be treated and disposed of in guidance with American Petroleum

Institute (API) or State of Louisiana, Department of Natural Resources, State Wide

Order 29B (LSO – 29B). The final disposal of drill cuttings may be disposal into HDPE

lined pits, concrete lined pits, land spread after dilution with native soil, use as fill

material for road construction or cement solidification. The drill cuttings and mud

produced during use of WBM will be disposed of at the well site within lined waste

pits. Domestic and excavation debris, plastic equipment wrapping is the major waste

that will be produced during construction of CPF/GPF.



A summary of waste generated due to proposed exploration and associated

development activities, including type and description of waste and recommended

waste disposal methods are provided in the following table:

Activity

Description Proposed Disposal Method Seismic

Dri lling

GPF/CPP

Flow Lines

Food waste: Kitchen waste e.g. fruit,

meat, vegetable residues etc.

Burial in bury

pit/composting

Recycleable waste: Paper, plastic,

textiles, cardboard, rubber, wood,

glass, tin cans, metal scrap,

aluminium cans, ferrous/non‐

ferrous materials and batteries etc.

Oily waste: Oily rags and used oil

etc.

Recycling

Recycling & incineration

Recycleable waste: Plastic or

aluminum pipe protection etc.

Recycling

Clinical waste: Syringes, glass

bottles, used bandages and expired

drugs etc.

Incinerate at appropriate

facility

Grey water: Wastewater from

kitchen, laundry and showers etc.

To be first sent to septic

tanks and finally

disposed of in soak pits

In case the soak pits get

filled during the

operation, grey water

will be transferred to

nearest municipal drains

with prior approval of

concerned authorities

Sewage/Black water: Wastewater

from toilets

STP should be the

preferred option

If no STP is available

then to be disposed of in

septic tanks and soak

pits

Drilling waste: Drill cuttings, excess

or spent drilling mud and rig wash

water

A water based mud will

primarily be used

during drilling. The drill

cuttings and WBM will

be stored at the well site

in lined pit. The drilling

mud will be allowed to



Activity

Description Proposed Disposal Method

Seismic

Dri lling

GPF/CPP

Flow Lines

evaporate inside the

mud pit and also dry

out. After that, the mud

pit and the cuttings pit

will be backfilled

OBM and cuttings will

be passed through a

separation system

consisting of shale

shakers and a Hi‐G

dryer. The separated

solids (cuttings) will be

temporarily stored in a

lined cuttings pit or in

steel containers and will

be transported to land

farming site or thermal

desorption contractor

site

Bentonite mud & cuttings: For

drilling of upholes and deep holes

to avoid the holes from collapsing

To be disposed of into

earthen pits, backfilled

after the mud and

cuttings are dried.

Bentonite is a natural

clay material and non‐

hazardous in nature.

The mud and cuttings

after drying will return

to dust

Minor Oil spills/soil

contaminated by oil

leakages or stains: Leaks

from vehicles,

equipment, or storage

containers at campsites

or work areas outside

the campsite or oil or

fuel stains produced

during handling and

transfer operations

Specialized treatment

such as incineration or

remediation such as

thermal, chemical or

biological

Best industrial

guidelines will be

followed

In case of chemical spill

the contaminated soil to

be land filled



Activity

Description Proposed Disposal Method

Seismic

Dri lling

GPF/CPP

Flow Lines

Quantity: Area and

depth of soil

contaminated; < 1 m2

and 0.3 m respectively

Moderate Fuel, oil or chemical

spills during transfer

or handling operations.

Quantity: Spill less than

200 litres

Major Spill during

transportation of fuel,

oil or chemicals or

failure of the

containment areas

Quantity: Spill more

than 200 litres

Wastewater generating from process:

Cleaning and hydro‐testing of

pipelines

To be disposed of in

earthen pits

To be drained to the

nearest drainage

channel with prior

approval of concerened

Produced Water To be disposed of in

impermeable (HDPE)

lined evaporation ponds

To be re‐injected into

deep subsurface

formations where

possible

Condensate To be transported and

sold to the nearest

refinery

Solid Waste: Concrete, building

materials, off cut pipe, plastic pipe

protectors, plastic sheeting and

cable drums etc.

Landfilling and

recycling as appropriate

b. Residual Impacts

It is believed that after applying the recommended mitigation measures, no

contamination of soil or water will occur.



Characteristic

Waste Type

Domestic and

Clinical Wastes

Fuel, Oil or

Chemical

Spills

Operational

Wastes

Duration Short Medium Medium

Extent Local Local Local

Likelihood Unlikely Possible Unlikely

Consequence Minor Minor Minor

Reversibility Reversible Reversible Reversible

Significance Low Medium Low


Mitigation measures for each category of waste are listed below. Where a category of

waste is common, the mitigation measures will apply equally to all segments of the

proposed project.

Domestic and Medical Wastes

Sewage Treatment Plant (STP) shall be preferred for handling of black/grey water

under BATNEEC/BAT, but in case of unavailability of STP, septic tank and soak

pits shall be provided. Septic tank and soak pit shall be covered properly to avoid

any bad smell in surrounding areas;

Wastewater from laundry, kitchen washings and showers will be disposed of into

separate soak pits;

Soak pits will be built in absorbent soil and located 300 m away from a perennial

surface water source or water well;

Soak pits will be constructed such that surface runoff cannot enter the pits;

Soak pits will be designed to accommodate wastewater generated during the total

duration of the operation;

In case the septic tank gets filled with sludge, septic tank shall be emptied through

vacuum truck and material shall be transferred to treatment facility or approved

municipal drain;

No solid waste will be disposed of in the field. All solid wastes will be disposed of

in waste bins provided within the campsite’s area;

All types of combustible, non‐combustible and hazardous wastes including plastic

or glass bottles and cans will be temporarily stored on site and sold/handed over to

a waste/recycling contractor who will utilize these wastes for recycling purposes;

Burning of wastes (any type) will not be allowed;

At the time of restoration septic tanks will be dismantled in place and backfilled

with at least 1 m of soil cover;



At the time of restoration soak pits will be backfilled with at least 1 m of soil cover;

and

Medical wastes will be temporarily stored onsite separately and incinerated at

appropriate facility.

Oily & Hazardous Wastes

Used oil and wastes will be transported to local contractors for recycling;

Shovels, plastic bags and absorbent material should be present near fuel and oil

storage or handling areas to attend spills and leaks;

A spill prevention and contingency plan will be prepared to deal with moderate

and major spills;

The soil contaminated from major spills may require specialized treatment such as

incineration or bioremediation. In case of chemical spill the contaminated soil may

have to be landfilled;

The soil contaminated from minor and moderate spills will be removed and

properly buried in such a manner that it does not contaminate the surrounding

soils or groundwater. In the case of spill >200 liters the contaminated soil will be

disposed of in line with the best industrial practices;

Fuels tanks will be daily checked for leaks and all such leaks will be plugged

immediately;

Fuel and oil storage areas will have secondary containment in the form of concrete

or brick masonry bunds. The volume of the containment area should be equal to

125% of the total volume of fuel stored;

All fuel tanks will be properly marked to highlight their contents;

All fuel and oil storage areas will have a concrete pad underneath to prevent soil

contamination in case of leaks or spills; and

Vehicles will be daily checked for fuel or oil leaks. Vehicles with leaks will not be

operated until repaired.

Operational Wastes

At the time of restoration all pin flags, signs and refuse from seismic lines will be

removed;

Bentonite mud used for the purpose of uphole and deep hole drilling will be

prepared in rig tanks. The used mud will be disposed of in the pit and left to dry.

After the mud has dried the pit will be backfilled;

During fuel and oil transfer operations such as re‐fuelling vibroseis/bulldozers

through a dedicated fuel vehicle, drips and spills will be avoided and drip pans

will be used;

A water based mud system will primarily be used for drilling of wells;



Waste pit at the well site will be lined with an HDPE liner;

The drill cuttings and WBM will be disposed into a pit lined with an impermeable

geo‐membrane. The pit will be larger than the required capacity to accommodate

overflows. At the time of restoration the pit will be backfilled with the cuttings

encapsulated within the liner and with a top soil cover;

The final disposal of OBM (if used) and contaminated drill cuttings will be carried

out after treatment at land farming site or thermal desorption;

UEPL will carry out feasibility study and prepare detailed treatment and disposal

plan of OBM cuttings;

OBM (if used) cuttings will be treated and disposed of (based on the chemical test

results) in guidance with American Petroleum Institute (API) or State of Louisiana,

Department of Natural Resources, State Wide Order 29B (LSO – 29B);

Produced formation fluids during testing will be flared along with the gas or

collected inside the lined waste pit at the well site. In case the fluids discharge into

the flare pit the soil at the sides of the flare pit will be excavated and disposed of

into the lined waste pit at the well site; and

Water used for cleaning and hydro‐testing of pipelines will be collected in earthen

pits where it will evaporate with time or drained into the nearest drainage channel

with the prior approval of concerned. The residual sludge or solids and the liner

will be disposed of following best industrial practices.

Minimum Distances for Waste Pits

Septic tanks and soak pits at 300 m from local water wells or hand pumps;

Drill cuttings and mud pits at the well site 300 m from local water resource; and

All other waste pits or enclosures at least 300 m from local settlements and local

water resources.

7.1.3 Climate and Ambient Air Quality


This section of the report considers the sources of emissions generated during the

proposed exploration and development activities on ambient air quality. The sources

of emissions can be categorized into intermittent and short term sources of emissions

during the operations which will last for a few months including seismic, drilling and

laying of flow lines.

Monitoring of air emissions from generators used in exploration activities shows that

the emissions remain within the NEQS (HPK’s various Independent Environmental

Monitoring projects of exploration and development activities in Sindh region). The

emissions will also disperse quickly with the prevalent wind currents.



Exhaust Emissions from Generators, Vehicles & Equipment

As discussed earlier stack emissions from generators that will be used at the campsites

and well site will generally remain within NEQS/SEQS. Any slight increase from the

NEQS/SEQS will not have any impact on the environment, as the emissions will

quickly disperse with the prevailing wind currents. Control over black smoke from

vehicles and construction machinery shall be kept by maintaining visual monitoring

and tuning or maintenance of the vehicles.

Dust Emissions due to Construction & Road Travel

Dust emissions due to construction and road travel shall be minimized by practising

good construction practices (such as keeping stock piles down wind and away from

communities and camp) and sprinkling water over the access road (wherever

required).

Emissions from Flaring

Emissions in the form of oxides of carbon, nitrogen and sulphur will be produced

during flaring. Emissions from flaring will have no effects on communities or rig site

workers and local air quality because the flare pit will be kept downwind of the well

site and more than 300 m from communities and the emissions will disperse and

dilute with prevalent wind currents. Safe distance will also be maintained for

construction/establishment of GPF/CPP.

Possible H2S Emissions in Case of Emergency

In the event of any release of hydrogen sulphide gas above safe acceptable limits

emergency response procedures will be adopted.

b. Residual Impacts

It is believed that after applying the recommended mitigation measures, no

deterioration of air quality will occur.



Duration Short Short Long Short


Likelihood Unlikely Unlikely Possible Unlikely



Significance Low Low Medium Low


General

Campsites will be located at least 300 m away from communities;

During construction dust emissions due to road travel will be minimized by

regulating vehicles speed and watering of the access track (wherever required);



Burning of waste (any kind) will not be allowed;

Generators, compressors and vehicles used will be maintained in a good condition

to ensure that emissions are kept to a minimum level;

During operation, emissions from all point sources should be monitored to check

compliance with SEQS;

Dust emissions during construction activities should be minimized by good

management practices such as locating stock piles out of the wind direction,

keeping the height of the stock piles to a minimum, keeping earthwork areas damp

etc.;

During construction leveling or widening along the access roads will be done in

sections, immediately followed by sprinkling of water and also preferably

compaction (where required); and

Appropriate measures will be taken to avoid ozone depletion & global warming

e.g. prohibit use of CFC gases etc.

Seismic Operation

Generators, compressors and vehicles used during seismic operations will be

maintained in a good condition to ensure that emissions are kept to a minimum

level.

Drilling Operation

Generators and vehicles used during construction of each well site and subsequent

drilling operations will be maintained in a good condition to ensure that emissions

are kept to a minimum level;

During drilling and construction dust emissions due to road travel will be

minimized by regulating and monitoring vehicles speed and watering of the access

track;

The access track selected to access the well location will maintain a reasonable

distance from communities; and

Flare pit will be kept downwind of the well site and at least 300 m from the nearest

community. The duration of flaring during well testing will be kept to the

minimum required.

Establishment/Construction of GPF/CPP

During detailed design for the GPF/CPP, emissions from point sources such as

flare and incinerator (for acid gases) should be modelled so that if there are any ill‐

effects on local communities and workers appropriate mitigation measures such

adjusting the stack heights can be taken; and

During operation of the GPF/CPP emissions from all point sources should be

monitored to check compliance with SEQS.



Lying of Flow Lines/Tie‐in/Wellhead Works

Access tracks used during laying of gas pipeline passing through communities will

be avoided. If unavoidable a speed limit of less than 30 km/hr will be observed on

the section of the road passing through the community.

Minimum Distances

The following minimum distances will be maintained from communities:

o Well Site, rig camp and construction camps for all activities – 300 m

o Quarry locations – 1,000 m

o Flare pit at well sites – 300 m

Access tracks to well sites and any other permanent facility – 300 m unless driven

by community demand. If a distance less than 300 m is maintained appropriate

water sprinkling over the access track.

Access tracks used during drilling – Preferably access tracks passing through

communities will be avoided. If unavoidable a speed limit of less than 30 km/hr

will be observed on the section of the road passing through the community.

7.1.4 Noise Pollution


Sources of noise during seismic, construction including GPF/CPP and drilling will be

generators, vehicles, drilling rig, flaring during well testing, plant operation and

construction equipment & machinery. These sources of noise like air emissions can be

categorized as short term and intermittent arising from seismic and drilling activities

and other associated developmental activities.

Increased noise levels during the operations although will not accumulate but can

individually be a source of nuisance for locals and a source of disturbance to wildlife.

Monitoring of actual noise levels from drilling rigs and campsites has also shown that

noise during construction and drilling attenuates to ambient levels (background levels

within the project area) after approximately 300 m from the campsites and well site.

Noise levels monitored from different vehicles under different conditions by HPK in

other drilling operations show that the noise levels from all vehicles comply with the

NEQS/SEQS level of 85 dB @ 7.5 m from the source and reach the ambient noise level

in the area at distances ranging from 40 to 70 m from the source. Table presented

below explains the permissible noise exposure limits which shall be met at working

sites during the entire course of operation.

For Lex & LAeq For Peak Pr (Lpk)

OSHA Action Level 85 dB‐A for TWA of 8 hours exposure

135 dB‐C 82 dB‐A for TWA of 12 hours exposure

OSHA Upper

Exposure Limit

90 dB‐A for TWA of 8 hours exposure 140 dB‐C

87 dB‐A for TWA of 12 hours exposure



As the project facilities will maintain appropriate distances from communities, effects

of noise on communities will not occur. Similarly, effects of vehicles noise on

communities will also not occur if the access tracks maintain a reasonable safe distance

from communities. Any effects of noise during the operation shall be further mitigated

by the measures listed below.

b. Residual Impacts

It is believed that after applying the recommended mitigation measures, the effects of

noise will be of low significance.



Duration Short Short Long Long


Likelihood Unlikely Unlikely Unlikely Unlikely



Significance Low Low Low Low


It shall be ensured that generators, vehicles and other potentially noisy equipment

used are in good working condition;

Well sites, campsites and all other project related surface facilities e.g. GPF/CPP

will be located 300 m away from nearest communities;

The use of horns by project vehicles shall be minimized. The use of pressure horns

shall not be allowed;

Movement of all project vehicles and personnel shall be restricted to within work

areas;

Noise levels at communities nearest to the GPF/CPP shall be monitored by Health,

Safety and Environment Officer (HSEO) of UEPL. In case these are found to exceed

safe acceptable limits appropriate mitigation shall be taken;

Generators will be kept within enclosures to minimize dispersion of noise; and

In areas with higher noise levels or longer shifts ear plugs and earmuffs will be

provided to workers.

7.1.5 Use of Water


Use of water from local surface or groundwater resources for the project resulting in

decreased availability of water for local users.

The project area have well‐established surface water resource. The most important

surface water feature in the area is Indus River which usually peaks in mid‐August or



early September. Apart from that, the project area also houses few dhands which are

located in low laying depressions where groundwater surfaces to the ground level. A

number of tube wells also exist in the project area with sufficient yield. The use of local

water wells during exploration and associated development activities is a common

practice by all operators and in almost all areas of Pakistan.

Due to the high surface water demand for irrigation and the biological significance of

surface water bodies, abstraction of surface water will not be done. The Indus River,

canals and associated irrigation network is the source of surface water in the area and

its use will not be feasible as the water is not potable. Hauling the water only for

operational use would mean increased logistics management, as potable water would

still have to be supplied from water wells for domestic use. Under special

circumstances like long haul distances, improper access for water bowsers in protected

areas etc. surface water resources may be exploited for limited water abstraction

during seismic operation only after getting approval from the concerned department.

Other than that, surface water resources will not be used during drilling activities.

Except flush and uphole drilling, water will not be required for jackrob drilling and

vibroseis operation. Limited upholes will only be drilled at selected locations. Since,

the water requirement during seismic surveys is not high it is assessed that the effect

on local wells will not be significant enough to cause any localized depletion of

aquifers or effects on local water requirement. In order to ensure that this remains to

be the case, the local water wells will only be used after ensuring that they have the

excess capacity to supply the water requirement and water levels/discharges will be

monitored to ensure that any effects remain negligible. Water for project will either be

obtained from water wells in the project area or UEPL may install its own water well

at a suitable location in the project area in consultation with the local community. The

aquifer yield will be calculated for ensuring that the available capacity at the local tube

well (safe yield minus local demand) is at least 50% greater than the project demand.

Discharge from the tube well will be regularly monitored to monitor any changes in

the yield of the well. In order to conserve sweet groundwater, it is also recommended

that UEPL should maximize wherever possible the use of brackish groundwater in its

operations such as seismic, drilling and establishment of associated surface facilities

etc.

With regards to water usage of it should be recognized that groundwater is a

communal resource. In order to share the groundwater in the project area with the

local communities, UEPL must ensure that its operations must not exploit the resource

in an unsustainable manner and that local communities are appropriately

compensated for the use of the communal resource. Therefore, for water abstraction

during proposed exploration and development activities, compensation means the

payment to local well owner at appropriate rates for the quantity of water obtained.



b. Residual Impacts

Even after application of mitigation measures water will continue to be used during

the entire development phase of the project but in a sustainable manner.



Duration Short Long Long Short

Extent Local Regional Regional Local

Likelihood Unlikely Possible Possible Unlikely



Significance Low Medium Medium Low


Water from surface water bodies i.e. wetlands or canals etc. will not be used for the

proposed exploration and associated development activities. Under special

circumstances like long haul distances, improper access for water bowsers in

protected areas etc. surface water resources may be exploited for limited water

abstraction during seismic operational needs only after getting approval from the

concerned department. The surface water resources will not be used other

exploration and development activities;

The quantity of water used during different project activities will be kept to the

minimum required by taking prudent water conservation measures on site. A

complete record of water consumption will be maintained by the UEPL’s Rep;

Groundwater will be used for project activities from existing tube wells or by

UEPL’s installed water wells. Water from the tube wells will only be used after

ensuring that the available capacity at the groundwater is roughly 50% greater

than the project demand. Discharge from the existing tube wells or UEPL’s

installed tube wells will be regularly monitored to monitor any changes in the

yield of the wells;

If a new water well is to be installed, the well will be located 300 m from existing

local wells and will be designed to abstract water preferably from deep aquifer not

being used by local communities;

Contamination of surface and groundwater resources will be avoided;

Preferably, the potable water requirement will be met by installing water treatment

system (such as reverse osmosis);

UEPL and project contractors will pay appropriate and justified compensation for

water utilized to the owners of water well; and

Marginally sweet water wells will be used for project activities. Where possible,

use of brackish water should be maximized for the project activities.



7.1.6 Blockage of Natural Drainage


It is recommended that well sites, campsites and associated development facilities e.g.

manifolds, EWT, GPF/CPP will be located in cleared and levelled terrain. The entire

project area experience rapid flow during rainfalls particularly along the surface water

bodies. As the well sites, campsites wand associated facilities will have limited areas

therefore no blockage to this rapid flow will occur. However, as a precautionary

measure area around the facilities shall also be landscaped to avoid blocking of natural

drainage.

The access roads and pipeline’s RoW may cross streambeds. Causeway crossings and

pipe culvert bridges will be provided at all stream crossings. To avoid obstruction to

sheet runoff in plain areas, any soil windrows formed along the access road during

construction activities shall be levelled. The gas transmission pipeline will be laid at a

depth of 3ft. Since, the water table in the project area is generally more than 10 ft.

below the ground surface, no direct impact on groundwater quality is anticipated

during pipeline laying.

b. Mitigation Measures

Area around the well sites, campsites and associated surface facilities shall be

landscaped to avoid blocking natural drainage;

Causeways and pipe culverts will be provided at all watercourse and minors

crossings to avoid blocking of natural drainage; and

Uncontrolled and unnecessary clearing, dozing, excavations or quarrying, storage

of construction material etc. will be avoided.

7.1.7 Site Restoration

a. Potential Sources of Impact

After completion of each activity, the project facilities will be restored as close to its

original condition as possible. One of the important tools is the photographic record of

project facilities e.g. campsite/s prior to setup will be taken and will be compared after

site restoration. The restoration of well sites and associated facilities (including access

tracks and campsites) is of utmost importance. As these facilities occupies areas of the

wildlife habitats, retention of these sites or improper disposal of wastes left at the end

of the drilling or construction activities would be in conflict with the principle of least

environment disturbance over the least possible time period in these areas.

b. Mitigation Measures

General

Demobilization of all equipment and machinery;

Disposal of any waste material remaining at the time of completion of the

operation;



Backfilling of all soak pits and septic tanks;

Dismantling and removal of fence or barriers surrounding the campsite areas; and

General restoration of the site area including landscaping and restoration of

drainage where required.

Seismic Operation

Restoration of seismic lines will include removal of all cables, geophones, station

units, flags, stakes and wastes from the lines and backfilling of all mud pits. For

reference purposes a photographic record of selected sections of seismic lines will

be taken before and after the operation.

Drilling Operation

Complete Restoration – Dry Well

All wastes at the well sites will be disposed of according to the requirements of the

EIA/EMP;

Liner from the water and waste pits at the well sites may be taken out and re‐used

or disposed of in the existing pits with proper restoration;

All concrete structures at the well sites will be broken and either transported out of

the project area or site restoration contractors will sent it for sale or reuse or

disposed of into the pits;

All pits at the well sites will be backfilled; and

The areas covered by the portion of the access track that will be of no use for other

wells will be restored, in that all gravel topping will be removed. This scenario will

be applicable only if the locals require the potions of the track to be restored or

otherwise it will be left on the site on the consent of the locals.

Partial Restoration – Producing Well

The well sites and access roads will be retained to support well access work for

further testing or during the production phase;

The outer chain link fence will be retained as a safety measure to keep wildlife

away from the pit areas;

The wellhead will be enclosed by a locked steel cage. This will serve as both a

safety and security measure as the site will be down‐manned pending further

production operations work; and

The constructed pit areas will be retained but all liquid and solid waste material

will be removed from the site and disposed of in line with the requirements of this

EIA/EMP.




7.2.1 Clearing of Vegetation & Loss of Habitat


Loss of vegetation can occur during the proposed exploration and associated

development project activities due to clearing of land along seismic lines, well sites,

campsites and RoW prepared for pipelines laying and the tracks prepared to access

the well sites, campsites, flow lines and surface production facilities.

Impacts on vegetation due to the sources mentioned above will be of less significant if

existing tracks are used as much as possible. No endemic species were identified in the

project area during the EIA site visit. The distribution of vegetation communities are

found in wide range in the project area during site visit. Therefore, limited vegetation

clearing will not result in extinction of any vegetation communities. Clearing will

preferably be carried out in areas where the vegetation is in a degraded state due to

livestock grazing or harvesting by local communities, and cutting of trees will be

avoided. The vegetation clearing on steep slopes will also be avoided to minimize soil

erosion.

b. Residual Impacts

If all mitigation measures given below are adhered with residual impacts will be the

loss of vegetation cleared from permanent facilities such as producing well sites,

access roads and GPF/CPP. At all other areas such as at temporary tracks vegetation

will regenerate with time. Even at the permanent facilities regeneration will also occur

after decommissioning and restoration of the sites.



Duration Medium Medium Medium Medium


Likelihood Certain Certain Certain Certain





General

Project related camps/facilities should be established outside the environmental

sensitive areas;

The campsite areas will be kept to the minimum required;

Camps will be located in existing clearings;

Use of local vegetation/wood as fuel by crew personnel will be prohibited;



Clearing of trees will be avoided as much as possible. Under unavoidable

circumstances any clearing required in forests shall be done with prior approval

and be compensated as per rules and regulations of Forest Department;

Outside forest protected area, any tree cutting if unavoidable for clearing of site

will be replaced/compensated by plantation of trees (10 trees for each tree cut). The

tree species should be indigenous to the region;

Periodic trainings will be provided to drivers on mitigation measures related to

off‐road travel and speed limits;

Dust emissions on access tracks will be reduced by keeping speed limits below 40

km/hr;


Campsites will avoid areas of dense vegetation as much as possible;

Access tracks will be avoided from passing through patches of dense vegetation;

Off‐road travel, required at sections of the road where construction work is in

progress, will be minimized and if required will be allowed only after approval

from UEPL’s Rep;

Clearing of vegetation will be minimized by keeping the road width to 5 m (except

at bends where greater width will be required for safety reasons), and by keeping

the length of new sections of the road to a minimum; and

Blasting, construction or drilling activities will not be performed in Indus River.

Seismic Operation

During seismic operation clearing of vegetation will be minimized by minimizing

the width of the vibroseis tracks, minimizing the preparation of new access tracks,

and keeping the width of new access tracks to the minimum required;

Crew personnel while working along seismic lines will concentrate within a

corridor of 4.5 m; and

Total land uptake by seismic camps and access track will be kept to the minimum

required.

Drilling Operation

During construction good management practices will be adopted to avoid

disturbance to areas adjacent to work areas including the access tracks, well sites

and campsites;

Well sites and campsite areas will be kept to a minimum; and

Campsite established for the purpose of construction will be located in existing

clearing. Vegetation clearing from these sites will be kept to a minimum.



Establishment/Construction of GPF/CPP

Existing access tracks will be utilized as much as possible;

The access track to the GPF/CPP will be properly compacted and maintained

throughout the entire operational life;

During construction movement of construction equipment will be restricted to

work areas only to avoid unnecessary disturbance to soils in the project area;

To minimize erosion due to quarrying, the quarry sites will be carefully selected

such that they are located in levelled areas with existing clearing and the quarry

sites are restored after use;

Clearing of vegetation will be minimized;


during the operation; and

Vehicles speed will be regulated and monitored to avoid excessive dust emissions.

Lying of Flow Lines/Tie‐in/Wellhead Works

Topsoil of the RoW of gas pipeline/flow line, will be separately stored. This topsoil

will be backfilled after proper compaction ensuring regeneration of vegetation;

Good engineering practices will be adopted during construction activities to

ensure that unnecessary clearing of vegetation outside work areas is avoided; and

Land area requirements for construction camps and RoW of gas pipeline will be

kept to the minimum required.

7.2.2 Disturbance to Wildlife


Potential sources of impacts on wildlife during the project activities include

disturbance due to construction of access roads, well sites, seismic camps, rig

campsites, construction/establishment of GPF/CPP, laying of pipelines, access road

usage during the project, light and noise from the camps, light and noise from well

sites (including flaring at the well sites and GPF/CPP).

Birds

The project area support fair populations of native and migratory birds. As the EIA

prohibits hunting, fishing, harassment, trapping, killing or feeding of any wildlife

species, therefore impacts of the project on these species found will be very less.

Similarly, the resident water birds associated with the wetland of the project area may

only be disturbed temporarily due to activities spread of this habitat. During the

migratory season, operation in this habitat may disturb the wintering birds as they

occupy most of the wetland being large in number. However, this impact would be

temporary and insignificant for survival of species as they will have the choice to settle

in neighbouring wetlands on Indus and nearby surface water bodies.



Mammals

The status of mammals including ungulate i.e. Hog deer is very poor in suitable

habitat within the project area. Their hunting will not be permissible being protected

under the provisions of SWPO, 1972. Other mammals like Asiatic jackal, Indian

porcupine, gerbils and jirds are quite common and very adaptive.

The residual impact of long duration activities of mammalian fauna may be

significant. The movement of vehicular transport, presence of personnel, exploration

and development activities may disturb the mammals, including burrowing taxa. Such

disturbance during mating and breeding season may seize or reduce the reproduction

of mammals as they require privacy and convenient protected places. Any activity

close to this area can potentially disturb the shy animals and may cause migration

from the area. The aspects of the proposed exploration and associated development

activities that may disturb the wildlife include presence of people in the area, noise

and movement of vehicles and machinery, physical damage to the habitat (breeding

sites, resting places, and grazing areas), blockage of access to escape terrain and

existing water resources. Careful planning and management of activities can avoid all

of the above impacts. The mitigation measures presented in the following section can

reduce the impact to acceptable level.

Reptiles

It is expected that reptiles will be displaced from close vicinity of proposed exploration

and associated development project activities but at the same time, project activities

will create hiding places for snakes and other reptiles. However, owing to the large

and wide spread population size of these reptilian species and the large area otherwise

available to them, insignificant or very less effect of the proposed project on reptiles

may occur. Mortality of reptiles during construction or due to road travel will be

avoided by adopting mitigation measures like speed control and restricting night

driving. In general all mitigation measures suggested at the end of this section will

ensure that wildlife species are protected and not adversely impacted by any means

due to proposed project activities.

b. Residual Impacts

Residual impact on wildlife will be the loss of habitat due to uptake by permanent

project facilities such as the producing wells or establishment of GPF/CPP.



Duration Short Short Short Short


Likelihood Possible Possible Possible Possible







General

Prior to commencement of any activity, awareness trainings will be provided to

contractor’s management and field crew on matters related to the requirements of

the EMP in this regard;

All mitigation measures to minimize noise levels, dust emissions, air emissions,

and waste management required by the EIA will be adhered to;

Food wastes will not be disposed of in the open. Food wastes collected in waste

segregation units will be disposed of according to waste disposal procedure on a

regular and strict basis as advised by the UEPL’s Rep;

Construction work near areas which show reptile populations will commence after

a soft start up and will be randomly monitored;

Hunting, fishing, feeding, harassment, killing or trapping of wildlife will not be

allowed;

Vehicles speed on access roads will be controlled to avoid incidental mortalities of

reptiles. Any such incident will be reported to the UEPL’s Rep. Vehicles speed will

be randomly monitored;


Cutting of trees/bushes will be avoided;

Project related camps/facilities should be established outside the environmental

sensitive areas;

Movement of all project personnel will be restricted to work areas;

Movement of project vehicles will be restricted only to the project access road or to

routes approved by the UEPL’s Rep;

Night travelling will only be done in case of emergency after getting approval

from UEPL’s Rep;


during the operation; and

Blasting, construction or drilling activities will not be performed in Indus River.

Seismic, Drilling, Construction of GPF/CPP and Flow Lines

Land uptake by seismic camps, seismic lines, well sites, campsites, GPF/CPP and

access roads will be minimized;

Clearing of RoW for access tracks & flow lines will be kept to the minimum;

The total duration of seismic, construction and drilling will be minimized by good

management practices;



Lights used at the well sites, campsites and project related facilities will be kept to

the minimum required;

Flaring during well testing will be done within enclosed ground burning flares

rather than elevated flares, to minimize light, heat radiation and noise levels; and

The duration and intensity of flaring at GPF/CPP will be kept to the minimum

required.



Socioeconomic, Cultural and Archaeological Environment

All development initiatives give rise to secondary impacts that affect socioeconomic

receptors in the project area. Socioeconomic impacts vary from project to project and

are not easily quantifiable. These are consequences of project activities on the human

population that alter the ways in which people live, work, interact, relate to one

another, organize to meet their needs and generally exist as members of society.

These also include more long‐term impacts such as cultural impacts involving changes

to the norms, values and beliefs that guide and rationalize their cognition of

themselves and their society. In the past socioeconomic impacts of large development

projects were mitigated through monetary compensation, or were altogether ignored.

However, the importance of these impacts has been recognized and it is very strongly

felt that impacts on communities’ cultural activities, local practices and day‐to‐day

activities have far reaching impacts on their psychological, emotional and social

wellbeing, whereby having an effect on their quality of life. Further to above,

utilization of any resources that are in possession of local owners shall be

appropriately compensated as per mutual agreement of both parties. In case of any

damage during company’s activities, matter shall be resolved mutually. This section

identifies, assesses and proposes mitigation for potential impacts of the project on key

parameters which define the wellbeing of the communities.


Sustenance income

o Leasing of private lands

o Sharing of water sources

o Uptake of livestock grazing areas/effect on mobility of local herdsmen and

potential for loss of livestock due to road accidents

o Effects on local businesses

Drinking water

o Sharing of local domestic water resources

Employment

o Distribution of employment opportunities during construction and operation

phase, subject to availability of local resource as per UEPL required

competency

Health

o Effect on health of local communities due to project wastes and dust emissions

Education

o Increased or reduced emphasis on education due to the project

Safety and Security



o Potential for road accidents, conflicts with locals and safety of local employees

Mobility and transportation

o Ease in mobility and transportation

Culture and religion

o Damage to cultural, archaeological or religious sites

Potential issues related to sustenance incomes have been assessed below:

Leasing of Private Lands

Land might have to be leased or acquired for seismic camp/s, seismic lines, well sites,

rig campsites, access tracks, construction campsites, GPF/CPP and RoW of pipelines.

Land for the project activities shall be leased as per local regulations and according to

mutual consent and deliberations of both parties.

Sharing of Water Resources

The project water usage will not affect the accessibility of locals to the water source in

the long or short term. Water should not be extracted from the shallow local reservoir

and the local water should only be used after ensuring that the abstraction process will

not result in any water shortage for the locals. New UEPL wells may be installed to

abstract water from the deep aquifer.

Uptake of Livestock Grazing Area/Effect on Mobility of Livestock Herds/Potential for

Loss of Livestock due to Road Accidents

The project will cover livestock grazing areas. Compared to the total available grazing

area, the uptake by the project will be insignificant and will not have any measurable

significant impacts. Project vehicles will follow safe speed limits, especially on seeing a

livestock herd near the road, to avoid any road accidents.

Effects on Local Businesses

Local business (such as shops and tea stalls) will experience a rise in sales as junior

level project staff and local employees will purchase items of general use from shops

and will patronize local tea stalls and eateries on a regular basis. However, it must be

noted that the impact so created will be of short‐term nature owing to the larger

workforce required during the construction phase than the operation phase of the

project.

Employment

Opportunities for wage labour in the project area are very few. As a consequence the

expectations of local residents in relation to employment during the project

(construction phase) will be high. Core activities of seismic, well sites, GPF/CPP and

pipeline construction require skilled and trained labour force, which is marginally

available in the area. However, the project will also, to a great extent, require the

services of unskilled workforce. All unskilled and some semi‐skilled workforce should



be hired equitably from within the local communities and the different tribes in the

area keeping in view of local regulations and company’s policy.

Health

Communities that are located close to the seismic camps, well sites, access roads,

GPF/CPP and pipeline routes will be exposed to dust emissions, gaseous emissions

from the well sites and any incidental spillage of fuel or oils. If the mitigation

measures relating to the control of dust emissions, oil or fuel spills and project wastes

are followed no impacts will occur. Local complaints of dust emissions and gaseous

emissions from rig sites and GPF/CPP will be noted and addressed immediately.

Safety & Security

The operations may affect the safety and security of the inhabitants of the areas in the

following ways: issues of road safety, conflicts between residents and the project

contractors and issues pertaining to the carriage of fire arms on the site. Community

sensitive project planning and implementation as prescribed through the

recommended mitigation measures will minimize the occurrence of any such impacts.

Disturbance from Noise

Seismic camps, construction camps, well sites and surface production facilities e.g.

GPF/CPP, manifolds or EWT must be located more than 300 m from communities. As

per assessment done in the section for physical environment no effect of the project

noise will occur on the local communities if the mitigation measures recommended

controlling the effect of noise are adhered with.

Mobility & Transportation

The project activities may affect mobility of local women, especially during the

construction phase of the project. Project personnel will be given gender sensitization

briefings and will be instructed to respect local norms and culture, particularly in

relation to the womenfolk. In connection to the usage of the access track by the women

of the area, they will not be restricted in any way and will be given due right to

crossing the road in pursuit of the daily chores, such as fetching water and fuel wood.

Community Grievances

It is very much possible that in spite of adhering to all mitigation measures, some

community grievances may arise during the construction and operation phase of the

project. Those grievances should be duly considered and addressed by the concerned

authorities in United Energy Pakistan Limited.

Archaeological, Cultural and Religious Opportunities

Cultural sites in the form of shrines, mosques and graveyards exist in the project area.

Location of construction campsites, rig sites and route alignment of gas pipeline

should be planned at appropriate distances from cultural sites to avoid damage to

access of local communities (especially woman) to these sites. There are no notified



archaeological sites in the project area. However, there are several graveyards and

other areas of cultural interest in the Kotri North Block.

b. Residual Impacts

Residual impact on socioeconomic, culture and archaeological environment will alter

the ways in which people live, work, interact, relate to one another, organize to meet

their needs and generally exist as members of society due development initiatives.



Duration Short Short Long Short


Likelihood Unlikely Unlikely Unlikely Unlikely





Project contractors and field staff shall be taken through a Community and

External Affairs Induction program before execution of project activities;

Local sources of drinking water will not be over‐exploited;

The access roads will be watered regularly to minimize dust emissions;

Construction of bypass to all major settlements and where necessary re‐routing the

access roads so that a safe distances is maintained from a settlements;

Drivers will be trained in responsible and safe driving practices; safe speed limits

for vehicles will be followed;

Strict compliance will be observed with UEPL’s HSE guidelines;

Use of local firewood for cooking by project and contractor staff to be prohibited;

Project surface facilities e.g. campsites or well sites will be located at minimum

distance of 300 m from communities thereby, mitigating the effect of noise and

emissions;

Any land acquired and distribution of compensation will be carried out

transparently on fast pace in accordance with the UEPL’s compensation

procedures;

All mitigation measures related to waste management, minimizing air emissions

and noise recommended in the EIA/EMP should be adhered with;

Project staff will respect cultural norms;

All community grievances will be addressed and rectified as appropriate;

All project facilities will be restored according to the standard protocols and

recommendations of the EIA/EMP;



Flow lines and access tracks will maintain a distance of 100 m from cultural,

religious and archaeological sites unless community demands greater distance e.g.

graveyards or mosques;

RoW for flow line should by pass major settlements to maintain safe distances;

The access roads will be watered regularly to minimize dust emissions (if

required); and

Construction of bypass to all major settlements, and where necessary rerouting the

access road so that a safe distances is maintained from a settlement.



8 Stakeholders Consultation

Stakeholders Consultation is a tool used for the purpose of communication, taken to

include; information dissemination, exchanging views, soliciting feedback and

suggestions on issues pertaining to the proposed project, plan future actions, initiate a

needs assessment and identify areas of concern.

During the field survey for this study, meetings were held with the communities

residing within the project area and its surroundings. Goths (village) headmen were

particularly sought after for consultations. The objective of these meetings was to

explore and record their views and concerns for inclusion in project design at the

planning phase.

In the same vein, meetings were also held with community and members of local and

provincial government. All the stakeholders were briefed regarding the proposed

exploration and associated development project activities planned by United Energy

Pakistan Limited in Kotri North Block (E.L. 2568‐21). Their concerns and suggestions

were recorded which are reproduced in this chapter.

Objectives of Stakeholders Consultation

Consultation with stakeholders leads to an overall understanding of the project on the

part of the communities and also gives the proponent a clearer understanding of the

stakeholder’s perspective. Effective public consultation can add substantial value to

the EIA process. The information gained through consultation exercise on the

stakeholders’ concerns, interests and their ability to influence decision‐making helps to

identify key cause of environmental problems.

This can be used to evaluate direct and indirect environmental impacts and assess

short term and long‐term resource use implications. The input from local communities

and affected stakeholders can help evaluating alternatives and strengthen the

management planning by incorporating local inputs and know‐how. These factors

contribute towards improved project implementation sensitized to the human

environment of the area. The objectives of stakeholders’ consultation were to:

Promote better understanding of the proposed exploration and associated

development activities through explaining its objectives and potential positive and

negative impacts;

Identify and address the concerns of all interested and affected stakeholders;

Provide a mechanism to resolve issues identified by communities, before project

plans are finalized and development begins, thereby, avoiding public outcry and

resentment; and

Instill trust between various stakeholders and the proponent to promote

cooperation.



Community Consultations

Community consultations were carried out in the project area through formal and

informal meetings, focus group discussions and in depth interviews especially

covering issues related to ‘gender’. The consultation exercise was conducted in Sindhi.

A local Sindhi speaker (Sociologist), assisted by environmentalist initiated the sessions

by giving a brief, simple and non‐technical description of the proposed project

activities providing an overview of likely positive and negative impacts. This was

followed by an open discussion in which all participants were encouraged to voice

their concerns and opinions. Feedback obtained from the members of the community

were documented and all issues and suggestions raised were recorded in detail.

Through this process the consultant reached out to a wide segment of the population

of the area, whereby actively involving all stakeholders in the decision‐making

process.

All information was imparted to the communities and other stakeholders in such a

manner that their expectations were not unnecessarily or unrealistically raised in order

to avoid any future conflict involving local public, leaders or administrators. Formal

and informal community consultations and focused group discussions were carried

out in almost all visited villages/goths during the field survey for current EIA.

Community’s Concerns & Reservations

All people with whom meetings were held were open to the idea of development in

the project area. No adverse concerns were raised, neither were there any objections to

the project concept. Most people welcomed the idea of project activities sensing a

relative boom in the localized economy particularly employments and provision of

better civic amenities in the area. They envisaged the project activities a short‐term as

well as long term benefit for the communities residing in the area. However, the

communities raised some legitimate concerns. The main concerns common to most

communities are listed below:

Local villagers shall be given priority during employment process especially local

unemployed educated people shall be given preference for technical jobs;

Compensations for land acquired/leased and standing crops should be disbursed

in a transparent manner on fast pace;

Standardized and accessible health facilities to the local communities of the area

should be provided;

Provision of better educational facilities should also be ensured to the children of

the residing communities;

Local cultural norms should be respected; and

Safety and security of the local communities should also be given due

consideration during the proposed project activities.



Other Stakeholders

In addition to holding consultation meetings with communities, meetings with

members of local and provincial government were also deemed essential. All the

stakeholders were given maximum project information verbally, by sharing TORs and

project area maps. Their concerns and suggestions were noted which have been

reproduced below. Proceedings of the meetings with Deputy Director Technical

(Sindh Environmental Protection Agency, Karachi), Range Forest Officer (Sindh Forest

Department, Hyderabad), Deputy Director (Sindh Environmental Protection Agency,

Hyderabad), Chief Engineer (Irrigation Development Sindh, Hyderabad), Technical

Officer (Directorate of Animal Husbandry Hyderabad, Livestock & Fisheries

Department, GoS ), Representative of Institute of Environmental Studies, Karachi

University, Regional Chair (West Asia, Commission on Ecosystem Management, The

World Conservation Union – IUCN, Zoology Department, Karachi University) and

Coordinator Marine Program (Worldwide Fund for Nature, Karachi). The remaining

meetings which were conducted consisted primarily of information collection and

dissemination. A complete list of these stakeholders consulted is provided in Table 8‐

1.

8.4.1 Deputy Director, Sindh Environmental Protection Agency, Karachi

HPK’s EIA team also paid a customary visit to meet Mr. Imran Sabir, Deputy Director

(Technical) at his Karachi office. Mr. Sabir was informed about the proposed

exploration and associated development activities with the help of prospective area

map. It was briefed to Mr. Sabir that United Energy Pakistan Limited is operator of the

lease with JV partners i.e. PPL and AROL and have also conducted environmental

assessments in the past for previously conducted exploration and development

activities. Mr. Sabir expressed much interest in briefing and provided his following

valuable suggestions:

As the project area lies in forest protected areas hence, Sindh Forest Department

(SFD) must be taken on‐board before and during the proposed project activities in

the leased area;

No Objection Certificate (NOC) from the relevant stakeholders (other than Sindh

EPA) must be obtained before commencement of project activities;

All applicable laws and regulations shall be complied during the proposed project

execution in addition to best industrial guidelines ensuring no or least harm on the

physical, biological and socioeconomic environment of the area;

In addition the SFD, local administration should also be taken on‐board during the

execution of the project activities to avoid social conflicts;

Appropriate offsets should be provided from sensitive environmental features e.g.

core wildlife areas, archeological sites, settlements etc. during the proposed project

activities;



Project specific Waste Management Plan should be developed for both domestic

and operational wastes and implemented with true spirit;

Local environmental protection department should also be consulted to improve

the environmental performance of the proposed project; and

Contamination of local water resources shall be strictly avoided during the project

activities and water conservation measures shall be taken during the entire course

of the operation.

Mr. Sabir further informed that when the EIA report would be officially submitted to

Sindh Environmental Protection Agency, it would be reviewed in detail and

comments will be addressed at that stage. EPA guidelines for carrying out impact

assessment are also crucial.

8.4.2 Range Forest Officer, Sindh Forest Department, Hyderabad

A formal consultation meeting was conducted with Mr. Bakht Hussain Jatoi to discuss

the environmental issues related to the proposed exploration and associated

development activities and their potential environmental impacts. Details of proposed

project activities and the prospective areas were briefed to Mr. Jatoi with the help of

maps. Mr. Jatoi briefed that agriculture has been stopped in the forest’s land as per

directions issued by the respected Supreme Court of Pakistan. He also explained the

jurisdiction of Forest Department and authoritative role for conduction of

development activities in jurisdiction of Forest Department. Mr. Jatoi also explained

the mechanism for obtaining NOC from the department and other legal obligations

which should be followed/fulfilled before and during the proposed project activities.

Furthermore, he expressed few certain concerns regarding the proposed project which

are discussed as follows:

NOC must be obtained from the department before commencement of project

activities in the area;

Natural habitat loss is a major concern which is anticipated due to proposed

project activities. The operation will certainly disturb the existing biodiversity and

ecosystem of the area therefore, proper mitigation measures should be suggested

to lessen the impacts on the natural existing environment and suggested

mitigation measures should be made part of operational and management

systems;

Deforestation must be avoided by taking appropriate measures;

Trees cutting should be avoided to the extent possible;

Key floral and faunal species of the area should be protected and conserved;

Systems and procedure should be developed for revival and protection of

ecosystem; and

Monitoring of the project related activities and reporting of the non‐conformance

to all concerned with reference to mitigation measures as suggested in the EIA.



8.4.3 Deputy Director, Sindh Environmental Protection Agency, Hyderabad

HPK paid a customary visit to meet with Mr. Abdul Rauf Qureshi, Deputy Director at

his Hyderabad office. He was informed with the help of the project area map about the

proposed project activities and their anticipated environmental impacts which may

arise during the execution of the activities. Later the meeting was also joined by other

officials from Sindh EPA, Hyderabad i.e. Mr. Ali Nawaz and Mr. Zulfiqar Baloch. All

representatives of Sindh EPA appreciated the consultation process and expressed

much interest in the briefing and provided valuable suggestions which are reproduced

below:

All applicable laws and regulations should be complied with during the proposed

project execution in addition to best industrial guidelines ensuring no or least

harm on the biological, physical and socioeconomic environment of the area;

As the project activities also fall in reserved forests’ boundary therefore, Sindh

Forest Department must be taken on‐board before and during the proposed project

activities;

Restoration of exploration and production sites is becoming nuisance and causing

environmental degradation hence, restoration of project sites must be ensured by

the proponent and Sindh EPA can be taken on‐board for the purpose;

As the project activities are planned in forest protected area with good diversity of

wildlife therefore, every effort should be made to protect the natural existing

environment;

Construction or blasting should not be performed in main body of Indus River;

Community development work in area focusing lower class suffering from the

enduring education, poverty, unemployment and social underdevelopment should

be carried out;

Vegetation clearing must be avoided and minimized to avert the biodiversity loss;

and

Contamination of soil and groundwater must be avoided by taking appropriate

mitigation measures.

Mr. Qureshi further informed that public participation should be ensured during the

EIA process. Sindh EPA once receive the EIA, comments will also be shared with the

proponent at that stage.

8.4.4 Technical Officer, Directorate of Animal Husbandry, Hyderabad

Member of EIA team also visited to meet Dr. Abdul Manan (Technical Officer,

Directorate of Animal Husbandry, Livestock and Fisheries Department, GoS) and

briefed about the proposed project scope and prospective area with the help of maps.

The purpose to carry out this meeting was to obtain the detailed information on the

livestock of the area, proposed exploration and development activities and their

potential impacts on the livestock which is a major source of income and social



security for communities residing in leased area. Dr. Manan briefed about the common

diseases for domestic animals which mainly includes goats, sheep, cows, buffalos,

donkeys and horses. During discussion Dr. Manan highlighted the importance of

global warming and its effects on domestic & wild animals. Impacts of pesticides and

chemicals used by the locals in agriculture fields were also discussed due to their

effects on growth and mortality rate of domestic animals. Dr. Manan also informed

that, in case of any disease outbreak (domestic or wild) in their jurisdiction,

Directorate takes the initiative to protect the domestic livestock and even wildlife. He

appreciated the stakeholder’s consultation process and his major concerns and

suggestions were as follows:

Zoning mechanism should be adopted for protection of livestock of the area.

Livestock saturated zones should be avoided to the extent possible;

Available water reservoirs should not be damaged or over exploited by the

proposed project activities;

Flaring should be minimized particularly during well testing and production

operations;

Controlled use of chemicals should be ensured to avoid the impact on locals

animals;

Veterinary Hospital with provision of complete facilities including Vet Officer (for

timely identification and rectification of project’s adverse impacts on the livestock

of the area), Mobile Unit and sufficient budget etc. was strongly recommended;

Every effort shall be made for protection of natural habitats of the area; and

Vegetation clearing shall be kept to the minimum required particularly range

lands.

8.4.5 Chief Engineer, Irrigation Department, Hyderabad

A formal consultation meeting was also carried out with Mr. Amjad Pervaiz Dawach

to discuss the environmental sensitivities related to the proposed exploration and

associated development project activities focusing the existing irrigation network in

the area. Details of the proposed activities and prospective areas was briefed to Mr.

Dawach with the help of maps. Furthermore, he expressed certain concerns regarding

the project activities, which are indicated below:

As the proposed project activities will also fall in the area where irrigation network

exits therefor, appropriate mitigation measures should be suggested to avert any

damage to existing irrigation network;

All applicable laws and regulations with respect to irrigation and drainage should

be complied with;

Vegetation clearing must be avoided and minimized particularly along the banks

of the existing irrigation network; and



Water abstraction for irrigation network should be done with the prior approval of

the department.

8.4.6 Institute of Environmental Studies, Karachi University

A formal consultation meeting was also carried out with Prof. Dr. Moazzam Ali Khan

to share project scope and to discuss the potential environmental issues related to the

proposed project activities planned by United Energy Pakistan Limited in Kotri North

Block (E.L. 2568‐21). As the institute has active participation in advisory role to various

agencies and departments on environmental matters, therefore considering a basic

stakeholder it deemed necessary to take Institute on‐board during the assessment

process. Details of proposed exploration and associated development activities with

respect to prospective area was briefed to Dr. Khan with the help of maps. He is an

erudite, outspoken and well‐informed personality about the environmental scenarios

in Sindh. Furthermore, he expressed some certain concerns regarding the proposed

project activities, which are indicated below:

Restoration of project working sites should be ensured after successful completion

of any segment of the proposed project;

There is need to cover all physical, biological and socioeconomic aspects of the

project area in detail;

Initiatives taken under CSR should be audited through independent auditing

mechanism;

Noise and dust emission which will be generated due to proposed project activities

should be controlled and mitigated as appropriate. Regular noise and ambient air

monitoring shall also be carried out as per all applicable laws;

Sustainable use of water should be ensured by taken prudent water conservation

measures during the entire phase of the proposed project;

A comprehensive Waste Management Plan should be developed for the project

which must cover all sorts of waste (liquid & solids) and followed on strict basis;

Safe and environmentally friendly provisions should be recommended in the EIA

report;

Environmental enhancement should also be focused which is usually ignored;

There should be arrangements for Independent Environmental Monitoring (IMC)

of the project related activities and reporting of all non‐conformances with

reference to EMP to Sindh EPA on strict and regular basis.

Dr. Khan further emphasized on abidance of all applicable laws and regulations

during the proposed project execution. In addition, best industrial guidelines shall also

be practiced ensuring no or least harm to the existing environmental conditions of the

area.



8.4.7 Regional Chair, Commission on Ecosystem Management, IUCN

A formal consultation meeting was also held with Prof. Dr. Muhammad Zaheer Khan

to discuss the proposed exploration and associated development project activities and

their potential impacts on the diverse wildlife of the Kotri North Block and its

immediate vicinities. Dr. Khan is Regional Chair, West Asia, Commission on

Ecosystem Management, The World Conservation Union – IUCN. Dr. Khan briefed

about ongoing research projects in wildlife protected areas of Sindh region. Details of

proposed project with sequence of events was briefed to Dr. Khan with the help of

maps. The outcome of the meeting is reproduced below:

As the project area lies in reserved forest areas hence, Sindh Forest Department

must be taken on‐board during the execution phase of the project;

All appropriate and practical mitigation measures should be suggested and taken

to protect and improve the existing natural environment of the area;

Vegetation clearing should be avoided as much as possible;

Most advanced and environment friendly techniques & technologies should be

employed/used during the execution of the project activities posing least

environmental disturbance;

Ambient air quality should not be deteriorated by the proposed project activities;

Local fuel wood shall not be used by the parties working in the project area; and

Range lands should also be protected during the execution of the proposed

exploration project activities.

8.4.8 Coordinator Marine Program, Worldwide Fund for Nature, Karachi

Members of EIA team also visited World Wildlife Fund for Nature’s (WWF) office in

Karachi to meet with Mr. Muhammad Moazzam Khan (Technical Director) but due to

his unavailability Mr. Jawad Umer Khan represented WWF in the consultation

meeting. Details of proposed exploration and associated development activities and

the prospective area was briefed to Mr. Khan with the help of maps. Mr. Khan openly

discussed his suggestion and reservations regarding the proposed activities in Kotri

North Block, which are discussed as follows:

All applicable laws and regulations should be complied with true spirit;

As the project area lies within the forest protected area hence, Forest Department

should be taken on‐board before and during the proposed project activities;

All adjacent areas to Indus River should be treated as environmentally sensitive

and fragile;

Activities should be planned in such a way that breeding seasons of key wildlife

species of the area are not disturbed;

Potential migration of wildlife due to operational reasons e.g. noise should be

closely monitored and take appropriate actions thereon;



Restoration of project sites/facilities should be ensured after successful completion

of project activities;

General public participation should be ensured during the assessment process and

their reservations and concerns should be addressed appropriately; and

Independent monitoring needs to be ensured during the execution of the proposed

exploration and associated development project activities.

8.4.9 Other meetings

Meetings were also held particularly with villages’ heads to disseminate information

regarding the proposed exploration and associated development activities. None of

the stakeholders consulted during the EIA consultation process showed any

uneasiness or apprehensions about the proposed project. Important recommendation

from villages’ heads and local elders are as under:

Locals should be preferred for employment;

The local cultural norms should be respected; and

The proponent should initiate comprehensive community development work in

the project area.

Key Findings and Issues

Biodiversity of area particularly should be protected by taking all concerned on‐

board;

Most of the communities and to some extent the local influential people are not

concerned over the environmental issues. They are mostly interested in getting

maximum benefits in terms of employment, local market boom and community

development programs;

People have hopes that the company would employ locals during its operations.

The biggest aspiration of the locals is getting one thing i.e. ‘employment’;

People have hopes that the company would develop roads and improve the

infrastructure of area; and

Compensations for land acquired/leased and standing crops should be disbursed

in a transparent manner on fast pace.



Table 8‐1: List of Stakeholders Consulted during EIA

No. Representative Organization/Department Designation

1. Mr. Mohammad Imran Sabir Sindh Environmental Protection

Agency, Karachi

Deputy Director

(Technical)

2. Mr. Bakht Hussain Jatoi Sindh Forest Department RFO, Hyderabad

3. Mr. Abdul Rauf Qureshi Sindh Environmental Protection

Agency, Hyderabad

Deputy Director,

Hyderabad Region

4. Mr. Ali Nawaz Sindh Environmental Protection

Agency, Hyderabad

Field Inspector,

Hyderabad

5. Mr. Zulfiqar Baloch Sindh Environmental Protection

Agency, Hyderabad

Field Inspector,

Hyderabad

6. Dr. Abdul Manan

Directorate of Animal

Husbandry, Hyderabad,

Livestock and Fisheries

Department, GoS

Technical Officer

7. Mr. Amjad Pervaiz Dawach Sindh Irrigation Department Chief Engineer

8. Prof. Dr. Moazzam Ali Khan Institute of Environmental

Studies, University of Karachi Professor

9. Prof. Dr. Muhammad Zaheer Khan

University of Karachi/ West

Asia, Commission on Ecosystem

Management, The World

Conservation Union – IUCN

Professor/Regional

Chair

10. Mr. Jawad Umer Khan Worldwide Fund for Nature

(WWF) Pakistan

Coordinator Marine

Program



Photographs: Consultation Record

Photograph 8‐1: Consultation at Goth Sufan

Bacho

Photograph 8‐2: Consultation with Mr. Imran

Sabir, Sindh EPA

Photograph 8‐3: Consultation with

Representatives of Sindh EPA, Hyderabad

Photograph 8‐4: Community consultation at

Goth Haji Shabu

Photograph 8‐5: Consultation with locals at

Goth Khuda Baksh

Photograph 8‐6: Consultation session with

RFO, Hyderabad



Photograph 8‐7: Consultation with Chief

Engineer, Irrigation Department, Hyderabad


Goth Bachal Dehta

Photograph 8‐9: Consultation at Goth Bakhshia

Mari

Photograph 8‐10: Consultation with Dr. Abdul

Manan


Prof. Dr. Moazzam Ali Khan


Goth Aliabad



Photograph 8‐13: Locals are being consulted at

Goth Karim Deno


Prof. Dr. Muhammad Zaheer Khan

Photograph 8‐15: Consultation session Mr.

Jawad Umer Khan (WWF Pakistan)


Goth Jaitharo


Goth Haji Ishaq

Photograph 8‐18: Consultation with locals at

Goth Gulshan‐e‐Shahbaz



9 Conclusion

Pakistan is an energy deficient country, a large part of the country’s energy demands

are met through imports which is a severe burden on country’s foreign reserves and

economy. There is, therefore, a vital need to explore for additional energy reserves. On

the other hand, Pakistan is struggling to overcome a severe energy crisis that is

directly and indirectly affecting all sectors of economy. The oil import bill of the year

2017‐18 reached US $ 12 billion, creating a huge burden on the foreign exchange

reserves.

Oil & gas exploration and production have the potential to transform and can help to

revolutionize the energy mix existing within the country and can significantly

improve Pakistan’s economy. However, if country makes concreted and dedicated

efforts, the same obstacles may be transformed into opportunities. It is essential to act

now, and to develop our oil and natural gas resources, especially in the wake of acute

shortages. Moreover, the report also discusses the generation of economic activity

through oil and gas exploration and the possible benefits for thousands of Pakistanis

who are in need of sources of sustainable livelihoods.

Whereas the proposed O&G exploration and associated development activities in

Kotri North Block (E.L. 2568‐21) will help towards achieving this objective. The

environmental study of the project area requires that potential environmental effects

due to the proposed project are evaluated, mitigation measures required to minimize

or obviate these impacts are assessed, implemented and monitored. Any residual

impacts are assessed for their significance.

These requirements have been addressed in this Environmental Impact Assessment

(EIA) study, which has covered in detail the following:

The proposed project activities;

Environmental baseline conditions of the project area;

Legislative requirements related to the proposed project;

Potential environmental effects of the proposed project activities on physical,

natural or biological and socioeconomic receptors; and

Mitigation and monitoring measures that will help in avoiding or minimizing

these impacts.

The operation will have a visible positive impact on the socioeconomic conditions of

the local residents of the area, manifested as increased local businesses, local

employment generated during the operations, increased mobility and increased

income due to disbursed money.

On the other hand, conservation of biodiversity in a sustainable way is also vital for

future of any country. Pakistan has taken practical steps towards protection of

environment in steady manner. Many efforts have been made for protection and



improvement of environmental biodiversity to reach the international standards

however, there are still too many gaps and differences due to lack of proper

management activities. Therefore, it is necessary to take serious actions for effective

management of protected areas. Enforcement of existing laws in more effective mode,

effective management plans, community involvement, engagement of more experts to

achieve conservation targets, funding and recommendations of the EIA will ensure

that protected areas and its existing environment is not adversely affected due to

proposed project activities.

This EIA concludes that the proposed exploration and associated development project

will not lead to adverse environmental impacts of such nature or magnitude if the

mitigation measures for all impacts identified here are implemented as per the

prescriptions of the EIA. Similarly, no significant and unacceptable changes in the

baseline environmental conditions of the project area will occur. Additionally, careful

implementation of the project specific Environmental Management Plan (EMP) will

ensure that environmental impacts are managed and minimized with project

proponent meets all legal & statutory requirements.


List of References

Ahmad, M. F. & Ghalib, S.A., 1975: A Checklist of Mammals of Pakistan. Ref. Zool

Sur. Pak. VII (1 & 2): 1‐34.

Ali, S. I. & Qaiser M., 1995‐till to date: Flora of Pakistan Fascicles. Karachi.

Ali, S., 1996: The Book of Indian Birds (Twelfth edition) Bombay Natural History

Society & Oxford University Press, Mumbai.

Alam, S.M., Naqvi, M.H. 2003. Water Scenario and Pakistan. NIA, Tandojam, Pakistan.

Government of Sindh., Sindh Environmental Protection Act., 2014.

Boyd, C.E. 2000. Water Quality: An introduction. Kluwer Academic Publishers Boston,

MA, USA. Burbank, D.W. 1982.

Busnel, R.G. and John Fletcher (eds.), 1978: Effects of Noise on Wildlife. New York:

Academic Press.

Convention on International Trade in Endangered Species of Wild Fauna and Flora

(CITES)., 1973.

Council of Environment Quality., USA 1978.

Department of Natural Resources., 1990: Statewide Order 29 – B, State of Louisiana.

Dharma Kumarsinhji, K. S., 1959: A field guide to big game census in India. Leaflet

No. 2. Issued by the Indian Board for Wildlife.

Dunbar brander, A.A., 1931: Wild Animals of central India, Edward Arnold, London.

E&P Forum, 1994: Guidelines for the Development and Application of Health, Safety

And Environmental Management Systems, Report No. 6.36/210, Exploration And

Production Forum July.

Ellerman, J.R. & T.C.S. Marrison‐Scott., 1951: Checklist of Palearctic and Indian

Mammals, 1758 to 1946. British Museum (Natural History), London.

EUAD/IUCN., 1992: The Pakistan National Conservation Strategy, Environment and

Urban Affairs Division, GoP and The World Conservation Union.

Fukushi, K., Kurisu, F., Oguma, K., Furumai, H., Fontanos, P. 2010. Southeast Asian

water environment 4, IWA publishing, London, UK.

Giles, H.R., 1971: Wildlife Management Techniques (Vol. 2). The Wildlife Society,

Washington, D.C.

Government of Pakistan., 1923. The Mines Act.

Government of Pakistan., 1949. Pakistan Petroleum (Production) Rules, Ministry of

Petroleum and Natural Resources, GoP.

Government of Pakistan., 1975. The Antiquities Act.


Government of Pakistan., 1986: Pakistan Petroleum (Exploration and Production)

Rules, Ministry of Petroleum and Natural Resources, GoP.

Government of Pakistan., 1997 a: Guidelines for Public Consultation: Draft, Pakistan

Environmental Protection Agency, GoP.

Government of Pakistan., 1997 c: Guidelines for Preparation and Review of

Environmental Reports: Draft, Pakistan Environmental Protection Agency, GoP.

Government of Pakistan., 1997 d: Policy and Procedures for Filing, Review and

Approval of Environmental Assessments, Pakistan Environmental Protection Agency

(September).

Government of Pakistan., 1997 e: Sectoral Guidelines – Oil and Gas Exploration and

Production, Pakistan Environmental Protection Agency (December).

Government of Pakistan., 2018. Pakistan Energy Year Book 2017‐18. Islamabad:

Ministry of Petroleum and Natural Resources, Hydrocarbon Development Institute of

Pakistan.

Government of Pakistan., Pakistan Environmental Protection Act., 1997.

Government of Pakistan., The Pakistan Penal Code., 1860.

Grimmet, R.Inskipp, C. & Inskippe, T., 1998: Birds of the Indian Subcontinent.

Halcrow Pakistan., 2004: Sectoral Guidelines for Upstream Petroleum Sector –

Onshore, Pakistan Petroleum Exploration & Production Companies Association

(PPEPCA)

Halcrow Pakistan., 2018: Environmental Impact Assessment (EIA) for 3D Seismic and

Drilling of Two Wells in Sukkur Block (E.L. 2768‐9), Sindh.

Halcrow Pakistan., 2019: Environmental Impact Assessment (EIA) for 3D Seismic

Survey and Drilling of Three Wells in Taung Block (E.L. 2567‐12), Sindh.

Halcrow Pakistan., 2017: Environmental Impact Assessment (EIA) for Drilling and

Associated Development Activities in Badhra Development & Production Lease,

Sindh.

Halcrow Pakistan., 2010: Environmental Impact Assessment (EIA) for Exploration

Activities in Kotri, Kotri North and Jungshahi Blocks.

Halcrow Pakistan., 2010: Initial Environmental Examination (IEE) for Exploration

Activities in Kotri, Kotri North and Jungshahi Blocks.

Halcrow Pakistan., 2017: Initial Environmental Examination for 3D Seismic Activities

in Zamzama Development & Production Lease.

Hompland, Gary et al., 1985: ʺElk Responses to Simulated Mine Disturbance in

Southeast Idaho.ʺ Journal of Wildlife Management. 49(3)751‐757.

IOGCC., The International Oil and Gas Compact Commission Guidelines on Disposal

of E&P Waste.


IPIECA in cooperation with E&P Forum., 1997: London.

IUCN., 1997: Biodiversity Action plan for Pakistan: First Draft, the World

Conservation Union.

IUCN., 1998: Draft Model Provincial Wildlife (Protection, Conservation and

Management) Act, the World Conservation Union.

IUCN., 2000: Red List of Threatened Animals.

IUCN., Guide lines on Oil and Gas conservation Commission, Rules and Regulations.

Jefferies, M., 1997: Biodiversity and Conservation London & New York.

Khan, F.K. 1991. A geography of Pakistan; environment, people and economy. Oxford

University Press. Karachi, Pakistan.

Larry W. Canter., 1996: Environmental Impact Assessment, McGraw Hill Publications.

Levin, D. A., 2000: The origin, expansion and demise of plant species. Oxford.

Lydekker, R., 1924: The game animals of India, Burma, Malaya and Tibe. Rowland

Word Ltd., London, 416 pp.

Malik, K. A., 1984: Palmae in Nasir, E. & Ali, S. I. (eds.) Flora of Pakistan. Karachi, pp

1‐33.

Miller, J.N., Miller, J.C. 2000. Statistical and chemometrics for analytical analysis.

Prentice Hall, California, USA.

Model Petroleum Blocks Agreements., 1994.

Munsell Color Company USA, 1954: Munsell Soil Colour Charts.

Nasir, E. & Ali, S. I., 1972‐1995: Flora of Pakistan Fascicles, Karachi, Islamabad.

NCS., 1972, National Conservation Strategy.

Oil and Gas (Safety in Drilling and Production) Regulations., 1974.

Population Census Organization., 2000: Government of Pakistan, 1998 District Census

Report of Dadu, Population Census Organization (PCO), Statistics Division,

Islamabad.


Report of Hyderabad, Population Census Organization (PCO), Statistics Division,

Islamabad.


Report of Thatta, Population Census Organization (PCO), Statistics Division,

Islamabad.

Prator, S.H., 1965: The Book of Indian Animals. Bombay Natural History Society,

India. 322 pp.

Raunkiaer, C., 1934: The life forms of plants and statistical plant geography, Oxford.


Ref. Minton, S.A., 1996: A contribution to the Herpetology of Pakistan.

Regulation of Mines and Oil fields and Mineral Development (Government Control)

Act., 1948.

Roberts, T.J., 1991: The Birds of Pakistan. Vol. 1 (Non‐Passeriformes), Oxford

University Press, Karachi.

Roberts, T.J., 1992: The Birds of Pakistan. Vol.2. Passeriformes. Oxford University

Press, Karachi.

Roberts, T.J., 1997: The Mammals of Pakistan. Oxford University Press, Karachi.

Schemnitz, D.S, 1990: Wildlife Management Techniques Manual. Fourth Edition:

Revised. The Wildlife Society. Washington D.C.

Scott., D.A.(E,D), 1989: A directory of Asian Wetlands. IUCN, Gland, Switzerland and

Cambridge, U.K.

The Convention on Conservation of Migratory Species of Wild Animals., 1979.

The Convention on Wetlands of International Importance, Ramsar., 1971.

Ticehurst, Claude B., 1923: The birds of Sind, Ibis: Jan., Part 3 pp. 1‐43.

USAID, 2013. Supplemental Report on Climate Change, Kurram Tangi Dam

Construction, usaid.gov/pdf‐docs/PA00KB12.pdf

UNIDO, 2000. Industrial Policy and the Environment in Pakistan: Industrial Policy

and Environment.

World Bank, United Nations Industrial Development Organisation and the United

Nations Environment Program., 1998: Pollution Prevention and Abatement

Handbook: Towards Cleaner Production. Environment Department, the World Bank,

United Nations Industrial Development Organisation and the United Nations

Environment Program.

World Bank., 1999: Environmental Assessment‐Operational Policy 4.01. Washington,

DC, USA.


OCTOBER 2019 HPK

Appendix A Environmental Management Plan


OCTOBER 2019 A-1 HPK

Appendix A – Environmental Management Plan

A.1 Introduction

United Energy Pakistan Limited (UEPL) intends to carry out exploration and

development activities in Kotri North Block (E.L. 2568‐21). These activities range from

2D/3D seismic surveys, drilling of exploration/development wells, laying of flow line/s

from producing wells to the hydrocarbons gathering system/processing facility,




decommissioning and site restorations.

This Environmental Impact Assessment (EIA) for the proposed project activities in

Block (E.L. 2568‐21) has identified potential impacts that are likely to arise. The EIA

has examined in detail both negative and positive impacts of each stage of the

operation from the initial establishment of the logistics facilities to demobilization and

restoration. Where adverse impacts have been identified, the EIA has recommended

practical mitigation measures. These mitigation measures include management and

monitoring practices, alternative technologies, physical controls or compensation. The

mitigation measures proposed are based on a good understanding of the sensitivity

and behaviour of environmental receptors within the project area, past experience,

case studies, legislative controls, guidelines and experts’ advices.

For any residual impacts (impacts remaining after applying the recommended

mitigation measures) or for impacts in which there has been a level of uncertainty in

prediction such as the level of disturbance to wildlife, monitoring measures have been

recommended. Advice on monitoring measures required was sought from experts

involved in the EIA and case studies of similar monitoring carried out in other

protected areas in Pakistan.

For the effective implementation and management of the mitigation measures and

monitoring requirements an Environmental Management Plan (EMP) has been

prepared and presented in this section. The EMP satisfies the requirement of the Sindh

Initial Environmental Examination and Environmental Impact Assessment Review

Regulations, 2014 and Pakistan Initial Environmental Examination and Environmental

Impact Assessment Review Procedures, 2000.

A.1.1 Regulatory Approval and Monitoring Mechanism

After getting ‘No Objection Certificate (NOC)’ from Sindh Environmental Protection

Agency (Sindh EPA), United Energy Pakistan Limited (UEPL) will be allowed to

conduct its proposed exploration and associated development activities in Kotri North

Block (E.L. 2568‐21). This EIA report is based on the fact that UEPL will obtain NOC

for the EIA (covering proposed exploration and associated development activities as

described in Chapter 4 of this EIA) from Sindh EPA and will submit the Project



Initiation Report (PIR) for each proposed exploration and development to Sindh EPA

(for information) fifteen days prior to the start of any operation.








forests, now mostly are under cultivation.

All activities which are being planned particularly seismic, drilling, laying of flow line

activities and establishment of processing facility (GPF) within the project area will be

monitored by a team of Independent Monitoring Consultant (IMC). The team will

comprise of activity monitor, wildlife monitor and a wildlife specialists (SWD

representative). Monthly effects monitoring and activity monitoring will also be

carried out according to the monitoring program recommended in the EMP.

A.1.2 Objectives of the Environmental Management Plan (EMP)

The EMP provides a delivery mechanism to address adverse environmental impacts,

to enhance project benefits and to introduce standards of good practice to be adopted

for all project works. The primary objectives of the EMP are:

Outline mitigation measures recommended in the EIA and define the

responsibility and timing for the implementation of these measures;

Develop a monitoring mechanism and identify parameters that can confirm the

implementation of the mitigation measures;

Define roles and responsibilities of the project proponent for the implementation of

EMP and identify areas where these roles and responsibilities can be shared with

other stakeholders; and

Define the requirements necessary for documenting compliance with the EMP and

communicating it to all concerned regulatory agencies.

A.1.3 Methodology

The basic approach to prepare this plan mainly comprise of:

A review of relevant environmental laws, policies, legislations and guidelines;

A review of past environmental studies carried out in Kotri North Block and

immediate concessions;

A review of relevant environmental data in Kotri North Block;

On the basis of past experience gained during the monitoring of similar projects in

relation to O&G exploration and production; and



Consultation with United Energy Pakistan Limited’s staff.

A.2 Legislation and Guidelines

The EIA has discussed national and international legislation and guidelines and their

relevance to the proposed project. United Energy Pakistan Limited shall ensure that

the operation is conducted in conformance to UEPL’s corporate environmental policy,

national legislation and relevant international conventions and that guidance is sought

from national and international guidelines. All relevant legislation, guidelines,

convention and corporate requirements are discussed in Chapter 3 of this EIA. UEPL

shall also ensure that the key project management staffs are aware of these legislation

and guidelines.

The Sindh Environmental Quality Standards (SEQS) specify standards for industrial

and municipal effluents, gaseous emissions, vehicular emissions and noise levels is

provided in Table 3‐1, Table 3‐2 and Table 3‐3 of EIA report. The standards for

ambient air requirements, noise levels and drinking water quality are provided in

Table 3‐4 to 3‐6. International standards for land treatment and on‐site burial of E&P

wastes in unlined pits is provided in Table 3‐7. Table 3‐8 provides the less stringent

criteria set by LSO 29B.

A.3 Organizational Structure with Roles & Responsibilities

A.3.1 Organizational Structure

The proposed project includes the following main organizations:

United Energy Pakistan Limited as the project proponent and owners of the EMP;

The seismic, construction, drilling, laying of flow line, establishment of processing

facility and all other contractors as the executors of the EMP;

Independent Monitoring Consultants (IMC) as the monitors for the execution of

the EMP and effects monitoring; and

Sindh Environmental Protection Agency, Sindh Wildlife Department and Sindh

Forest Department as the regulators.

These organizations will have the following roles and responsibilities during the

project activities.

A.3.2 Roles & Responsibilities

Abovementioned organizations will have the following role and responsibilities

during the proposed project activities.

a. Roles & Responsibilities of United Energy Pakistan Limited (UEPL)

As project proponents, UEPL will be responsible for ensuring the implementation of

the EMP. The HSE (Health, Safety and Environment) Manager will be responsible for

the overall environmental performance during the proposed operations. He will

delegate a representative from UEPL who will have functional responsibilities for



Health, Safety and Environmental (HSE) matters during the project. The UEPL

representative will hold prime responsibility for ensuring that the environmental

performance of the project is in accordance with governing legislations, UEPL’s

corporate objectives and the recommendations of this EIA. UEPL will ensure that the

provisions of the EMP are translated into the contractor’s requirements and that these

requirements are implemented to the full extent.

b. Roles & Responsibilities of Project Contractors

For the proposed project, UEPL will appoint contractors for different field operations.

The contractors will be responsible for implementation of, or adherence to all

provisions of the EIA and the EMP and with any environmental and other codes of

conduct required by UEPL. Overall responsibility for the contractor’s environmental

performance will rest with the person holding the highest management position

within the contractor’s organization in Pakistan. Reporting to their management the

contractor’s site manager will be responsible for the effective implementation of the

EIA and the EMP. The contractor’s HSE officer will have functional responsibilities to

ensure implementation of or adherence to the requirements of the EMP.

c. Roles and Responsibilities of IMC

To fulfil the monitoring requirements within area of operation, UEPL will appoint an

Independent Monitoring Consultant (IMC). The IMC will be responsible for carrying

out monitoring according to the requirements of the EMP. Program Manager of IMC

will be responsible for the management of the IMC field monitors and effects

monitoring team comprising of an activity monitor, wildlife monitor and wildlife

specialist (SWD) which will report to the Program Manager. IMC’s field

representatives will have functional responsibilities to ensure monitoring of the project

activities as per the requirements of the EMP. The IMC will report directly to UEPL

who will then disseminate the IMC reports and findings to Sindh EPA.

d. Roles and Responsibilities of Regulators

In pursuance to the sub‐regulation (2) of Regulation 9 of Sindh Initial Environmental

Examination and Environmental Impact Assessment Review Regulations, 2014 after

receiving the subject EIA from the proponent and issuing the confirmation of

completeness cause to be published in any English or Urdu national newspaper and in

a local newspaper of general circulation in the area affected by the project, a public

notice mentioning the type of project, its exact location, the name and address of the

proponent and the places at which the EIA of the project, subject to the restrictions in

sub‐section (3) of Section 17, can be accessed. The notice will fix a date and time and

place for the Public Hearing for any comments on the project or the EIA.

Sindh EPA, SFD and SWD will monitor compliance with the requirements of EMP of

the project and any additional mitigation measures provided in the NOC for the

project.



A.3.3 Planning & Design of the Operation

a. Design of the Operation

Design of the operation includes the activities detailed in the Chapter 4 of EIA report.

Following approval of the EIA, any changes to the proposed activities will be handled

through the Change Management Plan provided in this EMP.

b. Approvals

Obtaining No Objection Certificate (NOC) from the Sindh EPA will not relieve the

proponent of other legal obligations and hence UEPL and project contractors will

obtain all other relevant clearances and necessary approvals required by the

Government of Pakistan or Government of Sindh prior to commencing the respective

operations.

c. Contractual Provisions

Adherence to the requirements of the EIA and EMP in terms of environmental

mitigation will be required from all project contractors and thus EMP will form part of

their contracts with United Energy Pakistan Limited.

A.3.4 Implementation of the Operation

a. Coordination with Stakeholders

United Energy Pakistan Limited will ensure that coordination with project

stakeholders i.e. Sindh EPA and SFD on environmental and social matters as required

by the EMP are maintained throughout the course of operation. SWD can also be taken

on‐board to improve the biodiversity of the area.

b. HSE Management Systems

United Energy Pakistan Limited and its contractors will ensure that the mitigation

measures mentioned in the Mitigation Management Matrix for the core activities of

seismic, drilling, laying of flow line activities and establishment of processing facility

(Table A‐1, Table A‐2, Table A‐3 and Table A‐4) are adhered to and organizational

HSE Management Systems are implemented during the proposed project. The

contractors will abide by the relevant contractual provisions relating to the

environment.

c. Minimum Distances

The EIA specifies minimum distances to be maintained from environmental features

including communities, water resources, wildlife sensitive areas and archaeological

sites (if encountered) etc. These minimum distances from sensitive environmental

features for project activities are provided in Table A‐5, A‐6 and A‐7. The Contractors

shall ensure that these minimum distances are adhered to during the operation and

are inspected by United Energy Pakistan Limited’s Representative.



d. Monitoring

United Energy Pakistan Limited, contractors of the project and IMC will ensure that

monitoring of the proposed project activities are carried out according to the

monitoring program given in the EMP. An environmental monitoring program is

provided in Section 4 of the EMP. A tentative frequency of monitoring mitigation

measures is provided in Table A‐8.

e. Emergency Procedures

United Energy Pakistan Limited and the contractors will prepare contingency plans to

deal with any emergency situation that may arise during the operation e.g. major oil

spills, medical evacuation and communicate these to the regulatory agencies if

required or inquired.

f. Approvals

The project contractors will be responsible for obtaining all relevant approvals from

IMC such as approvals for waste contractors, water sources, camps’ location and

setup, and others as specified in the Mitigation Management Matrix.

g. Trainings

All contractors engaged in the activities will be responsible for the selection and

training of their staff capable of completing the project activities properly and

efficiently. The contractor with the assistance of IMC will be responsible for providing

trainings to their staff members according to the training program. The training

program is discussed briefly in Section 8.

h. Communication and Documentation

UEPL, IMC and the contractors will ensure that the communication and

documentation requirements specified in the EMP are fulfilled during the entire phase

of proposed project activities.

i. Restoration

United Energy Pakistan Limited will be responsible for the final restoration of work

areas according to the requirements of the EIA.

A.4 Environmental Monitoring

The objective of the environmental monitoring during proposed exploration and

associated development phase will be as follows:

To check compliance of the contractors and UEPL with the EMP by monitoring

activities of the project on a daily basis;

To monitor impacts of the operation in which there has been a level of uncertainty

in prediction such as impacts on wildlife and to recommend mitigation measures if

the impacts are assessed to be in excess of or different from those assessed in the

EIA. The aim will be attained through Effects Monitoring; and



To ascertain residual impacts of the entire course of the operation. This will be

achieved by Post‐Project Monitoring.

To achieve these objectives the following monitoring program will be implemented.

a. Compliance Monitoring

Compliance monitoring will be carried out to ensure compliance with the

requirements of the EIA and to document and report all non‐compliances. The

Mitigation Management Matrix for core activities i.e. Seismic, Drilling, Laying of Flow

Line/Tie‐in/Wellhead Works and Establishment of GPF/CPP are provided in the EMP

will be used as a management and monitoring tool. Inspection may be carried out

using standard checklists provided in the EMP. Activity monitoring will be the

responsibility of all organizations involved in the operation i.e. UEPL, IMC, Seismic,

Drilling and other project executor contractors.

The contractors HSEO will be responsible for monitoring the compliance of their

organization with the relevant EMP requirements. An IMC field monitor will monitor

the contractor’s compliance and will also ensure that during proposed project

activities, a system and plan is in place for effective compliance monitoring. Any non‐

compliance observed by IMC will be recorded in non‐compliance recording forms and

discussed during the daily environmental meeting. UEPL’s Representative will make

regular checks on the contractor’s works, keep records of all non‐compliances

observed during the execution of the project activities and the details of all remedial

actions taken to mitigate the adverse project impacts.

b. Effects Monitoring

IMC field monitor will be responsible to carry out the required effects monitoring

during the seismic, overall construction and drilling activities. A wildlife monitor and

specialists will also accompany him during monthly wildlife effects monitoring

survey.

c. Post‐Project Monitoring

The objective of this monitoring will be to determine the level of residual impacts of

the project activities on physical, biological and socioeconomic receptors of the project

area. The monitoring may be carried out within one month after the end of all

activities in the project area. As part of the post‐project monitoring methodology

restoration of sites will also be checked.

A.5 Communication & Documentation

A.5.1 Project/Activity Initiation Report

Prior to the start of any segment of the proposed exploration and associated

development activities, United Energy Pakistan Limited will inform the Sindh

Environmental Protection Agency (Sindh EPA) about the initiation of the respective

activity and relevant details such as site specific baseline conditions and any changes

from the EIA. The information will be submitted to Sindh EPA in the form of Project



Initiation Report or Activity Initiation Report at least 15 days prior to the start of the

particular activity.

A.5.2 Kick-off Meeting

For proposed exploration and associated development operation, prior to

commencement of work and after setup of the field camp, a meeting will be held on‐

site to discuss implementation of the EMP, show commitment to adhere with the EMP

and check readiness of the contractors to start the project. The meeting will be

attended by relevant management staff from United Energy Pakistan Limited and the

contractors. Sindh EPA, SFD and SWD officials may also be invited to attend the

meeting.

A.5.3 Daily Meetings & Reports

A daily meeting will be held during the proposed exploration and associated

development project activities to discuss the environmental conduct of the respective

operation, non‐compliances noted and their remedial measures. The meeting will be

attended by the UEPL Site Representatives, Contractor’s HSEO and IMC’s Activity

Monitor. The meetings will be recorded in the form of a Daily Environmental Report.

The report will be communicated to the UEPL’s HSE Representatives and senior

members of the contractors. The report will include:

Summary of project activities on that day;

UEPL and contractors environmental representatives present onsite; and

Non‐compliances observed and mitigation measures taken or required.

A.5.4 Monthly Reports

A Monthly Environmental Report (MER) will be prepared by IMC summarizing the

project activities and results of activity and Effects Monitoring. The purpose of these

reports will be to review the performance of the operation by reviewing the number of

non‐conformances and the environmental incidences that occurred during the

reporting period, progress on daily action items and to list recommendations for

additional controls, mitigation measures or monitoring requirements.

A.5.5 Effects Monitoring Reports

The results of effects monitoring surveys on biological, physical and socioeconomic

environment e.g. on wildlife, use of water resources, communities etc. will be

compiled by the Independent Monitoring Consultant in the form of a report. This

section on effects monitoring will be included in the monthly and final environmental

monitoring report. Effects monitoring requirements for proposed exploration and

associated development activities is provided in Table A‐9. The report as a minimum

will include:

Objectives and methodology;

Person(s) involved in the survey;



Areas surveyed:

Results of the monitoring exercise along with raw data collected on field; and

Conclusions on the effects of the project activities.

A.5.6 Social Complaints Register

The UEPL’s Site Representative will maintain a register of complaints received from

local communities and measures taken to mitigate these concerns. All community

complaints received will be sent to the UEPL’s HSE Management for further action.

A.5.7 Change Record Register

All changes to the EMP or the project will be handled through the Change

Management Plan provided in the EMP. These changes will be registered in a Change

Record Register.

A.5.8 Photographic Record

United Energy Pakistan Limited will ensure that a photographic record including the

following is maintained:

All areas used by the project activities; before use, during use and after restoration;

Key non‐compliances; and

Key project activities.

A.5.9 Final Monitoring Report

For each project a final monitoring report will be prepared by Independent Monitoring

Consultant (IMC). The report will include the following:

Introduction;

Details of the project activities;

Natural resources used during the project;

Non‐compliances recorded;

Effects of the project on wildlife, communities and physical resources;

Photographic records;

Approvals provided during the project;

Change management statements;

Trainings;

Conclusions; and

Recommendations for future projects.



A.6 Mitigation Management Matrix

Mitigation Management Matrix for proposed core operations i.e. seismic, drilling,

laying of flow line and establishment/construction of GPF with associated civil and

engineering activities is provided in Table A‐1, Table A‐2, Table A‐3 and Table A‐4.

The Mitigation Management Matrix will be used as a management and monitoring

tool for implementation of the mitigation measures required by the EIA. The matrix

lists down:

The required mitigation measures recommended in the EIA;

The person/organization directly responsible for adhering to or executing the

required mitigation measures and monitoring adherence to the mitigation

measures;

The parameters which will be monitored to ensure compliance with the mitigation

measures; and

The timing at which the mitigation or monitoring has to be carried out.

United Energy Pakistan Limited will hold primary and overall responsibility for

ensuring full implementation of the EMP.

A.7 Change Management Plan

The EIA recognizes that changes in the operation or the EMP may be required during

the proposed exploration and associated development project activities therefore,

provides a Change Management Plan to manage such changes. The management of

changes is discussed under two separate headings, Changes to the EMP and Changes

to the Operation.

A.7.1 Changes to the EMP

The EIA and the EMP have been developed based on the best possible information

available at the time of the EIA study. However, it is possible that during the conduct

of the proposed operation some aspects of the EMP may need to be changed owning

to their non‐applicability in a certain area of operation or the need for additional

mitigation measures based on the findings of environmental monitoring during the

operation. In such cases following actions shall be taken.

A meeting will be held between United Energy Pakistan Limited, the contractor and

the Independent Monitoring Team (if required). During the meeting the proposed

deviation from the EMP, planning and designing will be discussed and agreed upon

by all parties.

Based on the discussion during the meeting, a change report will be produced

collectively, which will include the original EMP clause/plan or design, the change

that has been agreed upon and the reasons for the change. The report will be signed by

all the parties and will be filed at the site office. All relevant project personnel will be

informed of the change.



A.7.2 Changes to the Operation

The change management system recognizes three orders of changes.

a. First Order Change

A first order change is the one that leads to a significant departure requires a

reassessment of the environmental impacts. Examples of first order impacts include:

Any other activity other than those specified in this EIA e.g. construction of PV

plant, establishment of wind farm; and

Seismic, drilling or establishment of hydrocarbon processing facility outside of

Kotri North Block;

Action Required – Environmental impacts of the proposed change will be reassessed

and sent to the Sindh Environmental Protection Agency for approval.

b. Second Order Change

A second order change is one that does not result in the project description or impacts

that are significantly different from those detailed in the EIA. Examples of second

order changes include:

During project activities, inability to adhere with the minimum distances

recommended in the EIA/EMP;

Use of oil based mud during drilling;

Increasing the crew size by over 100% during seismic acquisition;

Undertaking of construction activity during night time; and

Under unavoidable conditions (due to improper access for water bowsers, long

haul distances or unavailability of tube wells in the project area etc.) limited water

abstraction from surface water resources (not visited/inhabited by wildlife) to be

allowed (for seismic acquisition only) by IMC after getting a formal approval from

locals/influential and regulators like Irrigation Department and ensuring that

limited water will not result in water shortage at that point and social conflicts.

Action Required – The required action for such changes is to reassess the impact of the

activity on the environment and specify additional mitigation measures if required

and report the changes to the Sindh EPA. Sindh EPA will review the change

management statement and communicate any concerns. If Sindh EPA agrees with the

assessment of the IMC, it does not have to send a formal approval. 15 days after

submission of the change management statement, the change will be implemented

unless a communication to the contrary has been received from Sindh EPA.

c. Third Order Change

A third order change is one that does not result in impacts above those already

assessed in the EIA, rather these may be made on site to minimize the impact of an

activity such as:



Increasing the crew size by over 50% during seismic acquisition;

Use of vibroseis in a small portion of agricultural land;

Change in alignment of seismic lines or RoW of flow line to avoid sensitive areas;

and

One or all of the minimum distances specified in the EIA cannot be maintained

only once or twice during the operation.

Action Required – The only action required for such changes will be to record the

change in the Change Record Register.

A.8 Training Program

Environmental trainings will be formed, part of the environmental management

system. The training will be directed towards all personnel for general environmental

awareness.

A.8.1 Objectives

The key objective of training program is to ensure that the requirements of the EMP

are clearly understood and followed throughout the project. The trainings to the staff

will help in communicating environmental related restrictions specified in the EIA and

EMP.

A.8.2 Roles and Responsibilities

The contractors will be primarily responsible for providing environmental training to

all project personnel on potential environmental issues of the project. The contractors

will be responsible to arrange trainings and ensure the presence of targeted staff.

A.8.3 Training Program

The environmental awareness, EIA and EMP trainings will also be carried out during

the entire course of the proposed operation on the basis of following criteria:

a. Training Logs

All training logs will be maintained by the contractors. The training log will include:

Topic

Date, time and location

Trainer

Participants

b. Training Needs Assessment

In addition to the training specified in the training log special/additional trainings will

be provided during the project activity. The criteria to assess the need of training will

be based on the following:

When a specified percentage of staff is newly inducted in the project;



When any non‐compliance is repeatedly reported, refresher training will be

provided regarding that issue;

When any environmental incident/accident of minor or major nature occurs;

Arrival of new contractor/sub‐contractor; and

Start of any new process/activity.

Suggested training program during the proposed exploration and associated

development activities is provided in Table A‐10.

c. Training Material

The contractors will develop and prepare training material regarding environmental

awareness, sensitivity of the area, EIA, EMP and restrictions to be followed during the

project. Separate training material will be prepared for each targeted staff.



Table A‐1: Mitigation Management Matrix for Proposed Seismic Activities

No Impact & Mitigation Measure Responsibility &

Execution

Action/Monitoring

Parameter/Monitoring Method Timing

1 Changes in Landscape & Soil Erosion

1.1 Seismic lines in the undulating areas will follow natural contours

wherever possible. However, in areas where seismic line cutting is a

requirement, the activity will be carried out in a way that would

minimize disturbance to natural topography and soils

UEPL, IMC, SC Check line preparation During line

preparation

1.2 The width of lines cleared for vibroseis will be limited to 3 m to

minimize clearing of vegetation and disturbance to soil

UEPL, IMC, SC Randomly check width of lines During line

preparation

1.3 Clearing of vegetation will be kept to a minimum, especially dense

patches of vegetation and the areas where the wildlife presence is

confirmed and near surface water bodies

UEPL, IMC, SC Monitor land clearing activities During land clearing

1.4 The cutting of trees or tall shrubs will be avoided as much as possible UEPL, IMC, SC Supervise land clearing activities During land clearing

1.5 Construction and seismic camps will be located in existing clearings

and on levelled land

UEPL, IMC, SC Identify campsite for the SC At the time of site

selection for campsite

1.6 Total land uptake by the camps and access road will be kept to the

minimum required

UEPL, IMC, SC Check areas Prior to and during

construction of camps

1.7 During seismic operation the number of routes used will be kept to a

minimum and road travel will be minimized

UEPL, IMC, SC Approve access tracks and check

road travel

During the entire

operation

1.8 During seismic operation the preparation of new access tracks will be

minimized. Where improvement of existing tracks or development of

short lengths of new tracks is unavoidable the width of the access track

will not exceed 3 m

UEPL, IMC, SC Supervise preparation of access

tracks and randomly check width

of access track

Prior to and during

track preparation

1.9 Vehicles speed will be regulated and monitored to avoid excessive dust

emissions

UEPL, IMC, SC Set and monitor speed limits During the entire

operation

1.10 Off‐road travel should be avoided and observance of this should be

monitored during the operation

UEPL, IMC, SC Approve access track and

monitor off‐road travel

During the entire

operation




Execution

Action/Monitoring


1.11 Periodic trainings will be provided to drivers on mitigation measures

related to off‐road travel and speed limits

UEPL, IMC, SC Check training log and provide

trainings

During the entire

project

1.12 Photographs will be taken before any activity to record the conditions

of campsite, roads and seismic lines at locations that are likely to under

go soil erosion. Similar photographs will be taken at intervals

throughout the survey to monitor any changes and soil conditions

IMC, UEPL Supervise and ensure compliance During the entire

project

2 Soil and Water Contamination

2.1 Sewage Treatment Plant (STP) shall be preferred for handling of

black/grey water under BATNEEC/BAT, but in case of unavailability of

STP, septic tank and soak pits shall be provided

UEPL, IMC, SC Check provision of STP During the design and

construction of

campsite

2.2 Wastewater from laundry, kitchen washings and showers will be

disposed of into separate soak pits

UEPL, IMC, SC Check provision of soak pits at

campsite

During the

construction of

campsite

2.3 Soak pits shall be built in absorbent soil and located 300 m away from a

surface water source or a groundwater well

UEPL, IMC, SC Check soil condition and distance

between the soak pits and the

nearest water body

During the

construction of

campsite

2.4 Soak pits will be constructed such that surface runoff cann’t enter into

the pits

UEPL, IMC, SC Check design of the soak pit and

monitor construction

During the

construction of

campsite

2.5 All kinds of wastewater pits will be designed to accommodate

wastewater generated during the total duration of the operation

UEPL, IMC, SC Check design of wastewater pits Before construction

2.6 In case the soak pits get filled during the operation, grey water will be

discharged in the nearest municipal drains after getting formal

approval from local authorities. Sprinkling of grey water will be not be

allowed

UEPL, IMC, SC Check provision of soak pits and

monitor the transfer activity

During the entire

operation

2.7 No solid waste will be disposed of in the field. Within the camp areas

all solid wastes will be disposed of in waste bins provided within the

camp area

UEPL, IMC, SC Check provision of waste bins During the entire

operation




Execution

Action/Monitoring


2.8 Combustible, non‐combustible and hazardous wastes including plastic

or glass bottles and cans will be temporarily stored on site and

sold/handed over to a waste/recycling contractor who will utilize these

wastes for recycling purposes

UEPL, IMC, SC Check compliance During the entire

operation

2.9 At the time of restoration soak pits will be backfilled with at least 1 m

of soil cover keeping in view landscape of surrounding natural surface

UEPL, IMC, SC Check soil cover During the restoration

2.10 At the time of restoration septic tanks will be dismantled in place and

backfilled with at least 1 m of soil cover above the buried dismantled

septic tank

UEPL, IMC, SC Check soil cover During the restoration

2.11 It will be ensured that after restoration activities the campsites are

clean and that no refuse has been left behind

UEPL, IMC, SC Detail inspection After restoration

2.12 All concrete structures at the campsites will be removed and buried in

garbage or soak pits and the pits backfilled with at least 1 m of soil

cover

UEPL, IMC, SC Check compliance During the restoration

2.13 Restoration of seismic lines will include removal of all cables,

geophones, station units, flags, stakes and wastes from the lines and

back filling of all mud pits. For reference purposes a photographic

record of selected sections of seismic lines will be taken before and

after the operation

UEPL, IMC, SC Check line restoration During and after the

restoration of seismic

lines

2.14 Vehicles will only be washed in designated areas within campsites UEPL, IMC, SC Ensure provision of washing

areas and monitor any non‐

compliances

During the entire

operation

2.15 Vehicles will be daily checked for fuel or oil leaks. Vehicles with leaks

will not be operated until repaired

UEPL, IMC, SC Check maintenance logs and

ensure daily inspection of

vehicles for leaks

During the entire

operation

2.16 All fuel and oil storage areas will have a concrete pad underneath to

prevent soil contamination in case of leaks or spills

UEPL, IMC, SC Ensure provision of concrete pad During camp setup

and construction

activity




Execution

Action/Monitoring


2.17 All fuel tanks will be properly marked to highlight their contents UEPL, IMC, SC Check safety signs During the entire

operation

2.18 Fuel and oil storage areas will have secondary containment in the form

of concrete or brick masonry bunds. The volume of the containment

area should be equal to 125% of the total volume of fuel stored

UEPL, IMC, SC Check containment volume of the

bunded area

At the time of

construction

2.19 During fuel and oil transfer operations such as re‐fuelling

vibroseis/bulldozers through a dedicated fuel vehicle, drips and spills

will be avoided and drip pans will be used

UEPL, IMC, SC Ensure provision of drips pans,

provide training on safe re‐

fuelling practices, monitor oil or

fuel transfer

During the entire

operation

2.20 Fuels tanks will be daily checked for leaks and all such leaks will be

plugged immediately

UEPL, IMC, SC Inspect fuel tanks for leaks During the entire

operation

2.21 The soil contaminated from minor and moderate spills will be removed

disposed of appropriately


operation

2.22 The soil contaminated from major spills may require specialized

treatment such as incineration or bioremediation

UEPL, IMC, SC Monitor and supervise special

treatment, if any

During the entire

operation

2.23 A spill prevention and contingency plan will be prepared to deal with

moderate and major spills

UEPL, IMC, SC Study and examine the plan and

identify any flaws, if any before

its approval

Before the

commencement of

project

2.24 Shovels, plastic bags and absorbent material should be present near

fuel and oil storage or handling areas to attend spills and leaks

UEPL, IMC, SC Check provision of materials During the entire

operation

2.25 Used oil and vehicle related waste will be transported to local

contractors for recycling


operation

2.26 Bentonite mud used for the purpose of uphole and deep hole drilling

will be prepared in earthen pits. The used mud will be disposed of in

the same pit and left to dry. After the mud has dried the pit will be

backfilled

UEPL, IMC, SC Monitor preparation and disposal

of mud

During deep hole and

uphole drilling

2.27 Medical wastes will be temporarily stored onsite separately and

incinerated at nearest facility


operation




Execution

Action/Monitoring


2.28 Construction of burn pit and burning of waste will not be allowed UEPL, IMC, SC Check compliance During the entire

operation

2.29 Blasting, construction or drilling activities will not be performed in

Indus River

UEPL, IMC, SC Ensure compliance During the entire

operation

3 Deterioration of Air Quality

3.1 Generators, compressors, equipment and vehicles used during seismic

operations will be maintained in a good condition to ensure that

emissions are kept to a minimum level

UEPL, IMC, SC Check maintenance logs During the entire

operation

3.2 During seismic operations vehicles speed will be regulated and

monitored to minimize dust emissions

UEPL, IMC, SC Set and monitor speed limits During the entire

operation

3.3 Campsites will be located at least 300 m away from communities UEPL, IMC, SC Check distances of campsite from

communities

Prior to construction of

campsites

3.4 During construction and seismic operation dust emissions will be

minimized by sprinkling of the access tracks (wherever applicable)

UEPL, IMC, SC Set and monitor speed limits.

Monitor sprinkling of access track

During the entire

operation

3.5 Burning of waste will not be allowed and all combustible and non‐

combustible wastes will be handed over the approved waste contractor


operation

3.6 Comply with minimum safe distances from environmental receptors

recommended in the EIA study


operation

3.7 Access tracks used during proposed seismic operation passing through

communities will be avoided. If unavoidable a speed limit of less than

30 km/hr will be observed on the section of the road passing through

the community

UEPL, SC, IMC Ensure compliance During the entire

operation

3.8 During operation emissions from all point sources and ambient air

quality shall also be monitored to check compliance with SEQS in

accordance to applicable laws and regulations

UEPL, IMC, SC Ensure compliance with SEQS During the entire

operation

3.9 Appropriate measures will be taken to avoid ozone depletion UEPL, IMC, SC Monitor measures During the entire

operation




Execution

Action/Monitoring


3.10 During preparation of access tracks, levelling or widening along the

access road/s will be done in sections, immediately followed by

sprinkling of water and also preferably compaction (where required)

UEPL, IMC, SC Ensure compliance During the

construction phase

4 Noise Pollution

4.1 It will be ensured that generators, vehicles and other potentially noisy

equipment used during seismic activities are in good working

condition

UEPL, IMC, SC Monitor noise levels Prior to use of

machinery and

vehicles

4.2 Seismic camps will be located 300 m away from nearest communities UEPL, IMC, SC Check distances from the

community


the campsites

4.3 The use of horns by project vehicles will be minimized. The use of

pressure horns will not be allowed

UEPL, IMC, SC Train drivers, check vehicles and

record non‐compliances

During the entire

operation

4.4 Movement of all project vehicles and personnel will be restricted to

within work areas only

UEPL, IMC, SC Advise all drivers and monitor

non‐compliances

During the entire

operation

4.5 Appropriate control actions shall be taken to mitigate adverse noise

impacts in working areas, if levels found in excess of NEQS or SEQS at

the neighboring communities

UEPL, IMC, SC Monitor noise levels at

neighboring communities

During the entire

operation

4.6 Conduct regular noise monitoring as per applicable rules and

regulations

UEPL, IMC, SC Conduct regular noise monitoringDuring the entire

operation

5 Water Abstraction

5.1 Water from dhands, canals or any other suface water body will not be

used. Under special circumstances like long haul distances, improper

access for water bowsers in remote areas etc. surface water resources

may be exploited for limited water abstraction during seismic

operation (for operational needs only) after getting approval from the

concerned department

UEPL, IMC, SC Check sources of water

abstraction and ensure

compliance

During the entire

operation

5.2 The quantity of water used during seismic, drilling (flush or uphole

etc.) and camps construction operations will be kept to the minimum

required by taking prudent water conservation measures on site

UEPL, IMC, SC Check consumption of water During the entire

operation




Execution

Action/Monitoring


5.3 A complete record of water consumption during seismic and camps

construction will be maintained

UEPL, IMC, SC Check records During the entire

operation

5.4 Water required for seismic and construction of camps operation may

be obtained from existing local wells or newly installed UEPL water

wells in the area


operation

5.5 If a new water well is to be installed, the well will be located 300 m

from existing local wells and will be designed to abstract water

preferably from deep aquifer not being used by local communities

UEPL, IMC, SC Monitor distance from the

existing wells

Before the start of the

operation

5.6 Water from a local well will only be used after ensuring that the

available capacity at the tube well (safe yield minus local demand) is at

least 50% greater than the project demand. Discharge from the tube

well will be regularly monitored to monitor any changes in the yield of

the wells. If a single well fails to meet this requirement, water will be

obtained from multiple wells such that each well meets the above‐

mentioned requirement

UEPL, IMC, SC Check local demand and water

abstraction

During the entire

operation

5.7 For all water obtained from local wells, the owner will paid for the

water abstracted at the appropriate rates


operation

5.8 Preferably, the potable water requirement will be met by installing

water treatment system (such as reverse osmosis)

SC, IMC, UEPL IMC to guide on preservation of

water

During the entire

operation

6 Clearing of Vegetation & Loss of Habitat

6.1 The campsite areas will be kept to the minimum required UEPL, IMC, SC Check areas for the camps

establishment

Prior to camp setup

6.2 Camps will be located in existing clearings and levelled land UEPL, IMC, SC Check compliance Before camp setup

6.3 Clearing of vegetation will be kept to a minimum and avoided as much

as possible, especially dense patches of vegetation where wildlife

presence is confirmed and areas near surface water bodies

UEPL, IMC, SC Monitor clearing activities During entire

operation




Execution

Action/Monitoring


6.4 The cutting of trees or tall shrubs will be avoided as much as possible.

Under unavoidable circumstances any clearing required will be done

with prior approval of IMC and custodian of the area. Each tree cutting

for clearing of site will be replaced/compensated by plantation of trees

at site (10 trees for each tree cut). The tree species shall be indigenous

to the region

UEPL, IMC, SC Supervise land clearing activities During land clearing

activities

6.5 Use of local vegetation/wood as fuel by crew personnel will be stirctly

prohibited


operation

6.6 Dust emissions on access tracks will be reduced by keeping speed

limits below 40 km/hr


operation

6.7 Crew personnel while working along seismic lines will concentrate

within a corridor of 3 m


operation

6.8 Earthen pits for preparation and disposal of bentonite mud and drill

cuttings will be located in an area where minimum vegetation clearing

is involved


operation

6.9 Campsites will avoid areas of dense vegetation as much as possible UEPL, IMC, SC Check site allocated for campsites Before the start of

clearing acitivities

6.10 Access tracks will be avoided from passing through patches of dense

vegetation

UEPL, IMC, SC Check the alignment of access

tracks

Before land clearing

and construction

operation

6.11 During seismic operation clearing of vegetation will be minimized by

minimizing the width of the vibroseis tracks, minimizing the

preparation of new access tracks and keeping the width of new access

tracks to the minimum required

UEPL, IMC, SC Check compliance During entire

operation

7 Disturbance to Wildlife

7.1 Prior to commencement of seismic operation, awareness trainings will

be provided to contractor’s management and field crew on matters

related to the requirements of the EMP in this regard

UEPL, IMC, SC Provide environmental awareness

training

Before commencement

of seismic operation




Execution

Action/Monitoring


7.2 Hunting, fishing, harassment, feeding, trapping or killing of wildlife

will be strictly prohibited


operation

7.3 Vegetation clearing and land uptake during seismic operations will be

minimized


operation

7.4 Campsites for seismic operation will be located 300 m from surface

water bodies

UEPL, IMC, SC Check compliance Before the construction

7.5 The time period of operation near wetland/dhands/surface water bodies

and dense patches of vegetation will be minimized or avoided, if

possible; especially during rutting or breeding period of the key

wildlife species found in the project area by good planning and

efficient working to reduce the time period of disturbance. Within the

core habitat of wildlife the seismic operation should be completed

within the shortest time possible

UEPL, IMC, SC Check compliance During operation in

the area

7.6 Development of new access tracks during seismic activity will be

minimized, where access tracks are prepared their width will be kept

to 3 m

UEPL, IMC, SC Check compliance During entire

operation

7.7 For preparation of access tracks, routes involving minimum clearing of

vegetation will be selected, clearing of dense patches of vegetation will

be avoided

UEPL, IMC, SC Monitor clearing operation During land clearing

7.8 Seismic deep holes and upholes will avoid disturbing live bird nests

and small mammal and reptile holes


operation

7.9 Food wastes will not be disposed or left in the open UEPL, IMC, SC Check compliance During the entire

operation

7.10 Night traveling will be strictly prohibited and will only be allowed in

case of emergency


operation

7.11 A distance of 50 m will be maintained from surface water bodies

during data acquisition and line clearing

UEPL, IMC, SC Check distances and ensure

compliance

During the entire

operation




Execution

Action/Monitoring


7.12 Compressors and vehicles will be maintained in good condition and

provided with muffles to reduce noise

UEPL, IMC, SC Check maintenance logs and

ensure the provision of muffles

During the entire

operation

7.13 Blasting, construction or drilling activities will not be performed in

Indus River


operation

7.14 Impacts of the individual projects on wildlife will be monitored by

independent monitoring teams

UEPL, IMC Check compliance During the entire

operation

8 Disturbance to Communities

8.1 Project contractors and field staff shall be taken through a Community

and External Affairs Induction program before execution of seismic

activities

UEPL, IMC, SC Ensure arrangement of induction

program

Before commencement

of seismic activities

8.2 All community grievances will be recorded and maintained in a

Community Complaints Register. In addition to this close liaison will

be maintained between the community and the site representatives of

UEPL throughout the course of activities

UEPL, IMC, SC Check the provision of complaint

register and its access for

communities

During the entire

operation

8.3 Compensation amounts for land leased for various project components

will be disbursed in equitable and transparent manner on fast pace

UEPL, SC, IMC Check compensation records During the entire

operation

8.4 Compensation amounts will be paid to land owners before land is

acquired, if not possible, then amounts should be paid as soon as

possible

UEPL, SC, IMC Check compensation records During the entire

operation

8.5 Loss of standing crops, traditional land rights and community

ownership will be given due consideration while determining

compensation amounts

UEPL, SC, IMC Check compliance During the entire

operation

8.6 Compensation amounts will be settled based on prevailing market

rates and will be settled after an agreement is reached between the

local residents, operator and local administrator

UEPL, SC Check compliance During the entire

operation

8.7 All mitigation related to management of wastes, noise and dust

emissions suggested in the EIA will be adhered with


operation




Execution

Action/Monitoring


8.8 UEPL contractors will employ local residents during the project

activities subject to company’s competency criteria. Residents living

closest to the project location will be given priority in the employment

process


operation

8.9 Skilled and unskilled labour from local communities will be recruited

equitably from amongst the various tribes, avenues for conflict

resolution will be open and the employment procedures will be

transparent

SC, UEPL Check compliance During the entire

operation

8.10 Water sources currently being used for irrigation by the resident

communities will be exploited only after complying with relevant

requirements of the EIA


operation

8.11 Local sources of water will be used only after complying with relevant



operation

8.12 Flow of water in canals or water crossings will not be impeded UEPL, IMC, SC Check compliance During the entire

operation

8.13 Any damage to canals, watercourses, local roads or other infrastructure

will be repaired or compensated as per mutually agreed terms


operation

8.14 Strict compliance will be observed to UEPL’s HSE guidelines UEPL, IMC, SC Check compliance During the entire

operation

8.15 Drivers will be trained in responsible and safe driving practices, safe

speed limits for vehicles will be followed

UEPL, IMC, SC Provide training and monitor

compliance

During the entire

operation

8.16 In order to keep nearby local communities informed of the progress of

the operation, communication channels will be maintained between

local community and UEPL

UEPL, SC Check compliance During the entire

operation

8.17 Project staff will respect cultural norms UEPL, IMC, SC Train project staff on social norms

and sensitivities

During the entire

operation

8.18 Appropriate offsets will be provided from sites of religious, cultural or

archaeological significance


operation




Execution

Action/Monitoring


9 Site Restoration

9.1 Demobilization of all equipment and machinery UEPL, SC, IMC Check compliance During site restoration

9.2 Disposal of any waste material remaining at the time of completion of

the operation

UEPL, SC, IMC Ensure compliance During site restoration

9.3 Backfilling of all soak pits and septic tanks UEPL, SC, IMC Check compliance During site restoration

9.4 Dismantling and removal of fence or barriers surrounding the seismic

base camp area/fly camp/support camp

UEPL, SC, IMC Check compliance During site restoration

9.5 General restoration of the site area including landscaping and

restoration of drainage where required


9.6 Restoration of seismic lines will include removal of all cables,

geophones, station units, flags, stakes and wastes from the lines and

back filling of all mud pits. For reference purposes a photographic

record of selected sections of seismic lines will be taken before and

after the operation


Notes: SC: Seismic Contractor; IMC: Independent Monitoring Consultant; UEPL: United Energy Pakistan Limited’s Management or Representative



Table A‐2: Mitigation Management Matrix for Drilling and Associated Construction Activities

No. Impacts & Mitigation Measure Responsibility &

Execution

Action/Monitoring

Parameter/Monitoring MethodTiming

1 Changes in Landscape & Soil Erosion

1.1 Access tracks in the undulating areas will follow natural

contours to minimize disturbance to natural topography and

soils. Cutting along the sides of the slopes will be minimized

UEPL, IMC, CC Monitor clearing operation During land clearing

activities

1.2 Clearing of vegetation will be kept to a minimum, especially

dense patches of vegetation, areas where the presence of wildlife

is confirmed and near the surface water bodies

UEPL, IMC, CC Monitor land clearing activities Prior and during the land

clearing operation

1.3 The cutting of trees or tall shrubs will be avoided as much as

possible

UEPL, IMC, CC Supervise land clearing

activities

During land clearing for

access track, well site and

campsite

1.4 Total land uptake by the well site, camps and access road to the

well site will be kept to the minimum required

UEPL, IMC, CC Monitor land clearing activities

and randomly check compliance

with actual design

During construction

1.5 The access track to the well site will be selected to utilize existing

tracks as much as possible

UEPL, IMC, CC Monitor land clearing activities Prior to the construction

activitiy

1.6 The well site, rig camp and construction camp will preferably be

located in existing clearing and levelled land

UEPL, IMC Check location of facilities At the time of site selection

for well site, rig camp and

construction camp

1.7 The access track will be properly compacted at the time of

construction and thereafter properly maintained by watering

and compaction throughout the entire construction and drilling

operation

UEPL, IMC, CC Check compaction and

maintenance

During the entire operation

1.8 During construction movement of construction equipment will

be restricted to work areas only to avoid unnecessary

disturbance to soils in the project area

UEPL, IMC, CC Monitor movement of vehicles

and off‐road travel

During construction of project

facilities

1.9 Vehicles speed will be regulated and monitored to avoid

excessive dust emissions

UEPL, IMC, CC,

DC

Set and monitor speed limits During the entire operation




Execution

Action/Monitoring


1.10 Off‐road travel should be avoided and observance of this should

be monitored during the operation

UEPL, IMC, CC,

DC

Approve access track and

monitor off‐road travel

During the entire project

1.11 Periodic trainings should be provided to drivers on mitigation

measures related to off‐road travel and speed limits

UEPL, IMC, CC,

DC

Check training log and provide

trainings


1.12 Photographs will be taken before any activity to record the

conditions of campsite, roads and well site at paticular locations

that are likely to undergo soil erosion. Similar photographs will

be taken at time intervals throughout the operation to monitor

any changes and soil conditions

UEPL, IMC Supervise and ensure

compliance



2.1 Sewage Treatment Plant (STP) shall be preferred for handling of

black/grey water under BATNEEC/BAT, but in case of

unavailability of STP, septic tank and soak pits shall be provided

UEPL, IMC, CC Check provision of STP During the design and

construction of campsite

2.2 Wastewater from laundry, kitchen washings and showers will be

disposed of into separate soak pits

UEPL, IMC, CC Check provision of soak pits at

campsites

During the construction of

campsite

2.3 Soak pits will be built in absorbent soil and located 300 m away

from a surface water source or a water well

UEPL, IMC, CC Check soil condition and

distance between the soak pits

and the nearest water body


campsite

2.4 Soak pits will be constructed such that surface runoff cann’t

enter the pits

UEPL, IMC, CC Check design of the soak pit and

monitor construction


campsite

2.5 All soak pits will be designed to accommodate wastewater

generated during the total duration of the operation

UEPL, IMC, CC Check design of soak pit Before construction

2.6 In case the soak pits get filled during the operation, grey water

will be discharged in the nearest municipal drains after getting

formal approval from local authorities. Sprinkling of grey water

will be not be allowed

UEPL, IMC, CC,

DC

Check provision of soak pits and

monitor the transfer activity


2.7 No solid waste will be disposed of in the field. Within the camp

areas all solid wastes will be disposed of in waste bins provided

UEPL, IMC, CC,

DC

Check provision of waste bins During the entire operation




Execution

Action/Monitoring


2.8 All combustible, non‐combustible and hazardous waste

including plastic or glass bottles and cans will be temporarily

stored on site and sold/handed over to a waste/recycling

contractor who will utilize these wastes for recycling purposes

UEPL, IMC, CC,

DC

Check compliance During the entire operation

2.9 Construction of burn pit and burning of waste will not be

allowed

UEPL, IMC, CC Check compliance During the entire operation

2.10 At the time of restoration septic tanks will be dismantled in place

and backfilled with at least 1 m of soil cover above the buried

dismantled septic tank

UEPL, IMC, CC Supervise restoration and

randomly check thickness of soil

cover

During the restoration phase

2.11 At the time of restoration soak pits will be backfilled with at least

1 m of soil cover keeping in view landscape of surrounding

natural surface

UEPL, IMC, CC Supervise restoration and


cover

During the restoration phase

2.12 It will be ensured that after restoration activities the campsites

are clean and that no refuse has been left behind

UEPL, IMC, CC Visually check the restored site

and identify non‐complinace, if

any

After restoration

2.13 All concrete structures at the campsites will be removed and

buried in garbage or soak pits and the pits backfilled with at

least 1 m of soil cover

UEPL, IMC, CC Supervise removal and burial of

concereted strutures and


cover

During restoration

2.14 Vehicles will only be washed in designated areas within

campsites

UEPL, IMC, CC,

DC

Ensure provision of washing

areas and monitor any non‐

compliances


2.15 Vehicles will be daily checked for fuel or oil leaks. Vehicles with

leaks will not be operated until repaired

UEPL, IMC, CC,

DC

Check maintenance logs and

ensure daily inspection of

vehicles for leaks


2.16 All fuel tanks will be properly marked to highlight their contents UEPL, IMC, CC,

DC

Ensure that proper signs are

placed with the tanks





Execution

Action/Monitoring


2.17 Fuel and oil storage areas will have secondary containment in

the form of concrete or brick masonry bunds. The volume of the

containment area should be equal to 125% of the total volume of

fuel stored

UEPL, IMC, CC Check containment volume of

the fuel or oil bunded area

At the time of construction

2.18 Fuels tanks will be daily checked for leaks and all such leaks will

be plugged immediately

UEPL, IMC, CC,

DC

Inspect fuel tanks for leaks During the entire operation

2.19 The soil contaminated from minor and moderate spills will be

removed and disposed of properly

UEPL, IMC, CC,

DC


2.20 The soil contaminated from major spills may require specialized

treatment such as incineration or bioremediation

UEPL, IMC, CC,

DC

Monitor and supervise special

treatment, if any


2.21 A spill prevention and contingency plan will be prepared to deal

with moderate and major spills

UEPL, IMC, CC,

DC

Study and examine the plan and

identify any flaws, if any before

its approval

Before the commencement of

project

2.22 Shovels, plastic bags and absorbent material should be present

near fuel and oil storage or handling areas to attend spills and

leaks

UEPL, IMC, CC,

DC

Check provision of material &

equipment

During entire operation

2.23 Used oil and vehicle related waste will be transported to local

contractors for recycling

UEPL, IMC, CC,

DC

Approve waste contractor and

randomly check proper

recycling


2.24 Medical wastes will be temporarily stored onsite separately and

incinerated at nearest facility

UEPL, IMC, CC,

DC

Check compliance During entire operation

2.25 A water based mud system will be used for drilling UEPL, IMC, DC Check compliance During entire operation

2.26 Waste pits at the well site will be lined with an HDPE liner UEPL, IMC Check provision of HDPE liner Before comissioning of waste

pits

2.27 The drill cuttings and drilling mud will be disposed into pits

lined with impermeable geo‐membrane. The pits will be larger

than the required capacity to accommodate overflows. At the

UEPL, IMC, CC,

DC

Check design of waste pit and

ensure provision of geo‐

membrane. Monitor restoration

Before comissioning, during

operation and after

restoration of waste pits




Execution

Action/Monitoring


time of restoration the pits will be backfilled with the cuttings

encapsulated within the liner and with a top soil cover

with provision of proper soil

cover

2.28 Produced formation fluids will be flared along with the gas or

collected inside the lined waste pit at the well site. In case the

fluids discharge into the flare pit the soil at the sides of the flare

pit will be excavated and disposed of into the lined waste pit at

the well site

UEPL, IMC, DC,

CC

Check compliance Prior to and during disposal

of waste fluids

2.29 Produced formation fluids will be re‐injected into deep

subsurface formations (wherever possible)

UEPL, DC, IMC Check compliance Prior to and during disposal

of waste fluids

2.30 Sprinkling of untreated excess wastewater used for drilling

purposes will not be allowed. Sprinkling of treated wastewater

will only be done if meeting NEQS/SEQS

UEPL, IMC Check compliance During the entire operation

3 Use of Water

3.1 The surface water resources will no be used during construction

and drilling activities

UEPL, IMC, CC,

DC

Check sources of water

abstraction and ensure

compliance


3.2 The quantity of water used during construction and drilling will

be kept to the minimum required by taking prudent water

conservation measures on site

UEPL, IMC, CC,

DC

Check consumption of water During the entire operation

3.3 A complete record of water consumption during construction

and drilling will be maintained

UEPL, IMC, CC,

DC

Check Compliance During the entire operation

3.4 Water required for drilling and construction of camps operation

may be obtained from local wells (close to surface water bodies)

or new water wells installed by UEPL in the project area

UEPL, IMC, CC,

DC


3.5 Water from a local well will only be used after ensuring that the

available capacity at the tube well (safe yield minus local

demand) is at least 50% greater than the project demand.

Discharge from the tube well will be regularly monitored to

UEPL, IMC, CC,

DC

Check local demand and water

abstraction





Execution

Action/Monitoring


monitor any changes in the yield of the wells. If a single well

fails to meet this requirement, water will be obtained from

multiple wells such that each well meets the above‐mentioned

requirement

3.6 For all water obtained from local wells, the owner will be paid

for the water abstracted at the appropriate rates

UEPL, IMC, CC,

DC


3.7 If a new water well is to be installed, the well will be located 300

m from existing local wells and will be designed to abstract

water preferably from deep aquifer not being used by local

communities

UEPL, IMC, CC,

DC

Monitor distance from the

existing wells

Before start of the operation

3.8 Preferably, the potable water requirement will be met by

installing water treatment system (such as reverse osmosis)

UEPL, CC, DC,

IMC

IMC to guide on preservation of

water


4 Deterioration of Ambient Air Quality

4.1 Generators, vehicles and equipment used during construction

and drilling operations will be maintained in a good working

condition to ensure that emissions are kept to a minimum level

UEPL, IMC, CC,

DC

Check maintenance logs During the entire operation

4.2 Well site and campsites will be located at least 300 m away from

nearest community

UEPL, IMC, CC Check distances of well site and

campsite from communities

Prior to construction of well

site and campsites

4.3 During drilling and construction dust emissions due to road

travel will be minimized by regulating and monitoring vehicles

speed and watering of the access track wherever required

UEPL, IMC, CC Set and monitor speed limits.

Monitor sprinkling of access

track


4.4 The access track selected to access the well location will maintain

a reasonable safe distance from communities

UEPL, IMC, CC Check alignment of the access

track

Prior to improvement and

construction of the access

track

4.5 Dust emissions during construction activities will be minimized

by good management practices such as locating stock piles out of

the wind direction, keeping the height of the stock piles to a

minimum, keeping earthwork areas damp etc.

UEPL, IMC, CC Monitor dust emissions during

earthworks. Train CC on good

management practices

During the construction

operation




Execution

Action/Monitoring


4.6 Flare pit will be kept downwind of the well site and at least 300

m from the nearest community. The duration of flaring during

well testing will be kept to the minimum required

UEPL, IMC, CC,

DC

Check location and distance of

the flare pit from nearest

community and monitor flaring

Prior to construction of the

flare pit and during flaring

4.7 No burning of waste will be allowed on site UEPL, IMC, CC Ensure compliance During the entire operation

4.8 Appropriate measures will be taken to avoid ozone depletion &

global warming e.g. prohibit use of CFC gases etc.

UEPL, IMC, CC,

DC


4.9 During operation emissions from all point sources shall be

monitored to check compliance with SEQS

UEPL, IMC, CC,

DC

Ensure compliance During the entire operation

5 Noise Pollution

5.1 It will be ensured that generators, vehicles and other potentially

noisy equipment used during construction and drilling are in

good working condition

UEPL, IMC, CC,

DC

Monitor noise levels Prior to and during use of

machinery and vehicles

5.2 Well site, construction camps and rig camp will be located 300 m

away from nearest community

UEPL, IMC, CC Check distances from the

community


well site, rig camp and

campsites

5.3 The use of horns by project vehicles will be minimized. The use

of pressure horns will not be allowed

UEPL, IMC, CC,

DC

Train drivers, check vehicles and



5.4 Movement of all project vehicles and personnel will be restricted

to within work areas only

UEPL, IMC, CC,

DC

Advise all drivers and

investigate non‐compliances

from staff


5.5 Regular noise monitoring will be carried out from all noise

generating sources to ensure SEQS compliance

UEPL, IMC, CC,

DC

Check monitoring records During the entire operation

5.6 Blasting will be prohibited during proposed construction

activities of well sites in the project area to provide relief to the

sensitive environmental receptors. If deemed necessary it shall

be covered by change management plan provided in EMP of this

EIA

UEPL, IMC, CC Ensure compliance During construction activity

6 Blocking of Natural Drainage




Execution

Action/Monitoring


6.1 Area around the wells and campsites shall be landscaped to

avoid blocking natural drainage

UEPL, IMC, CC Check compliance During construction activities

6.2 Causeways and pipe culverts will be provided at all

watercourses (seasonal or permanent) crossings to avoid

blocking of natural drainage

UEPL, IMC, CC Ensure not to block the natural

drainage

During construction activities

6.3 Uncontrolled & unnecessary clearing, dozing, excavations or

quarrying, storage of construction material etc. will be avoided

UEPL, CC, IMC Ensure compliance During construction activities


7.1 The well site and rig camp areas will be kept to the minimum

required

UEPL, IMC, CC Check design and ensure

compliance

Before and during the

construction activity

7.2 The well site location will avoid areas of dense vegetation as

much as possible

UEPL, IMC, CC Check location of well site Before selection of drilling

location

7.3 The construction camp and rig camp will be located in existing

clearings and will avoid areas of dense vegetation

UEPL, IMC, CC Check compliance Before selection of drilling

location

7.4 Clearing of vegetation will be kept to a minimum; especially

dense patches of vegetation, areas where the presence of wildlife

is confirmed and near surface water bodies

UEPL, IMC, CC Monitor clearing operation During land clearing

activities

7.5 The access road to each well site will be aligned to minimize

dense patches of vegetation and will use existing tracks as much

as possible

UEPL, IMC, CC Check alignment of access road

and use of existing facilities

Before construction operation

7.6 The cutting of trees or tall shrubs will be avoided as much as

possible. Under unavoidable circumstances any clearing

required will be done with prior approval of IMC and custodian

of the area. Each tree cutting for clearing of site will be

replaced/compensated by plantation of trees at site (10 trees for

each tree cut). The tree species shall be indigenous to the region

UEPL, IMC, CC Supervise land clearing

activities

During land clearing

activities

7.7 Use of local vegetation as fuel by crew personnel will be

prohibited

UEPL, IMC, CC,

DC





Execution

Action/Monitoring


7.8 Dust emissions on access tracks will be reduced by keeping

speed limits below 40 km/hr

UEPL, IMC, CC,

DC


7.9 Access tracks will be avoided from passing through patches of

dense vegetation

UEPL, IMC, CC Check the alignment of access

tracks

Before land clearing and

construction operation

7.10 Quarry sites if required will be carefully selected such that they

are located in levelled areas with existing clearing and the quarry

sites are restored after use

UEPL, IMC, CC Check quarry sites and their

restoration

During construction activities


8.1 Prior to commencement of drilling operation, awareness

trainings will be provided to contractor’s management and field

crew on matters related to the requirements of the EMP in this

regard

UEPL, IMC, CC,

DC

Provide environmental

awareness training

Before commencement of

construction and drilling

operation

8.2 Hunting, fishing, trapping, feeding ,harassment or killing of

wildlife will be strictly prohibited

UEPL, IMC, CC,

DC


8.3 Vegetation clearing and land uptake will be minimized UEPL, IMC, CC Check compliance During the entire operation

8.4 Locate well site & campsite 300 m away from any surface water

bodies

UEPL, IMC, CC Randomly check distances and

identify any non‐compliances

Before the construction

activity

8.5 The drilling of wells within the areas where good population of

wildlife is confirmed shall be avoided as much as possible

UEPL, IMC Check compliance Before selection of drilling

location

8.6 For preparation of access tracks, routes involving minimum

clearing of vegetation will be selected, clearing of dense patches

of vegetation will be avoided

UEPL, IMC, CC Check alignment of access

tracks/routes and monitor

clearing operation

During land clearing activity

8.7 Food wastes will not be left in the open UEPL, IMC, CC,

DC


8.8 Night traveling will be strictly prohibited and will only be

allowed in case of emergency

UEPL, IMC, CC,

DC


8.9 Equipment and vehicles will be maintained in good working

condition and provided with muffles to reduce noise

UEPL, IMC, CC,

DC

Check maintenance logs and

ensure the provision of muffles





Execution

Action/Monitoring


8.10 The time period of operation near wetland/dhands/surface water

bodies and dense patches of vegetation will be minimized or

avoided, if possible; especially during rutting or breeding period

of the key wildlife species found in the project area by good

planning and efficient working to reduce the time period of

disturbance

UEPL, IMC, CC,

DC

Check time period of operation During the entire operation

8.11 Blasting will be prohibited during construction activities to

provide relief to the sensitive environmental receptors of the

area. If deemed necessary it shall be covered by change

management plan provided in EMP of this EIA

UEPL, IMC, CC Ensure compliance During construction activity

8.12 The duration and intensity of flaring will be kept to the

minimum required

UEPL, IMC, DC Monitor flaring activity During flaring activity

8.13 Construction and drilling activities will not be performed in

Indus River

UEPL, IMC Ensure compliance During the entire course of

project

9 Disturbance to Communities

9.1 Contractors staff shall be taken through a Community and

External Affairs Induction program before commencement of

each component of the project activities

UEPL, IMC, CC,

DC

Ensure compliance Before commencement of

each component of project

9.2 All community grievances will be recorded and maintained in a

Community Complaints Register. In addition to this close liaison

will be maintained between the community and the site

representatives of UEPL throughout the construction and

drilling activities

UEPL, IMC, DC,

CC

Check the provision of

complaint register and

maintaining a close liaison of

site representatives with locals


9.3 Compensation amounts for land leased for various project

components will be disbursed in equitable and transparent

manner on fast pace

UEPL, IMC, CC Check compensation records Before the commencement of

project activities




Execution

Action/Monitoring


9.4 Compensation amounts will be paid to land owners before land

is acquired, if not possible, then amounts should be paid as soon

as possible

UEPL, IMC, CC Monitor time taken for the

payment of compensations and

identify any sluggishness, if any


project activities

9.5 Loss of standing crops, traditional land rights and community

ownership will be given due consideration while determining

compensation amounts

UEPL, IMC, CC Monitor adherence with the

requirement during the

assessment of land value to

provide compensations


project activities

9.6 Compensation amounts will be settled based on prevailing

market rates and will be settled at mutually agreed terms and

conditions


requirement during the

assessment of land value to

provide compensations


project activities

9.7 All mitigation related to management of wastes, noise and dust

emissions suggested in the EIA will be adhered with

UEPL, IMC, CC,

DC


9.8 UEPL contractors will employ local residents during project

activities subject to company’s competency criteria

UEPL, IMC, CC,

DC

Monitor adherence with the

requirement


9.9 Skilled and unskilled labour from local communities will be

recruited equitably from amongst the various tribes, avenues for

conflict resolution will be open, and the employment procedures

will be transparent

UEPL, IMC, CC,

DC


requirement


9.10 Local residents living closest to the project location will be given

priority in the employment process

DC, UEPL, IMC,

CC


requirement


9.11 Water sources currently being used for domestic/irrigation by

the resident communities will be exploited only after complying

with relevant requirements of the EIA

UEPL, IMC, CC,

DC


requirement


9.12 Local sources of drinking water will be used only after

complying with relevant requirements of the EIA

UEPL, IMC, CC,

DC


requirement


9.13 Flow of water in canals or water crossings will not be impeded UEPL, IMC, CC,

DC





Execution

Action/Monitoring


9.14 Any damage to canals, water courses, roads or other

infrastructure during project activities will be repaired or

compensated as per mutual understandings

UEPL, IMC, CC,

DC

Check for damages along canals,

water courses, roads or other

infrastructure and ensure its

repair is conducted


9.15 Strict compliance will be observed to UEPL’s HSE guidelines UEPL, IMC, CC,

DC


requirement


9.16 Drivers will be trained in responsible and safe driving practices.

Safe speed limits for vehicles will be followed

UEPL, IMC, CC,

DC

Provide training and monitor

compliance


9.17 In order to keep nearby local communities informed of the

progress of the operation, communication channels will be

maintained between local community and UEPL

UEPL, IMC, CC,

DC


requirement by holding

frequent meetings to update

locals regarding project

activities


9.18 A complaints register regarding environment will be maintained

on site for registering of local complaints

UEPL, IMC, CC,

DC

Check the provision of

complaint register and its access

for general public


9.19 Project staff will respect cultural norms UEPL, IMC, CC,

DC


requirement


9.20 Appropriate offsets will be provided from sites of religious,

cultural or archaeological significance


requirement

Before construction activity

10 Site Restoration

Complete Restoration – Dry Well

10.1 All equipment and machinery at the well site will be

demobilized

DC, IMC, UEPL Check compliance During site restoration

10.2 All wastes at the well site will be disposed of according to the


DC, IMC, UEPL Check compliance During site restoration




Execution

Action/Monitoring


10.3 Liner from the water and waste pits at the well site may be taken

out and re‐used or disposed of in the existing pits with proper

restoration

CC, IMC, UEPL Check compliance During site restoration

10.4 All concrete structures at the well site will be broken and either

transported out of the project area by the demolition or site

restoration contractors for sale or reuse or disposed of into the

pits


10.5 All pits at the well site will be backfilled CC, IMC, UEPL Check compliance During site restoration

10.6 The areas covered by the portion of the access track that will be

of no use for other wells will be restored, in that all gravel

topping will be removed. This scenario will be applicable only if

the locals require the potions of the track to be restored or

otherwise it will be left intact on the consent of the locals


Partial Restoration – Producing Well

10.7 The well site and access roads will be retained to support well

access work for further testing or during the production phase

UEPL Check compliance During site restoration

10.8 The outer chainlink fence will be retained as a safety measure to

keep wildlife away from the pit areas

UEPL, IMC Check chain link fence is

retained

During site restoration

10.9 The wellhead will be enclosed by a locked steel cage. This will

serve as both a safety and security measure as the site will be

down‐manned pending further production operations work

UEPL, IMC Inspect wellhead is enclosed by

locked steel cage


10.10 The constructed pit areas will be retained but all liquid and solid

waste material will be removed from the site and disposed of in

line with the requirements of this EIA

IMC, UEPL Ensure that all liquid and solid

waste is removed


Note: IMC: Independent Monitoring Consultant; DC: Drilling Contractor; CC: Construction Contractor; UEPL: United Energy Pakistan Limited’s Management or Representative



Table A‐3: Mitigation Management Matrix for Laying of Flow Line/Tie‐ins/Wellhead Works

No. Impact & Mitigation Measure Responsibility &

Execution

Action/Monitoring


1 Changes in Landscape and Soil Erosion

1.1 Land area requirements for construction camp and RoW

of flow line will be kept to the minimum required

PC, UEPL Check compliance After marking of the campsite

layout, RoW of flow line on

ground by the PC and prior to

clearing of land at these areas

1.2 Good engineering practices will be adopted during

construction activities to ensure that unnecessary clearing

of vegetation and disturbance to soils outside work areas

are avoided

PC, UEPL Monitor land clearing activities During construction activity

1.4 Topsoil of the RoW will be separately stored. This topsoil

will be backfilled after proper compaction ensuring

minimum loss of topsoil

PC, UEPL Check complaince During construction activity

1.5 Clearing of vegetation (especially dense vegetation) will

be minimized by careful selection of construction camp

and flow line alignment

PC, UEPL Monitor land clearing activities During construction activity

1.6 Cutting of trees or even tall shrubs will be avoided PC, UEPL Monitor land clearing activities During construction activity

1.7 Use of existing tracks with the required improvement

works will be maximized. Unless driven by community

demand construction of new tracks will be kept to the

minimum

PC, UEPL Check complaince During construction activity

1.8 Off‐road travel will be avoided PC, UEPL Monitor off‐road travel During construction activity



PC, UEPL Monitor vehicles speed During construction activity

1.10 Periodic trainings will be provided to drivers on

mitigation measures related to off‐road travel and speed

limits

PC, UEPL Check compliance During construction activity




Execution

Action/Monitoring



2.1 Approval to start of construction of flow line should only

be provided by UEPL representative after ensuring that

all waste management facilities (waste segregation units,

soak pits, septic tanks etc.), equipment (waste bins, drip

pans, tarpaulins etc.) and procedures (approvals for

waste contractors etc.), prescribed in the EIA are in a state

acceptable to the UEPL representative

PC, UEPL Approval for waste contractors,

check provision of waste

management facilities at

construction camp


2.2 Sewage will be disposed of into septic system comprising

of septic tanks and soak pits. The septic tanks should be

built of concrete and brick masonry to avoid leaching of

wastewater from the tanks

PC, UEPL Check provision of septic tank

and soak pit

During construction activity

2.3 Wastewater from laundry, kitchen washings and showers

will be disposed of into separate soak pits

PC, UEPL Check provision of soak pits During construction activity

2.4 Soak pits will be built in absorbent soil and located 300 m

away from a perennial surface water source or water well

PC, UEPL Check soil condition and




2.5 Soak pits should be covered and constructed such that

surface runoff cannot enter the pits. Soak pits will be

designed to accommodate wastewater generated during

the total duration of the operation

PC, UEPL Check design of the soak pit and

monitor construction. Monitor

provision of covers and berms


2.6 In case the soak pits get filled during the operation, grey

water will be discharged in the nearest municipal drains

after getting formal approval from local authorities.

Sprinkling of grey water will be not be allowed

PC, UEPL Monitor wastewater levels in the

soak pits


2.7 Sprinkling of sewage will not be allowed PC, UEPL Check compliance during

routine visits





Execution

Action/Monitoring


2.8 No solid waste will be disposed of in the field. Within the

construction camp all solid wastes will be disposed of in

waste bins provided in the camp area

PC, UEPL Monitor provision of sufficient

waste bins


2.9 All combustible material, non‐combustible and

hazardous wastes including plastic or glass bottles and

cans will be temporarily stored on site and sold/handed

over to a waste/recycling contractor who will utilize these

wastes for recycling purposes

PC, UEPL UEPL to approve waste

contractors. Monitor waste

segregation and safe

transportation to the recycling

contractorʹs facility


2.10 Burning of waste will not be allowed PC, UEPL Monitor compliance During construction activity

2.11 At the time of restoration septic tanks will be dismantled

in place and backfilled with at least 1 m of soil cover

PC, UEPL Monitor restoration activity At the time of restoration

2.12 At the time of restoration soak pits will be backfilled with

at least 1 m of soil cover

PC, UEPL Monitor restoration activity At the time of restoration

2.13 Clinical wastes will be temporarily stored onsite

separately and incinerated at nearest hospital or a similar

facility

PC, UEPL UEPL to approve disposal

arrangement. Monitor waste

segregation and safe storage

onsite


2.14 Soil contaminated by minor spills/leakages (defined as

leaks from vehicles, machinery, equipment or storage

containers such that the area and depth of soil

contaminated is less than 1 sq ft and 3 inches

respectively) should be scraped and disposed of

according to best industrial guidelines

PC, UEPL Monitor any oil leaks and

appropriate disposal





Execution

Action/Monitoring


2.15 Moderate spills defined as spills of volume less than or

equal to 200 liters should be contained and controlled

using shovels, sands and native soil. These equipment

and materials should be made available at construction

campsite. The contaminated soil should be excavated and

stored in a bunded area lined with an impermeable base.

Depending on the volume, the contaminated soil should

be disposed of in accordance to best industrial guidelines

PC, UEPL Ensure provision of equipment

and material to control and

handle such spills on site.

Monitor disposal as per the



2.16 Major spills (defined in the EIA as spills of volume much

greater than 200 liters) will require initiation of UEPLʹs

Emergency Response Procedures. These spills should be

handled and controlled according to the measures listed

in UEPL’s Oil Spill Contingency Plan and will require

special treatment such as bioremediation etc.

PC, UEPL Ensure that UEPL Emergency

Response Procedures and Oil

Spill Contingency Plan are

available onsite. Ensure

appropriate response is initiated

at the time of such incident.

UEPL to check that the plan is

understood by all key personnel


2.17 All fuel and oil storage areas should have a concrete pad

underneath to prevent soil contamination in case of leaks

or spills

PC, UEPL Ensure provision of concrete padDuring construction activity

2.18 All fuel tanks should be properly marked to highlight

their contents

PC, UEPL Ensure that proper signs are



2.19 Fuel and oil storage areas should have secondary

containment in the form of concrete or brick masonry

bunds. The volume of the containment area should be

equal to at least 125% of the total volume of fuel or oil

stored

PC, UEPL Check containment volume of

the bunded area





Execution

Action/Monitoring



drips and spills should be avoided by using drip

pans/trays

PC, UEPL Ensure provision of drips pans,


fuelling practices, monitor oil or

fuel transfer activity


2.21 Fuels tanks should be daily checked for leaks and all such

leaks should be plugged immediately

PC, UEPL Inspect fuel tanks for leaks During construction activity

2.22 Waste oil should be provided to waste contractors

approved by the UEPL where it will be re‐used/recycled

PC, UEPL UEPL to approve waste

contractor and monitor safe

transportation of the waste oil

During construction and

operation phase

2.23 Shovels, plastic bags and absorbent material should be

present near fuel and oil storage or handling areas to

attend spills and leaks

PC, UEPL Monitor presence of materials

and equipment


2.24 Vehicles should only be washed within designated areas

within campsite. Mechanical maintenance works should

be done only in workshops

PC, UEPL Ensure provision of washing

areas and maintenance

workshops and monitor any

non‐compliances with the EIA

requirement during routine

monitoring


2.25 Vehicles should be daily checked for fuel or oil leaks.

Vehicles with leaks should not be operated until repaired

PC, UEPL Randomly inspect vehicles and

designated parking areas


2.26 Water used for cleaning and hydro‐testing of flow line

will be collected in lined pits where it will evaporate with

time or drained into the nearest drainage channel with

the prior approval of concerned authority. The residual

sludge or solids and the liner will be disposed of

following best industrial practices

UEPL, PC Check compliance During hydro‐testing of flow

lines and site restoration




Execution

Action/Monitoring


2.27 Evaporation pits will be built at a distance of 300 m from

local water wells or any perennial surface water source

PC, UEPL Check location of pits according

to safe distance


3 Deterioration of Air Quality

3.1 Generators, vehicles and other equipment and machinery

used during the operation should be properly tuned and

maintained to minimize air emissions

PC, UEPL Check maintenance logs During construction activity

3.2 Construction campsite will be located at least 300 m away

from communities

PC, UEPL Check distances of campsite

from communities


campsite

3.3 Dust emissions due to road travel should be minimized

by regulating vehicles speed and watering of the access

track (where applicable)

PC, UEPL Set and monitor speed limits.


track


3.4 Dust emissions during construction activities should be

minimized by good management practices such as

locating stock piles out of the wind direction, keeping the

height of the stock piles to a minimum, keeping

earthwork areas damp etc.

PC, UEPL Monitor dust emissions during

earthworks. Train PC on good



3.5 Burning of wastes will not be allowed PC, UEPL Monitor compliance During construction activity

3.6 Access tracks used during laying of flow line passing

through communities will be avoided

PC, UEPL Check alignment of the access

track and monitor vehicles speed

Before and during construction

activity

3.7 Appropriate measures will be taken to avoid ozone

depletion & global warming e.g. prohibit use of CFC

gases etc.

PC Ensure compliance During construction activity

4 Noise Pollution

4.1 During all operations generators, vehicles and other

equipment and machinery will be maintained in a good

condition to ensure that noise from them is kept to a

minimum level

PC, UEPL Monitor noise levels During construction activity




Execution

Action/Monitoring


4.2 Noise levels at communities nearest to the construction

campsite should be monitored by UEPL and PC. In case

these are found to exceed safe acceptable limits

appropriate mitigation should be taken

PC, UEPL Monitor noise levels as part of

the Effects Monitoring


4.3 Construction campsite will be located at least 300 m away

from nearest communities

PC, UEPL Check distances from the

community


campsite

4.4 Generators will be kept within enclosures to minimize

dispersion of noise

PC, UEPL Check provision of enclosure During construction activity

4.5 The use of horns by project vehicles should be

minimized. The use of pressure horns should not be

allowed

PC, UEPL Train drivers, check vehicles and



4.6 Movement of all project vehicles and personnel should be

restricted to within work areas only

PC Advise all drivers and


from staff


4.7 Conduct regular noise monitoring as per applicable laws

and regulations

PC, UEPL Monitor compliance During construction activity

5 Use of Water

5.1 Water from surface water resources will not be used for

project activities


5.2 The quantity of water used during construction phase

will be kept to the minimum required by taking prudent

water conservation measures on site. A complete record

of water consumption will be maintained by the UEPL’s

Representative

PC, UEPL Monitor water consumption,

advise water conservation

measures





Execution

Action/Monitoring


5.3 In case local water well has to be used, it will be

approved by the UEPL Rep. Water from these tube wells

will only be used after ensuring that the available

capacity at the tube well (safe yield minus local demand)

is at least 50% greater than the project demand. Discharge

from the tube well will be regularly monitored to monitor

any changes in the yield of the wells. If a single well fails

to meet this requirement, water will be obtained from

multiple wells such that each well meets the above‐

mentioned requirement

PC, UEPL Approve water well, record

abstraction of water


5.4 If a new water well is to be installed, the well will be

located 300 m from existing local wells and will be

designed to abstract water preferably from deep aquifer

not being used by local communities

PC, UEPL Monitor distance from the

existing wells

Before drilling of new water

well

5.5 UEPL and project contractors will pay proper and

justified compensation for water utilized to the water

well owners

PC, UEPL Ensure compliance During construction activity

5.6 Contamination of surface and groundwater resources will

be prohibited

PC, UEPL Ensure compliance During construction and

operation

6 Blockage of Natural Drainage

6.1 Area around construction campsite should be landscaped

to avoid blocking natural drainage

PC Monitor landscaping and any

obstruction caused to natural

drainage


6.2 Causeway crossings will be provided during the laying of

flow line at all surface water bodies to avoid blocking of

natural drainage

PC, UEPL Ensure construction of causeway

crossings where required





Execution

Action/Monitoring


6.3 Uncontrolled & unnecessary clearing, dozing, excavations

or quarrying, storage of construction material etc. will be

avoided

PC Ensure compliance During construction activity

7 Site Restoration

7.1 Demobilization of all equipment and machinery PC, UEPL Ensure compliance During restoration phase

7.2 Disposal of any waste material remaining at the time of

completion of construction activities

PC, UEPL Ensure compliance During restoration phase

7.3 Backfilling of all soak pits and septic tanks


7.4 Dismantling and removal of fence or barriers

surrounding the campsite area


7.5 General restoration of the site area including landscaping

and restoration of drainage where required



8.1 Land area requirements for construction camp and RoW

of flow line will be kept to the minimum required

UEPL Check area of camp and width of

RoW


8.2 Construction campsite established for the purpose of

construction will be located in existing clearing and

levelled land

PC, UEPL Check location of campsite Before construction activity

8.3 Off‐road travel will be avoided PC, UEPL Monitor movement of vehicles During construction activity

8.4 During construction movement of construction

equipment will be restricted to work areas only to avoid

unnecessary disturbance to the native vegetation in the

project area

PC Check compliance During construction activity

8.5 The access track (if any) will be properly compacted at

the time of construction and thereafter properly

maintained throughout the entire operational life

PC, UEPL Monitor compaction of access

track





Execution

Action/Monitoring




PC, UEPL Regulate and monitor vehicles

speed


8.7 Periodic trainings will be provided to drivers on


limits

PC, UEPL Provide training to drivers During construction activity

8.8 Good engineering practices will be adopted during

construction activities to ensure that unnecessary clearing

of vegetation outside work areas is avoided

PC Train construction supervisors,

monitor construction activities


8.9 Topsoil of the RoW of flow line will be separately stored.

This topsoil will be backfilled after proper compaction

ensuring regeneration of vegetation

PC Check compliance During excavation and

backfilling operation

8.10 Cuttings of trees or tall shrubs will be avoided PC, UEPL Check compliance During construction activity

8.11 Use of local vegetation/wood as fuel will not be allowed PC, UEPL Check compliance During construction activity


9.1 Prior to commencement of construction activity,

awareness trainings will be provided to contractor’s

management and field crew on matters related to the

requirements of the EMP in this regard

UEPL, PC Provide environmental

awareness training


construction activity

9.2 Land uptake by project facilities will be minimized UEPL, PC Check compliance After marking of the site layout

on ground by the PC and prior

to clearing of land at these

areas

9.3 The total duration of construction phase will be

minimized by good management

PC, UEPL Check compliance During construction phase

9.4 All mitigation measures to minimize noise levels, dust

emissions, air emissions and waste management required

by the EIA will be adhered to





Execution

Action/Monitoring


9.5 Food wastes will not be disposed of in the open. Food

wastes collected in waste segregation units will be

disposed of according to waste disposal procedure on a

regular and strict basis as advised by the UEPL Rep

PC, UEPL Monitor collection and disposal

of food waste


9.6 Construction work near areas which show small mammal

and reptile populations will commence after a soft start

up and will be randomly monitored


9.7 Vehicles speed on access road will be controlled to avoid

incidental mortalities of reptiles. Any such incident will

be reported to the UEPL representative. Vehicles speed

will be randomly checked

PC, UEPL Monitor speed limits During construction activity

9.8 Cutting of trees or tall shrubs will be avoided PC, UEPL Check compliance During construction activity

9.9 Movement of all project personnel and vehicles will be

restricted to work areas and to approved routes only


9.10 Night work during construction will be prohibited, night

traveling will not be allowed unless absolutely necessary


9.11 Lights used at construction campsite will be kept to the

minimum required

PC, UEPL Check compliance During installation of lights

9.12 Hunting, fishing, killing, feeding, trapping or harassment

of wildlife will not be allowed


9.13 Within the sensitive habitats of wildlife, operation will be

completed within the shortest time possible PC, UEPL Ensure compliance During construction activity

10 Socioeconomic, Archaeological and Cultural Environment

10.1 Local sources of drinking water will not be exploited PC, UEPL Monitor adherence with the

requirements


10.2 The access road will be watered regularly to minimize

dust emissions

PC, UEPL Monitor water sprinkling During construction activity




Execution

Action/Monitoring


10.3 RoW for flow line should by‐pass major settlements to

maintain safe distances

UEPL, PC Check alignment of flow line Before construction activity

10.4 Drivers will be trained in responsible and safe driving

practices, safe speed limits for vehicles will be followed

PC, UEPL Provide training and monitor

compliance


10.5 Strict compliance will be observed with UEPL’s HSE

guidelines

UEPL, PC Ensure compliance During construction activity

10.6 Labour from local communities will be recruited

equitably amongst the various tribes, avenues for conflict

resolution will be open and the employment procedures

will be transparent

PC, UEPL Monitor adherence with the

requirement and maintain

record of labour


10.7 Use of local firewood for cooking or heating by project

and contractor staff to be prohibited

PC, UEPL Monitor adherence with the

requirement


10.8 The vehicles speed for traveling along the access road

will be limited

PC, UEPL Monitor speed limits During construction activity

10.9 The construction campsite will be located at minimum

distance of 300 m from communities thereby, mitigating

the effect of noise and emissions

UEPL, PC Check distances Before construction activity

10.10 Any land acquired and distribution of compensation will

be carried out transparently

UEPL Check compliance Before construction phase

10.11 All mitigation measures related to waste management,

minimizing air emissions and noise recommended in the

EIA should be adhered with


10.12 Project staff will respect cultural norms PC, UEPL Check compliance During construction activity

10.13 All community grievances will be addressed and rectified

as appropriate


10.14 All project facilities will be restored according to the

standard protocols and recommendations of the EIA

UEPL, PC Check compliance During restoration




Execution

Action/Monitoring


10.15 During project communication links with local

communities will be maintained

PC, UEPL Check compliance During construction and

operation

10.16 During construction, all cultural, religious and

archaeological sites will be identified (if found) and

mitigation measures specified in the EIA will be followed

PC, UEPL Check compliance During construction and

operation

10.17 RoW of flow lines will maintain a distance of 100 m from

cultural, religious and archaeological sites, unless

community demands a greater distance e.g. graveyards

or mosques

UEPL, PC Check compliance During construction and

operation

Notes: UEPL: United Energy Pakistan Limited’s Management or Representative; PC: Project Contractor/s



Table A‐4: Mitigation Management Matrix for Establishment/Construction of GPF/CPP


Execution

Action/Monitoring


1 Changes in Landscape and Soil Erosion

1.1 Total land uptake by the construction contrator campsite/s

will be kept to the minimum required

UEPL, IMC, CC Check compliance After marking of the site layout

on ground by the CC and prior

to clearing of land at these areas

1.2 Contractor campsite/s will preferably be located in existing

clearing and levelled land and will avoid major earthworks

UEPL, IMC, CC Location of campsite in levelled

areas

Prior to site layout on ground

1.3 Existing access track/s to the GPF/CPP will be used as much

as possible

CC, UEPL, IMC Monitor off road travel and



1.4 To minimize erosion due to quarrying, the quarry sites will be

carefully selected such that they are located in levelled areas

with existing clearing and the quarry sites will be properly

restored after use

CC, UEPL, IMC Check compliance Prior to execution

1.5 Access track to the GPF/CPP will be properly compacted at

the time of construction and associated activities and

thereafter properly maintained throughout the entire

operational life

CC, UEPL, IMC Check compliance Compaction during execution to

minimize dust emissions and

loose sections of the track for the

use of entire operation

1.6 Off‐road travel should be strictly prohibited and observance

of this should be monitored during the operation

CC, UEPL, IMC Advise all personnel, monitor

any staff complaints and signs

of off‐road travel


1.7 Vehicles speed should be regulated and monitored to avoid

excessive dust emission

CC, UEPL, IMC Set speed limits, train drivers

and monitor non‐compliances


1.8 Clearing of vegetation and the cutting of trees will be

minimized as much as possible

CC, UEPL, IMC Monitor land clearing activities During design and construction

1.9 Movement of construction equipment should be restricted to

work areas only to avoid unnecessary disturbance to soils in

the project area

CC, IMC Monitor movement of vehicles

and off‐road travel

During Construction activity



Execution

Action/Monitoring


1.10 UEPL will monitor the access tracks (other than the main

access track for the project) to be used by water tankers,

dumper trucks and other vehicles

UEPL, CC, IMC Sprinkling of water on access

track to water wells


1.11 Periodic trainings should be provided to drivers on


limits

UEPL, CC, IMC Check training log, provide

trainings



2.1 Food waste and combustible packaging wastes that have no

re‐use should be stored temporarily onsite within designated

waste segregation areas for ultimate safe disposal

CC, UEPL, IMC Provision of sufficient waste

bins, segregation of waste


2.2 Dedicated waste segregation units/containers should be built

or placed at GPF and campsites

CC, UEPL, IMC Construction and monitoring of

waste segregation units

During entire project

2.3 Recyclable wastes including glass, tins, and metal scrap

should be provided to recycling contractors as appropriate

CC, UEPL, IMC IMC to approve waste

contractors. Monitor waste

segregation and safe

transportation to the recycling

contractorʹs facility


2.4 Waste oil should be provided to contractors for recycling as

appropriate. Recycled oil will not be brought back to site

CC, UEPL, IMC IMC to approve waste

contractor and monitor safe

transportation of the waste oil


2.5 Medical wastes should be temporarily stored onsite

separately and incinerated at a suitable location

CC, UEPL, IMC UEPL Rep to approve disposal

arrangement. Monitor waste

segregation and safe storage

onsite


2.6 Wastes should not be disposed of in the open CC, UEPL, IMC Monitor during routine visits During the entire operation

2.7 For collection of wastes at the GPF and campsite adequate

number of waste bins should be provided

CC, IMC Monitor provision of sufficient

waste bins




Execution

Action/Monitoring


2.8 Grey wastewater should be collected directly into septic tanks

and then to soak pits. Sprinkling of grey wastewater will not

be allowed

CC, IMC, UEPL Check provision of soak pits

and quality of wastewater


2.9 Sewage generated from the toilets should be collected and

treated in septic tanks. The septic tanks should be built of

concrete and brick masonry to avoid leaching of wastewater

from the tanks. The overflow from the tanks should discharge

into soak pits. In case the soak pits get filled the wastewater

shall be transferred from the site in a tanker and disposed of

into municipal drains in the nearest area

CC, UEPL, IMC Check provision of septic tank

and soak pit. Monitor

wastewater levels in the soak

pits


2.10 Soak pits should be built in absorbent soil and located 300 m

away from a surface water source or a groundwater well

CC, UEPL, IMC Check soil condition and



During design and construction

2.11 Soak pits should be covered and constructed such that surface

runoff cannot enter the pits

CC, UEPL, IMC Monitor provision of covers

and berms

Provision of berms during

construction and proper covers

during the entire operation

2.12 Soil contaminated by minor spills/leakages (defined as leaks

from vehicles, machinery, equipment or storage containers

such that the area and depth of soil contaminated is less than

1 sq. ft and 3 inches respectively) should be scraped and

treated as appropriate

CC, UEPL, IMC Monitor any oil leaks and safe

disposal of contaminated soil




Execution

Action/Monitoring


2.13 Moderate spills defined as spills of volume less than or equal

to 200 liters should be contained and controlled using

shovels, sands and native soil. These equipment and

materials should be made available at GPF/CPP and campsite

during the operation. The contaminated soil should be

excavated and stored in a bunded area lined with an

impermeable base. Depending on the volume, the

contaminated soil should be properly buried in such a

manner that it does not contaminate the surrounding soils or

groundwater

CC, UEPL, IMC Ensure provision of equipment

and material to control and

handle such spills on site.

Monitor disposal as per the



2.14 Major spills (defined in the EIA as spills of volume much

greater than 200 liters) will require initiation of UEPLʹs

Emergency Response Procedures. These spills should be

handled and controlled according to the measures listed in

UEPL’s Oil Spill Contingency Plan and will be disposed of as

per methods defined in UEPL’s Oil Spill Contingency Plan

UEPL, CC, IMC Ensure that UEPL Emergency

Response Procedures and Oil

Spill Contingency Plan are

available onsite. Ensure

appropriate response is

initiated at the time of such

incident. IMC to check that the

plan is understood by all key

personnel


2.15 All fuel and oil storage areas should have a concrete pad

underneath to prevent soil contamination in case of leaks or

spills

CC, UEPL, IMC Ensure provision of concrete

pad


2.16 All fuel tanks should be properly marked to highlight their

contents

CC, UEPL, IMC Ensure that proper signs are



2.17 Fuel and oil storage areas should have secondary

containment in the form of concrete or brick masonry bunds.

The volume of the containment area should be equal to at

least 125% of the total volume of fuel or oil stored

CC, UEPL, IMC Check containment volume of

the bunded area




Execution

Action/Monitoring



drips and spills should be avoided and drip pans should be

used

CC, UEPL, IMC Ensure provision of drips pans,


fuelling practices, monitor oil

or fuel stains


2.19 Fuel tanks should be regularly checked for leaks and all such

leaks should be plugged immediately

CC, UEPL, IMC Inspect fuel tanks for leaks During the entire operation

2.20 Shovels, plastic bags and absorbent material should be

present near fuel and oil storage or handling areas to attend

spills and leaks

CC, UEPL, IMC Monitor presence of materials

and equipment


2.21 Vehicles should only be washed within designated areas

within campsites. Mechanical maintenance works should be

done only in workshops

CC, UEPL, IMC Ensure provision of washing

areas and maintenance

workshops and monitor any

non‐compliances with the EIA

requirements during routine

monitoring


2.22 Vehicles shall be daily checked for fuel or oil leaks. Vehicles

with leaks shall not be operated until repaired

CC, UEPL, IMC Randomly inspect vehicles and

designated parking areas


2.23 Produced water separated at GPF/CPP shall be re‐injected to

reservoir through deep well injection (first priority).

However, it can be sent to lined E‐Pond if no technical

feasible options are available

CC, UEPL, IMC Check compliance During the entire operation

3 Climate and Ambient Air Quality

3.1 Campsites will be located at least 300 m away from

communities

UEPL, CC, IMC Check Compliance Before construction

3.2 Generators, compressors and vehicles used should be

properly tuned and maintained to minimize air emissions

CC, UEPL, IMC Check maintenance logs During the entire operation



Execution

Action/Monitoring


3.3 Dust emissions due to road travel should be minimized by

regulating vehicles speed and watering of the access track

(where applicable)

CC, UEPL, IMC Set and monitor speed limits.


track


3.4 Dust emissions during construction activities should be

minimized by good management practices such as locating

stock piles out of the wind direction, keeping the height of the

stock piles to a minimum, keeping earthwork areas damp etc.

CC, UEPL, IMC Monitor dust emissions during

earthworks. Train CC on good


During the construction

operation

3.5 During detailed design of the GPF/CPP, emissions from point

sources such as flare and incinerator (for acid gases) should

be modelled so that if there are any ill‐effects on local

communities and workers appropriate mitigation measures

such as adjusting the stack heights can be taken

UEPL, CC, IMC Check compliace During the entire operation

3.6 During construction leveling or widening along the access

road will be done in sections, immediately followed by

sprinkling of water and also preferably compaction (where

required)

CC, UEPL, IMC Access road construction/

maintenace


3.7 Emissions from all point sources should be monitored to

check compliance with SEQS

UEPL, CC, IMC Ensure monitoring being

conducted


4 Noise Pollution

4.1 It shall be ensured that generators, vehicles and other

potentially noisy equipment used are in good working

condition

CC, UEPL, IMC Monitor noise levels Prior to use of machinery and

vehicles

4.2 Noise levels at communities nearest to the GPF/CPP,

campsite and access track should be monitored and in case

these are found to exceed safe acceptable limits appropriate

mitigation shall be taken

UEPL, CC, IMC Monitor noise levels as part of

the Effects Monitoring Program

Frequency of monitoring

specified in the Effects

Monitoring Program

4.3 Campsite/s will be located 300 m away from nearest

communities

CC, UEPL, IMC Check distances from the

community

Prior to construction



Execution

Action/Monitoring


4.4 The use of horns by project vehicles should be minimized.

The use of pressure horns should not be allowed

CC, UEPL, IMC Train drivers, check vehicles

and record non‐compliances


4.5 Movement of all project vehicles and personnel should be

restricted to within work areas only

CC, UEPL, IMC Advise all drivers and


from staff


4.6 Provide noise barriers/enclosures to control noise levels from

generators and mechanical workshops etc. Moreover,

locate/setup noisy equipment or machinery as far as possible

from nearby receptors

UEPL, CC, IMC Check provision of noise

barriers/enclosures

During construction phase

4.7 Conduct regular noise monitoring as per applicable laws and

regulations

UEPL, CC, IMC Ensure compliance During the entire project

5. Use of Water

5.1 Water from surface water bodies will not be used CC, UEPL, IMC Check compliance During the entire operation

5.2 The quantity of water used during construction and operation

will be kept to the minimum required by taking prudent

water conservation measures on site. A complete record of

water consumption will be maintained

CC, UEPL, IMC Monitor water consumption,

advise water conservation

measures


5.3 Marginally sweet water wells will be used for constrution and

other project related activities. Where possible, use of

brackish water should be maximized for the project activities.

Discharge from the water well will be regularly monitored to

monitor any changes in the yield of the wells

CC, UEPL, IMC Approve water well, record

extraction of water


5.4 If a new water well is to be installed, the well will be located

300 m from existing local wells and will be designed to

abstract water preferably from deep aquifer not being used by

local communities

UEPL, IMC Ensure safe distance from

community water wells

During or before project activity



Execution

Action/Monitoring


5.5 Utilization of water resources that are in possession of local

owners shall be appropriately compensated as per mutual

agreement of both parties

CC, UEPL, IMC Ensure that proper

compensation is being paid


5.6 Preferably, the potable water requirement will be met by

installing water treatment system (such as reverse osmosis)

UEPL, CC, IMC IMC to guide on preservation

of water


6. Blockage of Natural Drainage

6.1 Area around the GPF/CPP and campsite shall be landscaped

to avoid blocking natural drainage

CC, UEPL, IMC Monitor landscaping and any

obstruction caused to natural

drainage

During the construction activity

6.2 Causeway crossings and pipe culverts will be provided at

stream crossings to avoid blockage of natural drainage

CC, UEPL, IMC Ensure construction of culverts

where required particularly

along the access track


6.3 Uncontrolled & unnecessary clearing, dozing, excavations or

quarrying, storage of construction material etc. will be

avoided

CC, IMC Ensure compliance During construction activity


7.1 Total land uptake will be kept to the minimum required UEPL Check compliance After marking of the site layout



7.2 Off‐road travel, required at sections of the road where

construction work is in progress, will be minimized and if

required will be allowed only after approval from UEPL Rep

CC, UEPL, IMC Train drivers and investigate

non‐compliances


7.3 Campsite areas will be located in existing cleared area CC, IMC, UEPL Supervise camp setup During setup of the construction

camps

7.4 The access track to the GPF/CPP will be selected to utilize

existing track as much as possible

CC, UEPL, IMC Ensure existing track to used as

much as possible

During selection of access track



Execution

Action/Monitoring


7.5 Clearing of vegetation will be avoided as much as possible.

Under unavoidable circumstances any clearing required will

be done with prior approval of IMC and custodian of the

area. Each tree cutting for clearing of site will be

replaced/compensated by plantation of trees at site (10 trees

for each tree cut). The tree species shall be indigenous to the

region

CC, UEPL, IMC Supervise land clearing

activities

During land clearing for the

campsites

7.6 Periodic trainings will be provided to drivers on mitigation

measures related to off‐road travel and speed limits

CC, UEPL, IMC Check training log, provide

trainings


7.7 Dust emissions on access tracks will be reduced by keeping

speed limits below 40 km/hr





7.9 Use of local vegetation as fuel will not be allowed CC, UEPL, IMC Check compliance During the entire operation

8. Disturbance to Wildlife

8.1 Prior to commencement of construction, awareness trainings

will be provided to contractor’s management and field crew

on HSE awareness

UEPL Provide environmental

awareness training


construction

8.2 Land uptake will be kept to minimium required UEPL, CC, IMC Check compliance After marking of the site layout



8.3 All mitigation measures to minimize noise levels, dust

emissions, air emissions, and waste management required by

the EIA will be adhered to


8.4 Food wastes will not be disposed of in the open CC, UEPL, IMC Monitor collection and disposal

of food waste




Execution

Action/Monitoring


8.5 Vehicles speed on access road will be controlled to avoid

incidental mortalities of reptiles. Any such incident will be

reported to all concerned departments with copy to

departmental heads. Vehicles speed will be randomly

checked

UEPL, CC, IMC Monitor speed limits During the entire operation

8.6 Cutting of trees will be avoided as much as possible CC, IMC Check compliance During Construction activity

8.7 Movement of all project personnel will be restricted to work

areas only

UEPL, CC, IMC Check compliance During entire operation

8.8 Movement of project vehicles will be restricted only to the

project access road or to routes approved by UEPL’s Rep

UEPL, CC, IMC Check compliance During the entire operation

8.9 Night travelling will only be done after getting approval from

UEPL’s Rep


8.10 Lights used at the GPF/CPP and campsite will be kept to the

minimum required

CC, UEPL, IMC Ensure that the EIA

requirement are met


8.11 Hunting, fishing or trapping of wildlife will not be allowed UEPL, CC, IMC Check compliance During the entire operation

8.12 Feeding or harassment of wildlife will not be allowed UEPL, CC, IMC Check compliance During the entire operation

9 Socioeconomic, Archaeological and Cultural Environment

9.1 Project contractors and field staff shall be taken through a

Community and External Affairs Induction program before

execution of project activities

UEPL Ensure training to contractors Before start of project activities

9.2 Local sources of drinking water will not be exploited UEPL, CC, IMC Monitor adherence with the

requirement


9.3 The access road will be watered regularly to minimize dust

emissions (if required)

UEPL, CC, IMC Monitor water sprinkling During the entire operation

9.4 Construction of by passes to all major settlements and where

necessary re‐routing the access road so that a safe distances is

maintained from a settlement

UEPL, CC, IMC Check alignment of access

routes




Execution

Action/Monitoring


9.5 Drivers will be trained in responsible and safe driving

practices, a speed limit shall be set and maintained in

addition vehicle log books will be maintained and inspected

for compliance

UEPL, CC, IMC Provide training and monitor

compliance


9.6 Labour from local communities will be recruited equitably

amongst the various tribes subject to company’s competency

criteria

UEPL, CC, IMC Monitor adherence with the

requirement and maintain

record of labour


9.7 Use of local firewood for cooking by contractor staff to be

prohibited

CC, IMC Monitor adherence with the

requirement


9.8 Campsite will be located at minimum distance of 300 m from

nearest residential communities thereby mitigating the effect

of noise and emissions

UEPL, CC, IMC Check the distance Before construction activity

9.9 Generators and vehicles will be regularly maintained to

minimize emissions

UEPL, CC, IMC Monitor air emissions During the entire operation

9.10 Project staff will respect cultural norms UEPL, CC, IMC Check compliance During the entire operation

9.11 Access road will be re‐aligned to maintain safe distance from

the edge of any graveyard and shrine (if found)

UEPL, CC, IMC Check distance Before and during construction

9.12 All community grievances will be addressed and rectified

appropriately

UEPL, CC, IMC Check compliance During the entire operation

Notes: CC: Construction Contractor; IMC: Independent Monitoring Consultant; UEPL: Management or Representative of United Energy Pakistan Limited



Table A‐5: Recommended Distances from Environmental Features during Seismic Operation

Item Distance

New access track/s 50 m from all surface water sources

100 m from archaeological significant and cultural sites (including

graveyard, religious sites and shrines)

100 m from villages (if and where possible)

Campsite/s 300 m from villages/town/city

Upholes 30 m from water wells

50 m from houses

50 m from surface water bodies

50 m from reptile hole/nest/den



Shot holes 50 m from water wells

50 m from houses

50 m from surface water bodies

50 m from reptile hole/nest/den



Table A‐6: Recommended Distance from Environmental Receptors during Drilling and Flow Line

Laying/Wellhead Works

Area/Facility

Distance (m)

Community Community

Water Well

Archaeological or

Cultural Site

Well site 300 300 300

Rig camp 300 300 300

Soak pits NA 300 m from

ground/surface

water resources

NA

RoW of flow line 100 100 50

Construction camp 300 300

Minimum distances of various project activities from environmental receptors (not mentioned in this table) will be decided

during project execution phase.



Table A‐7: Minimum Distance from Environmental Receptors during Establishment/

Construction of GPF/CPP

Area/Facility

Distance (m)

Community Community Water

Well

Archaeological or Cultural

Site

Construction camp 300 300 300

Quarry location 1,000 300 300

Soak pits NA 300 m from

ground/surface water

resources

NA

Minimum distances of various project activities from environmental receptors (not mentioned in this table will be decided

during project execution phase.


Table A‐8: A Tentative Frequency of Monitoring Mitigation Measures

Item Frequency

Line inspections Prior to start work on any seismic line

Access track inspection Prior to start work on any of access track development

Camp construction At the time of camp construction

Waste disposal at campsites Once a week as a minimum

Waste disposal at rig site & GPF Daily during routine field visits

Waste disposal along access tracks

and survey lines

Daily during routine field visits

Water use Once every week

Recycling contractors At the time of approval and then once during the operation

Access tracks and road travel Daily during routine field visits

Preparation of survey lines During survey of seismic lines

Shot holes/Upholes drilling,

shooting and recording

On a routine basis on selected seismic lines

Vehicles – Field inspections Daily during routine field visits

Vehicles – Camp inspections Twice a week as a minimum

Handling of fuels, oils and

chemicals

Once during camp construction & twice a week during

camp operation

Condensate storage Daily during routine field visits

Chemical storage Once every week

General controls Daily during routine field visits

Restoration During restoration



Table A‐9: Effects Monitoring Requirements

Parameter Potential Issue Monitoring

Parameter

Method Frequency Responsibility

Physical Parameters

Water Water lowering of

groundwater table or

reduced discharge in

water wells used by the

project and within 300 m

radius

Water well

discharge

Volumetric

discharge

measurement

Monthly during each

project

United Energy

Pakistan Limited

Limited (UEPL)


Wildlife Disturbance to wildlife

including key species of

the project area

Presence and

distribution

of wildlife in

the area of

operation

Wildlife surveys For each project the

frequency will be as

follows: Pre‐project, at

regular intervals during

the projects and after

restoration

Independent

Monitoring Team

(IMC)

Socioeconomic Environment

Communities Disturbance to

communities and

community complaints

Community

complaints

Community

consultation and

community

complaints register

Consultation with

communities through

UEPL’s site representative

prior to and throughout

each project

United Energy

Pakistan Limited

Limited (UEPL)



Table A‐10: Suggested Training Program

Project Activity Staff Contents

Seismic, Construction (all

activities) and Drilling

Drivers Road safety

Road restrictions

Vehicles restrictions

Waste disposal

Seismic and Construction

(all activities)

Survey Crew Wildlife sensitivities

Identification of sensitive areas

Communication of environmental problems to

appropriate personnel

Waste disposal



Bulldozer Operators Wildlife sensitivities

Identification and avoidance of sensitive areas

Waste disposal

Communication of environmental problems to

appropriate personnel



Mechanics and

Vehicles Operators

All Personnel

Environmental controls of

vehicles and equipment

Waste disposal



Camp Staff Safe camp operation

Waste disposal



Restoration and Clean‐

up Team

Restoration requirements

Note: ‘Construction’ activities also include construction of flow lines and GPF/CPP


OCTOBER 2019 HPK

Appendix B Environmental Monitoring Checklists


OCTOBER 2019 B-1 HPK

Checklist for Camp Establishment

No. Description Status Additional

Comments

1. Has the campsite been selected in consultation with

HSEO? Yes No

2. Have photographs been taken to record the pre‐

camping conditions? Yes No

3. Has the campsite been selected in existing clearings

and on levelled land? Yes No

4. Has the campsite been selected at least 300 meters

away from any communities? Yes No

5. Has the campsite been selected 300 meters from any

surface water body? Yes No

6. Have compensation amounts been settled based on

prevailing market rates? Yes No

7. Has any vegetation been cleared? Yes No

8. If yes, is the vegetation loss significant? Yes No

9. If yes, have the mitigation measures specified in the

EIA been adhered with? Yes No

10. Has the top soil been damaged significantly or root

stock destroyed? Yes No

11. Have the trees or bushes been used as fuel wood? Yes No

12. Have any trees been cut? Yes No

13. Has the natural drainage been disturbed or blocked? Yes No

14. Does the campsite have a septic system comprising of

septic tank and soak pit? Yes No

15. Have the soak pits for laundry, kitchen and showers

been built? Yes No

16. Have the soak pits been built in absorbent soil? Yes No

17. Have the soak pits (where required) been built down‐

slope from the camp? Yes No

18. Have the soak pits been designed to accommodate

wastewater generated during the total duration of the

operation?

Yes No

19. Are the soak pits within 300 meters of any surface

water source or a ground well? Yes No

20. Can surface water enter the soak pits? Yes No

21. Has plastic sheeting been placed under all concreted

structures? Yes No

22. Have all other mitigations measures specified in the

EIA been adhered to? Yes No

23. Are UEPL’s HSE guidelines being followed? Yes No

Name: Signature:

Date:



Additional Comments



Checklist for Camp Operation


Comments

1. Has any vegetation been cleared or damaged? Yes No

2. Are bushes or trees been used as fuel wood? Yes No

3. Is water drawn from a local water source? Yes No

4. If yes to point 3, has the yield and demand been

determined to ensure there is enough to meet the

requirements of the locals?

Yes No

5. If yes to point 3, is water well discharge being checked

and recorded on a regular basis? Yes No

6. If yes to point 3, is compensation being paid for the

water use? Yes No

7. Has the natural drainage been disturbed? Yes No

8. Are the fuels and oils handled in a safe manner,

ensuring no leakage or spillage? Yes No

9. Are the soak pits being constructed 300 meters away

from a surface water source or groundwater well? Yes No

10. Has any surface water entered the soak pits? Yes No

11. In case the soak pits get filled during the operation, has

the grey water been transferred to the nearest

municipal drains?

Yes No

12. Is sprinkling of wastewater being done on site? Yes No

13. Has arrangements for the transportation of black water

to the municipal drains been in placed? Yes No

14. Are there enough waste bins around the camp? Yes No

15. Are the waste bins emptied on a regular basis? Yes No

16. Is food waste disposed in the open? Yes No

17. Has the burning of wastes been practiced? Yes No

18. Is the combustible and non‐combustible waste being

sent to the approved waste contractor(s)? Yes No

19. Is medical waste being stored separately at the

campsite? Yes No

20. Is medical waste being disposed of properly i.e.

incinerated? Yes No

21. Are water consumption figures being maintained? Yes No


23. Have requirements of the EIA been adhered to? Yes No

Name: Signature:

Date:

Additional Comments



Checklist for Vehicles


Comments

1. Are the vehicles maintained and inspected regularly? Yes No

2. Are the oil, fuel and other leaks from the vehicles

immediately attended to? Yes No

3. Are the vehicles with leaks being operated? Yes No

4. Has there been any spillage during vehicle re‐fueling

or maintenance? Yes No

5. If yes, have recommended mitigation measures been

adhered to? Yes No

6. Are the vehicles being washed or serviced in the field? Yes No

7. Are the vehicles being washed in designated areas

having concrete pad and wastewater collection pits? Yes No

8. Is vehicle related waste, such as oils, filters, old tires or

parts are left unattended? Yes No

9. Is vehicle related waste, such as oils, filters, old tyres or

parts being disposed of properly? Yes No

10. Are the vehicles emitting excessive smoke? Yes No

11. Do the potentially noisy vehicles have properly

functioning silencers (mufflers)? Yes No

12. Do all vehicles have provision for containers/trash

bags to store trash/refuse? Yes No




Name: Signature:

Date:

Additional Comments



Checklist for Road Travel


Comments

1. Is the number of routes kept to a minimum? Yes No

2. Have photographs been taken to record pre‐usage

conditions? Yes No

3. Are the existing routes being used to access the

desired locations? Yes No

4. Have new access routes been developed? Yes No

5. If yes, have requirements of the EIA been adhered to? Yes No

6. Has vegetation clearing been minimized? Yes No

7. Has off‐road travel been observed or short cuts been

used? Yes No

8. Is vehicle speed limit of 30‐40 km/hr being followed? Yes No

9. Are heavily traveled routes watered (wherever

required) on a daily basis to minimize dispersion of

dust?

Yes No

10. Are the drivers careful and watchful about wild and

domestic animals? Yes No

11. Has any natural drainage been disturbed or altered? Yes No

12. Is any soil erosion observed? Yes No

13. If yes, have the mitigation measures been adhered to? Yes No

14. Is night travel avoided? Yes No

15. Is the use of horns avoided as far as possible? Yes No

16. Are pressure horns being used? Yes No

17. Do the vehicles carry adequate containers/trash bags

for litter/garbage and are they emptied at the

campsite or other designated location regularly?

Yes No

18. Are there any damages caused by project activities to

canals, watercourses, local roads or other

infrastructure (where applicable)?

Yes No

19. If yes, are these damages being repaired/compensated

as per mutual agreed terms? Yes No




Name: Signature:

Date:

Additional Comments



Checklist for Fuels, Oils and Chemicals


Comments

1. Do the fuel storage facilities have adequate secondary

containment up to 125% capacity in case of leakage or

spillage?

Yes No

2. Is there any other combustible or flammable material

in the fuel storage area? Yes No

3. Is regular inspection carried out to check leaks and

spills? Yes No

4. Have the entire oil and fuel storage areas concrete floor

underneath to prevent soil contamination from leaks

or spills?

Yes No

5. Are the fuel tanks properly marked with their

contents? Yes No

6. Are the fuel transfer arrangements protected against

spills? Yes No

7. Are the drip trays/pans being used? Yes No

8. Are tarpaulin sheets placed under equipment and fuel

containers that have the potential to spill or drip? Yes No

9. Is the fuel transfer operation being supervised in the

field? Yes No

10. Are the spills and leaks thoroughly cleaned? Yes No

11. Are the spilled oil or fuel and used clean‐up material

being disposed properly? Yes No

12. Are the spills and leaks reported and recorded? Yes No

13. Is contaminated soil being removed or covered

following proper clean‐up procedures? Yes No

14. Is the environmental emergency response plane

available on site? Yes No

15. Is the UEPL’s emergency response plan being followed

for spills and leaks (moderate or major spills)? Yes No

16. Has all the mitigation measures suggested in the EIA

been adhered to? Yes No


Name: Signature:

Date:

Additional Comments



General Environmental Checklist


Comments

1. Are activities taking place in agricultural or grazing

areas? Yes No

2. If yes, have compensation amounts being settled as per

mutual agreed terms or prevailing market rates? Yes No

3. Are permitting staff informing village leaders of

location and timing of all major activities? Yes No

4. Is a community complaints register being managed

and maintained? Yes No

5. Are there any damages caused by project activities to

canals, watercourses, local roads or other

infrastructure (where applicable)?

Yes No

6. If yes, are these damages being repaired/compensated

as per the recommendations of the EIA? Yes No

7. Are the cultural norms being respected by the project

staff? Yes No

8. Has off‐sets been provided from sites of religious,

cultural or archeological significance (if found)? Yes No

9. Is trash, wrappers, shopping bags, paper, cans, bottles

or any other kind of litter being left out in the open? Yes No

10. Have measures been taken to protect the vegetation of

the area? Yes No

11. Is the HSEO immediately notified of any wildlife

sightings and are the sightings logged? Yes No

12. Is the “no hunting, no killing, no feeding, no

harassment, no fishing and no trapping” policy strictly

enforced?

Yes No

13. Are any archeological sites or places of cultural or

religious significance disturbed? Yes No

14. In the event of incidental discoveries of archaeological

sites, are the contingency measures followed? Yes No

15. Is the “no shortcuts” policy followed? Yes No




Name: Signature:

Date:

Additional Comments



Checklist for Restoration and Rehabilitation of Drilling Sites


Comments

General

1. Have the erosion control measures been taken where

needed? Yes No

2. Has the contaminated soil been removed and disposed

of appropriately? Yes No

3. Have the sites been inspected to ensure the

recommended restoration measures have been strictly

adhered to?

Yes No

For Dry or Producing Well

1. Has the outer chainlink fence for producing well been

retained? Yes No

2. Has the wellhead for producing well been enclosed by a

locked steel cage for further production operations

work?

Yes No

3. Has all equipment and machinery at the dry well site

been demobilized? Yes No

4. Has all wastes at the well site been disposed of

properly? Yes No

5. Has liner from the water and waste pits at the dry well

site been taken out and re‐used or disposed of properly? Yes No

6. Have all concrete structures at the dry well site been

broken and either transported out of the project area by

the demolition or site restoration contractors for sale or

reuse or disposed of into the pits?

Yes No

For Campsites, Access Route

1. Have the camping sites been restored as close as

possible to the original condition? Yes No

2. Have the campsites been cleaned, leaving no refuse or

wastes behind? Yes No

3. Have the routes been restored as close as possible to the

original condition? Yes No

4. Have all the soak pits and septic tanks been backfilled

with an extra cap of 1 meter soil on top to cater

compaction?

Yes No


Name: Signature:

Date:

Additional Comments



Checklist for Laying of Seismic Lines


Comments

1. Have photographs been taken to record pre‐survey

conditions? Yes No

2. Has proper offsets been given from settlements? (if

any) Yes No

3. Has proper offsets from surface water bodies been

given? (if any) Yes No

4. Has proper offsets been provided to local water

sources or other water sources? Yes No

5. Has minimum distances from environmental receptors

been maintained from wetlands during data

acquisition?

Yes No

6. If yes, was it absolutely minimized? Yes No

7. Were any trees felled? Yes No

8. Were any trees or bushes burnt or disposed of? Yes No

9. Has soil erosion been observed as a result of the survey

related activities? Yes No

10. If yes, are mitigation measures needed? Yes No


EIA being adhered to? Yes No

12. Are whitewashed rocks used to mark survey lines? Yes No


Name: Signature:

Date:

Additional Comments



Checklist for Shooting and Recording


Comments

1. Are the holes drilled deeper than required? Yes No

2. Is the hole diameter larger than required? Yes No

3. Are the charges set at the specified depth? Yes No

4. Have the bird nests, small mammals and reptile holes

and carnivore Dens/caves being avoided during deep

holes and up holes operation?

Yes No

5. Is the charge quantity kept to a minimum, according to

the requirement? Yes No

6. Are deep holes packed with sand before shooting? Yes No

7. Is vegetation clearing avoided for drilling the holes? Yes No

8. Are the shot hole locations restored after the

recording? Yes No

9. Are all flagging, survey stakes and debris removed

after the recording? Yes No

10. Is refuse and waste collected and sent to the campsite

for proper disposal? Yes No

11. Has night traveling been observed? Yes No




Name: Signature:

Date:

Additional Comments



Checklist for Restoration & Rehabilitation of Seismic Operation


Comments

1. Have the campsite been restored as close as possible to

the original condition? Yes No

2. Have the campsite been cleaned, leaving no refuse or

wastes behind? Yes No

3. Have the routes been restored as close as possible to

the original condition? Yes No

4. Have the survey lines been restored as close as

possible to the original condition? Yes No

5. Have all flags, stakes, signs and refuse been removed? Yes No

6. Have all holes and mud pits made for the purpose of

up holes and deep holes been backfilled and restored? Yes No

7. Have the photographs of the above mentioned

activities been taken to compare with the pre‐project

conditions?

Yes No

8. Have all damages caused to local infrastructure during

the operation been repaired and restored? Yes No

9. Have the erosion control measures been taken where

needed? Yes No

10. Has it been ensured that the survey lines do not

become new routes? Yes No

11. Have the concrete blocks from the explosive storage

area been removed? Yes No

12. Have all the ditches, soak pits and septic tanks been

backfilled with an extra cap of 1 meter soil on top to

cater compaction?

Yes No

13. Has the contaminated soil been removed and disposed

of appropriately? Yes No

14. Have the sites been inspected to ensure the

recommended restoration measures have been strictly

adhered to?

Yes No


Name: Signature:

Date:

Additional Comments


Checklist for Flow Line Laying


Comments

1. Has the cutting along the slopes been minimized? Yes No

2. Has the width of RoW been limited to 40 ft to

minimize clearing of vegetation and disturbance to

soil?

Yes No

3. Has the clearing of dense patches of vegetation been

avoided? Yes No

4. Has clearing for RoW blocked the natural drainage? Yes No

5. Is tree cutting being minimized? Yes No

6. Were any trees felled? Yes No

7. Were any trees or bushes burnt or disposed of? Yes No

8. Are communities informed before commencing the

activity close to the settlements? Yes No

9 Has soil erosion been observed as a result of the

construction activities? Yes No

10. Has topsoil of the RoW been stored separately? Yes No

11. Has topsoil been backfilled ensuring minimum loss of

topsoil? Yes No

12. Has water used for cleaning and hydro‐testing of flow

line collected in lined pits? Yes No

13. Are safety measures for locals in place? Yes No

14. Has RoW for flow line by‐passed major settlements? Yes No

15. If yes, are mitigation measures needed? Yes No


EIA being adhered to? Yes No


Name: Signature:

Date:

Additional Comments


OCTOBER 2019 HPK

Appendix C Environmental Aspects Register


OCTOBER 2019 C-1 HPK

Appendix C – Environmental Aspects Register

The appendix provides an environmental impacts and aspects of the proposed

exploration and associated development activities mainly comprise of seismic,

drilling, flow line laying/tie‐ins/wellhead works and establishment/construction of

processing facilities i.e. GPF/CPP presented in Table C‐2, C‐3, C‐4 and C‐5

respectively. The register identifies the potential impacts of construction and

operational activities on various environmental resources. The register also categorizes

the significance of the impacts on the basis of their severity of consequence and the

probability of occurrence. The impact significance has been categorized on the basis of

the following criteria provided in Table C‐1.



Table C‐1: Criteria for Environmental Impacts and Aspects for Exploration and Associated Development Activities

1 2 3 4 5

Frequency

E

D

C

B

A

1 2 3 4 5

Consequence

Low

Tolerable (If ALARP)

Intolerable

Environmental Risk Scoring ‐ Consequence

5

Massive environmental damage in an extended area outside the boundaries

Extensive actions of remediation/restoration are required

Extended breaches of regulations, complaints of international concern

4

Major environmental damage within an large area outside the boundaries

Major actions for remediation/restoration are required

Major breaches of regulations, complaints of national concern

3 Medium environmental damage within a large area outside the boundaries

Medium actions for remediation/restoration are required



Repeated breaches of regulations, complaints of local/regional concern

2

Low environmental damage within a limited area outside the boundaries / Medium environmental damage within the

boundaries

Actions for clean‐up are required

Occasional breaches of regulations, complaints of local concern

1 Negligible environmental damage within the boundaries

Actions for clean‐up may be required

Environmental Risk Scoring ‐ Frequency

E Frequent ‐ happens several times per year in a location

D Probable ‐ happens several times per year in our Company

C Seldom ‐ happens once per year in our Company

B Unlikely ‐ heard of in our industry

A Improbable ‐ never heard of in our industry



Table C‐2: Environmental Aspect Register for Seismic Activities

No

Detailed Description of the Aspect – Impact

Existing Controls and their Adequacy

Impacts Significance Evaluation Questions Risk

(only evaluated for accident

scenarios)

Management

Attention

Actions

Description

of Aspect

(source‐

pathway‐

receptor)

Condition

(Threat)

Impact

(Consequence) N/A/E

Applicable

Legislation

Control Measures

(Engineered and

Management)

Control

Measure

Status

Comments

What is the regulatory

status?

Is there the potential to

endan

ger human

s,

wildlife or natural

f?


create an

environmental

libili

?


dam

age the

Compan

y’s

reputation?

Does the

Size or

Nature of

the

scenario

present an environment

issue in its

own right?

If >5 the

aspect is significant

Evaluate

Environmental

Risk

Consequence

Frequency

Risk

For Normal

and

Abnormal

Events

For

Accident

Scenarios

Actions Required

for Significant

Environmental

Aspects

1 Land

acquisition

Loss of

vegetation/crops/tree

s

Public grievances N Land Acquisition

Act, 1894

Equitable disbursement of

compensation amounts after

mutual agreement of both

parties

Manage and maintain a


register

Acceptable

2 2 2 2 2 10

‐ ‐

‐

2 Diesel storage

at site

Fire due to ignition

of spilled diesel

Air Pollution

(SOx, NOx, Acid

rain, Global

warming)

E Commitments in

EIA/EMP of

particular area

Spill control Plans

No smoking at site

Inspection of secondary

containments

SOP of diesel filling

procedure

Acceptable Training of

staff at site

regarding

Site

Emergency

Response

Plans

Evaluate Risk

2 D

Tolerable (if

ALARP)

‐ ‐

‐

Diesel spill from

diesel storage tanks

and from power

generation

equipment

Land

contamination

and water aquifer

deterioration

A Commitments in

EIA/EMP of

particular area

Secondary containment

around diesel tank

Liner under the power

engines

Routine inspections

Acceptable

1 1 1 2 2 7

‐ ‐

‐

3 Equipment and

crew

mobilization

and

demobilization

Dust and vehicular

emissions

Air pollution N Sindh

Environmental

Protection Act,

2014 Sindh

Environmental

Quality Standard,

2016

Regulate and monitor

vehicles speed

Maintain vehicles in a good

working condition

Avoid off‐road travel

Conduct vehicle and

equipment emission testing

Acceptable

2 2 1 2 2 9

‐ ‐

‐

Noise and vibration Noise pollution N Sindh

Environmental

Protection Act,

2014 Sindh

Environmental

Quality Standard,

2016

Minimize use of horns by

project vehicles

Use of pressure horns will

not be allowed

Conduct noise monitoring of

noise emitting vehicles and

equipment

Acceptable

2 2 1 2 2 9

‐ ‐

‐

Driving practices Safety hazards –

locals

N Motor Vehicles

Rules, 1969 or

Provincial Motor

Vehicles

(Amendment)

Ordinance, 2002

Train drivers in responsible

and safe driving practices

Observe and maintain

minimum/safe distances

from local communities

Avoid night travelling unless

required in case of an

emergency

Acceptable

1 2 1 2 2 8

‐ ‐

‐

4 Construction/

Improvement

of access tracks

Land clearing Soil erosion N Commitments in

EIA/EMP of

particular area

Minimize preparation of new

access tracks

Width of existing tracks

development or

improvements will be kept to

a minimum

Restrict movement of

personnel and construction

Acceptable

2 2 2 2 2 10

‐ ‐

‐



No





scenarios)

Management

Attention

Actions

Description

of Aspect

(source‐

pathway‐

receptor)

Condition

(Threat)

Impact

(Consequence) N/A/E

Applicable

Legislation

Control Measures

(Engineered and

Management)

Control

Measure

Status

Comments


status?


endan

ger human

s,

wildlife or natural

f?


create an

environmental

libili

?


dam

age the

Compan

y’s

reputation?

Does the

Size or

Nature of

the

scenario


issue in its

own right?

If >5 the


Evaluate

Environmental

Risk

Consequence

Frequency

Risk

For Normal

and

Abnormal

Events

For

Accident

Scenarios

Actions Required

for Significant

Environmental

Aspects

equipment to work areas

only

Maintain photographic

records of all activities to

monitor any changes and soil

conditions

Train drivers on mitigation

measures related to off‐road

travel


Maximize usage of existing

tracks

Handling of fuel, oil

and chemicals

Soil and water

contamination

N Hazardous

Substances Rules,

2014

Vehicles will be daily

checked for fuel or oil leaks

Fuel and oil transfer

operations will be done using

a dedicated fuel vehicle

Drip pans will be used to

avoid drips and spills

Procedure for transfer shall

be developed and

implemented

Acceptable

2 1 1 2 2 8

‐ ‐

‐

Use of horns/

improperly

maintained

machinery

Noise pollution N Sindh

Environmental

Protection Act,

2014 Sindh

Environmental

Quality Standards,

2016


project vehicles


not be allowed

Properly maintain vehicles

and construction equipment

Restrict all project vehicles

and personnel within work

areas

Conduct noise monitoring

Acceptable

2 2 1 2 2 9

‐ ‐

‐

Dust and vehicular

emissions


Environmental

Protection Act,

2014 Sindh

Environmental

Quality Standards,

2016


vehicles speed

Minimize dust emissions by

employing good





travel and speed limits

Acceptable

2 2 1 2 2 9

‐ ‐

‐

Loss of vegetation/

crops

Soil erosion/loss

of habitat

N The Forest Act,

1927

Minimize vegetation

clearance

Prohibit use of local

vegetation as fuel


access tracks


development or

improvements will be

minimized

Avoid clearing of trees

Acceptable

2 2 3 2 2 11

‐ ‐

‐



No





scenarios)

Management

Attention

Actions

Description

of Aspect

(source‐

pathway‐

receptor)

Condition

(Threat)

Impact

(Consequence) N/A/E

Applicable

Legislation

Control Measures

(Engineered and

Management)

Control

Measure

Status

Comments


status?


endan

ger human

s,

wildlife or natural

f?


create an

environmental

libili

?


dam

age the

Compan

y’s

reputation?

Does the

Size or

Nature of

the

scenario


issue in its

own right?

If >5 the


Evaluate

Environmental

Risk

Consequence

Frequency

Risk

For Normal

and

Abnormal

Events

For

Accident

Scenarios

Actions Required

for Significant

Environmental

Aspects

Access tracks should avoid

passing through the areas

with dense vegetation

Land acquisition for

access tracks

Loss of habitat N Sindh Wildlife

Protection

Ordinance, 1972

and Amendments

2001, Sindh

Environmental

Protection Act,

2014

Minimize total land uptake

by access roads


development or


minimized





Use single approved track

during construction

Acceptable

2 2 2 2 2 10

‐ ‐

‐

Driving practices/

Resource utilization

Safety hazards

and disturbance

to communities

N Motor Vehicles

Rules, 1969 or

Provincial Motor

Vehicles

(Amendment)

Ordinance, 2002




Comply with all EIA/EMP

mitigation related to waste,

noise and dust emissions



register

Local sources of drinking

water will be used only after

complying with relevant

requirements of the EIA/EMP

Repair any damage caused

by project activities to local

infrastructure

Observe strict compliance

with UEPL’s HSE guidelines

Project staff to respect all

cultural norms

Provide offsets from sites of

religious, cultural or


Acceptable

1 2 1 2 2 8

‐ ‐

‐

Vegetation clearing/

Vehicular movement

Disturbance to

wildlife

N Sindh Wildlife

Protection

Ordinance, 1972

and Amendments,

2001

Prohibit hunting, fishing,

trapping or harassment,

killing or feeding of wildlife


access tracks


development or

improvement will be

minimized

Select routes with minimum

vegetation clearing

Avoid dense patches of

vegetation

Maintain construction


Acceptable

2 2 2 2 3 11

‐ ‐

‐



No





scenarios)

Management

Attention

Actions

Description

of Aspect

(source‐

pathway‐

receptor)

Condition

(Threat)

Impact

(Consequence) N/A/E

Applicable

Legislation

Control Measures

(Engineered and

Management)

Control

Measure

Status

Comments


status?


endan

ger human

s,

wildlife or natural

f?


create an

environmental

libili

?


dam

age the

Compan

y’s

reputation?

Does the

Size or

Nature of

the

scenario


issue in its

own right?

If >5 the


Evaluate

Environmental

Risk

Consequence

Frequency

Risk

For Normal

and

Abnormal

Events

For

Accident

Scenarios

Actions Required

for Significant

Environmental

Aspects

Minimize time period of

operation near surface water

bodies (especially which are

breeding areas)

Monitor impacts of the

individual project on wildlife

species




5 Camp/s

construction/

Establishment/

Operation

Vegetation clearing Soil erosion/

Physical scarring

N The Forest Act,

1927

Minimize vegetation clearing

Avoid cutting of trees

Locate campsite in existing

clearings and on levelled

land

Minimize cut and fill as

much as possible

Minimize total land uptake

by the camps



monitor any changes in soil

conditions

Campsites will be located

outside of the boundaries of

areas with dense vegetation

Acceptable

2 1 2 2 2 9

‐ ‐

‐

Waste management/

Handling of fuels,

oils and chemicals

Soil/Water

contamination

N Sindh

Environmental

Protection Act,

2014

Hazardous

Substances Rules,

2014

Dispose sewage generated at

the campsite in septic system

comprising septic tanks and

soak pits

Dispose wastewater from

laundry, kitchen washings

and showers into separate

soak pits

Build soak pits in absorbent

soil

Keep septic system at

minimum distances of 300 m

from surface water sources or

groundwater wells

Design and construct soak

pits to prevent surface runoff

Design soak pits to

accommodate wastewater

generated during the total

duration of the operation

In case the soak pits get filled

during the operation, grey

water will be transferred to


Sprinkling of wastewater will

not be allowed

Acceptable

2 2 2 2 2 10

‐ ‐

‐



No





scenarios)

Management

Attention

Actions

Description

of Aspect

(source‐

pathway‐

receptor)

Condition

(Threat)

Impact

(Consequence) N/A/E

Applicable

Legislation

Control Measures

(Engineered and

Management)

Control

Measure

Status

Comments


status?


endan

ger human

s,

wildlife or natural

f?


create an

environmental

libili

?


dam

age the

Compan

y’s

reputation?

Does the

Size or

Nature of

the

scenario


issue in its

own right?

If >5 the


Evaluate

Environmental

Risk

Consequence

Frequency

Risk

For Normal

and

Abnormal

Events

For

Accident

Scenarios

Actions Required

for Significant

Environmental

Aspects

Solid wastes at the campsite

will be stored temporarily on

site for onward supply to a

waste contractor

Wash vehicles in designated

areas within campsite

Regularly check vehicles for

fuel or oil leaks

All fuel and oil storage areas

will have a concrete pad

underneath to prevent soil

contamination in case of

leaks or spills

All fuel tanks will be

properly marked to highlight

their contents

Fuel and oil storage areas

will have secondary

containment in the form of

concrete or brick masonry

bunds

Ensure provisions for proper

fuel and oil storage and

handling

Dust/Exhaust

emissions


Environmental

Protection Act,

2014 Sindh

Environmental

Quality Standards,

2016

Maintain vehicles and

equipment in good condition

Select campsite locations at

least 300 m away from

communities

Employ good management

practice to minimize dust

emissions

Acceptable

2 2 1 2 2 9

‐ ‐

‐

Use of horns/

Improper maintained

machinery

Noise and

vibration

N Sindh

Environmental

Protection Act,

2014 Sindh

Environmental

Quality Standards,

2016

Ensure that generators,

vehicles and other potentially

noisy equipment are in good

condition

Select campsite location at


communities


project vehicles


not be allowed

Restrict all project vehicles

and personnel within work

areas

Acceptable

2 2 1 2 2 9

‐ ‐

‐

Resource utilization Resource

depletion and

water pollution

N Sindh

Environmental

Protection Act,

2014

Prohibit use of water from

surface water bodies

Employ prudent water

conservation measures

Keep complete records of

water consumption during

project

Acceptable

2 3 2 2 2 11

‐ ‐

‐



No





scenarios)

Management

Attention

Actions

Description

of Aspect

(source‐

pathway‐

receptor)

Condition

(Threat)

Impact

(Consequence) N/A/E

Applicable

Legislation

Control Measures

(Engineered and

Management)

Control

Measure

Status

Comments


status?


endan

ger human

s,

wildlife or natural

f?


create an

environmental

libili

?


dam

age the

Compan

y’s

reputation?

Does the

Size or

Nature of

the

scenario


issue in its

own right?

If >5 the


Evaluate

Environmental

Risk

Consequence

Frequency

Risk

For Normal

and

Abnormal

Events

For

Accident

Scenarios

Actions Required

for Significant

Environmental

Aspects

Obtain water required for

seismic and construction

operation from local wells,

existing or new UEPL water

wells in the area

Install (if required) new

water wells 300 m from

existing local wells

Abstract water from deep

aquifer

Water from a local well will

only be used after ensuring

that the available capacity at

the tube well (safe yield

minus local demand) is at

least 50% greater than the

project demand

Abstraction of water for

seismic operation, from

irrigation network will only

be used after getting

approval from irrigation

department

Noise and vibration/

Waste disposal

Disturbance to

wildlife

N Sindh Wildlife

Protection

Ordinance, 1972

and Amendments,

2001


trapping, killing, feeding or

harassment of wildlife

Select campsite locations 300

m from surface water bodies

Avoid clearing of dense

patches of vegetation

Food wastes will not be left

in the open and shall be

buried

Maintain compressors and

vehicles in good condition


individual projects on

wildlife species

Acceptable

2 3 3 3 3 14

‐ ‐

‐

6 Clearing and

levelling of

seismic lines


Physical scarring

N The Forest Act,

1927

Minimize vegetation

clearance





conditions

Minimize disturbance to

natural topography and soils


vehicles speed





Acceptable

2 2 1 2 2 9

‐ ‐

‐



No





scenarios)

Management

Attention

Actions

Description

of Aspect

(source‐

pathway‐

receptor)

Condition

(Threat)

Impact

(Consequence) N/A/E

Applicable

Legislation

Control Measures

(Engineered and

Management)

Control

Measure

Status

Comments


status?


endan

ger human

s,

wildlife or natural

f?


create an

environmental

libili

?


dam

age the

Compan

y’s

reputation?

Does the

Size or

Nature of

the

scenario


issue in its

own right?

If >5 the


Evaluate

Environmental

Risk

Consequence

Frequency

Risk

For Normal

and

Abnormal

Events

For

Accident

Scenarios

Actions Required

for Significant

Environmental

Aspects

Waste disposal/

Handling of fuel, oils

and chemicals

Soil and water

contamination

N Sindh

Environmental

Protection Act,

2014

Hazardous

Substances Rules,

2014

Prohibit solid waste disposal

in the field


fuel or oil leaks

Use a dedicated fuel vehicle

for fuel and oil transfer

operation

Use drip pans to avoid drips

and spills

The soil contaminated from

minor and moderate spills

will be removed and sent to

waste contractor for

appropriate disposal e.g.

incineration or can be

disposed of in accordance to

best industrial guidelines

Acceptable

2 1 2 2 2 9

‐ ‐

‐

Use of horns/

Improperly

maintained

machinery

Noise pollution/

Disturbance to

wildlife

N Sindh Wildlife

Protection

Ordinance, 1972

and Amendments,

2001


project vehicles

The use of pressure horns

will not be allowed



equipment within work areas

Acceptable

2 2 1 2 2 9

‐ ‐

‐

Dust/Exhaust

emissions


Environmental

Protection Act,

2014 Sindh

Environmental

Quality Standards,

2016

Maintain vehicles in good

condition

Dust emissions during line

clearance activities will be

minimized by good



employing good


Conduct vehicle and


Acceptable

2 2 1 2 2 9

‐ ‐

‐

Loss of vegetation Loss of habitat N The Forest Act,

1927

Minimize clearing of

vegetation


vegetation as fuel by crew

personnel


Acceptable

2 2 2 2 3 11

‐ ‐

‐



No





scenarios)

Management

Attention

Actions

Description

of Aspect

(source‐

pathway‐

receptor)

Condition

(Threat)

Impact

(Consequence) N/A/E

Applicable

Legislation

Control Measures

(Engineered and

Management)

Control

Measure

Status

Comments


status?


endan

ger human

s,

wildlife or natural

f?


create an

environmental

libili

?


dam

age the

Compan

y’s

reputation?

Does the

Size or

Nature of

the

scenario


issue in its

own right?

If >5 the


Evaluate

Environmental

Risk

Consequence

Frequency

Risk

For Normal

and

Abnormal

Events

For

Accident

Scenarios

Actions Required

for Significant

Environmental

Aspects

Waste disposal/

Vehicular movement

Disturbance to

wildlife

N Sindh Wildlife

Protection

Ordinance, 1972

and Amendments,

2001





and land uptake





buried

Maintain minimum distances

of 50 m from the canals and

wetlands during line clearing


condition to reduce noise




breeding areas) by good




species

Acceptable

2 2 2 2 3 11

‐ ‐

‐

Driving practices/


Safety hazards

and disturbance

to communities

N Motor Vehicles

Rules, 1969 or

Provincial Motor

Vehicles

(Amendment)

Ordinance, 2002







Manage and maintain


register







infrastructure


with UEPL HSE guidelines

Project staff to respect

cultural norms




Acceptable

1 2 1 2 2 8

‐ ‐ ‐



No





scenarios)

Management

Attention

Actions

Description

of Aspect

(source‐

pathway‐

receptor)

Condition

(Threat)

Impact

(Consequence) N/A/E

Applicable

Legislation

Control Measures

(Engineered and

Management)

Control

Measure

Status

Comments


status?


endan

ger human

s,

wildlife or natural

f?


create an

environmental

libili

?


dam

age the

Compan

y’s

reputation?

Does the

Size or

Nature of

the

scenario


issue in its

own right?

If >5 the


Evaluate

Environmental

Risk

Consequence

Frequency

Risk

For Normal

and

Abnormal

Events

For

Accident

Scenarios

Actions Required

for Significant

Environmental

Aspects

7 Seismic survey

and data

acquisition

Disturbance to

communities and

resource utilization

Safety hazards

and community

complaints

N Commitments in

EIA/EMP of

particular area







Manage and maintain


register







infrastructure


with UEPL HSE guidelines

Project staff to respect

cultural norms




Water sources currently

being used for irrigation by

the resident communities

will be exploited only after



Maintain effective

communication channels

with local communities to

inform them about the

progress of various project

activities

Acceptable

1 1 1 2 2 7

‐ ‐

‐



No





scenarios)

Management

Attention

Actions

Description

of Aspect

(source‐

pathway‐

receptor)

Condition

(Threat)

Impact

(Consequence) N/A/E

Applicable

Legislation

Control Measures

(Engineered and

Management)

Control

Measure

Status

Comments


status?


endan

ger human

s,

wildlife or natural

f?


create an

environmental

libili

?


dam

age the

Compan

y’s

reputation?

Does the

Size or

Nature of

the

scenario


issue in its

own right?

If >5 the


Evaluate

Environmental

Risk

Consequence

Frequency

Risk

For Normal

and

Abnormal

Events

For

Accident

Scenarios

Actions Required

for Significant

Environmental

Aspects

Waste disposal/

Equipment handling

Disturbance to

wildlife

N Sindh Wildlife

Protection

Ordinance, 1972

and Amendments,

2001


trapping, feeding, killing or


Avoid disturbance to live

bird nests, reptiles and small

mammal holes during

seismic deep holes and

upholds drilling



buried

A minimum distance of 100

m to be maintained from the

canals and wetlands






breeding areas) by good


Monitor impacts of


All the waste from site shall

be collected and properly

managed at campsite

Acceptable

2 2 2 3 3 12

‐ ‐

‐

Noise and vibration Disturbance to

wildlife

N Sindh Wildlife

Protection

Ordinance, 1972

and Amendments,

2001

Minimize the use of horns by

project vehicles

The use of pressure horns

will not be allowed

Restrict movement of all

project vehicles and

personnel within work areas

All vehicles and equipment

shall be properly tuned and

maintained

Noise measurement shall be

carried out of all noisy

equipment and vehicles

Acceptable

2 2 2 2 2 10

‐ ‐

‐

Dust/ Exhaust

emissions


Environmental

Protection Act,

2014 Sindh

Environmental

Quality Standards,

2016


condition


good management practices

Regulate vehicles speed

Vehicles to be properly tuned

Conduct emission

monitoring as per applicable

laws and regulations

Acceptable

2 2 2 2 2 10

‐ ‐

‐



No





scenarios)

Management

Attention

Actions

Description

of Aspect

(source‐

pathway‐

receptor)

Condition

(Threat)

Impact

(Consequence) N/A/E

Applicable

Legislation

Control Measures

(Engineered and

Management)

Control

Measure

Status

Comments


status?


endan

ger human

s,

wildlife or natural

f?


create an

environmental

libili

?


dam

age the

Compan

y’s

reputation?

Does the

Size or

Nature of

the

scenario


issue in its

own right?

If >5 the


Evaluate

Environmental

Risk

Consequence

Frequency

Risk

For Normal

and

Abnormal

Events

For

Accident

Scenarios

Actions Required

for Significant

Environmental

Aspects

Waste management/

Handling of fuels,

oils and chemicals

Soil

contamination

N Sindh

Environmental

Protection Act,

2014

Hazardous

Substances Rules,

2014

No solid waste will be

disposed of in the field


fuel and oil leaks

Use dedicated vehicle for fuel

and oil transfer







disposed in accordance to the

best industrial guidelines

Acceptable

2 2 3 2 2 11

‐ ‐

‐

Loss of vegetation Soil

erosion/Public

grievance

N The Forest Act,

1927



vegetation as fuel

Contain crew personnel

within work areas

Camps shall be established in

existing cleared land

Acceptable

2 2 3 3 3 13

‐ ‐

‐

Resource utilization Water pollution/

Resource

depletion

N Sindh

Environmental

Protection Act,

2014







project

Obtain water required for

seismic and construction

operation from local wells,


wells in the area




the tube well (safe yield

minus local demand) is at

least 50% greater than the

project demand

Acceptable

2 3 2 2 2 11

‐ ‐

‐

Vehicular/Machinery

movement

Soil erosion/

Physical scarring

N Commitments in

EIA/EMP of

particular area




conditions






Acceptable

1 2 1 2 2 8

‐ ‐

‐

8 Waste

management


waste/Handling of

fuel, oil and

chemicals

Soil and water

contamination

N Sindh

Environmental

Protection Act,

2014 Sindh



comprising of septic tanks

and soak pits

Acceptable

2 2 3 2 2 11

‐ ‐

‐



No





scenarios)

Management

Attention

Actions

Description

of Aspect

(source‐

pathway‐

receptor)

Condition

(Threat)

Impact

(Consequence) N/A/E

Applicable

Legislation

Control Measures

(Engineered and

Management)

Control

Measure

Status

Comments


status?


endan

ger human

s,

wildlife or natural

f?


create an

environmental

libili

?


dam

age the

Compan

y’s

reputation?

Does the

Size or

Nature of

the

scenario


issue in its

own right?

If >5 the


Evaluate

Environmental

Risk

Consequence

Frequency

Risk

For Normal

and

Abnormal

Events

For

Accident

Scenarios

Actions Required

for Significant

Environmental

Aspects

Environmental

Quality Standard,

2016

Hazardous

Substance Rules,

2014


laundry, kitchen washings,

and showers into separate

soak pits


soil

Ensure that the soak pits

remain covered all the time

and measures are taken to

prevent entry of rainwater

into them

Design soak pits to






water will be transferred and

disposed in nearest

municipal drains with prior

approval of concerned

authorities


not be allowed



Recycle non‐combustible

waste

Burry all food waste properly

and shall not be left in open

Send combustible (except

food waste) to waste

contractor



Check vehicles for fuel or oil

leaks





leaks or spills


properly marked to highlight

their contents

Fuel and oil storage areas

will have secondary



bunds

Use dedicated vehicles for

fuel and oil transfer

operations



No





scenarios)

Management

Attention

Actions

Description

of Aspect

(source‐

pathway‐

receptor)

Condition

(Threat)

Impact

(Consequence) N/A/E

Applicable

Legislation

Control Measures

(Engineered and

Management)

Control

Measure

Status

Comments


status?


endan

ger human

s,

wildlife or natural

f?


create an

environmental

libili

?


dam

age the

Compan

y’s

reputation?

Does the

Size or

Nature of

the

scenario


issue in its

own right?

If >5 the


Evaluate

Environmental

Risk

Consequence

Frequency

Risk

For Normal

and

Abnormal

Events

For

Accident

Scenarios

Actions Required

for Significant

Environmental

Aspects


and spills

Check fuel tanks for leaks







disposed of in accordance to

the best industrial guidelines

A spill prevention and

contingency plan will be

prepared to deal with



fuel and oil, storage and

handling

Recycle used oil and vehicle

related waste

Bentonite mud used for the

purpose of uphold and deep

holes drilling will be

prepared in rig tank

Restore upholds and deep

holes

Incinerate all medical wastes

Maintain generators,

compressors and vehicles in

good condition



9 Community

issues


Loss of standing

crops

Soil

erosion/Public

grievance

N The Forest Act,

1927



register




UEPL contractors will

employ local residents

during the project activities

Water sources currently

being used for irrigation by

the resident communities

will be exploited only after







Acceptable

2 2 2 2 2 10

‐ ‐

‐



No





scenarios)

Management

Attention

Actions

Description

of Aspect

(source‐

pathway‐

receptor)

Condition

(Threat)

Impact

(Consequence) N/A/E

Applicable

Legislation

Control Measures

(Engineered and

Management)

Control

Measure

Status

Comments


status?


endan

ger human

s,

wildlife or natural

f?


create an

environmental

libili

?


dam

age the

Compan

y’s

reputation?

Does the

Size or

Nature of

the

scenario


issue in its

own right?

If >5 the


Evaluate

Environmental

Risk

Consequence

Frequency

Risk

For Normal

and

Abnormal

Events

For

Accident

Scenarios

Actions Required

for Significant

Environmental

Aspects

Flow of water in canal or

water crossings will not be

impeded


by project activities to canals,

watercourses, local roads or

other infrastructure

Strict compliance will be

observed to UEPL HSE

guidelines



Inform local communities

about the progress of various

project activities

Respect cultural norms

Provide appropriate offsets

from sites of religious,

cultural or archaeological

significance

10 Restoration General Public grievances/

Wildlife

protection/Waste

management/

Safety hazards

N Commitments in

EIA/EMP of

particular area

Restore soak pits after project

completion

Ensure that after restoration

activities the campsite is

clean and that no refuse has

been left behind

Remove all concrete

structures

Remove all pin flags, signs,

and refuse from seismic lines

Restore upholds and deep

holes

Acceptable

1 2 2 2 2 9

‐ ‐

‐

11 Explosive

Camp

Construction

General Public grievances/

Wildlife

Protection/Waste

management/

Safety hazards

N Commitments in

EIA/EMP of

particular area

Excavation as per

requirement, material for its

restoration Ensure distance

from local population and

wildlife

Restore properly with same

excavated material

Acceptable

1 2 2 2 2 9

‐ ‐

‐

N = Normal; A = Abnormal; E = Emergency



Table C‐3: Environmental Aspect Register for Drilling and Associated Construction Activities

No





scenarios)

Management

Attention

Actions

Description of

Aspect

(source‐

pathway‐

receptor)

Conditions (Threat) Impact

(Consequence) N/A/E

Applicable

Legislation

Control Measures

(Engineered and

Management)

Control

Measure

Status

Comments


status?


endan

ger human

s, w

ildlife

or natural features?


create an environmental

liability?


dam

age the Compan

y’s

reputation?

Does the Size or Nature of

the scenario present an

environment issue in its own

If >5 the


Evaluate

EnvironmentalRisk

Consequence

Frequency

Risk

For

Normal

and

Abnormal

Events

For

Accident

Scenarios

Actions

Required for

Significant

Environmental

Aspects

1 Land acquisition Vegetation clearing/

Loss of standing crops


Act, 1894


compensation amounts as per

mutual agreement of both

parties


community complaints register

Acceptable

2 2 2 2 2 10

‐ ‐

‐

2 Equipment and

crew

mobilization and

demobilization

Dust and vehicular

emissions


Environmental

Protection Act, 2014

Sindh

Environmental

Quality Standards,

2016

Regulate and monitor vehicles

speed


condition


Conduct vehicle and


Acceptable

2 2 1 2 2 9

‐ ‐

‐


Environmental


Sindh

Environmental

Quality Standards,

2016


project vehicles

The use of pressure horns will

not be allowed


noise emitting vehicle and

equipment

Acceptable

2 2 1 2 2 9

‐ ‐

‐

Driving Practices Safety hazards –

locals

N Motor Vehicles

Rules, 1969 or

Provincial Motor

Vehicles

(Amendment)

Ordinance, 2002



Observe and maintain

minimum/safe distances from

local communities



emergency

Acceptable

1 2 1 2 2 8

‐ ‐

‐

3 Construction/

Improvement of

access tracks

Land clearing Soil erosion N EIA/EMP

Commitments


access tracks


development or improvements

will be kept to a minimum



equipment to work areas only

Maintain photographic records

of all activities to monitor any

changes and soil conditions



travel



tracks

Access track to the well site

will be properly compacted

Acceptable

2 2 2 2 2 10

‐ ‐

‐



No





scenarios)

Management

Attention

Actions

Description of

Aspect

(source‐

pathway‐

receptor)


(Consequence) N/A/E

Applicable

Legislation

Control Measures

(Engineered and

Management)

Control

Measure

Status

Comments


status?


endan

ger human

s, w

ildlife




liability?


dam

age the Compan

y’s

reputation?




If >5 the


Evaluate

EnvironmentalRisk

Consequence

Frequency

Risk

For

Normal

and

Abnormal

Events

For

Accident

Scenarios

Actions

Required for

Significant

Environmental

Aspects


and chemicals

Soil and water

contamination

N Hazardous

Substances Rules,

2014

Vehicles will be daily checked

for fuel or oil leaks

Fuel and oil transfer operations

will be done using a dedicated

fuel vehicle



Concrete pad will be

constructed for refuelling of

vehicles at drilling site

Procedure for transfer of fuel

or oil shall be developed and

implemented

Oil spill drill will be carried

out on regular interval to cater

with emergency situation

Acceptable

2 1 1 2 2 8

‐ ‐

‐

Use of horns/

Improperly

maintained machinery

and vibration

Noise Pollution N Sindh

Environmental


Sindh

Environmental

Quality Standards,

2016


project vehicles

Use of pressure horns will not

be allowed

Properly maintain vehicles and

construction equipment

Restrict all project vehicles and



Acceptable

2 2 1 2 2 9

‐ ‐

‐

Dust and vehicular

emissions


Environmental


Sindh

Environmental

Quality Standards,

2016


speed


employing good management

practices





Sprinkling to be carried out to

avoid dust emission

Acceptable

2 2 1 2 2 9

‐ ‐

‐

Loss of vegetation Soil erosion/

Damage to habitat

N The Forest Act, 1927 Minimize vegetation clearance

Prohibit use of local vegetation

as fuel


access tracks

Width of the access track to the

well site will not exceed 5.5 m



will be minimized



passing through the areas with

dense vegetation

Acceptable

2 2 3 2 2 11

‐ ‐

‐



No





scenarios)

Management

Attention

Actions

Description of

Aspect

(source‐

pathway‐

receptor)


(Consequence) N/A/E

Applicable

Legislation

Control Measures

(Engineered and

Management)

Control

Measure

Status

Comments


status?


endan

ger human

s, w

ildlife




liability?


dam

age the Compan

y’s

reputation?




If >5 the


Evaluate

EnvironmentalRisk

Consequence

Frequency

Risk

For

Normal

and

Abnormal

Events

For

Accident

Scenarios

Actions

Required for

Significant

Environmental

Aspects

Land acquisition for

access tracks, well site

and campsite

Loss of habitat N Sindh Wildlife

Protection

Ordinance, 1972

and Amendments,

2001

Sindh

Environmental




during construction

Width of the access track to the

well site will not exceed 5.5 m

Minimize total land uptake by

access roads, well sites and

campsites



will be minimized



dense vegetation

Acceptable

2 2 2 2 2 10

‐ ‐

‐

Driving practices/


Safety hazards and

disturbance to

communities

N Motor Vehicles

Rules, 1969 or

Provincial Motor

Vehicles

(Amendment)

Ordinance, 2002













Repair or compensate any

damage caused by project

activities to local infrastructure

Observe strict compliance with

UEPL HSE guidelines


cultural norms

Provide offsets will from sites

of religious, cultural or


Acceptable

1 2 1 2 2 8

‐ ‐

‐


Vehicular movement

Disturbance to

wildlife

N Sindh Wildlife

Protection

Ordinance, 1972

and Amendments,

2001





access tracks


development or improvement

will be minimized


vegetation clearing


vegetation

Maintain construction vehicles

and equipment



Acceptable

2 2 2 2 3 11

‐ ‐

‐



No





scenarios)

Management

Attention

Actions

Description of

Aspect

(source‐

pathway‐

receptor)


(Consequence) N/A/E

Applicable

Legislation

Control Measures

(Engineered and

Management)

Control

Measure

Status

Comments


status?


endan

ger human

s, w

ildlife




liability?


dam

age the Compan

y’s

reputation?




If >5 the


Evaluate

EnvironmentalRisk

Consequence

Frequency

Risk

For

Normal

and

Abnormal

Events

For

Accident

Scenarios

Actions

Required for

Significant

Environmental

Aspects


breeding areas)



species



dense vegetation



emergency

4 Camp & well

site construction/

Establishment/

Operation


Physical scarring

N The Forest Act, 1927 Minimize vegetation clearing


Locate well site and campsites

in existing clearing and on

levelled land

Avoid cut and fill as much as

possible


the well site and camps



changes in soil conditions

Stockpiles will be located

downwind during well site

construction

Campsites will be located

outside the boundaries of areas


Acceptable

2 1 2 2 2 9

‐ ‐

‐

Waste management/

Handling of fuels, oils

and chemicals

Soil/Water

contamination

N Sindh

Environmental


Hazardous

Substances Rules,

2014



comprising of septic tanks and

soak pits


laundry, kitchen washings and

showers into separate soak pits


soil

Keep septic system at



groundwater wells

Design and construct soak pits

to prevent surface runoff

Design soak pits to







disposed into the nearest

Acceptable

2 2 2 2 2 10

‐ ‐

‐



No





scenarios)

Management

Attention

Actions

Description of

Aspect

(source‐

pathway‐

receptor)


(Consequence) N/A/E

Applicable

Legislation

Control Measures

(Engineered and

Management)

Control

Measure

Status

Comments


status?


endan

ger human

s, w

ildlife




liability?


dam

age the Compan

y’s

reputation?




If >5 the


Evaluate

EnvironmentalRisk

Consequence

Frequency

Risk

For

Normal

and

Abnormal

Events

For

Accident

Scenarios

Actions

Required for

Significant

Environmental

Aspects

municipal drains with the

prior approval of concerned

authorities


not be allowed


will be stored temporarily on

site for onward supply to a

waste contractor

Burning of waste will not be

allowed




fuel or oil leaks




contamination in case of leaks

or spills

All fuel tanks will be properly

marked to highlight their

contents

Fuel and oil storage areas will

have secondary containment in

the form of concrete or brick

masonry bunds



handling

Ensure preparation of a spill

prevention and contingency

plan

Ensure provisions of a HDPE

liner for the waste pits at the

well site

Dust/Exhaust

emissions


Environmental


Sindh

Environmental

Quality Standards,

2016



Select well site and campsite

locations at least 300 m away

from communities



emissions

Acceptable

2 2 1 2 2 9

‐ ‐

‐

Use of horns/

Improperly


Noise and

vibration

N Sindh

Environmental


Sindh

Environmental

Quality Standards,

2016




condition

Select well site and campsite

locations at least 300 m away

from communities

Acceptable

2 2 1 2 2 9

‐ ‐

‐



No





scenarios)

Management

Attention

Actions

Description of

Aspect

(source‐

pathway‐

receptor)


(Consequence) N/A/E

Applicable

Legislation

Control Measures

(Engineered and

Management)

Control

Measure

Status

Comments


status?


endan

ger human

s, w

ildlife




liability?


dam

age the Compan

y’s

reputation?




If >5 the


Evaluate

EnvironmentalRisk

Consequence

Frequency

Risk

For

Normal

and

Abnormal

Events

For

Accident

Scenarios

Actions

Required for

Significant

Environmental

Aspects


project vehicles


be allowed



Resource utilization Water pollution/

Resource depletion

N Sindh

Environmental


Use of water from surface

water bodies is prohibited





project

Obtain water required

construction and drilling

operation from local wells

(close to Irrigation canal),


wells in the area

Install (if required) new water

wells 300 m from existing local

wells


aquifer




the tube well (safe yield minus

local demand) is at least 50%

greater than the project

demand

Abstraction of water for

drilling operation, from

irrigation network will only be

used after getting approval

from irrigation department

Pay appropriate compensation

for the amount of water

abstracted to the well owners

Acceptable

2 3 2 2 2 11

‐ ‐

‐



No





scenarios)

Management

Attention

Actions

Description of

Aspect

(source‐

pathway‐

receptor)


(Consequence) N/A/E

Applicable

Legislation

Control Measures

(Engineered and

Management)

Control

Measure

Status

Comments


status?


endan

ger human

s, w

ildlife




liability?


dam

age the Compan

y’s

reputation?




If >5 the


Evaluate

EnvironmentalRisk

Consequence

Frequency

Risk

For

Normal

and

Abnormal

Events

For

Accident

Scenarios

Actions

Required for

Significant

Environmental

Aspects

Noise and vibration/

Waste disposal

Disturbance to

wildlife

N Sindh Wildlife

Protection

Ordinance, 1972

and Amendments,

2001




Select campsite locations 300 m

from surface water body



Food wastes will not be left in

the open and shall be buried





species

Avoid night travel unless


emergency

Acceptable

2 3 3 3 3 14

‐ ‐

‐

5 Waste

management


waste/Handling of

fuel, oil & chemicals

Soil and water

contamination

N Sindh

Environmental


Sindh

Environmental

Quality Standards,

2016

Hazardous

Substances Rules,

2014

Dispose sewage generated in

septic system comprising

septic tanks and soak pits





soil

Ensure that the soak pits

remain covered all the time

and measures are taken to

prevent entry of rainwater into

them

Design soak pits to







disposed into nearest

municipal drains with the


authorities


not be allowed



Recycle non‐combustible waste

Burry all food waste properly

Send combustible waste

(except food waste) to waste

contractor

Burning of waste will be

prohibited

Acceptable

2 1 2 2 2 9

‐ ‐

‐



No





scenarios)

Management

Attention

Actions

Description of

Aspect

(source‐

pathway‐

receptor)


(Consequence) N/A/E

Applicable

Legislation

Control Measures

(Engineered and

Management)

Control

Measure

Status

Comments


status?


endan

ger human

s, w

ildlife




liability?


dam

age the Compan

y’s

reputation?




If >5 the


Evaluate

EnvironmentalRisk

Consequence

Frequency

Risk

For

Normal

and

Abnormal

Events

For

Accident

Scenarios

Actions

Required for

Significant

Environmental

Aspects




leaks





or spills



contents




masonry bunds

Use dedicated vehicles for fuel

and oil transfer operations


and leaks

Check fuel tanks for leaks or

spills


minor and moderate spills will

be removed and sent to waste

contractor for appropriate

disposal e.g. incineration or

can be disposed of in

accordance to the best

industrial guidelines






fuel and oil, storage and

handling


related waste

Incinerate all clinical wastes

Maintain vehicles and other


6 Community

issues

Land acquisition/



Public grievances N The Forest Act, 1927 Manage and maintain a



mitigations related to waste,


UEPL contractors will employ

local residents during the

project activities

Acceptable

2 2 2 2 2 10

‐ ‐

‐



No





scenarios)

Management

Attention

Actions

Description of

Aspect

(source‐

pathway‐

receptor)


(Consequence) N/A/E

Applicable

Legislation

Control Measures

(Engineered and

Management)

Control

Measure

Status

Comments


status?


endan

ger human

s, w

ildlife




liability?


dam

age the Compan

y’s

reputation?




If >5 the


Evaluate

EnvironmentalRisk

Consequence

Frequency

Risk

For

Normal

and

Abnormal

Events

For

Accident

Scenarios

Actions

Required for

Significant

Environmental

Aspects

Local residents living closest to

the project location will be

given priority in the

employment process subject to

company selection criteria

Groundwater sources

currently being used for

irrigation by the resident

communities will be exploited

only after complying with

relevant requirements of the

EIA/EMP

7 Fire and

explosion at

drilling rig

derrick

Release of raw gas

from wellhead during

drilling activity

Air pollution due

to burning flames

Land and water

contamination

from drilling mud

and hydraulic

fluids

E Oil & Gas Safety

Regulations, 1974

UEPL

Environmental

Management

Standard

Well Control System

Blowout Preventer are

installed in order to control the

back kick of raw natural gas

Acceptable

Evaluate Risk

4 B

Tolerable (if ALARP)

‐

Follow the site

emergency response

plan and emergency

drills as per routine

‐

8 Produced water

production

during testing

operation

Overflow from lined

pit due to high

produced water

production and high

rains

Soil erosion A Commitments in

EIA/EMP of

particular area

Testing operation comprises

only of 2‐3 days operation

During that period, produced

water is sent to lined pit which

is big enough to handle

amounts of produced water

Even in case of high levels or

with chance of overflow,

produced water will be sent to

pit made for drill cuttings

Produced water can be re‐

injected into the deep

subsurface formations

wherever possible

Acceptable

1 2 2 2 2 9

‐ ‐

‐

9 Chemicals

storage at

drilling site

Spill of chemicals Land

contamination and

soil erosion

A Commitments in

EIA/EMP of

particular area

Storing of chemicals in

secondary containments

Acceptable

Evaluate Risk

2 D

Tolerable (if

ALARP)

‐

Inspection of

secondary

Containment

‐

10 Diesel storage

and use at

drilling site

Fire due to ignition of

spilled diesel

Air Pollution

(NOx, SOx, Acid

rain, Global

warming)

E Commitments in

EIA/EMP of

particular area

Spill control Plans

No smoking at site

Inspection of secondary

containments

SOP of diesel filling procedure

Acceptable

Evaluate Risk

2 D

Tolerable (if

ALARP)

‐

Training of staff at

site regarding Site

Emergency

Response Plans

‐

Diesel spill from diesel

storage tanks and

Land

contamination and

A Commitments in

EIA/EMP of

particular area

Secondary containment

around diesel tank

Liner under the power engines

Acceptable

1 1 1 2 2 7

‐ ‐

‐



No





scenarios)

Management

Attention

Actions

Description of

Aspect

(source‐

pathway‐

receptor)


(Consequence) N/A/E

Applicable

Legislation

Control Measures

(Engineered and

Management)

Control

Measure

Status

Comments


status?


endan

ger human

s, w

ildlife




liability?


dam

age the Compan

y’s

reputation?




If >5 the


Evaluate

EnvironmentalRisk

Consequence

Frequency

Risk

For

Normal

and

Abnormal

Events

For

Accident

Scenarios

Actions

Required for

Significant

Environmental

Aspects

from power

generation equipment

water aquifer

deterioration

Routine inspections

11 Use of mud

during drilling

operation

Loss of containment

from mud tanks and

circulation system

including pumps

Land

contamination/

Water aquifer

contamination

E Commitments in

EIA/EMP of

particular area

Mud control system

PM of mud pumps

Acceptable

Evaluate Risk

2 D

Low

‐ ‐

‐


Wildlife

protection/Waste

management/

Safety hazards

N Commitments in

EIA/EMP of

particular area

All pits at the well site and

campsite will be backfilled


activities the well site and

campsite is clean and that no

refuse has been left behind

Remove all concrete structures

In case of a dry well, access

track sections not in use will be

restored

In case of a producing well ,

well site and access roads will

be retained to support well

access works for testing and

other operational requirements

Wellhead for a producing well

will be enclosed by a lock steel

cage

In case of producing well,

retain construction pit areas for

producing wells but remove all

liquid waste from the site

Acceptable

1 2 2 2 2 9

‐ ‐

‐




Table C‐4: Environmental Aspect Register for Laying of Flow Line/Tie‐in/Wellhead Works

No





scenarios)

Management

Attention

Actions

Description of

Aspect

(source‐

pathway‐

receptor)

Condition (Threat) Impact

(Consequence) N/A/E

Applicable

Legislation

Control Measures

(Engineered and

Management)

Control

Measure

Status

Comments


status?


endan

ger human

s, w

ildlife




liability?


dam

age the Compan

y’s

reputation?


the scenario present an env

issue in its own right?

If >5 the

aspect is

significant

Evaluate

EnvironmentalRisk

Consequence

Frequency

Risk

For

Normal

and

Abnormal

Events

For

Accident

Scenarios

Actions

Required for

Significant

Environmental

Aspects

1 Land acquisition Vegetation clearing/



Act, 1894


compensation amounts for

land leased

Pay compensation amounts as

soon as possible

Loss of standing crops,

traditional land rights and

community ownership will be

given due consideration while

determining compensation

amounts

Compensation amounts will be

settled based on prevailing

market rates



register

Avoid settlements and

agriculture fields as far as

possible

Compensation amounts will be

settled after an agreement is

reached between the local

residents, company and local

administrator

Acceptable

2 2 2 2 2 10

‐ ‐

‐

2 Equipment and

crew

mobilization and

demobilization

Dust and vehicular

emissions


Environmental


Sindh

Environmental

Quality Standards,

2016


speed


condition

Avoid off‐road travel as much

as possible

Conduct vehicle and


Acceptable

2 2 1 2 2 9

‐ ‐

‐


Environmental


Sindh

Environmental

Quality Standards,

2016


project vehicles


not be allowed


noise emitting vehicles and

equipment

Acceptable

2 2 1 2 2 9

‐ ‐

‐

Driving practices Safety hazards –

locals

N Motor Vehicles

Rules, 1969 or

Provincial Motor

Vehicles

(Amendment)

Ordinance, 2002

Train drivers on responsible


Observe minimum distances

from local communities


speed


condition


Acceptable

1 2 1 2 2 8

‐ ‐

‐



No





scenarios)

Management

Attention

Actions

Description of

Aspect

(source‐

pathway‐

receptor)


(Consequence) N/A/E

Applicable

Legislation

Control Measures

(Engineered and

Management)

Control

Measure

Status

Comments


status?


endan

ger human

s, w

ildlife




liability?


dam

age the Compan

y’s

reputation?




If >5 the

aspect is

significant

Evaluate

EnvironmentalRisk

Consequence

Frequency

Risk

For

Normal

and

Abnormal

Events

For

Accident

Scenarios

Actions

Required for

Significant

Environmental

Aspects

Conduct vehicle and


Vehicular/machinery

movement

Damage to local

infrastructure

N Commitments in

EIA/EMP

Minimize and control

unnecessary logistic activities

Regulate speed limits on local

roads subject to road condition

Observe height of overhead

electric/phone transmission

lines especially during

transportation of heavy

equipment

Properly manage

transportation of heavy

equipment and movement of

heavy traffic

Acceptable

1 2 1 2 2 8

‐ ‐

‐

3 Construction/

Improvement of

access tracks


Off‐road travel

Soil erosion/

Wildlife

disturbance

N Sindh Wildlife

Protection

Ordinance 1972 and

Amendments, 2001


and cutting of trees

Locate campsite and other

land acquired for flow line and

operation activities in existing

clearings (if possible) and on

levelled land


access tracks

Select routes of minimum

disturbances for development

of new tracks



will be kept to a minimum



equipment to work areas only



changes and soil conditions



travel


as possible


tracks

Acceptable

2 2 2 2 2 10

‐ ‐

‐

Handling of fuel and

oil

Soil and water

contamination

N Hazardous

Substances Rules,

2014

Vehicles will be daily checked



operations will be done using

a dedicated fuel vehicle



Procedure for transfer shall be

developed and implemented

Acceptable

2 1 1 2 2 8

‐ ‐

‐



No





scenarios)

Management

Attention

Actions

Description of

Aspect

(source‐

pathway‐

receptor)


(Consequence) N/A/E

Applicable

Legislation

Control Measures

(Engineered and

Management)

Control

Measure

Status

Comments


status?


endan

ger human

s, w

ildlife




liability?


dam

age the Compan

y’s

reputation?




If >5 the

aspect is

significant

Evaluate

EnvironmentalRisk

Consequence

Frequency

Risk

For

Normal

and

Abnormal

Events

For

Accident

Scenarios

Actions

Required for

Significant

Environmental

Aspects

Use of horns/

Improperly


Noise pollution N Sindh

Environmental


Sindh

Environmental

Quality Standards,

2016


bulldozers, vehicles and other

potentially noisy equipment is

in good condition



communities


vehicles


be allowed

Restrict all vehicles and


only


2 2 1 2 2 9

‐ ‐

‐

Dust and vehicular

emissions


Environmental


Sindh

Environmental

Quality Standards,

2016


speed



practices


as possible




Properly maintain vehicles and

equipment



only



emissions

Acceptable

2 2 1 2 2 9

‐ ‐

‐



Soil erosion/Public

grievance

N The Forest Act,

1927

Minimize vegetation clearance


access tracks



will be minimized







amounts



dense vegetation



as fuel

Acceptable

2 2 3 2 2 11

‐ ‐

‐



No





scenarios)

Management

Attention

Actions

Description of

Aspect

(source‐

pathway‐

receptor)


(Consequence) N/A/E

Applicable

Legislation

Control Measures

(Engineered and

Management)

Control

Measure

Status

Comments


status?


endan

ger human

s, w

ildlife




liability?


dam

age the Compan

y’s

reputation?




If >5 the

aspect is

significant

Evaluate

EnvironmentalRisk

Consequence

Frequency

Risk

For

Normal

and

Abnormal

Events

For

Accident

Scenarios

Actions

Required for

Significant

Environmental

Aspects

Land clearing of

access track

Loss of habitat/

Disturbance to

wildlife

N Sindh Wildlife

Protection

Ordinance, 1972

and Amendments,

2001

Sindh

Environmental



access roads



will be minimized



dense vegetation



during construction

Acceptable

2 2 2 2 2 10

‐ ‐

‐

Driving practices/

Dust emissions

Safety hazards and

disturbance to

communities

N Motor Vehicles

Rules, 1969 or

Provincial Motor

Vehicles

(Amendment)

Ordinance, 2002








community complaint register

Repair any damage caused by

project activities to local

infrastructure by mutual

consensus


UEPL HSE guidelines


cultural norms




Acceptable

1 2 1 2 2 8

‐ ‐

‐

Vehicular/Machinery

movement

Disturbance to

wildlife

N Sindh Wildlife

Protection

Ordinance, 1972

and Amendments,

2001


killing, trapping, feeding or



access tracks


development or improvement

will be minimized


vegetation clearing

Maintain construction vehicles

and equipment

If possible minimize time

period of operation in areas

where wildlife presence is

confirmed, especially reported

breeding areas



dense vegetation

Acceptable

2 2 2 2 3 11

‐ ‐

‐

4 Camp

construction/


Physical scarring

Soil erosion N The Forest Act,

1927



Acceptable

2 1 2 2 2 9

‐ ‐

‐



No





scenarios)

Management

Attention

Actions

Description of

Aspect

(source‐

pathway‐

receptor)


(Consequence) N/A/E

Applicable

Legislation

Control Measures

(Engineered and

Management)

Control

Measure

Status

Comments


status?


endan

ger human

s, w

ildlife




liability?


dam

age the Compan

y’s

reputation?




If >5 the

aspect is

significant

Evaluate

EnvironmentalRisk

Consequence

Frequency

Risk

For

Normal

and

Abnormal

Events

For

Accident

Scenarios

Actions

Required for

Significant

Environmental

Aspects

Establishment/

Operation

Locate campsites in existing

clearings and on levelled land


the camps




Proper restoration will be done

after camp demobilization

Waste management/

Handling of fuel, oils

& chemicals

Soil and water

contamination

N Sindh

Environmental


Hazardous

Substances Rules,

2014



comprising of septic tanks and

soak pits





soil

Ensure provision of grease pits

at kitchen drain outlets

Keep septic systems at



groundwater wells

Design and construct soak pits

to prevent surface runoff

Design soak pits to







nearest municipal drains with


authorities


will be disposed of in waste

bins

Burning of waste will not be

allowed




fuel or oil leaks





or spills



Acceptable

2 2 2 2 2 10

‐ ‐

‐



No





scenarios)

Management

Attention

Actions

Description of

Aspect

(source‐

pathway‐

receptor)


(Consequence) N/A/E

Applicable

Legislation

Control Measures

(Engineered and

Management)

Control

Measure

Status

Comments


status?


endan

ger human

s, w

ildlife




liability?


dam

age the Compan

y’s

reputation?




If >5 the

aspect is

significant

Evaluate

EnvironmentalRisk

Consequence

Frequency

Risk

For

Normal

and

Abnormal

Events

For

Accident

Scenarios

Actions

Required for

Significant

Environmental

Aspects

contents




masonry bunds



handling

Dust/Exhaust

emissions


Environmental


Sindh

Environmental

Quality Standards,

2016





communities



emissions

Carryout emission testing of


Acceptable

2 2 1 2 2 9

‐ ‐

‐

Use of horns/

Improperly


& equipment

Noise and

vibration

N Sindh

Environmental


Sindh

Environmental

Quality Standards,

2016




condition



communities


project vehicles


be allowed



only

Maintenance of equipment and

machinery shall be carried out

on regular basis

Carryout noise monitoring of

noisy equipment

Acceptable

2 2 1 2 2 9

‐ ‐

‐

Water abstraction/


Water pollution/

Resource depletion

N Sindh

Environmental




Under unavoidable conditions

(due to improper access for

water bowsers, long haul

distances or unavailability of

tube wells in the project area

etc.) water abstraction from

surface water body will be

allowed after getting a formal

approval from relevant

department




Acceptable

2 3 2 2 2 11

‐ ‐

‐



No





scenarios)

Management

Attention

Actions

Description of

Aspect

(source‐

pathway‐

receptor)


(Consequence) N/A/E

Applicable

Legislation

Control Measures

(Engineered and

Management)

Control

Measure

Status

Comments


status?


endan

ger human

s, w

ildlife




liability?


dam

age the Compan

y’s

reputation?




If >5 the

aspect is

significant

Evaluate

EnvironmentalRisk

Consequence

Frequency

Risk

For

Normal

and

Abnormal

Events

For

Accident

Scenarios

Actions

Required for

Significant

Environmental

Aspects

water consumption for camps

and operational usages



wells


aquifer

Groundwater resources will

not be over exploited







demand

Utilization of water resources

that are in possession of local

owners shall be appropriately

compensated as per mutual


Waste disposal/Use of

machinery

Disturbance to

wildlife

N Sindh Wildlife

Protection

Ordinance, 1972

and Amendments,

2001





the open

Food waste will be properly

buried in a bury pit



Acceptable

2 3 3 3 3 14

‐ ‐

‐

5 Clearing,

levelling and

excavation for

flow line right of

way (RoW)


Physical scarring

Soil erosion/

Damage to habitat

A The Forest Act,

1927






Minimize disturbance to

natural topography and soils


speed


as possible




Acceptable

2 2 2 2 1 9

‐ ‐

‐



No





scenarios)

Management

Attention

Actions

Description of

Aspect

(source‐

pathway‐

receptor)


(Consequence) N/A/E

Applicable

Legislation

Control Measures

(Engineered and

Management)

Control

Measure

Status

Comments


status?


endan

ger human

s, w

ildlife




liability?


dam

age the Compan

y’s

reputation?




If >5 the

aspect is

significant

Evaluate

EnvironmentalRisk

Consequence

Frequency

Risk

For

Normal

and

Abnormal

Events

For

Accident

Scenarios

Actions

Required for

Significant

Environmental

Aspects

Waste disposal/


and chemicals

Soil and water

contamination

A Sindh

Environmental


Hazardous

Substances Rules,

2014

Prohibit solid waste disposal

in the field

Regularly check vehicle for

fuel or oil leaks

Use a dedicated fuel vehicle


operation


and spills

Incineration or bioremediation

to treat soils contaminated

with oil spills

Acceptable

2 1 2 2 2 9

‐ ‐

‐

Use of horns/

Improperly


Noise and

vibration

N Sindh Wildlife

Protection

Ordinance, 1972

and Amendments,

2001


project vehicles

Maintain generators

construction machinery in

good condition


not be allowed



equipment within work areas

Acceptable

2 2 1 2 2 9

‐ ‐

‐

Dust/Exhaust

emissions


Environmental


Sindh

Environmental

Quality Standards,

2016


condition



practices


vehicle and equipment

Maintain safe distances from

sensitive environmental

receptors

Acceptable

2 2 1 2 2 9

‐ ‐

‐



Loss of habitat/

Public grievance

N The Forest Act,

1927

Minimize clearing of

vegetation


as fuel by crew personnel







amounts

Minimize width of flow line

right of the way

Acceptable

2 2 2 2 3 11

‐ ‐

‐



No





scenarios)

Management

Attention

Actions

Description of

Aspect

(source‐

pathway‐

receptor)


(Consequence) N/A/E

Applicable

Legislation

Control Measures

(Engineered and

Management)

Control

Measure

Status

Comments


status?


endan

ger human

s, w

ildlife




liability?


dam

age the Compan

y’s

reputation?




If >5 the

aspect is

significant

Evaluate

EnvironmentalRisk

Consequence

Frequency

Risk

For

Normal

and

Abnormal

Events

For

Accident

Scenarios

Actions

Required for

Significant

Environmental

Aspects

Waste disposal/

Vehicular movement

Disturbance to

wildlife

N Sindh Wildlife

Protection

Ordinance, 1972

and Amendments,

2001





and land uptake




the open

Food waste will be properly

buried in a bury pit


condition to reduce noise

Initiate activities with soft start

to allow time for wildlife

species to move away from the

project area

Acceptable

2 2 2 2 3 11

‐ ‐

‐

Driving practices/

Local resource

utilization

Safety hazards and

disturbance to

communities

N Motor Vehicles

Rules, 1969 or

Provincial Motor

Vehicles

(Amendment)

Ordinance, 2002







Manage and maintain


register





Repair any damage (if any)

caused by project activities to

local infrastructure by mutual

consensus


UEPL HSE guidelines

Project staff to respect cultural

norms




Maintain effective

communication channels with

local communities to inform

them about the progress of

various project activities

Acceptable

1 2 1 2 2 8

‐ ‐

‐



No





scenarios)

Management

Attention

Actions

Description of

Aspect

(source‐

pathway‐

receptor)


(Consequence) N/A/E

Applicable

Legislation

Control Measures

(Engineered and

Management)

Control

Measure

Status

Comments


status?


endan

ger human

s, w

ildlife




liability?


dam

age the Compan

y’s

reputation?




If >5 the

aspect is

significant

Evaluate

EnvironmentalRisk

Consequence

Frequency

Risk

For

Normal

and

Abnormal

Events

For

Accident

Scenarios

Actions

Required for

Significant

Environmental

Aspects

6 Flow line laying

(stringing,

welding etc.)/

Flow line

operation

Disturbance to

wildlife

Ecological

misbalance

N Sindh Wildlife

Protection

Ordinance, 1972

and Amendments,

2001





the open. Food waste will be

properly buried in a bury pit



Acceptable

2 3 3 3 3 14

‐ ‐

‐

Use of horns/

Machinery movement

Noise and

vibration

N Sindh

Environmental


Sindh

Environmental

Quality Standards,

2016

Minimize the use of horns by

project vehicles


not be allowed

Restrict movement of all

project vehicles and personnel

within work areas

Carryout noise monitoring of

noisy equipment and

machinery

Acceptable

2 2 2 3 3 12

‐ ‐

‐

Dust/Exhaust

emissions


Environmental


Sindh

Environmental

Quality Standards,

2016


condition





vehicle and machinery

Maintain safe distances

Acceptable

2 2 2 2 2 10

‐ ‐

‐

Waste disposal/


and chemicals

Soil and water

contamination

N Sindh

Environmental


Hazardous

Substances Rules,

2014



Regularly check vehicle for

fuel and oil leaks

Use dedicated vehicle for fuel

and oil transfer



with oil spills

Waste management plan shall

be developed

oil/fuel transfer procedure

shall be developed and

implemented

Acceptable

2 2 3 2 2 11

‐ ‐

‐



No





scenarios)

Management

Attention

Actions

Description of

Aspect

(source‐

pathway‐

receptor)


(Consequence) N/A/E

Applicable

Legislation

Control Measures

(Engineered and

Management)

Control

Measure

Status

Comments


status?


endan

ger human

s, w

ildlife




liability?


dam

age the Compan

y’s

reputation?




If >5 the

aspect is

significant

Evaluate

EnvironmentalRisk

Consequence

Frequency

Risk

For

Normal

and

Abnormal

Events

For

Accident

Scenarios

Actions

Required for

Significant

Environmental

Aspects

Water abstraction/


Water pollution/

Resource depletion

N Sindh

Environmental




Under unavoidable conditions

(due to improper access for

water bowsers, long haul

distances or unavailability of

tube wells in the project area

etc.) water abstraction from

surface water body will be

allowed after getting a formal

approval from concerned

government department




water consumption for camps

and operational usages



wells


aquifer

Groundwater resources will

not be over exploited







demand

Utilization of water resources

that are in possession of local

owners shall be appropriately

compensated as per mutual


Acceptable

2 3 2 2 2 11

‐ ‐

‐

7 Waste

management


waste/Handling of

fuel, oil & chemicals

Air, soil and water

contamination

N Sindh

Environmental


Hazardous

Substances Rules,

2014

Sindh

Environmental

Quality Standards,

2016


the campsite in septic systems

comprising septic tanks and

soak pits





soil

Construct soak pits to prevent

surface runoff entry

Design soak pits to




Ensure provision of grease pits

Acceptable

2 2 3 2 2 11

‐ ‐

‐



No





scenarios)

Management

Attention

Actions

Description of

Aspect

(source‐

pathway‐

receptor)


(Consequence) N/A/E

Applicable

Legislation

Control Measures

(Engineered and

Management)

Control

Measure

Status

Comments


status?


endan

ger human

s, w

ildlife




liability?


dam

age the Compan

y’s

reputation?




If >5 the

aspect is

significant

Evaluate

EnvironmentalRisk

Consequence

Frequency

Risk

For

Normal

and

Abnormal

Events

For

Accident

Scenarios

Actions

Required for

Significant

Environmental

Aspects

at kitchen drain outlets




nearest municipal drains with


authorities




waste



Burning of waste will be

prohibited


leaks



underneath with secondary



bunds to prevent soil


or spills



contents

Use dedicated vehicles for fuel

and oil transfer operations


and leaks



with oil spills






related waste

Incinerate all clinical wastes

Maintain generators,

compressors and vehicles in

good condition




the open. Food waste will be

properly buried in a bury pit

8 Community

issues



Soil erosion/Public

grievance

N The Forest Act,

1927



Acceptable

2 2 2 2 2 10

‐ ‐

‐



No





scenarios)

Management

Attention

Actions

Description of

Aspect

(source‐

pathway‐

receptor)


(Consequence) N/A/E

Applicable

Legislation

Control Measures

(Engineered and

Management)

Control

Measure

Status

Comments


status?


endan

ger human

s, w

ildlife




liability?


dam

age the Compan

y’s

reputation?




If >5 the

aspect is

significant

Evaluate

EnvironmentalRisk

Consequence

Frequency

Risk

For

Normal

and

Abnormal

Events

For

Accident

Scenarios

Actions

Required for

Significant

Environmental

Aspects

register

Disburse compensation

amounts in an equitable and

transparent manner

Pay compensation amounts as

soon as possible






amounts

Pay appropriate compensation

amounts




If there are opportunities,

ensure equitable and

transparent recruitment of

local unskilled labour during

different phases of the project

activities subject to company’s

selection criteria

Local residents living closest to

the project location will be

given priority in the

employment process





Flow of water in surface water

body will not be impeded



guidelines



A mechanism will be defined

to address the local

community grievances

appropriately

Project staff will respect

cultural norms

Provide appropriate offsets

from sites of religious, cultural

or archaeological significance


Wildlife

protection/Waste

N Restore soak pits after project

completion


activities the campsite is clean

Acceptable

1 2 2 2 2 9

‐ ‐

‐



No





scenarios)

Management

Attention

Actions

Description of

Aspect

(source‐

pathway‐

receptor)


(Consequence) N/A/E

Applicable

Legislation

Control Measures

(Engineered and

Management)

Control

Measure

Status

Comments


status?


endan

ger human

s, w

ildlife




liability?


dam

age the Compan

y’s

reputation?




If >5 the

aspect is

significant

Evaluate

EnvironmentalRisk

Consequence

Frequency

Risk

For

Normal

and

Abnormal

Events

For

Accident

Scenarios

Actions

Required for

Significant

Environmental

Aspects

management/

Safety hazards

and that no refuse has been left

behind

Remove all concrete structures

Avoid using local fuel wood




Table C‐5: Environmental Aspect Register for Hydrocarbon Processing Facility (GPF/CPP)

No

Detailed Description of the Aspect ‐ Impact

Existing Controls and their Adequacy Impacts Significance Evaluation

Questions

Risk (only evaluated for

accident scenarios)

Management Attention

Actions

Description of

Aspect (source‐

pathway‐

receptor)

Condition

(Threat)

Impact

(Consequence) N/A/E

Applicable

Legislation

Control Measures

(Engineered and

Management)

Control

Measure

Status

Comments


status?


endan

ger human

s, w

ildlife


create an env liability?


dam

age the Compan

y’s



If >5 the

aspect is

significant

Evaluate

Environmental Risk

Consequence

Frequency

Risk

For Normal

and

Abnormal

Events

For

Accident

Scenarios

Actions Required for

Significant Environmental

Aspects

1 Land

acquisition

Loss of

vegetation/crops/

trees

Public

grievances

N Land

Acquisition

Act, 1894

Compensation as per

mutual agreement

Acceptable 2 2 2 2 2 10

‐ ‐

‐

2 Equipment and

crew

mobilization

and

demobilization

Dust and

vehicular

emissions


Environmental

Protection Act,

2014 (Sindh

Environmental

Quality

Standard, 2016)


vehicles speed

Maintain vehicles in a

good condition


Maintain safe distances

from communities

Acceptable

2 2 1 2 2 9

‐ ‐

‐

Noise and

vibration

Noise

pollution

N Sindh

Environmental

Protection Act,

2014 (Sindh

Environmental

Quality

Standard, 2016)

Minimize use of horns

by project vehicles

The use of pressure

horns will not be

allowed

Reduce speed while

passing close to

settlements

Acceptable

2 2 1 2 2 9

‐ ‐

‐

Driving practices Safety hazards

‐ locals

N Motor Vehicles

Rules, 1969 or

Provincial

Motor Vehicles

(Amendment)

Ordinance,

2002

Train drivers in

responsible and safe

driving practices

Observe minimum

distances from local

communities

Night travelling will

only be done after

getting approval from

HSEO

Acceptable

1 2 1 2 2 8

‐ ‐

‐

3 Construction/

Improvement of

access tracks

Land clearing Soil

erosion/loss of

habitat/loss of

vegetation

N Land

Acquisition

Act, 1894

Sindh Wildlife

Protection

Ordinance,

1972 and

Amendments

2001

Sindh

Environmental

Protection Act,

2014

Use of existing track as

much as possible to

minimize preparation of

new access track

Width of existing track

development or


kept to a minimum


personnel and


to work areas



monitor any changes

and soil conditions

Acceptable

2 2 2 2 2 10

‐ ‐

‐



No



Questions


accident scenarios)


Actions

Description of

Aspect (source‐

pathway‐

receptor)

Condition

(Threat)

Impact

(Consequence) N/A/E

Applicable

Legislation

Control Measures

(Engineered and

Management)

Control

Measure

Status

Comments


status?


endan

ger human

s, w

ildlife




dam

age the Compan

y’s



If >5 the

aspect is

significant

Evaluate

Environmental Risk

Consequence

Frequency

Risk

For Normal

and

Abnormal

Events

For

Accident

Scenarios



Aspects

Train drivers on

mitigation measures

related to off‐road travel


Access track to the

GPF/CPP will be

properly compacted

Handling of fuel,

oils and

chemicals

Soil and water

contamination

N Hazard

Substances

Rules, 2014

Vehicles will be daily

checked for fuel or oil

leaks


operations will be done

using a dedicated fuel

vehicle

Drip pans will be used

to avoid drips and spills

Acceptable

2 1 1 2 2 8

‐ ‐

‐

Use of

horn/improperly

maintained

machinery

Noise

pollution

N Sindh

Environmental

Protection Act,

2014 (Sindh

Environmental

Quality

Standard, 2016)


by project vehicles

Use of pressure horns

will not be allowed

Properly maintain

vehicles and


Restrict all project

vehicles and personnel

within work areas

Acceptable

2 2 1 2 2 9

‐ ‐

‐

Dust and

vehicular

emissions


Environmental

Protection Act,

2014 (Sindh

Environmental

Quality

Standard, 2016)


vehicles speed

Minimize dust emissions

by employing good



Sprinkle water where

necessary

Train drivers on

mitigation measures


and speed limits

Acceptable

2 2 1 2 2 9

‐ ‐

‐

Driving

practices/resource

utilization

Safety hazards

and

disturbance to

communities

N Motor Vehicles

Rules, 1969 or

Provincial

Motor Vehicles

(Amendment)

Ordinance,

2002

Train drivers on

mitigation measures


and speed limits

Comply with all

EIA/EMP mitigation

related to waste, noise

and dust emissions

Acceptable

1 2 1 2 2 8

‐ ‐

‐



No



Questions


accident scenarios)


Actions

Description of

Aspect (source‐

pathway‐

receptor)

Condition

(Threat)

Impact

(Consequence) N/A/E

Applicable

Legislation

Control Measures

(Engineered and

Management)

Control

Measure

Status

Comments


status?


endan

ger human

s, w

ildlife




dam

age the Compan

y’s



If >5 the

aspect is

significant

Evaluate

Environmental Risk

Consequence

Frequency

Risk

For Normal

and

Abnormal

Events

For

Accident

Scenarios



Aspects



register

Local sources of

drinking water will be

used only after



Observe strict

compliance with UEPL

HSE guidelines


cultural norms

Provide offsets from

sites of religious,

cultural or

archaeological

significance

Vehicular

movement

Disturbance to

wildlife/loss of

vegetation

N Sindh Wildlife

Protection

Ordinance,

1972 and

Amendments

2001

Prohibit hunting,

fishing, trapping or


Minimize preparation of

new access tracks


development or


kept to a minimized

Select routes with

minimum vegetation

clearing


vegetation

Maintain construction



operation near dhands

(especially which are

breeding areas) and

canals


individual projects on

wildlife species

Access tracks should

avoid passing through

the areas with dense

vegetation

Acceptable

2 2 2 2 3 11

‐ ‐

‐



No



Questions


accident scenarios)


Actions

Description of

Aspect (source‐

pathway‐

receptor)

Condition

(Threat)

Impact

(Consequence) N/A/E

Applicable

Legislation

Control Measures

(Engineered and

Management)

Control

Measure

Status

Comments


status?


endan

ger human

s, w

ildlife




dam

age the Compan

y’s



If >5 the

aspect is

significant

Evaluate

Environmental Risk

Consequence

Frequency

Risk

For Normal

and

Abnormal

Events

For

Accident

Scenarios



Aspects

4 Camp/GPF/CPP

expansion,

establishment

and operation

Vegetation

clearing

Soil erosion/

Physical

scarring

N The Forest Act,

1927 Minimize vegetation

clearing


Locate campsites in

existing clearing and on

levelled land

Minimize total land

uptake by campsite and

GPF/CPP



monitor any changes in

soil conditions

Acceptable

2 1 2 2 2 9

‐ ‐

‐

Waste

management

/handling of fuel,

oils and

chemicals

Soil/Water

contamination

N Sindh

Environmental

Protection Act,

2014

Hazardous

Substance

Rules, 2014

Sewage Treatment Plant

(STP) shall be preferred

for handling of

black/grey water under

BATNEEC/BAT, but in

case of unavailability of

STP, septic tank and

soak pits shall be

provided. Septic tank

and soak pit shall be

covered properly to

avoid any bad smell in

surrounding areas

Sprinkling of grey water

will not be allowed; in

case the septic tank gets

filled with sludge, septic

tank shall be emptied

through vacuum truck

and material shall be

transferred to treatment

facility or approved

municipal drain

Produced water

separated at GPF shall

be re‐injected to

reservoir through deep

well injection (first

priority).

However it can be sent

to lined E‐Pond if no

technical feasible

options are available

Acceptable

2 2 2 2 2 10

‐ ‐

‐



No



Questions


accident scenarios)


Actions

Description of

Aspect (source‐

pathway‐

receptor)

Condition

(Threat)

Impact

(Consequence) N/A/E

Applicable

Legislation

Control Measures

(Engineered and

Management)

Control

Measure

Status

Comments


status?


endan

ger human

s, w

ildlife




dam

age the Compan

y’s



If >5 the

aspect is

significant

Evaluate

Environmental Risk

Consequence

Frequency

Risk

For Normal

and

Abnormal

Events

For

Accident

Scenarios



Aspects

Solid wastes at the

campsite and GPF/CPP

will be disposed of in

waste bins

Wash vehicles in

designated areas within

campsite

Regularly check vehicles


All fuel and oil storage

areas will have a

concrete pad underneath

to prevent soil


leaks or spills


properly marked to

highlight their contents

Fuel and oil storage

areas will have

secondary containment

in the form of concrete

or brick masonry bunds

Ensure provision for

proper fuel and oil

storage and handling

Ensure preparation of a

spill prevention and

contingency plan

Ensure provisions of a

HDPE liner for the waste

pits at the campsite and

GPF/CPP

Dust/Exhaust

emissions


Environmental

Protection Act,

2014 (Sindh

Environmental

Quality

Standard, 2016)


equipment in good

condition

Select campsite locations

at least 300 m away from

communities

Employ good

management practice to

minimize dust emissions

Regular monitoring of

GPF/CPP point source

emissions to ensure

compliance with SEQS

Acceptable

2 2 1 2 2 9

‐ ‐

‐



No



Questions


accident scenarios)


Actions

Description of

Aspect (source‐

pathway‐

receptor)

Condition

(Threat)

Impact

(Consequence) N/A/E

Applicable

Legislation

Control Measures

(Engineered and

Management)

Control

Measure

Status

Comments


status?


endan

ger human

s, w

ildlife




dam

age the Compan

y’s



If >5 the

aspect is

significant

Evaluate

Environmental Risk

Consequence

Frequency

Risk

For Normal

and

Abnormal

Events

For

Accident

Scenarios



Aspects

Use of

horns/improper

maintained

machinery

Noise and

vibration

N Sindh

Environmental

Protection Act,

2014


vehicles and other

potentially noisy

equipment are in good

condition

Select campsite locations

at least 300 m away from

communities

Randomly monitor noise

levels at nearest

receptors. Also consult

communities regarding

disturbance due to noise

and vibration


by project vehicles

Use of pressure horns

will not be allowed

Restrict all project

vehicles and personnel

within work areas

Use noise barriers if

required

Acceptable

2 2 1 2 2 9

‐ ‐

‐

Resource

utilization

Resource

depletion/

water

pollution

N Sindh

Environmental

Protection Act,

2014

Prohibit use of water

from surface water

bodies



Keep complete records

of water consumption

during project

construction and

operation

Obtain water required

for project activities

from local wells, existing

or new UEPL water

wells in the area

Install (if required) new

water wells 300 m from

existing local wells

Abstract water from

deep aquifer

Water from a local well

will only be used after

ensuring that the

Acceptable

2 3 2 2 2 11

‐ ‐

‐



No



Questions


accident scenarios)


Actions

Description of

Aspect (source‐

pathway‐

receptor)

Condition

(Threat)

Impact

(Consequence) N/A/E

Applicable

Legislation

Control Measures

(Engineered and

Management)

Control

Measure

Status

Comments


status?


endan

ger human

s, w

ildlife




dam

age the Compan

y’s



If >5 the

aspect is

significant

Evaluate

Environmental Risk

Consequence

Frequency

Risk

For Normal

and

Abnormal

Events

For

Accident

Scenarios



Aspects

available capacity at the

tube well (safe yield

minus local demand) is

at least 50% greater than

the project demand

Water from dhands will

not be used

Minimize fuel

consumption, encourage

conservation techniques

Noise and

vibration/waste

disposal

Disturbance to

wildlife

N Sindh Wildlife

Protection

Ordinance,

1972 and

Amendments

2001

Prohibit hunting,

fishing, trapping or


Food wastes will not be

left in the open


equipment in good

condition

Night travelling will

only be done after

getting approval from

HSEO

Acceptable

2 3 3 3 3 14

‐ ‐

‐

5 Waste

management

Improper

disposal of waste/

handling of fuel,

oil and chemicals

Soil and water

contamination

N Sindh

Environmental

Protection Act,

2014 (Sindh

Environmental

Quality

Standard, 2016)

Dispose sewage

generated in septic

systems comprising of

septic tanks and soak

pits

Dispose wastewater

from laundry, kitchen

washings, and showers

directly into soak pits

Build soak pits in

absorbent soil

Ensure that the storage

soak pits remain covered

all the time and

measures are taken to

prevent entry of

rainwater into them

Design soak pits to

accommodate

wastewater generated

during the total duration

of the operation

In case the soak pits get

filled during the

Acceptable

2 2 3 2 2 11

‐ ‐

‐



No



Questions


accident scenarios)


Actions

Description of

Aspect (source‐

pathway‐

receptor)

Condition

(Threat)

Impact

(Consequence) N/A/E

Applicable

Legislation

Control Measures

(Engineered and

Management)

Control

Measure

Status

Comments


status?


endan

ger human

s, w

ildlife




dam

age the Compan

y’s



If >5 the

aspect is

significant

Evaluate

Environmental Risk

Consequence

Frequency

Risk

For Normal

and

Abnormal

Events

For

Accident

Scenarios



Aspects

operation, grey water

will be transferred to


with prior approval of

concerned authorities

Produced water

separated at GPF/CPP

shall be re‐injected to

reservoir through deep

well injection (first

priority).

However it can be sent

to lined E‐Pond if no

technical feasible

options are available




waste

Burning waste will not

be allowed

Wash vehicles in

designated areas within

campsite

Check vehicles for fuel

or oil leaks

All fuel and oil storage

areas will have a

concrete pad underneath

to prevent soil


leaks or spills


properly marked to

highlight their contents

Fuel and oil storage

areas will have

secondary containment

in the form of concrete

or brick masonry bunds

Use dedicated vehicles


operations

Use drip pans to avoid

drips and oil stains



No



Questions


accident scenarios)


Actions

Description of

Aspect (source‐

pathway‐

receptor)

Condition

(Threat)

Impact

(Consequence) N/A/E

Applicable

Legislation

Control Measures

(Engineered and

Management)

Control

Measure

Status

Comments


status?


endan

ger human

s, w

ildlife




dam

age the Compan

y’s



If >5 the

aspect is

significant

Evaluate

Environmental Risk

Consequence

Frequency

Risk

For Normal

and

Abnormal

Events

For

Accident

Scenarios



Aspects

Check fuel tanks for

leaks

The soil contaminated

from minor and

moderate spills will be

removed and sent to



incineration




moderate and major

spills

Ensure provision of

proper fuel and oil,

storage and handling

Recycle used oil and

vehicles related waste

Incinerate medical waste

in a medical waste

incineration facility


other equipment in good

condition

Minimize dust emissions

by good management

practices

Food wastes will not be

left in the open

Ensure provision of a

HDPE liner for the waste

pits at the campsite and

GPF/CPP

6 Community

issues

Land acquisition/


Loss of standing

crops

Public

grievances N As per

commitments

of EIA/EMP

UEPL Community

Representative will deal

with community to

address their stances

A mechanism will be

defined to address the

local community

grievances appropriately

Manage and maintain


register

Acceptable

2 2 2 2 2 10

‐ ‐

‐



No



Questions


accident scenarios)


Actions

Description of

Aspect (source‐

pathway‐

receptor)

Condition

(Threat)

Impact

(Consequence) N/A/E

Applicable

Legislation

Control Measures

(Engineered and

Management)

Control

Measure

Status

Comments


status?


endan

ger human

s, w

ildlife




dam

age the Compan

y’s



If >5 the

aspect is

significant

Evaluate

Environmental Risk

Consequence

Frequency

Risk

For Normal

and

Abnormal

Events

For

Accident

Scenarios



Aspects

Comply with all

EIA/EMP mitigation

related to waste, noise

and dust emissions

Groundwater sources

currently being used by

the resident

communities will be

exploited only after



Local sources of

drinking water will be

used only after





guidelines

Respect cultural norms

Provide appropriate

offsets from sites of


archaeological

significance


EIA Kotri North Block F01 - epasindh.gov.pk tech/EIA Kotri North Block.pdf · OCTOBER 2019 ES-5 HPK development well. Each proposed well will be drilled using a conventional land

Documents