Environmental Impact Assessment tech/EIA of LPG... · 2019. 6. 10. · LPG Handling and Transport Services at PIBT Environmental Impact Assessment Final Report HBP Ref.: R9E02JSL

LPG Handling and Transport Services at PIBT

Environmental Impact Assessment

Final Report

HBP Ref.: R9E02JSL

June 10, 2019

Pakistan International Bulk Terminal

Karachi

EIA of LPG Handling and Transport Services at PIBT

Hagler Bailly Pakistan Contents R9E02JSL: 06/10/19 ii

Contents

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

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

1.2 Project Overview ...................................................................................... 1-1

1.3 The Project Proponent ............................................................................. 1-1

1.4 Introduction to the EIA ............................................................................. 1-2

1.5 Project Category ....................................................................................... 1-2

1.6 Scope of the EIA ....................................................................................... 1-2

1.7 Quantitative Risk Assessment ................................................................ 1-2

1.8 Report Organization ................................................................................. 1-2

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

2.1 Sindh Environmental Protection Act 2014 .............................................. 2-1

2.1.1 IEE-EIA Regulations 2014 .............................................................. 2-3

2.1.2 Rules and Regulations for Submission ............................................ 2-3

2.2 Other Relevant Laws ................................................................................ 2-7

2.2.1 Port Qasim Authority Act, 1973 ....................................................... 2-8

2.2.2 Factories Act, 1934 ......................................................................... 2-9

2.2.3 Hazardous Substances ................................................................. 2-10

2.2.4 The Forest Act 1927 ..................................................................... 2-10

2.2.5 Labor and Health and Safety Legislation ....................................... 2-11

2.2.6 International Treaties .................................................................... 2-11

2.2.7 Environmental Standards .............................................................. 2-14

2.3 Institutional Framework ......................................................................... 2-16

2.4 Compliance with the Applicable Licenses and Regulations ............... 2-17

2.5 World Bank/IFC Environmental, Health and Safety Guidelines for Crude Oil and Petroleum Products .................................................. 2-19

2.5.1 Fire Precautions ............................................................................ 2-19

2.5.2 First Aid ........................................................................................ 2-19

2.5.3 Labeling of Equipment .................................................................. 2-20

2.5.4 Communicate Hazard Codes ........................................................ 2-20

2.5.5 Hazardous Materials and Oil ......................................................... 2-20

2.6 IFC Performance Standards .................................................................. 2-20

3. Project Description.......................................................................... 3-1

3.1 Project Background ................................................................................. 3-1


Hagler Bailly Pakistan Contents R9E02JSL: 06/10/19 iii

3.2 Project Location ....................................................................................... 3-1

3.3 Pakistan International Bulk Terminal ...................................................... 3-3

3.4 Project Layout .......................................................................................... 3-3

3.5 Project Features ....................................................................................... 3-6

3.5.1 Jetty Services ................................................................................. 3-6

3.5.2 Transfer to Customer LPG storage facility ...................................... 3-7

3.5.3 LPG Pipelines ................................................................................. 3-8

3.5.4 Firefighting Network ........................................................................ 3-9

3.5.5 Construction .................................................................................... 3-9

4. Analysis of Alternatives .................................................................. 4-1

4.1 No Project Option ..................................................................................... 4-1

4.2 Alternative Site Location .......................................................................... 4-2

4.3 Case for New LPG Storage ...................................................................... 4-3

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

5.1 Study Area ................................................................................................ 5-1

5.2 Physical Environment .............................................................................. 5-2

5.2.1 Topography, Geology and Seismic Hazards ................................... 5-4

5.2.2 Climate ........................................................................................... 5-9

5.2.3 Land Use and Cover ..................................................................... 5-10

5.2.4 Air Quality ..................................................................................... 5-12

5.2.5 Water Resources .......................................................................... 5-15

5.2.6 Noise ............................................................................................ 5-17

5.2.7 Traffic ............................................................................................ 5-17

5.3 Ecological Baseline ................................................................................ 5-18

5.3.1 Mangroves .................................................................................... 5-18

5.3.2 Marine Invertebrates ..................................................................... 5-19

5.3.3 Coastal Fish Fauna and Fishing .................................................... 5-20

5.3.4 Marine Mammals .......................................................................... 5-22

5.3.5 Marine Reptiles and Amphibians ................................................... 5-23

5.3.6 Avifauna ........................................................................................ 5-23

5.3.7 Terrestrial Vegetation .................................................................... 5-25

5.3.8 Terrestrial Mammals ..................................................................... 5-26

5.3.9 Terrestrial Reptiles ........................................................................ 5-27

5.3.10 Protected Areas ............................................................................ 5-27

5.3.11 Habitat Assessment ...................................................................... 5-28

5.4 Socio-economic Baseline ...................................................................... 5-30

5.4.1 Methods of Data Collection ........................................................... 5-30

5.4.2 Administrative Setup ..................................................................... 5-33


Hagler Bailly Pakistan Contents R9E02JSL: 06/10/19 iv

5.4.3 Current Land-use .......................................................................... 5-33

5.4.4 Cultural Heritage ........................................................................... 5-36

5.4.5 Indigenous or Ethnic Minorities ..................................................... 5-36

5.4.6 Health and Health Facilities .......................................................... 5-37

5.4.7 Educational Institutions ................................................................. 5-38

5.4.8 Social Infrastructures and Decision-Making Institutions................. 5-38

5.4.9 Physical Infrastructure .................................................................. 5-38

6. Information Disclosure, Consultation and Participation ............. 6-1

6.1 Objectives of Stakeholder Consultations ............................................... 6-1

6.2 National Regulations and International Practice for Stakeholder Consultations ...................................................................... 6-2

6.2.1 Pakistan Environmental Law ........................................................... 6-2

6.3 Stakeholder Identification and Analysis ................................................. 6-3

6.4 Consultation Methodology ...................................................................... 6-3

6.4.1 Consultation Material ...................................................................... 6-3

6.4.2 Consultation Mechanism for Institutional Consultations .................. 6-3

6.4.3 Consultation Mechanism for Community Consultations .................. 6-6

6.4.4 Documentation and Reporting......................................................... 6-8

7. Environmental Impacts and Mitigation Measures ........................ 7-1

7.1 Introduction .............................................................................................. 7-1

7.2 Methodology ............................................................................................. 7-1

7.3 Quantitative Risk Assessment ................................................................ 7-1

7.3.1 Methodology and Principles ............................................................ 7-2

7.3.2 Design Assumptions ....................................................................... 7-4

7.3.3 Summary of Results for Each Identified Hazard .............................. 7-5

7.3.4 Results and Conclusion .................................................................. 7-5

7.3.5 Conclusion and Recommendation ................................................ 7-11

7.4 Construction Phase Impacts ................................................................. 7-11

7.4.1 Physical Environment ................................................................... 7-11

7.4.2 Ecological Impacts ........................................................................ 7-14

7.4.3 Socioeconomic Impacts ................................................................ 7-15

7.5 Operation Phase ..................................................................................... 7-16

7.5.1 Physical Environment ................................................................... 7-16

7.5.2 Ecological Impacts ........................................................................ 7-17

7.5.3 Socioeconomic Impacts ................................................................ 7-18

8. Environmental Management Plan .................................................. 8-1

8.1 Purpose and Objectives of the EMP ........................................................ 8-1


Hagler Bailly Pakistan Contents R9E02JSL: 06/10/19 v

8.2 Management Approach ............................................................................ 8-1

8.3 Management Responsibilities ................................................................. 8-2

8.4 Mitigation Plan .......................................................................................... 8-3

8.5 Monitoring Plan ........................................................................................ 8-8

8.5.1 Objective of Monitoring ................................................................... 8-8

8.5.2 Performance Indicators ................................................................... 8-8

8.5.3 Environmental Monitoring Plan ....................................................... 8-8

8.5.4 Environmental Records ................................................................. 8-11

8.6 Communication and Documentation .................................................... 8-11

8.6.1 Meetings ....................................................................................... 8-11

8.6.2 Reports ......................................................................................... 8-11

8.6.3 Change-Record Register .............................................................. 8-11

8.7 Change Management ............................................................................. 8-11

8.7.1 First-Order Change ....................................................................... 8-12

8.7.2 Second-Order Change .................................................................. 8-12

8.7.3 Third-Order Change ...................................................................... 8-12

8.7.4 Changes to the EMP ..................................................................... 8-12

8.8 Environmental Training.......................................................................... 8-13

8.9 Frameworks for Key EMP-Related Plans .............................................. 8-15

8.9.1 Occupational Health and Safety Plan ............................................ 8-15

8.9.2 Risk Assessment and Management Plan ...................................... 8-16

8.9.3 Emergency Preparedness and Response Plan ............................. 8-16

8.9.4 Stakeholder Engagement Plan ...................................................... 8-17

8.9.5 Construction Management Plan .................................................... 8-17

8.9.6 Waste and Hazardous Waste Management .................................. 8-17

8.9.7 Decommissioning Plan.................................................................. 8-24

9. Conclusion ....................................................................................... 9-1

Appendices

Appendix A: Detailed Log of Institutional Consultation Meetings

Appendix B: Detailed Log of Community Consultation Meetings

Appendix C: Background Information Document


Hagler Bailly Pakistan Exhibits R9E02JSL: 06/10/19 vi

Exhibits

Exhibit 2.1: EIA Review and Approval Procedure .................................................... 2-5

Exhibit 2.2: Key Environmental Laws in Sindh ......................................................... 2-7

Exhibit 2.3: International Environmental Treaties Endorsed by Pakistan ............... 2-12

Exhibit 2.4: SEQS Limits for Ambient Air Quality ................................................... 2-14

Exhibit 2.5: SEQS Limits for Effluents (mg/l, unless otherwise defined) ................. 2-15

Exhibit 2.6: Sindh Environmental Quality Standards for Noise .............................. 2-16

Exhibit 2.7: IFC Performance Standards and Applicability on the Project .............. 2-21

Exhibit 3.1: Project Location of Proposed Project .................................................... 3-2

Exhibit 3.2: PIBT Facility Entrance (December 2017) .............................................. 3-3

Exhibit 3.3: PIBT Jetty ............................................................................................. 3-4

Exhibit 3.4: Trestle Bridge Connecting the Jetty to PIBT Offshore Facility ............... 3-4

Exhibit 3.5: Project Layout ....................................................................................... 3-5

Exhibit 3.6: LPG Handling Arm ................................................................................ 3-7

Exhibit 3.7: Trestle Bridge Connecting Jetty to PIBT Storage Facility (December 2017) .................................................................................. 3-8

Exhibit 3.8: Route of Pipeline .................................................................................. 3-8

Exhibit 3.9: An Example of LPG Pipeline ................................................................. 3-9

Exhibit 5.1: Study Area ............................................................................................ 5-3

Exhibit 5.2: Topography of the Project area............................................................. 5-5

Exhibit 5.3: Lithology of the Project Area ................................................................. 5-6

Exhibit 5.4: Seismic Hazard Map of Pakistan .......................................................... 5-7

Exhibit 5.5: Historical Tsunamis in the Project Area ................................................ 5-8

Exhibit 5.6: Mean Climatic Data of Karachi.............................................................. 5-9

Exhibit 5.7: Land Use and Cover Distribution in the Study Area ............................ 5-10

Exhibit 5.8: Land Use and Cover Distribution in the Study Area ............................ 5-11

Exhibit 5.9: Ambient Air Quality Measurements in Literature ................................. 5-12

Exhibit 5.10: Secondary Air Quality Sampling Locations ......................................... 5-13

Exhibit 5.11: Ambient Air Quality Sampling Results................................................. 5-14

Exhibit 5.12: Surface Water Resources ................................................................... 5-16


Hagler Bailly Pakistan Exhibits R9E02JSL: 06/10/19 vii

Exhibit 5.13: Photographs of Surface Drains in the Study Area ............................... 5-17

Exhibit 5.14: SEQS and IFC-EHS Noise Limits ....................................................... 5-17

Exhibit 5.15: Truck Traffic from PIBT near Project Site ............................................ 5-18

Exhibit 5.16: Marine Invertebrate Species Observed in Intertidal Mud Flats at Port Qasim in October 2014 and June 2015 ................................... 5-20

Exhibit 5.17: Fishing in Port Qasim Area ................................................................. 5-22

Exhibit 5.18: Vegetation Species observed in Port Qasim Area............................... 5-26

Exhibit 5.19: Protected Areas .................................................................................. 5-28

Exhibit 5.20: List of Surveyed Settlements .............................................................. 5-31

Exhibit 5.21: Location of Surveyed Settlements ...................................................... 5-32

Exhibit 5.22: Summary of Land Use in the Study Area ............................................ 5-33

Exhibit 5.23: Photographs of Land Use in the Study Area ....................................... 5-34

Exhibit 5.24: Milk Transport Containers ................................................................... 5-35

Exhibit 5.25: Typical Sizes of Cattle Farm Operations ............................................. 5-35

Exhibit 5.26: Construction in the Study Area ........................................................... 5-36

Exhibit 5.27: Estimated Settlement Size .................................................................. 5-36

Exhibit 5.28: Ethnicity and Languages Spoken in the Study Area ............................ 5-37

Exhibit 5.29: Yearly Occurrence of Disease in the Study Area ................................ 5-37

Exhibit 5.30: Access to Educational Institutions ....................................................... 5-38

Exhibit 5.31: Photographs of Physical Infrastructure ............................................... 5-39

Exhibit 6.1: List of Institutions and Industries Contacted with Location and Date ..... 6-4

Exhibit 6.2: Institutional Stakeholder Consultation Locations ................................... 6-5

Exhibit 6.3: Photographs of Institutional Stakeholder Consultations ........................ 6-6

Exhibit 6.4: List of Community Stakeholders Consulted .......................................... 6-6

Exhibit 6.5: Consultation Locations ......................................................................... 6-7

Exhibit 6.6: Photographs of Community Stakeholder Consultations ........................ 6-8

Exhibit 6.7: Summary of Concerns Raised by Institutions ........................................ 6-8

Exhibit 6.8: Summary of Concerns Raised by Community ....................................... 6-9

Exhibit 7.1: QRA Process ........................................................................................ 7-2

Exhibit 7.2: Framework for Tolerability of Risk ......................................................... 7-3

Exhibit 7.3: Example Project Risk Matrix ................................................................. 7-4

Exhibit 7.4: Project Risk Matrix Color Legend .......................................................... 7-4


Hagler Bailly Pakistan Exhibits R9E02JSL: 06/10/19 viii

Exhibit 7.5: LSIR of LPG Transfer Pipeline .............................................................. 7-5

Exhibit 7.6: IRPA of LPG Transfer Pipeline ............................................................. 7-6

Exhibit 7.7: LSIR Map Jetty ..................................................................................... 7-7

Exhibit 7.8: IRPA Map Jetty ..................................................................................... 7-7

Exhibit 7.9: F-N Plot Jetty ........................................................................................ 7-8

Exhibit 7.10: F-N Plot LPG Pipeline ........................................................................... 7-9

Exhibit 7.11: Risk Matrix - Asset Risk ...................................................................... 7-10

Exhibit 7.12: Risk Matrix – Environmental Risk ....................................................... 7-10

Exhibit 7.13: Predicted Pollutant Levels at Project Site, 2015 and 2050 (µg/m3) ..... 7-17

Exhibit 8.1: Roles and Responsibilities for Environmental Monitoring ...................... 8-2

Exhibit 8.2: Mitigation Plan during Construction Phase ........................................... 8-4

Exhibit 8.3: Mitigation Plan for the Operation Phase ................................................ 8-6

Exhibit 8.4: Construction Waste Management Plan Summary ................................. 8-7

Exhibit 8.5: Monitoring Plan during Construction Phase .......................................... 8-9

Exhibit 8.6: Monitoring Requirements during Operational Phase ........................... 8-10

Exhibit 8.7: Training Program ................................................................................ 8-14

Exhibit 8.8: Construction Management Plan .......................................................... 8-19

Exhibit 8.9: Construction Waste Management Plan Summary ............................... 8-23


Hagler Bailly Pakistan Introduction

R9E02JSL: 06/10/19 1-1

1. Introduction

Pakistan International Bulk Terminal (PIBT) intends to construct and operate a Liquefied

Petroleum Gas (LPG) Handling and Transport Facility (the ‘Project’) at its existing site in

Port Qasim, Karachi. The Project involves the development of an LPG handling facility

at the existing jetty and pipeline transport to an LPG storage facility to be operated by JS

Petroleum Private Limited (“JSPL” also referred to as “Customer"). In order to comply

with environmental regulations, PIBT acquired the services of Hagler Bailly Pakistan

Pvt. Ltd (HBP) to carry out the Environmental Impact Assessment (EIA) of the proposed

Project. LPG storage is the responsibility of the Customer and a separate Initial

Environmental Examination (IEE) study has been carried out for the storage of LPG.

This EIA report identifies and evaluates the potential environmental and social impacts

which may result from Project-related activities and, where necessary, introduces

measures to mitigate adverse impacts. The EIA process and report meets the regulatory

standards enforced by the Sindh Environmental Protection Agency (SEPA).

1.1 Project Setting

The proposed Project lies in southwestern part of North West Industrial Zone (NWIZ) of

Port Qasim Area, approximately 15 km from National Highway (N 5), in the southern

part of the Malir District, Karachi. The facility will be located in southwestern part of the

Port Qasim within the existing site of Pakistan International Bulk Terminal (PIBT)

(see Section 3 for more detail).

1.2 Project Overview

An LPG handling arm unit will be constructed on the west corner of the jetty for

offloading LPG vessels. LPG from carrier vessels will be transferred to the pipelines that

will carry the LPG from jetty to Customer’s site. Two pipelines will be constructed

between the Customer’s storage facility and PIBT’s jetty - one for liquid transfer and one

for vapor return/balance to ship tanks, with diameters 260 mm and 155 mm respectively.

PIBT is responsible for the transportation of LPG to the Customer site and transportation

of vapor back to the jetty.

The purpose of the Project is to safely and efficiently transport LPG to Port Qasim and

transfer it to a designated storage facility whilst ensuring compliance with all national

laws and environmental management for economically viable handling and transport

operation.

1.3 The Project Proponent

The Project proponent is Pakistan International Bulk Terminal (PIBT) (Pvt.) Limited, a

subsidiary of Pakistan International Container Terminal (PICT). The principal activities

of PIBT are to serve as an import/export terminal for coal, clinker and cement on a

30 year build, operate and transfer concession from Port Qasim Authority (PQA).



R9E02JSL: 06/10/19 1-2

1.4 Introduction to the EIA

This EIA was conducted to meet the regulatory requirements of Pakistan contained in the

Pakistan Environmental Protection Act, 1997 and its associated rules and regulations,

rules and regulations of the Sindh Environmental Protection Act 2014.

1.5 Project Category

In the Sindh province of Pakistan, the Sindh Environmental Protection Agency (Review of

Initial Environmental Examination and Environmental Impact Assessment) Regulations,

2014 provides the project categorization. The regulations include regulations for transport

facilities. Under these regulations, ports and harbor development for ships of 500 gross

tons and above require an EIA. The Project involves development of jetty services and

construction of pipelines for transport of LPG, all of which will involve handling of

chemicals which will exceed 500 tons. An EIA, has therefore, been developed for the

Project.

1.6 Scope of the EIA

The scope of the EIA includes assessment of impacts for the development of jetty

services and for the construction of pipelines from the existing jetty to the Customer’s

site. This also includes construction of an LPG handling arm unit. In addition, the EIA

provides appropriate mitigation and management measures.

This EIA is based on secondary sources included literature, particularly scholarly articles,

journals, recent ESIA surveys and reports carried out by Hagler Bailly Pakistan which

together provide a comprehensive picture of the resources of the area. In addition, a field

visit to the Project site and vicinity was conducted on December 13 and 14, 2017.

1.7 Quantitative Risk Assessment

PIBT acquired the services of RINA Consulting S.p.A1 to carry out a Quantitative Risk

Assessment (QRA) of the LPG Handling and Transport2. The aim and scope of QRA was

to assess and identify overall risks to Project and credible scenarios (such as fire,

explosion and flammable material dispersion) related to equipment and piping failure

leading to possible fluid releases and its effects, in terms of frequency of occurrence and

associated physical and chemical consequences, with respect to health and safety of

people and assets.

1.8 Report Organization

Section 1 (Introduction) provides an overview of the Project, introduces the Project

proponent, and outlines the scope of this study.

1 RINA Consulting is the engineering consultancy division of the RINA Group, the result of the integration

of a number of internationally respected RINA Companies including D’Appolonia, Centro Sviluppo Materiali, Edif ERA (ERA Technology), G.E.T., Logmarin Advisors, OST Energy, Polaris, SC Sembenelli Consulting and Seatech.

2 RINA Consulting S.p.A 2018, Quantitative Risk Assessment (QRA) for the Development of LPG Import Terminal at Port Qasim.



R9E02JSL: 06/10/19 1-3

Section 2 (Legal, Administrative and Institutional Framework) briefly discusses existing

national and provincial policy and resulting legislation for sustainable development and

environmental protection; and then presents the legislative requirements that need to be

followed while conducting an EIA.

Section 3 (The Proposed Project) contains information about key features of the

proposed Project, such as its location, design, construction and operation.

Section 4 (Analysis of Alternatives) discusses alternatives to the proposed Project that

were considered.

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

biological, and socioeconomic conditions around the Project site

Section 6 (Information Disclosure, Consultation and Participation) presents the

objectives and outcomes of stakeholder consultations which were conducted during the

EIA.

Section 7 (Environmental Impacts and Mitigation Measures for the Proposed Project)

presents an assessment of the Project’s impact to the physical, biological, and

socioeconomic environment, as well as recommended mitigation measures.

Section 8 (Environmental Management Plan) presents the plans that need to be

implemented to practice the mitigation measures recommended to control environmental

impacts.

Section 9 (Conclusions) will summarize the findings and recommendations of this EIA

study.


Hagler Bailly Pakistan Legal and Institutional Framework R9E02JSL: 06/10/19 2-1

2. Legal and Institutional Framework

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

practice governing the EIA.

The proposed Project facility is subject to the legislative and regulatory requirements of

the Government of Sindh (GoS).3 The legal statutes that have been reviewed include the

Sindh Environmental Protection Act, 2014, Sindh Environmental Protection Agency

(Review of Initial Environmental Examinations (IEE) and Environmental Impact

Assessment (EIA)) Regulation, 2014 (IEE-EIA Regulations 2014), and Sindh

Environmental Quality Standards (SEQS) 2016. The EIA meets the regulatory

requirements of Sindh included in the Sindh Environmental Protection Act, 2014, and its

associated rules and regulations.

2.1 Sindh Environmental Protection Act 2014

On December 16, 2014, SEPA enacted the Sindh Environmental Protection Act (Review

of Initial Environmental Examination and Environmental Impact Assessment)

Regulations, 2014 (the “IEE-EIA Regulations”).

This act is the basic legislative tool empowering the provincial government to frame

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

of issues and extends to air, water, industrial liquid effluent, marine, and noise pollution,

as well as to the handling of hazardous wastes. The following articles of the Sindh Act

2014 have a direct bearing on the proposed Project:

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

therein, no person shall discharge or emit or allow the discharge or emission of

any effluent, waste, pollutant, noise or any other matter that may cause or likely

cause pollution or adverse environmental effects, as defined in Section 2 of this

Act, in an amount, concentration or level which is in excess to that specified in

Sindh Environmental Quality Standards…’

Article 11(2): ‘All persons, in industrial or commercial or other operations, shall

ensure compliance with the Environmental Quality Standards for ambient air,

drinking water, noise or any other Standards established under section 6(1)(g)(i)4;

shall maintain monitoring records for such compliances; shall make available

these records to the authorized person for inspection; and shall report or

communicate the record to the Agency as required under any directions issued,

notified or required under any rules and regulations.’

3 The Pakistan Environmental Protection Act of 1997 is no longer applicable in the province of Sindh

following the passing of the 18th amendment in 2014. As of now, Punjab, Sindh, and Balochistan have enacted their own environmental protection laws. These provincial laws are largely based on the act of 1997 and, hence, provide the same level of environmental protection as the parent law.

4 SEPA has yet to issue Sindh Environmental Quality Standards (SEQS). SEPA has only issued standards for ambient air quality notified on August 5, 2014.



Article 14 (1): ‘Subject to the provisions of this Act and the rules and regulations,

no person shall cause any act, deed or any activity’, including;

b. disposal of solid and hazardous wastes at unauthorized places as prescribed;

c. dumping of wastes or hazardous substances into coastal waters and inland water bodies; and

d. release of emissions or discharges from industrial or commercial operations as prescribed.

Article 15 (1): ‘Subject to the provisions of this Act, no person shall operate or

manufacture a motor vehicle or class of vehicles from which air pollutants or

noise are being emitted in an amount, concentration or level which is in excess of

the Sindh Environmental Quality Standards or, where applicable, the standards

established under sub-clause (i) of clause (g) of sub-section (1) of section 6’.

Article 17(1): ‘No proponent of a project shall commence construction or

operation unless he has filed with the Agency an initial environmental

examination or environmental impact assessment, and has obtained from the

Agency approval in respect thereof’

Article 17(2): The agency shall;

a. review the initial environmental examination and accord its approval, subject to such terms and conditions as it may prescribe, or require

submission of an environmental impact assessment by the proponent; or

b. review the environmental impact assessment and accord its approval subject to such terms and conditions as it may deem fit to impose or

require that the environmental impact assessment be re-submitted after

such modifications as may be stipulated or decline approval of the

environmental impact assessment as being contrary to environmental

objectives.

Article 17(3): ‘Every review of an environment impact assessment shall be

carried out with public participation and, subject to the provisions of this Act,

after full disclosure of the particulars of the project’.

Article 17(4): ‘The Agency shall communicate its approval or otherwise within a

period of two months from the date that the initial environmental examination is

filed, and within a period of four months from the date that the environmental

impact assessment is filed complete in all respects in accordance with the

regulations, failing which the initial environmental examination or, as the case

may be, the environmental impact assessment shall be deemed to have been

approved, to the extent to which it does not contravene the provisions of this Act

and the rules and regulations’.

Article 20(1): ‘The Agency shall from time to time require the person in charge of

a project to furnish, within such period as may be specified, an environmental

audit or environmental review report or environmental management plan

containing a comprehensive appraisal of the environmental aspects of the project’.



Article 20(2): The report of a project prepared under sub-section (1) shall include:

a. analysis of the predicted qualitative and quantitative impact of the project as compared to the actual impact;

b. evaluation of the efficacy of the preventive, mitigation and compensatory measures taken with respect to the project; and

c. recommendations for further minimizing or mitigating the adverse environmental impact of the project.

Article 20(3): ‘Based on its review of the environmental audit report, the Agency

may, after giving the person in charge of the project an opportunity of being

heard, direct that specified mitigation and compensatory measures be adopted

within a specified time period and may also, where necessary, modify the

approval granted by it under section 17’.

2.1.1 IEE-EIA Regulations 2014

The Sindh IEE-EIA Regulations of 2014 provides the necessary details on the

preparation, submission, and review of the IEE and the EIA. There are provisions for two

types of environmental assessments, the environmental impact assessment (EIA)5 and the

initial environmental examination (IEE).6 Categorization of projects requiring IEE and/or

EIA is one of the main components of the IEE-EIA Regulations 2014. Projects have been

classified on the basis of the expected degree of adverse environmental impact. Project

types listed in Schedule II of the regulations are designated as potentially seriously

damaging to the environment and require EIA, and those listed in Schedule I as having

potentially less adverse effects and require an IEE. Oil and gas extraction projects

including exploration, production, gathering systems, separation, and storage are included

in Schedule I (List of Projects Requiring an IEE) under Category B. Under the act,

‘Project’ is defined as “any activity, plan, scheme, proposal or undertaking involving any

change in the environment and includes… (a) “construction or use of buildings or other

works” ; (b) “construction or use of roads or other transport systems” as well as (e) “any

change of land use or water use”. As described Section 1 (Introduction) the Project is

categorized as a transport project which requires the transport and handling of more than

500 gross tons, therefore, it requires an EIA.

2.1.2 Rules and Regulations for Submission

Regulation 9 of the IEE-EIA Regulations 2014 requires that ‘(1) Ten paper copies and

two electronic copies of an lEE or EIA shall be filed with the Federal Agency; (2) Every

lEE and EIA shall be accompanied by (a) an application, in the form set out in Schedule

5 Environmental Impact Assessment means an environmental study comprising collection of data,

prediction of qualitative and quantitative impacts, comparison of alternatives, evaluation of preventive, mitigatory and compensatory measures, formulation of environmental management and training plans and monitoring arrangements, and framing of recommendations and such other components as may be prescribed;

6 Initial Environmental Examination means a preliminary environmental review of the reasonably foreseeable qualitative and quantitative impacts on the environment of a proposed project to determine whether it is likely to cause an environmental effect for requiring preparation of an environmental impact assessment.



V; (b) copy of receipt showing payment of the review fee; (c) no objection certificates

from the relevant departments in case of EIA shall be the part of reports; and (d) the

environmental check list as per its guidelines.

Exhibit 2.1 shows the prescribed procedure for review of EIA by the EPA which is

contained in Regulations 10–17. The key features are:

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

English and Urdu newspapers and in local language newspaper informing the

public about the project and where it’s EIA can be accessed. It will also set a date

for a public hearing which shall be at least 30 days after the publication of the

notice.

If it considers necessary, the EPA can form a Committee of Experts to assist the

EPA in the review of the EIA. The EPA may also decide to inspect the project

site.



Exhibit 2.1: EIA Review and Approval Procedure



Article 17(4) of SEPA Act 2014 binds the SEPA to ‘communicate its approval or

otherwise … within a period of four months from the date the environmental impact

assessment is filed complete in all respects in accordance with the regulations, failing

which … the environmental impact assessment shall be deemed to have been approved,

to the extent to which it does not contravene the provisions of this Act and the rules and

regulations’.

Regulation 7 of the IEE-EIA Regulations 2014 pertains to the guidelines. It states that:

‘(1) The Agency may issue guidelines for preparation of an lEE or EIA or an

environmental checklist, including guidelines of general applicability and sectoral

guidelines indicating specific assessment requirements for planning, construction and

operation of projects relating to a particular sector. (2) where guidelines have been issued

under sub-regulation (1), an IEE or EIA shall be prepared, to the extent practicable, in

accordance therewith and the proponent shall justify in the IEE or EIA or in

environmental checklist any departure therefrom.’

The relevant guidelines are the follows:

Policy and Procedures for the filling, review, and approval of environmental

assessments set out the key policy and procedural requirement. It contains a brief

policy statement on the purpose of environmental assessment and the goal of

sustainable development and also states that environmental assessment is

integrated with feasibility studies.

Guidelines for the preparation and review of environmental reports which cover

the following:

Scoping, alternatives, site selection, and format of environmental reports;

Identification, analysis and prediction, baseline data, and significance of

impacts;

Mitigation and impact management and preparing an environmental

management plan;

Reporting;

Review and decision making;

Monitoring and auditing;

Project management.

Guidelines for Public Consultation which covers the following:

Consultation, involvement and participation;

Identifying stakeholders;

Techniques for public consultation (principles, levels of involvement, tools,

building trust);

Effective public consultation (planning, stages of EIA where consultation is

appropriate);

Consensus building and dispute resolution;



Facilitating involvement (including the poor, women, building community,

and NGO capacity)

Guidelines for sensitive areas which identifies the sensitive areas

2.2 Other Relevant Laws

The scope of environmental law implied by the legal definition of ‘environment’ given in

the Pakistan Environmental Protection Act of 1997 results in numerous laws enacted

since the nineteenth century being classified as environmental laws. These include laws

pertaining to forests, water resources, wildlife, land, agriculture, health and town

planning. Laws that may have relevance to the environment with a brief scope of the law

and their applicability listed below in Exhibit 2.2.

Exhibit 2.2: Key Environmental Laws in Sindh

Legal Instrument Scope and Applicability Relevance

The Antiquities Act 1975

and Sindh Cultural Heritage

Act 1994

Preservation and protection of

antiquities (any object more than

75 years old). Empowers the

government to declare any

antiquity as protected

There is no protected antiquity at

the proposed site or its

surroundings. Will apply to any

chance find of archaeological

resource during excavation

Boiler Act 1923 and Boilers

Act (Sindh Amendment)

Ordinance 1971

Regulation including safety of

boilers (any closed vessel

exceeding 23 liters in volume)

used for generating steam

Not applicable

Canal and Drainage Act

1873 and Sindh Irrigation

Act 1879

Regulates all surface water bodies

(both natural and constructed

using public resources).

Not applicable since there are no

perennial surface water bodies in

Project area of influence

Electricity Act 1910 and

Electricity Rules 1937

Regulates production,

transmission, distribution, and use

of electricity

Applicable to the Project including

sections relating to safety (See

Section 7)

Forest Act 1927 Regulates forest resources.

Empowers the government to

declare any forest area reserved

or protected.

No relevance as there are no

reserve or protected forest in the

Project area of influence

Land Acquisition Act 1894 Empowers the government to

acquire private land for projects of

national importance and lays

down the acquisition procedure

No resettlement is required for this

Project

Petroleum Act 1934 Regulates import, transportation,

storage, production, refining and

blending of petroleum products

and other flammable substances

Storage and transportation of

petroleum products at the site will

be governed by this law

Coastal Zone Regulation

1991

Restricts the setting up of new

industries, or expansion of existing

industries, handling of hazardous

wastes, discharge of untreated

Relevant to Project, in particular to

the handling and discharge of

hazardous and flammable



Legal Instrument Scope and Applicability Relevance

effluents, dumping of municipal

wastes and effluents as landfills

within the coastal zone.

Exceptions are provided for

construction of ports, harbors,

jetties, wharves, quays, bridges

and sea links.

material, in this case, LPG (See

Section 7)

Sindh Wildlife Protection

Ordinance 1974

Empowers the government to take

measures for protection of wildlife

in the province by declaring

setting aside certain areas as

national park, wildlife sanctuary,

and game reserve, and by

declaring certain species as

protected.

The project site is not located near

any wildlife sanctuaries, national

parks or other protected areas.

Sindh Water Management

Ordinance 2002

“To provide for the establishment

on long term, sustainable and

participatory basis, of public

systems for the distribution and

delivery of irrigation water, the

removal of drainage water and the

management of flood waters”

Not relevant to the Project.

Explosives Act 1884 Regulates handling and storage of

explosive substances

Is applicable to the Project as it

involves storage of LPG.

2.2.1 Port Qasim Authority Act, 1973

This Act provides for the establishment of the Port Qasim Authority, defines its

functions, powers and internal organization, and lays down rules relative to the

management of and navigation in marine ports and inland waterways. The particular

sections applicable to the Project are:

Section 71(B) (2): “No Owner, Agent or Master of a vessel, or any industry,

manufacturing establishment, mill, factory or any kind, cargo handling company,

terminal operator, etc., shall discharge any solid or liquid, waste, oily, noxious

radioactive and hazardous substances, bilge discharges, residues and mixtures

containing noxious solid and liquid wastes, de-blasting of un-washed cargo tanks

and line washing, garbage, emission of any effluent or waste or air pollution or

noise in any amount concentration or level in excess of the National

Environmental Quality Standards, or standards, which may be specified, from

time to time, by the Authority for Port limits.”

Section 71(B)(3): “Any person contravening the provisions of sub-section (2)

shall be liable to penalty as determined and notified by the authority from time to

time for each contravention in addition to the charges for cleaning of the Port and

removal of pollution therefrom.”



Section 71(C)(1): “No proponent of a project shall commence construction or

operation unless he has filed with this Authority as Initial Environmental

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

effect, an Environment Impact Assessment, and has obtained from the authority

approval in respect thereof.”

Section 71(C (2): “The Authority shall: (a) review the initial environmental

examination and accord its approval, or required submission of an Environmental

Impact Assessment by the proponent; or (b) review the Environmental Impact

Assessment and accord its approval subject to such condition as it may deem fit to

impose, or require that the Environment Impact Assessment be re-submitted after

such modification as may be stipulated.”

The regulations in the Port Qasim Authority (PQA) act require that the proponent submit

an EIA, and obtain approval from SEPA. The proponent needs to provide this EIA to the

PQA for their review and approval according to section 71 (C) (2). During the operation

phase, in particular, the Project must ensure that they do not violate the provisions of

section 71 (B) (2) by preventing discharges above the acceptable limits provided in the

SEQS. The developer should be aware that violation of this would result in liability for

penalty and cleanup charges for cleaning of the port. Section 7 provides impacts of

discharges above SEQS and their mitigation measures.

2.2.2 Factories Act, 1934

Particular sections of the act applicable to this Project are:

Section 13(1): “Every factory shall be kept clean and free from effluvia arising

from any drain, privy or other nuisance.”

Section 14(1): “Effective arrangements shall be made in every factory for the

disposal of wastes and effluents due to the manufacturing process carried on

therein.”

Section 16(1): “In every factory in which, by reason of the manufacturing process

carried on, there is given off any dust or fume or other impurity of such a nature

and to such an extent as is likely to be injurious or offensive to the workers

employed therein, effective measures shall be taken to prevent its accumulation in

any work-room and its inhalation by workers and if any exhaust appliance is

necessary for this purpose, it shall be applied as near as possible to the point of

origin of the dust, fume or other impurity, and such point shall be enclosed so far

as possible.”

Section 16(2): “In any factory, no stationary internal combustion engine shall be

operated unless the exhaust is conducted into open air and exhaust pipes are

insulated to prevent scalding and radiation heat, and no internal combustion

engine shall be operated in any room unless effective measures have been taken to

prevent such accumulation of fumes therefrom as are likely to be injurious to the

workers employed in the workroom.”



Section 20(1): “In every factory, effective arrangements shall be made to provide

and maintain at suitable points conveniently situated for all workers employed

therein a sufficient supply of wholesome drinking water.”

Section 26(1) d(i): “In every factory, the following shall be securely fenced by the

safeguards of substantial construction which shall be kept in position while the

parts of machinery required to be fenced are in motion or in use, namely (a) every

part of an electric generator, a motor or rotary convertor.”

The Act regulates a range of conditions relating to labor. These include health and

safety, restrictions on working hours of adults, holiday with pay, and special

provisions for adolescents with children. It also provides for government

inspection staff to function as directed by the government, penalties and

procedures relating to violations of the Act as well as supplemental information

for staff (such as display of factory notices, removal of difficulties, protection

against discrimination etc.). The Project needs to comply with the requirements

under these regulations.

2.2.3 Hazardous Substances

Article 13 of the Sindh Act 2014 states that ‘Subject to the provisions of this Act, no

person shall import, generate, collect, consign, transport, treat, dispose of, store, handle or

otherwise use or deal with any hazardous substance except—(a) under a license issued by

the Agency; or (b) in accordance with the provisions of any other law for the time being

in force, or of any international treaty, convention, protocol, code, standard, agreement or

other instrument to which Government is a party.’

Hazardous substance is defined in Article 2(xxv) of the SEPA 2014 as “(a) a substance

or mixture of substances, other than a pesticide as defined in the Agricultural Pesticides

Ordinance, 1971 (II of 1971), which, by reason of its chemical activity or toxic,

explosive, flammable, corrosive, radioactive or other characteristics, causes, or is likely

to cause, directly or in combination with other matters an adverse environmental effect;

and (b) any substance which may be prescribed as a hazardous substance”

To date, SEPA has not prescribed any substance as hazardous nor has it defined the

procedure for licensing. As and when, such procedures are defined and a license for any

particular substance is required, the Project proponent will obtain the license. However,

best industry practice and internationally accepted guidelines for hazardous substances

will be used for the proposed Project.

2.2.4 The Forest Act 1927

The Act empowers the provincial forest departments to declare any forest area reserved

or protected. The act also empowers the provincial forest departments to prohibit the

clearing of forests for cultivation, grazing, hunting, removing forest produce, quarrying,

felling, and lopping.

Mangrove plantations enjoy a special legal status under the Forest Act of 1927. The act

declared 344,870 ha of mangroves as “Protected Forest” and put it under the jurisdiction



of the Sindh Forest Department (SFD). In 1973, the SFD transferred an area of 64,400 ha

to PQA. However, the areas with PQA continue legally to be “Protected Forests”.7

2.2.5 Labor and Health and Safety Legislation

The Constitution of Pakistan contains a range of provisions concerning labor rights, in

particular:

Article 11 of the Constitution prohibits all forms of slavery, forced labor and child

labor;

Article 17 provides for a fundamental right to exercise the freedom of association

and the right to form unions;

Article 25 lays down the right to equality before the law and prohibition of

discrimination on the grounds of sex alone; and

Article 37(e) makes provision for securing just and humane conditions of work, to

ensure that children and women are not employed in vocations unsuited to their

age or sex, and to provide maternity benefits for women in employment.

The Labor law regulates at both provincial and national levels with compulsory

employment agreements containing the terms set out by the labor laws. There are various

laws containing health and safety requirements including: Mines Act 1923; Factories Act

1934; Factories Rules; Hazardous Occupations Rules 1963; Provincial Employees Social

Security Ordinance 1965; and Workmen’s Compensation Act 1923. No single

comprehensive piece of legislation deals with occupational or community safety and

health.

2.2.6 International Treaties

Exhibit 2.3 lists the important international environmental treaties that Pakistan has

signed and are relevant to the Project. They concern: biological diversity, waste, and

pollution.

7 International Union for Conservation of Nature (IUCN) Pakistan. Mangroves of Pakistan–Status and

Management. IUCN, 2005.



Exhibit 2.3: International Environmental Treaties Endorsed by Pakistan

Topic Convention Date of Treaty

Entry into Force in Pakistan

Relevance to Project

Waste and pollution

International Convention on Oil Pollution Preparedness, Response and Co-operation

1990 1995 The Project can result in discharges, which can contribute to oil pollution.

Stockholm Convention on Persistent Organic Pollutants –seeks to protect human health and the environment from Persistent Organic Pollutants, which are chemicals that remain intact in the environment for long periods, become widely distributed geographically and accumulate in the fatty tissue of humans and wildlife.

2001 2008 The Project involves the handling of organic compounds that can become pollutants if mishandled.

Biodiversity and the protection of plants and animals

Convention on Biological Diversity – covering ecosystems, species, and genetic resources and also the field of biotechnology. The objectives are:

conserve of biological diversity;

sustainable use of its components; and

fair and equitable sharing of benefits arising from genetic resources.

1992 1994 Flora and fauna of conservation importance has been reported from the Project site and vicinity including mangroves, coastal birds and marine mammals.

Bonn Convention on the Conservation of Migratory Species of Wild Animals - aims to conserve terrestrial, marine and avian migratory species throughout their range. It is concerned with the conservation of wildlife and habitats on a global scale.

1979 1987 A number of migratory bird species have been reported from the Project site and vicinity

Convention on International Trade in Endangered Species of Wild Fauna and Flora - to ensure that international trade in specimens of wild animals and plants does not threaten their survival.

1973 1976 Some faunal species reported from Project site and vicinity are included in the CITES Species List.

International Plant Protection Convention (1997 Revised Text) - to prevent the international spread of pests and plant diseases. It requires maintenance of lists of plant pests, tracking of pest outbreaks, and coordination of technical assistance between member nations.

1951/52 1954 Habitat disturbances caused by the Project can enhance the spread of alien invasive species



Topic Convention Date of Treaty

Entry into Force in Pakistan

Relevance to Project

Convention on Wetlands of International Importance especially as Waterfowl Habitat and associated protocols and amendments - to promote conservation and sustainable use of wetlands. The Ramsar List of Wetlands of International Importance now includes almost 1,800 sites (known as Ramsar Sites). There are currently 19 Ramsar sites in Pakistan.

1971 (amended

1987)

1976 (amended 1994)

The Project site is located approximately 30 km away from the Outer Indus Delta which is a Ramsar site and supports a number of migratory birds.



2.2.7 Environmental Standards

The proposed Project is legally required to comply with the SEQS (Sindh Environmental

Quality Standards). In addition to SEQS, the Project’s environmental performance will

also assess compliance with the IFC guidelines on emissions and effluent discharge8.

Article 11(1) of the Sindh Act 2014 states that: ‘Subject to the provisions of this Act and

the rules and regulations, no person shall discharge or emit or allow the discharge or

emission of any effluent, waste, pollutant, noise or any other matter that may cause or

likely to cause pollution or adverse environmental effects, as defined in Section 2 of this

Act, in an amount, concentration or level which is in excess to that specified in Sindh

Environmental Quality Standards…’

The Sindh EPA has promulgated several standards, the SEQS, which were applicable to

the entire province of Sindh. These include:

Ambient air quality (9 parameters)

Drinking water (32 parameters)

Ambient noise

Industrial effluents (32 parameters)

Industrial gaseous emissions (16 parameters).

Exhibit 2.4 through Exhibit 2.6 provide SEQS Guidelines for key parameters of ambient

air quality, effluents and noise.

Exhibit 2.4: SEQS Limits for Ambient Air Quality

Pollutants Time-weighted Average Sindh Standards (μg/m3)

Sulfur Dioxide (SO2) Annual Average 80

24 hours 120

Oxide of Nitrogen as (NO) Annual Average 40

24 hours 40

Oxide of Nitrogen as (NO2) Annual Average 40

24 hours 80

Ozone (O3) 1 hour 130

Suspended Particulate Matter (SPM) Annual Average 360

24 hours 500

Respirable particulate Matter PM10 Annual Average 120

24 hours 150

Respirable Particulate Matter PM2.5 24 hours 75

Annual Average 40

8 International Finance Corporation. "Environmental, Health, and Safety Guidelines for Thermal Power

Plants " World Bank Group, 2008



Pollutants Time-weighted Average Sindh Standards (μg/m3)

Lead (Pb) Annual Average 1

24 hours 1.5

Carbon Monoxide (CO) 8 hours 5,000

1 hour 10,000

Exhibit 2.5: SEQS Limits for Effluents (mg/l, unless otherwise defined)

Parameter SEQS (Into Sea)

Temperature increase2 =



Parameter SEQS (Into Sea)

Arsenic 1.0

Barium 1.5

Iron 8.0

Manganese 1.5

Boron 6.0

Chlorine 1.0

Exhibit 2.6: Sindh Environmental Quality Standards for Noise

No. Category of Area/Zone Effective from 1st July, 2010 Effective from 1st July, 2012

Limit in dB(A) Leq*

Day Time Night Time Day Time Night Time

1. Residential are (A) 65 50 55 45

2. Commercial are (B) 70 60 65 55

3. Industrial area (C) 80 75 75 65

4. Silence zone (D) 55 45 50 45

Note:

1. Day time hours: 6 .00 am to 10.00 pm

2. Night Time hours: 10.00 pm to 6.00 am

3. Silence zone: Zones which are declared as such by the competent authority. An area comprising not less than 100 meters around hospitals, educational institutions and courts and courts.

4. Mixed categories of areas may be declared as one of the four above-mentioned categories by the competent authority.

5. dB(A) Leq: time weighted average of the level of sound in decibels on scale A which is relatable to human hearing.

2.3 Institutional Framework

Under the Sindh Act 2014, SEPA is an autonomous agency. For administrative purposes,

it is part of the Forest, Environment and Wildlife Department of the Government of

Sindh. SEPA is a regulatory agency with the following main functions:

Enforcement of Sindh Act 2014

Prepare environmental policies for approval of the GoS

Implement environmental policies

Publish annual state of the environment report for Sindh

Prepare or revise SEQS

Ensure implementation of SEQS

Establish systems and procedures for environmental management



Promote research and studies on environmental issues

Issue license for handling of hazardous substance

Certify environmental laboratories

Initiate legislation for environmental protection

Provide assistance to government agencies in case of environmental accidents

Providing advice to the government on issues related to environment

Assist governments agencies in implementation of waste management schemes

Provide guidance to public on environmental matters

Assist education institutions in prescribing environmental curricula

Undertake measures to enhance awareness on environment among general public

Disseminate knowledge on environment

Specify safeguards for the prevention of accidents which may cause pollution

Review and approve mitigation plans and give guidance for clean-up operations

Encourage the formation and working of nongovernmental organizations,

community organizations and village organizations for environmental protection

Carry out any other task related to environment assigned by the government.

SEPA has the authority to review and issue approval of the EIA/IEE of the

proposed Project.

2.4 Compliance with the Applicable Licenses and Regulations

PIBT facilities will comply with the standards and specifications for licenses prescribed

by Oil and Gas Regulatory Authority (OGRA) and Ministry of Petroleum. These

prescribed standards are also consistent with international standards practiced elsewhere

in the world.

The National Fire Protection Association (NFPA) standard 58 of the NFPA, USA

for the storage and handling of LPG:

In 1940, The NFPA combined several standards adopted as NFPA-58. Since then

various standards have been revised containing different applications of LPG.

These standards apply to handling, storing, transferring, and the building of

facilities and systems with regard to LPG. The standards provide measures and in-

depth characteristics for each associated component in order to ensure safety

throughout the LPG supply chain

Government of Pakistan (GoP) Ministry of Petroleum and Natural Resources

(MP&NR), LPG Policy Guidelines, 2013

The objective of this policy is to address issues that were not covered in previous

LPG policies, and to encourage growth of the LPG industry in a sustainable

manner. Issues regarding LPG production, licensing, safety standards, pricing,

import and export have been addressed in these policy guidelines.



Codes of practice prepared by Liquefied Petroleum Gas Industry Technical

Association, UK (LPGITA)

These codes provide guidance on best engineering and safe practices concerning

LPG and covers transportation, storage, installation, operations, and utilization of

LPG.

American Society of Mechanical Engineers (ASME) Codes for LPG storage tanks

and pipeline/piping

The ASME provides design and construction requirements as per US regulations

for LPG tanks and piping. Parameters considered include a selection of materials,

stress values, testing requirements, welding procedures and qualification

requirements.

DOT specifications 4B, 4BA, and 4BW for LPG cylinders

DOT specifications provide manufacturing regulations for cylinders to ensure that

each cylinder produced conforms to the requirements. This includes the seams.

Welding techniques, wall thickness, heat treatment, hydrostatic tests, flattening

tests and other physical tests

Hazardous Substance Rules, 2014

The Hazardous substance rules of Sindh provide a comprehensive list of

substances prescribed as hazardous substances, the proper licensing procedures

along with guidelines on packing and labeling, general safety precautions, safety

plans, inspection and monitoring, waste management plan and the import of

hazardous substances

Explosive license under the Petroleum Rule, 1937 and the Gas Cylinder Rules,

1940

Under the Petroleum Act, the government issued rules to regulate the import,

storage, manufacture, and distribution of LPG. The rule laid down detailed

standards for the implementation of the main act. The Explosives Act, 1884, and

Rules 1940: and the Gas Cylinder Rules, 1940 issued under this legislation to

ensure public health and safety and reduce risk of fatal injuries.

BS codes of practice

The British Standard BS 5482-1:2005 makes recommendations on the selection of

materials and components on design considerations, on installation, on inspection,

and testing. The standard, however, does not apply to installation requirements of

bulk tanks supplying LPG

ISO Certifications

The International Organization for Standardization founded in 1947 is responsible for

setting international standards for many proprietary, industrial and commercial

applications. An ISO certification is not a license, it merely certifies that a system or

process or service has all the requirements for standardization and quality assurance.



The Project proponent will construct, maintain and operate his works connected with

storage, filling, and transportation of LPG in accordance with the rules mentioned above

to avoid any possible accidents that can endanger public health and safety.

2.5 World Bank/IFC Environmental, Health and Safety Guidelines for Crude Oil and Petroleum Products

The World Bank Group published the Environmental, Health and Safety Guidelines

(known as the ‘EHS Guidelines’) initially in 2007 and 2008. The EHS Guidelines are

technical reference documents with general and industry-specific examples of Good

International Industry Practice (GIIP), as defined in IFC’s Performance Standard 3 on

Pollution Prevention and Abatement. The General EHS Guidelines, as well as those

specific to crude oil and petroleum products, are relevant to the Project.

These environmental, health, and safety (EHS) guidelines are technical reference

documents with general and industry-specific examples of ‘good international industry

practice’. The EHS guidelines define performance levels and measures considered

achievable in new facilities employing existing technology at reasonable costs.

Application of the EHS guidelines to existing facilities may involve the establishment of

site-specific targets, based on environmental assessments and/or environmental audits, as

appropriate, with a suitable timetable for achieving them.

Some of the health and safety guidelines the Project will follow are:

2.5.1 Fire Precautions

Equipping facilities with fire detectors, alarm systems, and fire-fighting

equipment. The equipment should be maintained in good working order and be

readily accessible. It should be adequate for the dimensions and use of the

premises, equipment installed, physical and chemical properties of substances

present, and the maximum number of people present.

Provision of manual firefighting equipment that is easily accessible and simple to

use

Fire and emergency alarm systems that are both audible and visible

2.5.2 First Aid

The employer should ensure that qualified first aid is available at all times.

Appropriately equipped first-aid stations should be easily accessible throughout

the place of work

Eye-wash stations and/or emergency showers should be provided close to all

workstations where immediate flushing with water is the recommended first-aid

response

Dedicated and appropriately equipped first aid room(s) should be provided where

the scale of work or the type of activity being carried out so requires. First aid

stations and rooms should be equipped with gloves, gowns, and masks for

protection against direct contact with blood and other body fluids



Remote sites should have written emergency procedures in place for dealing with

cases of trauma or serious illness up to the point at which patient care can be

transferred to an appropriate medical facility.

2.5.3 Labeling of Equipment

All vessels that may contain substances that are hazardous owing to their

chemical or toxicological properties, or temperature or pressure, should be labeled

as to the contents and hazard, or appropriately color coded.

Similarly, piping systems that contain hazardous substances should be labeled

with the direction of flow and contents of the pipe, or color coded whenever a

valve or junction device interrupts the pipe passing through a wall or floor.

2.5.4 Communicate Hazard Codes

Copies of the hazard coding system should be posted outside the facility at

emergency entrance doors and fire emergency connection systems where they are

likely to come to the attention of emergency services personnel.

Information regarding the types of hazardous materials stored, handled or used at

the facility, including typical maximum inventories and storage locations, should

be shared proactively with emergency services and security personnel to expedite

emergency response when needed.

Representatives of local emergency and security services should be invited to

participate in periodic (annual) orientation tours and site inspections to ensure

familiarity with potential hazards present

2.5.5 Hazardous Materials and Oil

The transfer and storage of liquid materials in crude oil and petroleum products pose the

risk for potential leaks and spills from tanks, pipes, hoses and pumps during the loading

and unloading of the products for storage and transportation. Furthermore, these materials

are flammable and thus create a hazard of fire and explosion. Measures to manage such

incidences include:

Storage tanks and their components should meet international standards for

structural design and performance to avoid ruinous failures during operations.

Such standards typically include flow control, metering, grounding and overfill

protection

As discussed in the general guidelines, storage tanks should have secondary

containment, which varies in design depending on the size and location of the

tanks. These include impervious linings under tanks, and double wall containment

as well as properly trained personnel that can adhere to formal procedures

Periodic inspection of equipment for corrosion and structural integrity.

2.6 IFC Performance Standards

The IFC published its PSs in April 2006 and revised them in 2012. Information on the

IFC standard and applicability for the Project is provided in Exhibit 2.7



PS 1 establishes the importance of integrated assessment to identify the social and

environmental impacts, risks and opportunities of projects, effective community

engagement through disclosure of Project related information and consultation with local

communities on matters that directly affect them; and management of social and

environmental performance throughout the life of the project. PS 2 through 8 establish

requirements to avoid, reduce, mitigate or compensate for impacts on people and the

environment, and to improve conditions where appropriate.

Exhibit 2.7: IFC Performance Standards and Applicability on the Project

IFC PS Applicability

Performance Standard 1: Assessment and Management of Environmental and Social Risks and Impacts

Applicable to the Initial Environmental Examination process.

Performance Standard 2: Labor and Working Conditions

Applicable to employment and labor policies of the Project.

Performance Standard 3: Pollution Prevention and Abatement

Applicable to the Project’s pollution prevention and abatement options

Performance Standard 4: Community Health, Safety, and Security

Applicable to the potential community health and safety risk and the security system of the Project.

Performance Standard 5: Land Acquisition and Involuntary Resettlement

Not Applicable as there is no land acquisition involved in the Project. The Project is in a designated industrial area.

Performance Standard 6: Biodiversity Conservation and Sustainable Management of Living Natural Resources

Applicable to the Project as the terrestrial and coastal biodiversity may be impacted.

Performance Standard 7: Indigenous Peoples

Not applicable.

Performance Standard 8: Cultural Heritage

Not applicable.


Hagler Bailly Pakistan Project Description R9E02JSL: 06/10/19 3-1

3. Project Description

The Project involves off-loading imported LPG from carrier vessels at PIBT jetty in Port

Qasim Area, Karachi, and transporting it to neighboring Customer LPG storage facility

via pipelines. The general description and basic parameters of the proposed Project are

discussed in this section.

3.1 Project Background

PIBT plans to enter into a services agreement with the LPG storage facility, where, PIBT

will construct a LPG handling unit at its existing jetty and then transfer LPG via pipelines

from jetty to the Customer’s LPG storage facility nearby. Currently PIBT is only

equipped to handle coal, clinker and cement. By going into a services arrangement with

the Customer they will be dealing with a cleaner fuel compared to coal and reduce

pressure on the Customer to build a jetty that will have higher impact on environment

compared to using an existing jetty.

3.2 Project Location

The proposed Project lies in southwestern part of North West Industrial Zone (NWIZ) of

Port Qasim Area, approximately 15 km from National Highway (N 5), in southern part of

the Malir District, Karachi. It lies south of the proposed Customer LPG storage facility.

The geographical coordinates of the handler at the jetty and start of transfer pipeline are

approximately 67° 16' 24.87" E, 24° 47' 27.87" N. (see Exhibit 3.1).



Exhibit 3.1: Project Location of Proposed Project



3.3 Pakistan International Bulk Terminal

PIBT has been setup as the Pakistan’s first terminal dedicated for handling coal, clinker

and cement. It was setup on a 30-year build, operate and transfer concession from the

PQA. It was constructed on reclaimed land of 62 acres (25 hectares). The terminal facility

is connected to a 460 m long jetty via a 2.7 km long trestle. It is primarily a coal, cement

and clinker handling facility. A photograph of the entrance gate of PIBT terminal and

jetty is shown in Exhibit 3.2 and Exhibit 3.3 respectively.

The existing jetty comprises of two coal ship unloading cranes and one cement loading

crane. The jetty is connected to the storage area via trestle bridge spanning over 2.7 km in

length (see Exhibit 3.4). The trestle supports two conveyor belt systems, for coal and

cement.

3.4 Project Layout

A proposed plan for LPG handling and transfer via pipelines to Customer storage facility

are shown in a proposed Project layout provided in Exhibit 3.5. It comprises of:

LPG handling unit will be placed 83.5 m from the west corner of the jetty as

shown in Exhibit 3.5, with minimum safe horizontal distance from the LPG

handling facility to coal and cement handling.

LPG transfer pipelines from the jetty to Customer LPG storage facility. It is

expected to be constructed adjacent to the existing trestle bridge as shown in

Exhibit 3.5.

Exhibit 3.2: PIBT Facility Entrance (December 2017)



Exhibit 3.3: PIBT Jetty

Source: HBP Project field survey, December 2017

Exhibit 3.4: Trestle Bridge Connecting the Jetty to PIBT Offshore Facility

Source: HBP Project field survey, December 2017



Exhibit 3.5: Project Layout



3.5 Project Features

The Project comprises of jetty services and construction of pipelines from the existing

jetty to the Customer LPG storage facility. Detailed information is provided in following

sections.

3.5.1 Jetty Services

As discussed in Section 3.3, the existing jetty has two coal and one cement handling unit.

The jetty is connected to the storage area via trestle bridge spanning approximately

2.7 km in length. The trestle has two conveyor belt systems and has the capacity to add

one more conveyor for enhanced handling in future. The trestle is designed to support

Access Bridge for maintenance, firefighting and other services. Salient features of jetty

are:

Permissible Draft: 13 m

Quay wall Length: 460 meters plus mooring dolphins

Two Vessel Berthing simultaneously

2 Ship Unloading Cranes (Coal): 1850 tons/hour (rated capacity each)

1 Ship Loading Crane (Cement/Clinker): 1200 tons/hour

Belt Conveyor: 3600 tons/hour

LPG Handling Arm Unit

A LPG handling arm unit will be constructed on the west corner of the jetty for

Environmental Impact Assessment tech/EIA of LPG... · 2019. 6. 10. · LPG Handling and Transport Services at PIBT Environmental Impact Assessment Final Report HBP Ref.: R9E02JSL

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