The sponsor has presented plans and agreed to additional measures to address these potential issues and impacts to ensure that the proposed project will, upon implementation of the specific agreed measures, comply with all relevant environmental and social requirements, namely the law and regulations of Pakistan, IFC’s Policy and Performance Standards on Social and Environmental Sustainability and applicable World Bank/IFC environmental, health and safety guidelines. Applicable guidelines for this project are: Oil and Gas Development (Onshore) July 1998; Occupational Health and Safety, June 2003; General Environmental Guidelines, July 1998; and, Hazardous Materials Management Guidelines, December 2001.
The information about how these potential impacts will be addressed by the sponsor is summarized in the paragraphs that follow.
Health, Safety, Environmental and Social management and compliance
DPL has a Health, Safety and Environment (HSE) policy which states the company’s commitment “to maintain and enforce an effective HSE program that applies to all employees” and that HSE is a “primary consideration” by line management “in the planning and implementation of all company activities”. A separate environmental policy states that “all DPL projects will meet or exceed the minimum standards established by environmental legislation, regulations or recognized industry standards”.
To achieve these policy commitments, DPL has established a company wide HSE Management System (HSE-MS) that contains the components necessary to provide and document a system for management, mitigation and monitoring of HSE across the company.
The HSE-MS requires that a project specific HSE management plan will be developed for each project that includes the HSE management measures necessary for the project, emergency response plans and procedures for monitoring HSE performance and reporting arrangements. A project-specific HSE management plan for the Safed Koh concession area will be in place before the Salsabil development construction activities begin. The plan will serve as an interface between DPL’s company HSE-MS requirements and the HSE plans and procedures that will be the responsibility of contractors involved with the project. HSE guidelines for contractors have been prepared by DPL for inclusion in their contracts. These guidelines will be adapted to meet specific project needs and will contain the HSE standards and procedures applicable to all contractor personnel working on DPL projects and at DPL facilities.
DPL has conducted separate Initial Environmental Evaluation (IEE) studies for their gas processing facilities and future drilling program in the Salsabil field. Required by Pakistan law, the IEEs assess the significance of the proposed activities and operations with respect to their potential to cause adverse environmental and social impacts. Each IEE contains an environmental management plan (EMP) that describes how different environmental and social aspects of the project development will be managed and the measures included in these EMPs will be incorporated into the project-specific HSE management plan. The IEEs have been submitted to the Environmental Protection Department (EPD) in Punjab for review and approval.
An HSE committee, made up of key senior management, periodically reviews company HSE performance for all DPL facilities along with any HSE management improvements required including changes to the HSE-MS. In addition, a field HSE committee will be set up for operations in the Safed Koh block to review HSE performance in the field.
A DPL HSE manager/representative will be based in the field to provide oversight, training and advice on HSE matters as well as risk analysis, planning and incident investigation. By auditing performance, the HSE manager/representative will ensure implementation of the HSE procedures and adherence to standards by all field staff and contractors. In addition to the HSE manager/representative and in accordance with local guidelines, an Independent Monitoring Consultant (IMC) appointed by DPL will be in the field to monitor the implementation of the specific procedures documented in the EMP attached to the IEEs. The IMC will provide periodic reports regarding performance to the EPD in Punjab and to DPL management.
In terms of specific compliance with standards, project facilities and operations will be designed to comply with applicable World Bank/IFC environmental, health and safety guidelines. The project will also comply with Pakistan environmental laws and regulations, in particular the requirements of the petroleum exploration and production sector guidelines for HSE management of December 1996 and the National Environmental Quality Standards (NEQS) for liquid effluents and air emissions.
- Wastes
As part of DPL’s HSE management planning, a waste management plan for all hazardous and non-hazardous wastes will be developed before Salsabil field construction activities begin. The plan will include procedures to be implemented for the handling, storage, treatment and disposal of wastes generated through all stages of the project development. Options for the re-use, recycling and treatment of wastes generated will be evaluated. The plan will incorporate a waste manifest system including a waste tracking mechanism for wastes that are removed from the site for final disposal.
The transportation of wastes from DPL sites will be conducted by licensed and approved waste management contractors and off-site disposal facilities will be checked to ensure that they meet international standards.
Principal effluent streams generated by the Salsabil project will include: waters used for equipment and pipeline integrity hydrotesting during the commissioning of new facilities; drilled cuttings and drilling muds from the drilling program; produced waters from the processing facilities; and, sewage waters from the workforce camp facilities and work sites. Each will be handled as follows:
The water used to flood the facility equipment and pipelines for system integrity hydrotests will not contain any toxic additives and will be disposed of directly to the ground surface.
Water based mud systems with low toxicity will be used for the drilling program. Drilled cuttings and spent muds will be disposed of directly to containment mud pits that will be fitted with a geo-membrane liner.
Relatively small volumes of produced waters will be produced (c. 20 barrels per day). These waters will be disposed of to evaporation ponds lined with geo-membrane liners.
Sewage waste waters will be treated in a series of septic tanks to meet local regulations for effluent quality and then disposed of to the ground through a soakaway system. The sewage effluents will be routinely monitored to ensure that they comply with project standards.
Designated areas will be assigned at the field for the storage of chemicals and hazardous wastes, the storage of fuels and vehicle and equipment maintenance. These areas will have secondary containment so that oil, fuel and chemical spills will be contained in the event of a spill. The condensate storage tanks will also be housed in suitably bunded areas.
- Air and noise emissions
Air emission levels resulting from routine operations at the Salsabil field gas processing plant will be low. The main source of emissions will be the exhaust emissions from process plant power generators consisting of two gas powered generators and one back-up diesel power generator set. Additional emissions will result from the facility flare, although flaring will only occur during infrequent plant shut-down events or during emergencies when the remaining gas in the processing plant will be flared for safety reasons. Salsabil is a sweet gas field; no hydrogen sulfide has been detected in the gas.
Air emission dispersion modeling will be conducted as part of the finalization of the Salsabil field gas processing plant design program. The model will establish direction and location of maximum concentrations of emissions to ensure that there is no risk to human health in the local communities close to the plant site. An ambient air quality monitoring program will also be established for the operations phase of the project.
The plant design engineers will assess noise emissions from the main equipment components for the process plant site so that World Bank Group noise emission level guidelines at local residences will be followed. A noise monitoring program will be developed for operations.
Air emissions and noise will also be generated during drilling operations and the plant and pipeline construction programs at the Safed Koh block. The short duration of these programs will result in limited emissions, but procedures including: appropriate equipment siting; restricted vehicle and machinery movements; and, regular vehicle and equipment maintenance will be followed to ensure that emissions and noise are kept to a minimum. Excessive dust generation during the construction program will be mitigated by watering down the construction areas when necessary. Ambient air quality and noise levels at the nearest communities will be periodically measured.
- Workforce health and safety management
Work sites and equipment will be designed and controls will be put in place to ensure that there are no significant risks to personnel health and safety. All workers will be provided with appropriate personal protective equipment (PPE) and the wearing of PPE on the field will be mandatory. HSE inductions and an HSE training schedule for the field staff will be developed which will ensure that the workforce (including contractors) have sufficient training in HSE requirements. Regular HSE meetings will be held with the workforce to review and reinforce HSE procedures.
- Emergency response planning
DPL is developing emergency response plans containing the procedures to follow in the event of an emergency at the field. Plans already in place and under development include: a fire safety procedure, personal injury and illness plan (to include procedures for medical evacuation), a hydrogen sulfide procedure (in case any is detected in the future) and an oil and chemical spill contingency plan.
Training specific to emergency response procedures and instructions, including drills, will be carried out in the field.
- Community relations
The Safed Koh Concession Area is a part of the tribal area administratively attached to Dera Ghazi (D.G.) Khan district in the southern part of Punjab province of Pakistan. It is situated to the west of Taunsa Tehsil (sub-district) on the eastern north-south frontline low-hills of the Sulaiman Mountain Range. The town of Taunsa Tehsil is situated in between the Indus River and Safed Koh, some 60 km to the east of the Salsabil field area to be developed and some 100 km to the north of the town of D. G. Khan.
The settled areas nearest to the DPL field development area are predominantly inhabited by sub-tribes of the Baloch Tribe. These sub-tribes are closely linked with mainstream social, economic and political systems of the district, province and the country and are not considered to be indigenous. DPL’s field development area is located on a hilltop. More than 95% of the population in the area lives in the lower plains and not in the hills although, there are three hamlets close to the proposed site for DPL’s gas processing plant: Rodho Top (population c. 400 people) approximately 1 km from the plant site; Rodho Sharqi (population c. 300) at a distance of approximately 2.5 km and Rodho Gharbi Nilagh (population c. 1,300) some 3 km distance. Rhodo Gharbi Nilagh is located within 1 km of the Dewan well number 4 to be drilled.
The location of local population and agricultural land under use were key factors in the selection of the pipeline route from DPL’s gas processing facilities to the Dhodak – Kot Addu pipeline. The total length of this pipeline will be close to 20 km. Disturbance to local agricultural systems will be minimal, as for the most part the pipeline will be installed in barren land. In addition, affected households from the agricultural areas possess large landholdings, so that land to be ceded or temporarily leased to SNGPL for the pipeline will be a small fraction of their entire landholding.
DPL has conducted extensive consultation with the local communities as part of their land acquisition requirements. Consultations were held with the assistance of the local government authorities and with the involvement of tribal leaders. DPL continues to keep regular contacts with local communities and relations are good. DPL will develop a public consultation and disclosure plan (PCDP) that will document its future and continuing community consultation arrangements. They will systematize their relations with local communities by hiring a dedicated community liaison officer (CLO) to supervise communication and information disclosure. The CLO will also be responsible for the community grievance mechanism to be developed as well as community development services and projects.
At Safed Koh, the anticipated workforce will require approximately 100 personnel during the processing plant construction program and up to 40 staff on site during plant operations. A drilling crew of up to 70 personnel will be on site during drilling operations. Some of the individuals from the local communities will gain employment during field development. DPL will adhere to Pakistan labor law for its workforce and will also put in place a procedure to explain to local communities how skilled and unskilled labor will be contracted.
- Land acquisition
DPL has begun the process of land acquisition for its Salsabil field development. DPL negotiated directly with the land owners with assistance from the regional government. The land acquisition is undertaken in accordance with the Land Acquisition Act, 1984 which governs land acquisition in Pakistan.
A 20 year land lease agreement has been made with the landowners for the gas processing plant location. This was at the landowners request as their preference was for a regular income from rent rather than a one-off payment from a sale. Land lease rates were based on current prevailing rates and, although the terrain is rocky, dry and barren with scarce vegetation and there are no agricultural activities apart from some limited goat herding in the hill top area, the highest rates for fertile agricultural land have been applied. Therefore, no land-users will be economically displaced.
SNGPL will be responsible for the land acquisition required for the pipeline. As is standard practice, land use restrictions will be imposed along the ROW directly on top of the gas pipeline once it is operational. For this purpose, permanent land acquisition will be necessary for a strip of land between 11 to 22 feet wide along the pipeline right of way (ROW) depending on final specifications. An additional 30-40 feet wide strip of land will be leased from landowners for use during the construction of the pipeline. This leased area will be returned to the land owner with no restrictions imposed following construction.
The total land required for all of the facilities including the pipeline and the exploration wells is approximately 170 acres. This is a small proportion of the total land available in the area. No one will be physically displaced as a result of this project.
Land acquisition will continue as the project progresses and DPL will continue to follow the procedures that they have implemented to ensure that they comply with Pakistan legislation and World Bank/IFC policies. DPL will document its land acquisition and leasing procedures for the Safed Koh concession, and will monitor the process followed by SNGPL to acquire/lease lands for the construction of the pipeline linking DPL’s gas processing facilities to the Dhodak-Kot Addu pipeline.
- Community development
DPL has already provided some development contribution to nearest communities, including the construction of a primary school, a medical dispensary and the supply of potable water from a well some 15 km to the north at the Dhodak gas plant. In addition, DPL has upgraded and has been maintaining an access road originally built for the earliest drilling activities in the 1970’s for the benefit of these communities. Also, DPL has contributed to community feasts, especially during Ramadan and Baqar Eid, by distributing food to the communities. More generally, within the scope of the Safed Koh concession terms, DPL will contribute funds for social welfare programs. Depending on production rates this contribution will range from a minimum of USD 20,000 to a maximum of USD 75,000 annually.
- Security
As part of the development planning, DPL will make its own usual security arrangements for its staff, contractors and facilities. A security plan and procedures will be developed that will ensure adequate training and the appropriate conduct of security personnel. Procedures and training will take into account similar engagement principals and guidelines contained in the UN Code of Conduct for Law Enforcement Officials, the UN Basic Principles on the Use of Force and Firearms by Law Enforcement Officials and the Voluntary Principles on Security and Human Rights.
