The LNG branch jetty will be built at the existing EVTL terminal. The major portion of the pipeline will be built inside the port industry zone. The right of way for the 3-km section of the pipeline on private land will be negotiated according to market prices. Indigenous Peoples were not identified in the project area and no issues related to cultural heritage were identified in the project area; thus PS7: Indigenous Peoples and PS8: Cultural Heritage is not applicable

A new LNG branch jetty will be constructed for LNG unloading, floating storage, and regasification. The natural gas will be transferred to the national gas pipeline network through a new 24 km underground pipeline, including a 3 km right of way (ROW) on private land outside of the port authority industry zone. Approximately 1.3 – 1.6 million cubic meters of sediment will be dredged from the jetty site. The dredged materials will be disposed within a 50 ha mangrove area inside the port industry zone as demarcated by Port Authorities.

The key E&S risks and issues include the following:

- Occupational health and safety

- Operational hazards, fire prevention, and emergency response

- Road transportation and community safety

- Biodiversity conservation for the mangrove area

Mitigation measures for the potential E&S impacts have been identified and are incorporated into an ESAP. The potential adverse E&S impacts of this project are diverse and irreversible and this is therefore an E&S Category A project.

Land and Natural Environment: The proposed LNG branch jetty and FSRU will be located adjacent to the existing EVTL jetty facility, which is along the navigable creek of PQ. 20 km of the proposed 24 km gas pipeline is inside the PQ industry zone. Approximately 1 km is along a railway and National Highway and 3 km is though a barren semi desert land. There are no residential areas near the pipeline. The nearest community to the LNG jetty is approximately 5 km away. There are mangroves near the jetty site and along the navigable creek of the Port Qasim Authority (PQA), which are natural reserve area. According to the ESIA, there is no other natural reserve area or protected species at or near the jetty or along the pipeline route.

Corporate Environmental and Social Policy: Engro has a corporate E&S policy, which requires management and utilization of resources and operations in such a way that the safety and health of the workforce, neighbors, customers, and visitors are ensured. Engro E&S policy also requires that safety, health and environmental responsibilities extend beyond protection and enhancement of its own facilities to include chemical transportation. EHS departments/units at each Engro facility are responsible for enforcing EHS operational procedures. The corporate E&S policy is covered during new employee induction and annual refresher training.

Identification of Risks and Impacts: Engro contracted external experts to conduct an ESIA for the proposed LNG terminal project. The ESIA was approved by the local environmental authority (Sindh Environment Protection Agency) SEPA after a thorough Public Hearing and review of the project by Expert’s Committee. As required by IFC, the ESIA was revised to meet IFC Performance Standards and the applicable World Bank Group (WBG) EHS Guidelines. The revised ESIA also includes an assessment of cumulative impacts, air emission modeling, a quantitative risk assessment (QRA) conducted by Lloyd’s Register UK, and LNG ship maneuvering simulation conducted by BMT Argoss UK. The revised ESIA postulated and analyzed a range of potential EHS risks for this project, including high risk and catastrophic risk scenarios and concluded that after implementation of mitigation measures impacts from the risks postulated can be reduced to low or insignificant level.

Environmental and Social Management and Organization: At EVTL, there are comprehensive EHS management programs and implementation procedures for each operational process, including EHS operational procedures for each workplace and ambient environment monitoring, hazardous material management, industrial solid waste management, equipment operation safety procedures, emergency response, ship EHS management, road tanker EHS management, EHS requirements for onsite contractors, etc. As part of this project, new EHS procedures will be prepared by EETL for the proposed FSRU and gas pipeline operations. The EVTL facility has acquired an Integrated Management System (IMS) for a combined and coordinated certification of compliance with ISO 9001, ISO14001 and OHSAS 18001 standards, certified by Bureau Veritas in United Kingdom and EETL shall follow the same practices. Daily EHS management is handled by the EHS unit, staffed by full-time safety and environmental engineers. At each operational unit, there are part-time EHS coordinators, who support the fulltime EHS manager/engineers for operational EHS managements. The EHS manager reports to Terminal manager. In accordance with the ESAP, EETL will conduct a risk/gap analysis for the operational alignment between EVTL and FSRU, and integrate its EHS management with the FSRU contractor’s EHS management to ensure safe operations of the FSRU, gas pipeline, and the existing liquid chemicals unloading/storage.

Emergency Preparedness and Response: Fire hazard and toxic chemical release are the main operational risks at the EVTL facility and the company has strict management procedures to control fire hazard and prevent chemical leak. Personal electronics are not allowed in the storage and jetty area and all vehicles within this area are equipped with spark arrestors. There are fire and toxic gas sensors, and detection of temperature, smoke, explosion level, and toxic chemical concentrations at all high risk areas. The sensor systems and closed circuit TVs (CCTVs) are connected with the central control room at the facility and the emergency response (ER) center of PQA.As part of the project, the EVTL central control room will also monitor key safety parameters in real time.

There is enough firefighting water and foam storage on site. In case of major fire, the fire system will be automatically transferred to sea water firefighting. Sprinkler systems and foam firefighting equipment are installed at all tank farms and other potential fire sources. All firefighting equipment is routinely inspected by the EHS unit. EVTL has its own fire brigade, which is supported by PQA fire brigade. EVTL has an onsite clinic for emergency treatment and a major hospital is approximately 12 km away. Material safety data sheets (MSDS) for all toxic chemicals handled by the terminal are located at the facility. Copies of these MSDS are also kept at the ER clinic. The EETL LNG Jetty will be fully equipped with a Fire and Gas Detection System and fire monitors and sprinkler systems.

EVTL holds weekly firefighting drills, quarterly company level drills, which involve the PQA fire brigade, neighboring facilities, and the local hospital according to a scenario. As part of the project, The ER plan will include EETL, EVTL and FSRU operation and all the firefighting/ER drills will also involve the FSRU contractor.

Monitoring and Review: There is an EHS briefing before and after each shift. The management holds monthly EHS meeting with the EHS manager and each operational unit manager. Quarterly safety meetings for all employees are also held. The Terminal manager, together with the EHS department, also conducts routine EHS inspections. External safety experts are contracted for safety audits. The European based international Chemicals Distribution Institute for Terminals (CDI-T) was contracted in 2003 to audit and verify jetty/storage operation safety. This certification was replaced with Terminal Health Assessment (THA) designed and conducted by Vopak. At EVTL last THA was conducted in 2010 with score of over 95% and next THA audit is planned in 2014.  Vopak also conducts routine EHS audits. Any non-compliances, identified during the various inspections/audits, are recorded by the EHS unit. Equipment can be shut-down in the case of immediate danger. Corrective actions are required for non-compliances and implementation of the action will be reviewed in the future inspection/audit. The non-compliance records and corrective actions implementation are reviewed at monthly EHS meetings.

Raw Materials and Resource Efficiency: There are no manufacturing processes at this project.  The main consumption is of seawater (cooled for regasification), natural gas for turbines at FSRU, and electricity for gas pumping. Seawater will be discharged back to the sea. FSRU consumes approximately 68,000 m3 natural gas per year for the gas turbines. Energy efficiency is considered in the gas turbine design and a heat recovery system will be installed at the gas turbines. According to the design criteria, the energy consumption for regasification is 24 MWe for 7 GSm3 natural gas per year, which meets the WBG EHS guideline benchmark of 30 MWe for 8 GSm3/year.

Pollution Preventions and Compliances: The primary wastewater generated onsite will be sanitary wastewater and facility cleaning wastewater, which is treated onsite before discharged. The effluents will meet both local regulatory standards and WBG EHS Guideline limits. The seawater for regasification heating will be controlled within 3 °C of the ambient seawater at the edge of mixing zone.  There are onsite emergency spill tanks to hold spilled chemicals from the jetty and truck loading area. EVTL have had no major spills (>200 kg) at its operational history. The firefighting wastewater is held within secondary containment at each tank farm. EETL will monitor the emissions from gas turbine stack for this project to ensure compliance with both local and IFC requirements. Both sanitary and industry wastes are disposed of through PQA’s approved waste management contractors.

Hazardous Materials and Operational Hazard: LNG will be handled by EE and regassified-liquid natural gas (RLNG) will be handled by EETL. Other liquid chemicals handled by EVTL are also hazardous materials. The handling, storage, and transportation of these materials could pose serious dangers to the employees and nearby industries if not well managed. All the storage tanks onsite go thorough periodic inspections by external experts. Quantitative risk assessments (QRA) are conducted for storage of all hazardous materials to ensure safety for major buildings onsite and nearby companies. EVTL prepares detailed procedures to handle these hazardous materials and EETL will replicate the systems for LNG handling. All the hazardous liquids are stored at above ground tanks with proper secondary containment volumes. Hazard operability studies (HAZOP) have been prepared for all the handling processes and will be updated if process is modified. HAZOP for the LNG project was held in UK in January 2014 and was conducted by Lloyd’s Register, participated by Royal Vopak of Holland, China Harbor, Excelerate Energy, Technica Ltd UK, Qatargas, Port Qasim and SSGC. As part of this project, a detailed QRA and ship maneuvering simulation modeling were conducted as references for detailed designs. Subsequently, a detailed Consequence Analysis Report was conducted by Lloy’ds Register which concludes that the Exclusion Zone remains within EETL berthing pocket, i.e. 150m away from the Marine Loading Arm (MLA)  manifold.

All ships are required to comply with International Maritime Organization (IMO)’s applicable regulations on the safety, security, efficiency, and the marine/atmospheric environment protections. The terminal has a 3-months advance ship planning. All ships reporting to the berth have to be pre-approved by terminal management. The similar compatibility studies between the FSRU and LNG Carrier (NGC) shall be conducted prior to engaging of the LNGC for the project. Before unloading, EHS engineers and ship operation staff will review all safety, fire prevention, leak prevention, and ER features.

All road tankers are contracted by EVTL’s clients. Before each road tanker enters the EVTL site for hazardous chemical pickup, EVTL staff will check the tanker safety condition and review the certificates for tankers and drivers. Only qualified tankers and drivers are allowed to enter EVTL sites. For long-term contracted road tankers, EVTL pre-approves the extended contracts and reviews their insurance records periodically. 

Greenhouse Gases (GHG): After this project is implemented, the Elengy Terminal project will generate approximately 47,000tonnesof CO2-equivalent annually, mainly from natural gas consumption at the FSRU turbine.

Community Health, Safety and Security: The nearest residential community to the EETL site is more than 5 km distant. The majority of the pipeline is within PQA industry zone and there are no residential areas in the industry zone. The last 3 km pipeline goes through barren privately owned land. The QRA also indicates that the impact radius under the worst scenario is within the jetty area. The normal operations at the jetty and pipeline have no impacts to the local communities.

Emergency Preparedness and Response: EVTL has ER plans available, and conducts routine drills for firefighting and potential chemical explosion/releases and EETL will prepare similar procedures for LNG. EVTL only allows ships meeting IMO regulations to deliver the Chemicals &LPG. EETL will follow the similar procedures. For road transportation, EVTL requires its clients to only contract transportation companies that have defensive driving programs, acceptable safe driving records, and sufficient emergency response methods. EVTL also reviews insurance information for all long-term transportation contractors.

Security Personnel:  The terminal shares land access through EVTL that has its own private security guards and is within PQA premises, which is itself guarded by PQA guards. The water front is under surveillance by naval intelligence guards and coast guards.  EVTL is to assess the risk of having different layers of armed security forces at its facilities, and integrate an armed security usage policy and procedures into EHS management system in order to ensure that contracted security personnel records are screened before employment and that security personnel are trained on human rights and Voluntary Principles and that security incidents are recorded, investigated and corrective actions implemented. In addition, these procedures will include internal and external grievance mechanism and process code violations from security personnel against members of the community and employees.

Being in the industrial port zone, EETL project facility is not located in close proximity of settlements. Besides providing employment opportunities to local community, the company is engaged in several community outreach activities under its Corporate Social Responsibility program by Engro. The company allocates 1% of annual before tax earning for CSR program implementation.

There is no settlement in the close proximity of Elengy Terminal project area. In addition, fishing is prohibited within the port area and the closest boundary that fishing allowed is at a distance of ~12 km. Thus, the project is not expected to have any impacts on community livelihoods.

Therefore, the project’s main external communities are the other companies with industrial facilities in the same port area. The 20 km of the pipeline which will be constructed within the scope of Elengy Terminal project passes underground through some adjacent facilities. EETL has already developed a SEP and implemented it during the planning period of the project. However, EETL will ensure that an updated stakeholder engagement plan will be developed and implemented during the construction and operational phases of the project. The plan will identify the different categories of internal and external stakeholders including affected facilities and landowners, determine procedures for consultation, disclosure of information and a solid and locally applicable grievance mechanism.