Inception Report for Monthly Environmental Monitoring of Patuakhali 2x660 MW STPP Project

INCEPTION REPORT
For Monthly Environmental Monitoring
Of

Patuakhali 2x660 MW Ultra At Kalapara,

Super Critical Coal Fired Patuakhali,
Power Plant Project Bangladesh

Prepared For:

Ashuganj Power Station Company Ltd. (APSCL)

Prepared By:

Adroit Environment Consultants Ltd. (AECL)

2/12, Block B, Humayun Road, Mohammadpur, Dhaka-1207, Bangladesh
Cell: +880 1711-565728, +880 1733376609-10, Tel: +88029116712,
+88029116713,
Fax: +88029116714, E-Mail: [email protected], [email protected],
Web: www.aecl-bd.org
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Inception Report for Monthly Environmental Monitoring of Patuakhali 2x660 MW STPP Project

Table of Contents
ABBREVIATION ........................................................................................................................................ 5
Executive Summary................................................................................................................................. 6
1.0 Introduction ...................................................................................................................................... 7
1.1 Background ................................................................................................................................... 7
1.2 Importance of the Project ............................................................................................................. 7
1.3 Rationale of the Study................................................................................................................... 8
2.0 Project Description............................................................................................................................ 9
2.1 Project Location ............................................................................................................................ 9
2.2 Project Summary ......................................................................................................................... 11
3.0 Legal & Legislative Framework, Regulations and Policy Considerations ........................................ 13
3.1 Background of Policy and Legal Considerations in Bangladesh .................................................. 13
3.2 Regulatory Body .......................................................................................................................... 13
3.3 Environmental Clearance Process............................................................................................... 13
3.4 Applicable Policies & Legal Provisions ........................................................................................ 16
3.5 National Environmental Legal Provisions in Connection with Setup, Operation and
Maintenance ..................................................................................................................................... 18
3.6 Policy Guidance ........................................................................................................................... 20
4.0 Team Formation .............................................................................................................................. 27
4.1 Study Team Requirement ........................................................................................................... 27
4.2 Study Team ................................................................................................................................. 27
4.3 Management of the study .......................................................................................................... 28
5.0 Reconnaissance of Field Visit .......................................................................................................... 28
5.1 Objective of the Field Visit .......................................................................................................... 28
5.2 Team Composition ...................................................................................................................... 28
5.3 Field Activities ............................................................................................................................. 29
6.0 Findings of the Field Visit ................................................................................................................ 30
6.1 Project Location Data .................................................................................................................. 30
6.2 Preliminary Environmental Data ................................................................................................. 32
6.2.1 Air Quality ............................................................................................................................ 33
6.2.2 Noise Level ........................................................................................................................... 33
6.2.3 Water Resources .................................................................................................................. 33
6.2.4 Soil Resources ...................................................................................................................... 33
Present Site Condition ...................................................................................................................... 35
7.0 Methodology................................................................................................................................... 36

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7.1 Introduction ................................................................................................................................ 36

7.2 Monitoring Plan .......................................................................................................................... 36
7.3 Sampling Locations and GPS Coordinates................................................................................... 36
7.4 Ambient Air Quality Monitoring Methodology ........................................................................... 39
7.4.1 Sampling Procedure ............................................................................................................. 39
7.4.2 Equipment Used ................................................................................................................... 39
7.4.3 Analysis Procedure ............................................................................................................... 40
7.5 Ambient Noise Level Monitoring ................................................................................................ 41
7.5.1 Monitoring procedure of noise level ................................................................................... 41
7.6 Methodology for Water Quality Analysis ................................................................................... 41
7.6.1 Sampling Principle ................................................................................................................ 41
7.6.2 Equipment ............................................................................................................................ 42
7.6.3 Sampling Criteria .................................................................................................................. 42
7.6.4 Analysis Principle ................................................................................................................. 42
7.7 Soil and Sediment Quality Monitoring ........................................................................................ 43
7.7.1 Principle ............................................................................................................................... 43
7.7.2 Material/Equipment ............................................................................................................ 44
7.7.3 Essential measures ............................................................................................................... 44
7.7.4 Analysis Principle ................................................................................................................. 44
8.0 Work Schedule ................................................................................................................................ 46
9.0 Current & Future Activities to be Performed.................................................................................. 48
10.0 Conclusion ..................................................................................................................................... 48
11.0 References .................................................................................................................................... 49

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Inception Report for Monthly Environmental Monitoring of Patuakhali 2x660 MW STPP Project

List of Figures

Figure 1: Location map of the proposed project site............................................................................ 10

Figure 2: Location Map of the proposed project with boundary ......................................................... 31
Figure 3: Wind-Rose Diagram of Last 3 Years ....................................................................................... 32
Figure 4: Locations of sampling sites around the Project ..................................................................... 34
Figure 5: North-West Side of the Project .............................................................................................. 35
Figure 6: North-East Side of the Project ............................................................................................... 35
Figure 7: Near Rehabilitation Area........................................................................................................ 35
Figure 8: North-West Side of the Project .............................................................................................. 35
Figure 9 & 10: Field Team of AECL in the site ....................................................................................... 35
Figure 11: APM 460 sampler ................................................................................................................. 39
Figure 12: AAS 127 Mini ........................................................................................................................ 40
Figure 13: Niskin Sampler ..................................................................................................................... 42
Figure 14: Post Auger ............................................................................................................................ 44
Figure 15: Grab Sampler ....................................................................................................................... 44

List of Tables

Table 1: Access to Nearest Facilities ....................................................................................................... 9

Table 2: Proposed Project at a Glance .................................................................................................. 11
Table 3: National Legal provisions for the project to ensure environmental protection ..................... 17
Table 4: Summary of the Relevant Polices............................................................................................ 20
Table 5: Team Composition for the Study ............................................................................................ 27
Table 6: Additional Team Members...................................................................................................... 27
Table 7: Composition of Team Members for Reconnaissance Field Visit ............................................. 29
Table 8: Field Activities of the Project .................................................................................................. 29
Table 9: Area Coordinates of APSCL Patuakhali 2x660 MW Ultra Super Critical Coal Fired Power Plant
Project boundary .................................................................................................................................. 30
Table 10: Environmental Variables, Testing Parameters and Sample Quantity ................................... 36
Table 11: Ambient Air Sampling Locations ........................................................................................... 36
Table 12: Ambient Noise Level Monitoring Locations .......................................................................... 37
Table 13: Surface Water Sampling Locations........................................................................................ 38
Table 14: Ground Water Sampling Locations ....................................................................................... 38
Table 15: Soil Sampling Locations ......................................................................................................... 38
Table 16: Sediment Sampling Locations ............................................................................................... 38
Table 17: Instrument Specification (Noise Meter)................................................................................ 41

List of Annexure

Annexure 1.0: Terms of Reference

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ABBREVIATION

EIA Environmental Impact Assessment

IFC International Finance Corporation
ADB Asian Development Bank
MoA Ministry of Agriculture
MoC Ministry of Communication
MoCAT Ministry of Civil Aviation and Tourism
EC Electric Conductivity
ECA Environment Conservation Act /Ecological Critical Area
ECC Environmental Clearance Certificate
ECR Environment Conservation Rules
MoEF Ministry of Environment and Forestry
MoFL Ministry of Fisheries and Livestock
MoPEMR Ministry of Power, Energy and Mineral Resources
MoWR Ministry of Water Resources
PM Particulate Matter
CO Carbon Monoxide
SPM Suspended Particulate Matter
MW Mega Watt
SOx Oxides of Sulphur
NOx Oxides of Nitrogen
EMP Environmental Management Plan
CEMP Construction Environmental Management Plan
DO Dissolved Oxygen
TDS Total Dissolved Solid
TSS Total Suspended Solid
AAS Atomic Absorption Spectrophotometer
ICPMS Inductively Coupled Plasma Mass Spectrometry
APHA American Public Health Association

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Executive Summary
Electricity has become an indispensable need for the development. It is also a prime essentiality to
sustain modern urban life. There is a huge demand for electricity in our day-today life as well as in
various sectors of the economy. Power is the main driving force of current progress and the foundation
of all advancement exercise of the nation. The total power produced in the country is not sufficient to
take care of the predominant demand of the nation.

The Government of Bangladesh took initiatives to increase the power generation capacity to fulfil the
rising power demand of the country. The Power System Master Plan (PSMP2016) recommends a
diversification of fuel used in electricity generation as natural gas reserve is depleting fast and
accordingly the Government of Bangladesh has a plan to reach a capacity of 40,000MW of electricity
by 2030 and half of which (20,000 MW) will be generated from coal to reduce the dependency on
natural gas. The Masterplan, targets composition of the power supply as of 2030 is set at 50% for
domestic and imported coal, 25% for domestic and imported (in the form of LNG) natural gas and 25%
for other sources such as oil, nuclear power, and renewable energy. The coal-based generation is the
least cost option in consideration to present economy.

To cope up with the government vision of power generation it has set a target to increase generation
to 3800MW by 2021 and 6500 MW by 2030. As part of the Power System Master Plan (PSMP) towards
supplying electricity, APSCL intends to construct a 2x660 MW coal-fired plant,which will be extended
up to 4000 MW.The proposed project site is located on the western bank of Rabnabad Channel within
four mauza namely, Debpur, Chaltabunia, Dhankhali and Panchjunia of Dhankhali & Champapur
Unions, in Kalapara Upazila under Patuakhali District.

The main objective here is to conduct the environmental monitoring of the project on a monthly basis
and record the real-time status of the impact area during construction phase which shall be used to
compare with the baseline (initial) environmental status to identify and understand the resulting
impact followed by undertaking precise mitigation measures when required.

In anticipation of the signing of the Agreement, as part of the inception phase, a reconnaissance field
visit has been made to the proposed site of Patuakhali 2x660 MW Ultra Super Critical Coal Fired Power
Plant Project at Kalapara Upazila, Patuakhali District, Bangladesh. The purpose of the visit was to
inspect the field for obtaining a general environmental overview along with the condition of the site
area to establish a tentative work plan. The main objective of this program is to identify the possible
key impact areas in the project and record the GPS coordinates for the monthly environmental study.

To perform a reconnaissance survey an assigned team comprised of three men visited the site from
2nd January, 2021 to 3rd January 2021. The detailed information of this field visit is presented in Table
8. Detail work Schedule has been proposed for entire work. Term of Reference (ToR) is attached as
Annexure 1.

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1.0 Introduction

1.1 Background

We have reached a certain point of our civilization when electricity is required for almost all of the
daily purposes. Power and energy are vital factors that determine the growth path of a developing
country like Bangladesh whereas; electricity is the major source of power for country's most of the
economic activities. Consistent supply of power and energy can ensure development of the economy.
Nonetheless the huge demand supply gap prevailing in the power sector has turned out to be a hurdle
for the economic expansion of the nation. Power sector of Bangladesh is a proud sector of the country
with installed power generation capacity of 22,562 MW as of October 2019 (including captive and
renewable energy). Power sector of Bangladesh is one of the booming sectors of the country. Now
94% of the total population has access to electricity and per capita generation is 510 kWh (including
renewables and captive). The majority of power produced in the country is used for commercial
purposes. The demand for electricity in the rural areas has experienced significant growth over the
years mainly driven by agriculture and small & medium enterprises.

The Government of Bangladesh has a plan to raise its generation capacity up to 33,000 MW of
electricity by 2030 and half of this will be generated from coal to reduce the dependency on natural
gas. To comply with this plan, Ashuganj Power Station Company Limited (APSCL) intends to construct
a 2x660 MW Coal Fired Thermal Power Plant in Patuakhali District, which will have ultimate Capacity
of 4000 MW. The proposed project site is located on the western bank of Rabnabad Channel within
four mauza namely, Debpur, Chaltabunia, Dhankhali and Panchjunia of Dhankhali & Champapur
Unions, in Kalapara Upazila under Patuakhali District.

This inception report aims to perform monthly environmental analysis of the proposed project entitled
“Patuakhali 2x660 MW Ultra Super Critical Coal Fired Power Plant Project” at Kalapara Upazila,
Patuakhali District, Bangladesh. The proponent of this project is Ashuganj Power Station Company
Ltd., Ministry of Power, Energy and Mineral Resources (MoPEMR), Government of Bangladesh.

1.2 Importance of the Project

The proposed power plant will add 2x660 MW electricity to our national grid that will improve our
present electricity generation significantly and as well as trigger our national economic development.
Not only that, but industrial development will also be initiated after implementation. Additionally, it
will create employment opportunity for the local people and improve the transportation system in the
project area, which will ultimately play an important role in poverty reduction and develop social
safety net condition. Moreover, this coal-based power plant will thereby play an important role in fuel
diversification in electricity generation and reduce pressure on natural gas reserve.

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1.3 Rationale of the Study

APSCL has prepared a comprehensive Environmental Impact Assessment (EIA) study report. According
to that EIA, a detailed environment management plan (EMP) for the project implementation period
was suggested. So, to comply with the plan APSCL authority has engaged Adroit Environment
Consultants Ltd. a leading environmental engineering and consulting management system in
Bangladesh, to perform the monthly environmental monitoring of the project which includes sampling
of the environmental variables, analysis of different parameters and preparation of the report
accordingly. AECL will provide continuous feedback to PIU including Project Director (PD) on the said
services. The monthly monitoring report shall aim to analyze the environmental variables at their
current state which shall be compared to the baseline data to identify the impact and deploy
mitigation measures accordingly.

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2.0 Project Description

2.1 Project Location

The proposed 2x660 MW power plant project site is located between latitude 22°03'48.04"N to
22°03'3O.78"N and longitude 90°17'42.70"E to 90°20'10.06"E at Debpur, Dhankhali, Chaltabunia &
Panchjunia mouzas of Dhankhali & Champapur Unions in Kalapara Upazila, under Patuakhali district
of Bangladesh. The site is located on the western bank of river Rabnabad/ Patuakhali and adjacent to
proposed Sena Kolyan Sangstha (SKS), Rural Power Company Limited (RPCL) & Northwest Power
Generation Company Limited (NWPGCL) power plants in the south. The site is selected based on
availability of uninhabited land, proximity to water source, fuel source (CoaI Terminal) and fuel
transportation. Land requirement for the proposed project is 930.615 Acres and dominated with
agricultural land use (835 acre) which is around 89.7% of the total land (930.615 acre).

The proposed project site is accessible through the metal road Patuakhali – Kuakata Highway. The site
can be accessed easily through waterways (Patuakhali and other rivers). However, there is no railway
connection to the site. Nearest Airport is Barisal Airport at about 110 Km by road. There are no
industrial establishments near the site. The only economic activities of the proposed site are
agricultural, fisheries and plantation. No natural park, wildlife sanctuary and archaeological important
building exist in the project boundary. Approach road from this highway to plant site needs to be
planned & developed right from the construction stage. Presently, road connectivity is limited.

The distances from nearest town, port etc. are given in the following Table 1.

Table 1: Access to Nearest Facilities

Sl No. Description Data

1 Nearest Railway Station Chandpur / Bagherhat

2 Nearest Town Kalapara
3 Nearest Port Payra port
4 Name of District and Patuakhali, 72 km from site
Distance
5 Name of Airport & Distance Barisal Airport,110 km from site
6 National Highway/ Distance National highway N8 terminating in Patuakhali and
regional highway R881 is 8.5km away from site

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Figure 1: Location map of the proposed project site

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2.2 Project Summary

The proposed project is a 2x660MW sub-bituminous coal-based ultra-super critical thermal power
Plant. Each 660 MW Plant will consist of one ultra-supercritical, balanced draft, pulverized coal fired
Boiler with built in Dry Low NOx burners suitable for outdoor installation with a stack of 275-meter-
high and a tandem compound, multi cylinder design condensing type steam turbine directly coupled
with hydrogen cooled generator suitable for indoor installation. Blended coal with 4970 Kcal/kg design
GCV is considered to be the primary fuel for the power station The condensing type steam turbine ,
circulating cooling water station with intake and discharge channel, switchyard, water treatment
plant, Effluent Treatment Plant, demineralization plant, desalinization plant, coal terminal, coal
handling system (Conveyor belt and stockpiles), ash handling and disposal system (Ash pond), ESP,
FGD, township, administrative building, control room buildings, and approach road are also be
included in this project. Generated power will be evacuated from the plant at 400 KV. Power will be
evacuated through plant’s substation.

Using Pyra Port Authority’s Jetty the imported coal from source countries like Australia or Indonesia
will be unloaded and finally stored in plant stockyard using conveyer belt.
The Project once completed, would add 2x660 MW net power to the national power grid. Thereby
improving the present power grid scenario significantly and triggering the national economic
development through industrialization. Moreover, it will create employment opportunity for the local
people and improve the transportation system in the Project area, which will ultimately play an
important role in poverty reduction and develop social safety net condition. The Plant will be designed
to meet the Best Available Control Technology (BACT) emission.

Table 2: Proposed Project at a Glance

Proponent Ashuganj Power Station Company Ltd (APSCL)
Location Dhankhali & Champapur Union in Kalapara Upazila
under Patuakhali District
Capacity 1320 MW
Configuration 2 660 MW
Plant type Ultra-Super Critical Coal Fired Power Plant
Primary fuel (type) Bituminous/Sub-bituminous Coal
Source Coal South Africa, Indonesia, and Australia
Daily Coal requirement 12,726 T/Day (at 100% load factor)
Annual Coal requirement 4.64 MT/Year (considering 100% load factor)
Sulphur Content 0.38 % to 0.52%
Ash Content in Coal Avg 12% (9 -14%)
Ash Generation 1527 ton per day; Fly ash 1298 ton per day (85%)
Bottom ash 229 ton per day (15%)

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ESP Twin-chamber five-electric-field ESP will be equipped

with dust collection efficiency of not lower than 99.72%
Low NOx The boiler adopts low NOx burner with efficiency of not
lower than 87% and staged air distribution
combustions to assure NOx emission concentration at
boiler outlet lower than 510 mg/Nm3
FGD Limestone-gypsum wet type –desulfurization will be
adopted with desulfurization efficiency of not lower
than 93%. The sulphur dioxide concentration at
chimney outlet will be lower than 200 mg/Nm3
Maximum Emission of SOx 242.3 g/s
Maximum Emission of NOx 578.2 g/s
Maximum Emission of PM 30.3 g/s
Stack Height 275 meters
Water Intake (Makeup water) 4,639 m3/hr. (e.g. 1.3 m3/S.), 0.003% of lowest flow
condition in Rabnabad Channel
Water Discharge after 2052 m3/hr
Treatment
Thermal Plume/Heated Water No Discharge of Heated Water
Land Requirement 930.615 Acres
Number of Affected 120
Households
Project Cost 2,775.64 Million USD (approximately 22,205 Crores in
BDT)
Source: Feasibility Study Report

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3.0 Legal & Legislative Framework, Regulations and Policy Considerations

3.1 Background of Policy and Legal Considerations in Bangladesh

For protecting the environment from industrial pollution and environmental degradation,
Government of Bangladesh has promulgated some policies, strategies, laws, rules & regulations and
action plans. The clauses and requirements of these regulatory legislations and policy imperatives
must be taken in to consideration for compliance by the proponents/operators of any industrial
establishment in the country.

As an institutional arrangement, Government of Bangladesh has designated the “Department of

Environment" (DOE) with the sole responsibility for the regulatory functions to enforce of the
provisions of environmental laws, rules and regulations to prevent environmental degradation in the
country. Under these legal provisions, the industrial entrepreneurs must take mitigation measures for
protecting the environment from pollution impacts and must get ‘Environmental Clearance’ from DoE
before setting up and running their industries. These rules are equally applicable to both new and the
existing industries. There are some other sectoral rules related to the industrial projects, which
predate environmental legislations. These legislations have become effectively obsolete with the
promulgation of the ECA, 1995 and the ECR, 1997 and their subsequent amended versions.

3.2 Regulatory Body

Prior to initiating a development project, it is essential to obtain environment clearance from the
Department of Environment (DoE). The environmental aspects of power projects are governed by the
Environmental Conservation Act, 1995 (including all amendments), the Environmental Conservation
Rules, 1997(including all amendments) and other applicable Acts. The requirement for undertaking
environmental studies has been specified under the ECA, 1995 and the ECR, 1997. Section 12 of ECA,
1995 stipulates, "No industrial unit or project shall be established or undertaken without obtaining
environmental clearance from the Director General, Department of Environment (DG, DoE) in the
manner prescribed by the rules". Further, Section 20 of the Act has bestowed rule-making powers on
the government and Clause 2(f) of this section requires that rules be made to "evaluate and review
the Environmental Impact Assessment (EIA) of various projects and activities, and procedures are
established for approval". All those requirements have been promulgated in the ECR, 1997.

3.3 Environmental Clearance Process

Environmental Conservation Rule (ECR), 1997 enlist a basic process flow for environmental evaluation
of the Project thus establishes required procedures. Rule 7 of the ECR’1997 categorizes different types
of projects and the step-by-step procedure for each category on how to get the required clearance
accordingly. The following shall outline the statement from rule 7 as such.

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(1) For the purpose of issuance of Environmental Clearance Certificate, the industrial units and projects
shall, in consideration of their site and impact on the environment, be classified into the following four
categories:
(a) Green;
(b) Orange – A;
(c) Orange – B; and
(d) Red.
(2) Industries and projects included in the various categories as specified in sub-rule (1) have been
described in Schedule – 1.
(3) Environmental Clearance Certificate shall be issued to all existing industrial units and projects and
to all proposed industrial units and projects falling in the Green Category.
(4) For industrial units and projects falling in the Orange – A, Orange – B and Red categories, firstly a
Location Clearance Certificate and thereafter an Environmental Clearance Certificate shall be issued.
Provided that the Director General may, without issuing a Location, Clearance Certificate at the first
instance, directly issue Environmental Clearance Certificate if he, on the application of an industrial
unit or project, considers it appropriate to issue such certificate to the industrial unit or project.
(5) The entrepreneur of the concerned project shall apply to the concerned Divisional Officer of the
Department in Form 3 along with appropriate fees as specified in Schedule 13.
(6) The following documents shall be attached with an application made under sub-rule (5):

(a) For Green Category:

(i) general information about the industrial unit or project;

(ii) exact description of the raw materials and the manufactured product; and
(iii) no objection certificate from the local authority;

(b) For Orange – A Category:

(i) general information about the industrial unit or project;

(ii) exact description of the raw materials and the manufactured product;
(iii) no objection certificate from the local authority;
(iv) process flow diagram;
(v) Layout Plan (showing location of Effluent Treatment Plant);
(vi) effluent discharge arrangement;
(vii) outlines of the plan for relocation, rehabilitation (if applicable);
(viii) other necessary information (if applicable);

(c) For Orange – B Category:

(i) report on the feasibility of the industrial unit or project (applicable only for proposed industrial unit
or project);
(ii) report on the Initial Environmental Examination of the industrial unit or project, and also the
process flow diagram, Layout Plan (showing location of Effluent Treatment Plant), design of the
Effluent Treatment Plant (ETP) of the unit or project (these are applicable only for a proposed industrial
unit or project);

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(iii) report on the Environmental Management Plan (EMP) for the industrial unit or project, and also
the Process Flow Diagram, Layout Plan (showing location of Effluent Treatment Plant), design of the
Effluent Treatment Plant and information about the effectiveness of the ETP of the unit or project,
(these are applicable only for an existing industrial unit or project);
(iv) no objection certificate from the local authority;
(v) emergency plan relating adverse environmental impact and plan for mitigation of the effect of
pollution;
(vi) outline of the relocation, rehabilitation plan (where applicable);
(vii) other necessary information (where applicable).

(d) For Red Category:

(i) report on the feasibility of the industrial unit or project (applicable only for proposed industrial unit
or project);
(ii) report on the Initial Environmental Examination (IEE) relating to the industrial unit or project, and
also the terms of reference for the Environmental Impact Assessment of the unit or the project and its
Process Flow Diagram; 0r, Environmental Impact Assessment report prepared on the basis of terms of
reference previously approved by the Department of Environment, along with the Layout Plan
(showing location of Effluent Treatment Plant), Process Flow Diagram, design and time schedule of the
Effluent Treatment Plant of the unit or project, (these are applicable only for a proposed industrial
unit or project);
(iii) report on the Environmental Management Plan (EMP) for the industrial unit or project, and also
the Process Flow Diagram, Layout Plan (showing location of Effluent Treatment Plant), design and
information about the effectiveness of the Effluent Treatment Plan of the unit or project (these are
applicable only for an existing industrial unit or project);
(iv) no objection certificate of the local authority:
(v) emergency plan relating adverse environmental impact and plan for mitigation of the effect of
pollution;
(vi) outline of relocation, rehabilitation plan (where applicable);
(vii) other necessary information (where applicable);
(7) If an application for an Environmental Clearance Certificate for an industrial unit or project of Green
Category is made under sub-rule (5) along with the relevant documents specified in sub-rule (6), then,
within 15 days of the receipt of the application, the certificate shall be issued or the application shall
be rejected mentioning appropriate reason for such rejection.
(8) If an application is made under sub-rule (5) along with the relevant documents specified in sub-rule
(6), then in the case of an Orange- A Category industrial unit or project, within thirty days of the receipt
of the application, and in the case of an Orange-B or Red Category industrial unit or project, within
sixty days of the receipt of the application, a Location Clearance Certificate shall be issued or the
application shall be rejected mentioning appropriate reasons for such rejection.
(9) Upon receiving Location Clearance Certificate under Sub-rule (8), the entrepreneur–
(a) may undertake activities for land development and infrastructure development;
(b) may install machinery including ETP (applicable for industrial units or projects of Orange-A and
Orange-B Category only);
(c) shall apply for Environmental Clearance Certificate upon completion of the activities specified in
clauses (a) and (b), and, without the Environmental Clearance Certificate, shall not have gas line

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connection, and shall not start trial production in the industrial unit, and in other cases shall not
operate the project (applicable for Orange-A and Orange-B Category industrial units or projects only);
(d) shall submit for approval of the Department the EIA report prepared on the basis of program
outlined in IEE Report along with time schedule and ETP design (applicable only for Red Category
industrial units or projects);
(10) Where an application is received under clause (c) of sub-rule (9), Environmental Clearance
Certificate shall, within fifteen working days in case of industrial unit or project of Orange-A Category
and within 30 working days in case of industrial unit or project of Orange-B Category, be issued to the
entrepreneur or the application shall be rejected mentioning appropriate reasons.
(11) Where an application is received under clause (d) of sub-rule (9) in relation to an industrial unit
or project of Red Category, the EIA report along with the time schedule and ETP design shall, within
sixty working days, be approved or the application shall be rejected mentioning appropriate reasons;
(12) After EIA is approved under sub-rule (11), the entrepreneur –
(a) may open L/C for importing machineries which shall include machineries relating to ETP; and
(b) shall, after installation of ETP, apply for Environmental Clearance Certificate without which he shall
not have gas line connection and shall not start trial production in case of an industrial unit, and in
other cases shall not start operation of the project.
(13) Where an application under clause (a) of sub-rule (12) is received in relation to an industrial unit
or project of Red Category, Environmental Clearance Certificate shall be granted to the concerned
entrepreneur within thirty working days, or the application shall be rejected mentioning appropriate
reasons.
(14) Where an application is received under sub-rule (5) along with the documents specified in sub-
rule (6), Environmental Clearance Certificate shall, within thirty working days in case of an industrial
unit or project of Orange-A Category and within sixty working days in case of Orange-B and Red
Category, be issued to the concerned entrepreneur or the application will be rejected mentioning
appropriate reasons.

The proposed project however falls under the red category as per criteria basis. The EIA of this project
was fabricated on December, 2019 and approved on January, 2020.

3.4 Applicable Policies & Legal Provisions

Legal provisions relevant to environmental protection applicable to the planning, construction,
operation and coal transportation were identified according to the approved EIA report.

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Table 3: National Legal provisions for the project to ensure environmental protection

ISSUE TITLE NATIONAL REGULATION

GOVERNANCE OF POWER a. Bangladesh Energy Regulatory Commission Act, 2003
GENERATION AND b.Power System Master Plan, 2010
MANAGEMENT SYSTEM c. National Energy Policy
COAL SOURCING a. Bangladesh Coal Policy (Draft)
b. Master Plan on Coal Power Development, 2010
c. Import and Export Control Act, 1950
COAL TRANSPORTATION a. Terrestrial Water and Maritime Zones Act 1974 & Rules 1977 b.
The Ferries Act, 1885
c. Ports Act, 1908
d. Bangladesh Merchant Shipping Ordinance 1983
e. The Prevention of the Interference with Aid to Navigable
f. Waterways Ordinance, 1962
g. Payra Port Authority Act, 2013
PREVENTION OF POLLUTION, a. Payra Port Authority Act, 2013
AND b. Ports Act, 1908
PROTECTION OF c. The Forests Act, 1927
ENVIRONMENT d. Environment Conservation Act, 1995 and the Amendments
thereafter
e. Environment Conservation Rules, 1997
f. The Environment Court Act, 2000
HEALTH AND SAFETY a. Fatal Accidents Act, 1855
b. Dock Laborers Act, 1934
c. Dangerous Cargoes Act, 1953
d. Imports and Exports (Control) Act, 1950
e. Public Safety Ordinance, 1953
f. The Explosives Act, 1884
g. Fire prevention and Extinguish Act, 2003
PROCUREMENT IN a. The Public Procurement Regulations, 2003 and Revisions
ISSUE Bangladeshi Legislation or Regulation
BANGLADESH thereafter
TRANSPORT, HANDLING AND a. Environment Conservation Act, 1995 (Amendments thereafter)
STORAGE OF DANGEROUS b. Ports Act, 1908
GOODS c. Petroleum Act, 1934
d. Dangerous Cargoes Act, 1953

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3.5 National Environmental Legal Provisions in Connection with Setup, Operation and
Maintenance

The Environment Conservation Act of 1995 is the key legislation in relation to environment protection
in Bangladesh. This Act has been promulgated for environment conservation, standards, development,
pollution control and abatement. It has repealed the Environment Pollution Control Ordinance of
1977. The Act has been subsequently amended in 2000, 2002, 2007 and latest amendments done up
to year 2010. The main objectives of the Act are:

➢ Conservation and improvement of the environment and

➢ Control and mitigation of pollution of the environment the main strategies of the Act can be
summarized as:
➢ Declaration of ecologically critical areas and restriction on the operations and processes, which
can or cannot be carried/initiated in the ecologically critical areas
➢ Regulations in respect of vehicles emitting smoke harmful for the environment
➢ Environmental clearance
➢ Regulation of the industries and other development activities‟ discharge permits
➢ Promulgation of standards for quality of air, water, noise and soil for different areas for different
purposes
➢ Promulgation of a standard limit for discharging and emitting waste and
➢ Formulation and declaration of environmental guidelines

According to the law before setting up any new project/interventions by the Government/
nongovernment agencies/public, the proponents are required to obtain respective clearance from the
Department of Environment. Under the Environment Conservation Rules 1997, the project promoter
must obtain site clearance from the Director General of Department of Environment. An appeal
procedure does exist for those promoters who fail to obtain clearance. The Department of
Environment executes the Act under the leadership of the Director General.

Under the Environment Conservation Act, 1995 the first set of rules promulgated is the Environment
Conservation Rules, 1997. The Rules have provided categorization of industries/ projects, hence
identified types of environmental assessments needed against respective categories of
industries/projects. The Environment Conservation Act (Amendment), 2000 provides responsibility for
compensation in cases of damage to ecosystems and these are-

(1) The polluter pay principle is included herein.

(2) increased provision of punitive measures both for fines and imprisonment.
(3) fixing authority on cognizance of offences.
The Bangladesh Environment Conservation Act (Amendment), 2002 elaborates on the followings:
(1) restriction on polluting automobiles
(2) restriction on the sale and production of environmentally harmful items like those that polythene
bags
(3) assistance from law enforcement agencies for environmental actions
(4) break up of punitive measures
(5) authority to try environmental cases.

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The Environmental Rules are not explicit for various oil and gas exploration interventions. Rather, this
is covered under the broader heading of “exploration, extraction and distribution of mineral
resources” under the „Red‟ category projects. So far, the Rule has been updated three times - February
and August 2002 and April 2003.

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3.6 Policy Guidance

Under the study a number of sectoral national policies have been reviewed to identify the guiding principles which are relevant to the coal based thermal
power plant installation, operation and maintenance activities. The sectoral policies will include energy, environment, water, forest, transport, import;
fisheries etc. Analysis of the relevant policies is summarized in Table 2:

Table 4: Summary of the Relevant Polices

Relevant Provisions to the Project Obligations of APSCL Requirement of APSCL

Title and Scope
Activities
Agricultural Policy, 1999

Agricultural Preserve and develop land productivity Ashuganj Power Station Company Limited Extension Department,
Policy, 1999 Should: take appropriate measures to prevent Soil Resource
loss of land fertility in and around Project site Development Institute
during the project implementation period. If
not, then compensate the loss.
Agricultural Section 2.1 Objective; Preserve existing Ashuganj Power Station Company Limited MoA, Bangladesh Rice
Policy, 1999 biodiversity of different crops Should take appropriate measures to prevent Research Institute
loss of any indigenous crop variety of the project (BRRI), BARC
site Viz. preserve the indigenous crop verity. If
not, then compensate the loss.
Agricultural Section 12.1 Land Use; Appropriate Ashuganj Power Station Company Limited must MoA, MoFL
Policy, 1999 measures will be taken in the light of the follow the appropriate land acquisition procedure
Land Use Policy, to stop the trend of as per the GOB
shifting agricultural land into to other due
to its use for non-agricultural purposes.
Environment Policy 1992

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Environment Section 3.2.1 Industry; Adoption of Ashuganj Power Station Company Limited must MoEF, MoFL, MoPEMR,
Policy,1992 corrective measures by polluting comply with the Government regulation. DoE and other relevant
industries in phases government agencies
Environment Section 3.2.4 Industry; Encourage Ashuganj Power Station Company Limited should MoEF, MoFL, DoE
Policy 1992 development of environmentally sound use economically viable and environmentally
and appropriate technology and initiatives friendly technology Provide analysis of
on research and extension in the fields of alternatives in the EIA report
Industry. Balance such initiatives with the
best use of labor and provision of proper
Wages.
Environment Section 3.3.1 Health; Prevent activities, Ashuganj Power Station Company Limited MoEF, LGED, DPHE,
Policy 1992 which are harmful to public health in all should take all appropriate measures to prevent Local Administration
spheres, including development risky activities that may affect the Public.
Environment Section 3.3.5 Health; Ensure healthy Ashuganj Power Station Company Limited DoE, DPHE
Policy 1992 workplace for workers should take all appropriate measures to ensure
healthy workplace for the workers
Environment Section 3.4.1 Energy and Fuel Ashuganj Power Station Company Limited must MoEF, DoE, MoPEMR,
Policy 1992 Reduce and discourage the use of those fuels use the fuels in their machinery and vehicles that Local Government
which pollute the environment and increase reduce pollution in the environment Institutes
the use of environmentally sound and less
harmful fuels
Environment Section 3.4.2 Energy and Fuel reduce the use of Ashuganj Power Station Company Limited should MoPEMR
Policy 1992 fuel wood, agricultural residues etc. to meet use materials other than fuel wood and
energy need and increase the use of agricultural residue
alternative energy sources
Environment Section 3.4.5 Energy and Fuel Ashuganj Power Station Company Limited should: MoPEMR
Policy 1992 Conserve country's fossil fuel reserves and Consider the provision for long term aspects
renewable sources of energy
Environment Policy Section 3.4.6 Energy and Fuel; Conduct EIA Ashuganj Power Station Company Limited should MoEF
1992 before implementing the projects for conduct EIA
extraction of fuel and mineral resources

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Environment Section 3.5.1 Water development; Ensure Ashuganj Power Station Company Limited should: MoEF
Policy 1992 environmentally sound utilization of all water Ensure conservation of freshwater resources
resources
Environment Section 3.5.5 Water development keep Ashuganj Power Station Company Limited should: MoEF
Policy 1992 the rivers, canals, ponds, lakes, haors, Make sure that the nearby water bodies and
baors and all other water bodies and resources are not polluted due to project
water resources free from pollution activities.
Environment Section 3.6.2 Prevent land erosion, preserve Ashuganj Power Station Company Limited MoEF, MoFL
Policy 1992 and increase soil fertility, and expand should take appropriate measures to prevent
activities for conservation and land erosion in the project site.
environmentally sound management of
newly accreted land
Environment Section 3.7.2 Forest; Include tree plantation Ashuganj Power Station Company Limited MoEF, FD
Policy 1992 programme in all relevant development should: Carry out afforestation in and around the
activities project site
Environment Section 3.7.3 Forest; Stop shrinkage and Ashuganj Power Station Company Limited should: MOEF, FD
Policy 1992 depletion of forest land and forest resources Take appropriate measures minimize the
deforestation around the site
Environment Section 3.7.5 Forest Conserve wildlife and Ashuganj Power Station Company Limited should: MoEF, FD
Policy 1992 biodiversity Take appropriate measures to prevent loss of the
biodiversity and undertake compensatory
measures in case of inevitable damage if any
Environment Section 3.7.6 Forest; Conserve and develop Ashuganj Power Station Company Limited MoEF, MoWR, FD
Policy 1992 wetlands and protect migratory birds must: avoid activities which cause huge damage
to wetlands and destroy the any fish sanctuary
or species habitat of conservation significance
Environment Section 3.8.2 Fisheries; Prevent activities that Ashuganj Power Station Company Limited WET, EIA
Policy 1992 diminish the wetlands natural habits of fish should: Take appropriate measure, so that the Report
nearby fish habitats are not threatened due to
project activities, viz. do not discharge untreated
waste water into the river

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Environment Section 3.11.2 Transport and Communication; Ashuganj Power Station Company Limited should: MoEF, MoC, Roads and
Policy 1992 Ensure that vehicles and people using roads, Use the vehicles (which are going to be used Highway Department,
rails, air and inland waterways do not pollute during the operation of the project) which cause Railway Authority,
the environment and take steps to protect less pollution to the environment. Take necessary Inland Water Transport
health of the workers running these measures to protect health of the workers Authority
transports running transports
Environment Section 3.11.3 Transport and Communication; Ashuganj Power Station Company Limited should: MoEF, MoC, Roads and
Policy 1992 Control activities in inland ports and dockyards Need to consider this provision while importing Highway Department,
which cause pollution of water and the local and transporting the coals Port Authority,
environment Inland Water transport
Authority
Environment Section 3.12.1 Integrate environmental Ashuganj Power Station Company Limited should: MoEF
Policy 1992 consideration into all housing and urban While setting up the proposed location town,
planning activities and research consider the integrated environmental aspects
Energy Policy 1996 Section 1.2 Objective (v); Rational use of total Ashuganj Power Station Company Limited should: MoPEMR
energy sources Ensure the coal are used rationally Hydrocarbon Unit
Energy Policy 1996 Section 7.3 Technology Assessment, Ashuganj Power Station Company Limited should: MoPEMR
Necessary arrangements are to be made to Consider these (Mentioned) factors while
select appropriate technologies i.e. selecting the technologies.
conversion, efficiency, transferability,
adaptability, environmental effects, cost
should be considered while selecting
technologies
Energy Policy 1996 Promote use of economically viable Ashuganj Power Station Company Limited MoPEMR
environment friendly technology is to be should: Use economically viable and
promoted environmentally friendly technology
Land Use Policy 2010 Section 2 (e) Objective Ensure the land use in Ashuganj Power Station Company Limited should: MoFL and DoE
Harmony with the natural environment. Follow the Government‟s land use plan
Land Use Policy 2010 Section 2 (i) Objective; Conserve the natural APSCL compensate for destroying the natural MoFL, Forest
forest forest plantation on the other nearby areas Department
Reforestation and plantation on the annulled
forest area.
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Land Use Section 2 (i) Objective; Prevent river bank Ashuganj Power Station Company Limited should: MoFL and MoWR
Policy 2010 erosion Prevent activities that may cause river bank
erosion
Land Use Policy 2010 Section 2 (h) Objective; Prevent the land Ashuganj Power Station Company Limited should: MoFL and DoE
pollution Take appropriate measures to prevent/ reduce
the land pollution
Land Use Policy 2010 Section 3.4 Land Use; Maintaining a balanced Ashuganj Power Station Company Limited MoFL, MoWR, Forest
ecosystem considers proper authorization to utilizing the Department and others
area (project site) from the concerned authority,
via, seek authorization from the Forest
Department for utilizing the forest land
Forest Policy 1994 Conserve the natural forest (protected, Ashuganj Power Station Company Limited should: MoEF, FD
reserved and unclassified state forest) Take appropriate measures to mitigate adverse
impact (due to project activities) on the forest of
the power plant location area
Forest Policy 1994 Restoration of natural forest to preserve Ashuganj Power Station Company Limited should: MoEF, FD
biodiversity and wildlife Carry out afforestation and reforestation of
forests cleared during the project activity
Forest Policy 1994 Without proper authorization, forest land Ashuganj Power Station Company Limited MoEF, FD
Cannot be used for non-forest purpose. should: Seek for permission from the Forest
Department for using the forest area for non-
forest purpose
Tourism Policy 1992 Section 5 (3): Development, preservation and Ashuganj Power Station Company Limited need: MoCAT
maintenance of tourism resources of the To look into the matter so that any tourism
country resource nearby the powerplant is not affected
due to the project activities
Tourism Policy 1992 Section 7: Restoration and maintenance of Ashuganj Power Station Company Limited must: MoCAT
archaeological and historical sites Not destroy any archaeological and historical
sites of the with the power plant location of the
Power Plant
Tourism Section 8: Conservation of wildlife Ashuganj Power Station Company Limited need to MoEF
Policy 1992 consider this provision

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Fisheries Policy 1998 Section 9.10; Protect natural water bodies and Ashuganj Power Station Company Limited must: MoFL, Fisheries
marine biodiversity. Consider this provision and take appropriate Department
measure to reduce adverse impact on the water
bodies
Fisheries Policy 1998 9.10.2 Control activities which may have Ashuganj Power Station Company Limited must: MoFL, Fisheries
adverse effect on the fish resources Control the activities which may have adverse Department
impact on the fish resources
Fisheries Policy 1998 9.10.6 Implement laws to prevent discharge of Ashuganj Power Station Company Limited must MoFL, Fisheries
untreated waste into water bodies. comply with these laws Department
Water Policy 1999 Section 4.8 Water and Industry; a) Zoning Ashuganj Power Station Company Limited must: MoFL, MoWR
regulation will be established for location of Follow the zoning regulation of the Government
new industries in consideration of fresh and
safe water availability and effluent discharge
possibilities.
Water Policy 1999 b) Effluent disposal will be monitored by Ashuganj Power Station Company Limited must: MoWR
relevant Government agencies to prevent Allow the monitoring authority to monitor their
water pollution effluent discharge
Water Policy 1999 c) Standards of effluent disposal into common Ashuganj Power Station Company Limited need to DoE/MoWR
water courses will set by WARPO in comply with the polluter pay principle under the
consultation with DoE national legislation
Water Policy 1999 d) Industrial polluters will be required under Ashuganj Power Station Company Limited need DoE/MoWR
law to pay for the cleanup of water body to comply with the polluter pay principle under
Polluted by then. the national legislation
Water Policy 1999 Section 4.12 Water and Environment; d) Ashuganj Power Station Company Limited should: MoWR
Protect against degradation and resuscitate Consider this provision while implementing the
natural water bodies such as lakes, ponds, project
Heels, tanks, etc. affected by man-made
Intervention or other causes.
Water Policy 1999 i) Enforce the 'polluter pay' principle in the Ashuganj Power Station Company Limited need to DoE
development of regulatory guidelines for all follow the regulatory Guidelines.
regulatory actions designed to protect public
health and the environment
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Industrial Objective To take appropriate measures for Policy 1999 Ashuganj Power Station Company Limited need DoE, MoPEMR
1999 Preventing to consider the provision during implementation
of the project activities
Housing Policy1999 Section 4.7; Initiate planning to produce more APSCL should carry out afforestation and MoHPW/MoHFW
forest products used to build infrastructures Reforestation activities to restore degraded lands
and attention be given to environmental
management
Housing Policy 1999 Section 4.9; While implementing any new Ashuganj Power Station Company Limited MoHFW/MoC
housing project, need to consider the local should: Consider the provision while
building modes, upholding and conservation of implementing the township under the project
the cultural heritage activities
Housing Section 5.1.3 Land; Ensure that the minimum Ashuganj Power Station Company Limited should: MoHPW
Policy 1999 land acquired for any development Adopt the principle during land acquisition APSCL
project/programmer
BSAP Strategy 2: Conserve ecosystems, species and Ashuganj Power Station Company Limited MoEF/ DoE
genetic pool of the country to ensure that the should:
present and future well-being of the country • Create an inventory of all the species of flora
and its people are secure and fauna in the area.
• Conduct EIA and SIA reports.
BSAP Strategy 3: Restore ecosystems and Ashuganj Power Station Company Limited MoEF/ DoE
rehabilitate endangered species should:
• Construct ETP to restrict amount of pollution
• Create buffer zones in and around the
project site
• Carry on afforestation and reforestation
activities on abandoned site
BSAP Strategy 10: Ensure wise use of wetland Ashuganj Power StatioAPSCLn Company Limited MoWR/ MoEF
resources environment pollution and should:
maintaining the ecological balance Consider the provision while implementing the
project.

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4.0 Team Formation

4.1 Study Team Requirement

AECL & APSCL together developed a technical team for the reconnaissance field visit. After signing of the
contract agreement, AECL mobilized a team for the initial site visit. In order to accomplish the study within the
stipulated time frame, initiatives have been taken through preparation of an action plan, selecting the team
members and providing all necessary logistics and technical support to perform required investigations. The
team mobilized for initial site visit on 2nd January, 2021.

4.2 Study Team

A multidisciplinary team has been formed for the corresponding purpose. The team members with their project
wise assigned positions are presented in Table 5 below-

Table 5: Team Composition for the Study

SI No. Name of Professional Position Assigned

1 Dr. Nasir Uddin Khan Environmental Specialist (Team Leader)
2 Fakhruddin Ali Ahmed Ecologist
3 Dr. Baki Billah Fisheries Expert

Some additional members are also involved in this study for the smooth and in time execution of the project.
The following Table 6 shows the additional team member.

Table 6: Additional Team Members

SI No. Name of Professional Position Assigned

1 Md. Saiful Islam Project Co-Ordinator
2 Md Al-Amin Senior Environmental Engineer
3 Md. Faisal Bin Mahmud Senior Chemist/Associate Coordinator
4 Md. Kamal Uddin Environmental Engineer
5 Md. Al Mamun Environmental Engineer
6 Md. Khalid Hossain Environmental Engineer
7 Sohel Sarder Sample Collector/Attendant

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4.3 Management of the study

The consultant (AECL) will work under the overall supervision of the Project Director, “Patuakhali 2x660
(2*660) MW Coal Based Super Thermal Power Plant Project” and maintain close liaison with APSCL. The
Concerned Office of Ashuganj Power Station Company Ltd. shall accompany the consultants for the first
time upon addressing with local government authority for the commencement of the consultancy working
environment. The Team Leader is responsible for direct supervision of the study. He will guide the
multidisciplinary team to achieve the goal of the study. Each report and related deliverables shall be
reviewed carefully by the Team Leader and finally shall be checked by the reviewer.

5.0 Reconnaissance of Field Visit

5.1 Objective of the Field Visit

In anticipation of the signing of the Agreement, as part of the inception phase, a reconnaissance field visit
has been made for the proposed site of Patuakhali 2x660 MW Ultra Super Critical Coal Fired Power Plant
Project at Kalapara Upazila, Patuakhali District, Bangladesh.

The purpose of the visit was to inspect the field for understanding the general environmental condition
on which the methodology of the study and analytical testing would be based on. A tentative project map
and study area map has been prepared before visiting the project site. The main objective of this field
program is to physically identify and understand the project area and the specific locations in it, which
were under the baseline survey study in line with environmental perspective.

The objectives can be summarized as follows –

➢ Initial information of the tentative proposed project area;

➢ Visualize the location of project area, approach road and land areas;
➢ Identify & understand the impact areas;
➢ Record the GPS coordinates of the sampling locations and reverify them with the baseline survey
report.

5.2 Team Composition

A multidisciplinary team was selected for the reconnaissance field visit. Lot of ground works have been
conducted like location mapping, sensitive areas demarcation, geophysical settings etc. during the field
visit. Designated personnel of the project authority guided the team and facilitate the study well. The
proposed project is located at Kalapara Upazila, Patuakhali District, Bangladesh. The project land area has
been finalized as 930.615 acres for the proposed power plant. All members of the investigating team

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collectively and individually overviewed the study area. They explored the project area as well as the study
area resting on their arena of expertise. Composition of team members for reconnaissance field visit is
shown Table 7.

Table 7: Composition of Team Members for Reconnaissance Field Visit

Name of Organization Personal Name Role Played in the Projects

Ashuganj Power Station Md. Golam
Executive Engineer
Company Ltd. (APSCL) Rabbani
Ashuganj Power Station Mohammad Ali
Assistant Manager
Company Ltd. (APSCL) (Security)
Adroit Environment Md Al-Amin
Sr. Environment Engineer
Consultants Ltd.
Adroit Environment Md. Faisal Bin
Sr. Chemist
Consultants Ltd. Mahmud
Adroit Environment Md. Kamal Uddin
Jr. Environment Engineer
Consultants Ltd.
Adroit Environment Md. Al-Mamun
Jr. Environment Engineer
Consultants Ltd.

5.3 Field Activities

Two-day field visit was planned for reconnaissance survey to the study area on 2nd ~ 3rd January, 2021.
The site has good communication of water ways and roadways. 30 m width and & 700 m road will be
constructed to facilitate the communication with project site. The field activities have been described
sequentially in Table 3.2 below.

Itinerary of the field program along with the activities performed during the reconnaissance survey has
been as follows.

Table 8: Field Activities of the Project

Date Time Offices/Sites

Visited
2nd December, Morning to Departure at 6:30 AM from APSCL site office at Ashuganj to
2021 (Saturday) Noon designated project site at Kalapara, Patuakhali.

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Date Time Offices/Sites

Visited
The team member of APSCL officials and AECL reached to the
Patuakhali 2x660 MW Ultra Super Critical Coal Fired Power Plant
Project site at 4:20 PM. Later, the team members respectively
Afternoon
performed their jobs to collect relevant information during their
walk to the study site. During field survey APSCL officials were
always with the team.
Evening Departure for Patuakhali at 6:30 PM

Morning Only AECL officials Arrived at site about 8:30 AM

The team investigated and identified possible impact sensitive
3rd December, areas. The proposed areas that were under the baseline survey
2021 (Sunday) Morning study for sampling of the ambient air, noise, surface water, ground
water, soil and sediment was observed & the GPS coordinates were
recorded accordingly.
Noon Left site at 1:00 PM and departure for Dhaka at night.

6.0 Findings of the Field Visit

6.1 Project Location Data

From the Reconnaissance of field visit, preliminary data for monthly environmental monitoring was
collected. GPS reading of different important points was recorded and revirified in accordance with that
of baseline survey study. The land acquisition is in progress already. GPS Coordinates of important
locations are given in Table: 9

Table 9: Area Coordinates of APSCL Patuakhali 2x660 MW Ultra Super Critical Coal Fired
Power Plant Project boundary

Points Latitude Longitude

1. 22° 4'17.43"N 90°17'44.77"E

2. 22° 3'42.80"N 90°17'42.17"E
3. 22° 3'17.73"N 90°17'40.32"E
4. 22° 3'51.94"N 90°18'12.99"E
5. 22° 3'15.06"N 90°19'4.91"E
6. 22° 3'39.46"N 90°19'7.18"
7. 22° 3'38.64"N 90°19'23.66"E
8. 22° 3'23.13"N 90°19'14.03"E
9. 22° 3'9.73"N 90°20'5.26"E
10. 22° 3'29.53"N 90°20'11.61"E
11. 22° 3'41.31"N 90°20'14.45"E
12. 22° 3'44.94"N 90°19'47.55"E
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Figure 2: Location Map of the proposed project with boundary

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6.2 Preliminary Environmental Data

The summers here have a good deal of rainfall, while the winters have very little. The average of
temperature varies from 26-34°C according to Khepupara weather station.

Figure 3: Wind-Rose Diagram of Last 3 Years

Monthly average maximum rainfall occurred in June and monthly average minimum rainfall recorded
during winter season. The rainy season is very prominent in this region. The monthly average relative
humidity near the project area varies seasonally from 74% to 88%. The dominant wind direction in this
area is from west-northwest during the winter period and from south, southwest in summer/monsoon
period. The surrounding Environment of the proposed project area is described below-

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6.2.1 Air Quality

During the site visit it was observed that the air was fresh, smokeless and refreshing. The situation with
respect to air quality in the area is good. We expect the air quality will not be affected much if all mitigation
measures are implemented during construction & operation phases and there is no industry/ factory
around the project site. In compliance with the baseline survey study air quality will be measured in eight
(8) locations during monthly monitoring.

6.2.2 Noise Level

In the rural areas however the noise level is relatively lower than urban areas. It is assumed that in project
areas noise level would be far below the Environmental Quality Standards of Bangladesh. Sound Level
around the project area is low. Noise Level will be measured at fourteen (14) locations for monitoring
study which is similar to the baseline study.

6.2.3 Water Resources

The proposed Project are situated on the western bank of the Rabnabad Channel. Huge quantity of water
will be used in multiple purposes of power plant. Cooling water, plant water, domestic water etc. will be the
major uses of water in the proposed power plant projects. The land area of the project needs to be developed
at a certain level so that the plant area is safe from natural calamities. Two (2) ground waters and three (3)
surface waters will be analyzed on a monthly basis.

6.2.4 Soil Resources

The proposed Project represents mostly agricultural lands. The project is situated on the western bank of
the Rabnabad Channel. As there is no industry or plants nearby and the land is mostly used for growing crops,
the soil shall be of good quality and fertile. Two (2) soil and two (2) sediment samples shall be collected prior
to analysis on a monthly basis.

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Figure 4: Locations of sampling sites around the Project

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Present Site Condition

Figure 5: North-West Side of the Project Figure 6: North-East Side of the Project Figure 7: Near Rehabilitation Area

Figure 8: North-West Side of the Project Figure 9 & 10: Field Team of AECL in the site

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7.0 Methodology

7.1 Introduction

Prior to the start of the construction work, environmental baseline condition (Dry Season) is conducted
accordingly. Baseline survey and sampling shall be carried out in two seasons (dry and wet season or as
required by Client/DoE. The monthly environmental monitoring study shall aim to record the concurrent
environmental condition and compare them with the baseline data to identify any fluctuation in the
concentration of the environment variables. In the event of such event this monthly monitoring report will
aid to deploy proper mitigation measure as per the cEMP.

7.2 Monitoring Plan

Table 10: Environmental Variables, Testing Parameters and Sample Quantity

Sampling
Sl. No. Environmental Items Parameters to be Analyzed
Quantity
1 Ambient Air PM2.5, PM10, SPM, SOx, NOx & CO, 08

2 Ambient Noise Leq Value (Day & Night) 14

pH, DO, TSS, TDS, Oil & Grease, turbidity, EC,
3 Surface Water 03
Lead, Iron, Zinc, Copper, Total Coliforms
4 Ground Water pH, TDS, DO, As, Fe 02

5 Soil pH, salinity, total P, NH4+, As, Pb 02

6 Sediment pH, salinity, total P, NH4+, As, Pb 02

7.3 Sampling Locations and GPS Coordinates

Table 11: Ambient Air Sampling Locations

Sl. Assigned ID Monitoring GPS Coordinates Location Marker in Terms of the
No. Variable Project Area
01. AQ1 Ambient Air 22° 4'7.66"N North-West-East Side
90°17'48.34"E
02. AQ2 Ambient Air 22° 3'23.16"N South-West Side
90°17'43.11"E

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03. AQ3 Ambient Air 22° 3'22.22"N South Side

90°18'40.19"E
04. AQ4 Ambient Air 22° 3'15.38"N South-East Side
90°19'53.32"E
05. AQ5 Ambient Air 22° 3'40.98"N North-East Side
90°19'59.91"E
06. AQ6 Ambient Air 22° 3'43.73"N North Side
90°18'26.24"E
07. AQ7 Ambient Air 22° 4'24.40"N Nearby Rehabilitation Village (1
90°18'6.56"E km)
08. AQ8 Ambient Air 22° 4'33.66"N Nearby Rehabilitation Village (5
90°18'4.44"E km)

Table 12: Ambient Noise Level Monitoring Locations

Sl. Assigned ID Monitoring GPS Coordinates Location Marker in Terms of the
No. Variable Project Area
01. NQ1 Ambient Noise 22° 4'7.66"N North-West-East Side 1
90°17'48.34"E
02. NQ2 Ambient Noise 22° 4'16.87"N North-West-East Side 2
90°17'58.88"E
03. NQ3 Ambient Noise 22° 3'23.16"N South-West Side 1
90°17'43.11"E
04. NQ4 Ambient Noise 22° 3'23.17"N South-West Side 2
90°18'6.90"E
05. NQ5 Ambient Noise 22° 3'22.22"N South Side 1
90°18'40.19"E
06. NQ6 Ambient Noise 22° 3'15.38"N South Side 2
90°19'53.32"E
07. NQ7 Ambient Noise 22° 3'8.45"N South Side 3
90°18'30.52"E
08. NQ8 Ambient Noise 22° 3'17.68"N South Side 4
90°19'10.42"E
09. NQ9 Ambient Noise 22° 3'40.98"N North-East Side 1
90°19'59.91"E
10. NQ10 Ambient Noise 22° 3'39.33"N North-East Side 2
90°19'25.94"E
11. NQ11 Ambient Noise 22° 3'43.73"N Norh Side 1
90°18'26.24"E
12. NQ12 Ambient Noise 22° 3'39.66"N Norh Side 2
90°19'0.35"E
13. NQ13 Ambient Noise 22° 4'24.40"N Nearby Rehabilitation Village (1
90°18'20.45"E km)
14. NQ14 Ambient Noise 22° 4'33.66"N Nearby Rehabilitation Village (5
90°18'4.44"E km)

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Table 13: Surface Water Sampling Locations

Sl. Assigned ID Monitoring GPS Coordinates Local Title/Name
No. Variable
01. SWQ1 Surface Water 22° 3'18.21"N Upstream & Downstream of the
90°20'18.85"E Rabnabad Channel
02. SWQ2 Surface Water 22° 3'42.45"N Local Canal
90°19'21.05"E
03. SWQ3 Surface Water 22° 4'23.15"N Nearest Pond
90°18'8.32"E

Table 14: Ground Water Sampling Locations

Sl. Assigned ID Monitoring GPS Coordinates Local Title/Name
No. Variable
01. GWQ1 Ground Water 22°04'20.56"N Residential Area, Nomorhut
90°18'4.33"E Bazar
02. GWQ2 Ground Water 22° 3'53.01"N Local Settlement
90°18'36.52"E

Table 15: Soil Sampling Locations

Sl. Assigned ID Monitoring GPS Coordinates Local Title/Name
No. Variable
01. SQ1 Soil 22° 3'48.76"N Project Site (West)
90°18'2.69"E
02. SQ2 Soil 22° 3'33.45"N Eastside of the Project Area
90°20'28.37"E

Table 16: Sediment Sampling Locations

Sl. Assigned ID Monitoring GPS Coordinates Local Title/Name
No. Variable
01. SDQ1 Sediment 22° 3'33.45"N Upstream, Rabnabad Channel
90°20'28.37"E
02. SDQ2 Sediment 22° 3'0.62"N Downstream, Rabnabad Channel
90°19'58.23"E

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7.4 Ambient Air Quality Monitoring Methodology

Air pollution is the change in the natural composition of the air we breathe, beyond some defined limits. This
change is induced by releasing harmful substances into the atmosphere and it causes damage to our health
and environment. Natural sources of air pollution include sea spray, volcanic activity, forest fire, and dust
storms. Anthropogenic sources include motor vehicles, industrial production processes, and power generation.

7.4.1 Sampling Procedure

Particulate monitoring is accomplished with Respirable Dust sampler, which is a vacuum type device that
draws air with particulate matter through a filter paper. Particles within the range of 100 to 0.1 microns’
diameter are ordinarily collected on glass fiber filter. The instrument sucks the ambient air with a blower at a
flow rate that allows suspended particles to pass to the filter surface. This sampling filter paper is dried up in
the laboratory and the weight difference is the amount of PM10 or PM2. 5, content measured in micro grams per
cubic meter of air collected over a period of 24 hours.

7.4.2 Equipment Used

The APM 460 sampler uses an improved cyclone with sharper cutoff (D50 at 10 microns) to separate the
coarser particulates from the air stream before filtering it on the glass microfibre filter. By using the APM 460,
measurement of Respirable Particulate Matter can be done accurately and TSPM can also be assessed by
collection of dust retained in the cyclone cup.

Figure 11: APM 460 sampler

APM 460 BL comes with an in-built voltage stabilizer to compensate for voltage fluctuations. This model has
been made more user-friendly by providing a lighting arrangement for night operation, tool box within the
instrument, softer handles, lockable top-cover and wheels for easy transportation. The cabinet design has also

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been improved to prevent entry of rain water and dust into the machine. Owing to its modular design, APM
460 BL can be easily paired with a gaseous sampling attachment (for monitoring SO2, NOx, NH3, Ozone etc.)
as gaseous sampling requires only a few LPM of air flow.

Figure 12: AAS 127 Mini

The AAS 127 system is a manual method for sampling fine particles (PM2.5 fraction) and is based on impactor
designs standardized by USEPA for ambient air quality monitoring. Ambient air enters the sampler system
through an omni-directional inlet designed to provide a clean aerodynamic cut-point for particles greater than
10 microns. Particles in the air stream finer than 10 microns proceed to a second impactor that has an
aerodynamic cut-point at 2.5 microns. The air sample and fine particulates exiting from the PM 2.5 impactor
are passed through a 47 mm diameter Teflon filter membrane that retains the fine particulate matter. The
sampling rate of the system is held constant at 1 m3/hr by a suitable critical orifice. The standard system is
supplied with a Dry Gas Meter to provide a direct measure of the total air volume sampled. Owing to its
modular design, APM 550 can be easily paired with a gaseous sampling attachment (for monitoring SO2, NOx,
NH3, Ozone etc.) as gaseous sampling requires only a few LPM of air flow.

7.4.3 Analysis Procedure

Principle of West Gaeke Method is based on the absorption and stabilization of SO2 from air by a solution of
Sodium tetrachloromercurate II to form the dichlorosulfitomercurate II complex. Quantitative determination
is accomplished by adding acid bleached parasonaline HCl and formaldehyde to the sulfite complex and
measuring the color intensity by a UV Spectrophotometer.

Principle of Jacobs-Hochheiser Method refers to Ambient NO2 is collected by bubbling Air through a solution
of Sodium Hydroxide and Sodium Arsenite. The concentration of Nitrite ion produce during sampling is
determined colorimetrically by reacting the Nitrite ion with Hydrogen Peroxide, Sulphanilamide, NEDA (N-(1-

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Naphthyl) Ethylenediamine di-hydrochoride) and measuring the Absorbance of highly colored azo dye at 540
nm.

7.5 Ambient Noise Level Monitoring

Noise quality will be measured instantly on the site by Wensn WS 1361C Digital Sound Level Meter. At each
location 2 minutes’ interval reading was taken for both day and night. At the time of measurement, whenever
there is an interfering effect like mike noise, human voice from house and bazaar, vehicular sound, sound of
machine and tool from workshop etc. are also recorded.

7.5.1 Monitoring procedure of noise level

Noise quality has been measured instantly on the site by Noise level meter. At each location multiple readings
were taken over a short period of time (both night & day) to calculate the L eq value. Two measurements such
as maximum & minimum modes were recorded. At the time of measurement, whenever there was an
interfering effect like mike noise, human voice, vehicular sound, sound of machine and tool from workshop
etc., were also recorded.

Table 17: Instrument Specification (Noise Meter)

Design Standards IEC651 TYPE 2; ANSI S1.4 TYPE 2

Measuring Range 30~130 dBA or 35~130 dBC
Frequency Weighting A and C
Time Weighting Fast & Slow
Linearity Weighting 50 dB
Resolution 0.1 dB
Sample rate 2 times/second

7.6 Methodology for Water Quality Analysis

7.6.1 Sampling Principle

The procedures described are to be used by field personnel when collecting and handling water samples in the
field. On the occasion that field personnel determine that any of the procedures described in this section are
either inappropriate, inadequate or impractical and that another procedure must be used to obtain a water
sample, the variant procedure will be documented in the field logbook, along with a description of the
circumstances requiring its use. Prepare a Sampling and Analysis Plan (SAP) which describes the sampling
locations, numbers and types of samples to be collected, and the quality control requirements of the assigned
project.

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7.6.2 Equipment

1) Plastic Bottle 2) Gloves 3) Niskin sampler 4) Icebox

Figure 13: Niskin Sampler

7.6.3 Sampling Criteria

1. Collect samples in an area free of excessive dust, rain or other sources of contamination. In case of
surface water if needed clean the surface of water body while sampling at low depth.
2. Store samples in a secure location to preclude conditions which could cause contamination. Samples
shall be custody sealed during long-term storage or shipment.
3. Collected samples are in the custody of the sampler or sample custodian until the samples are
relinquished to another party.
4. Documentation of field sampling is done in a bound logbook.
5. Always wear gloves while sampling.
6. Always collect cold water; never sample hot water.
7. Do not touch the inside of the sample bottle or its cap.

7.6.4 Analysis Principle

APHA Standard methods for the examination of water and waste water, 21st edition American Public Health
Association, Washington, DC. The first edition of Standard Methods was published in 1905. Since then it has
been considered to be the best available guidance of water analysts, which covers all aspects of water and
wastewater analysis techniques and categorizes the analytical methods based on the constituent and not on
the type of water. Since the Twenty-First Edition, all existing, revised and new methods are available online
(www.standardmethods.org). The recently published Twenty-Second Edition contains 87 EPA-approved
methods, 233 revised methods and 14 new methods described in ten chapters divided in sections.

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Atomic absorption spectrometry (AAS) technique uses basically the principle that free atoms (gas) generated
in an atomizer can absorb radiation at specific frequency. The sample is vaporized and the element of interest
atomized at high temperatures. The element concentration is determined based on the attenuation or
absorption by the analyte atoms, of a characteristic wavelength emitted from a light source. The light source
is typically a hollow cathode lamp containing the element to be measured. Separate lamps are needed for each
element. The detector is usually a photomultiplier tube. A monochromator is used to separate the element line
and the light source is modulated to reduce the amount of unwanted radiation reaching the detector.

Potentiometry is one of the methods of electroanalytical chemistry. It is usually employed to find the
concentration of a solute in solution. Potentiometric titration is a technique similar to direct titration of a redox
reaction. It is a useful means of characterizing an acid. No indicator is used; instead the potential is measured
across the analyte, typically an electrolyte solution.

UV spectroscopy obeys the Beer-Lambert law, which states that: when a beam of monochromatic light is
passed through a solution of an absorbing substance, the rate of decrease of intensity of radiation with
thickness of the absorbing solution is proportional to the incident radiation as well as the concentration of the
solution. The expression of Beer-Lambert law is-
A = log (I0/I) = Ecl

Digital Dissolved Oxygen Meter contains a polarographic type probe with an incorporated temperature sensor
which serves for precise Dissolved Oxygen (DO) and Temperature measurement.

The Digital pH Meter is a useful instrument that is meant to measure the pH value of both acidic and alkaline
water.

TDS-3 is an ideal meter (tool) that can be used for any application; Ranging from water purification, to
hydroponics to industrial waste water treatment.

7.7 Soil and Sediment Quality Monitoring

7.7.1 Principle

Collection of large number of samples is recommended so that sample of desired size can be obtained by sub-
sampling. For soil quality analysis work, samples are collected from a soil profile representative to the soil of
the marked/affected area. Consultant will decide & monitor the sampling location, number of samples to be
taken & the frequency of sampling. In case of sediment, clear surface water bodies shall be given priority.
Multiple sampling shall be done prior to homogenization of the sample.

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7.7.2 Material/Equipment

• Auger (post hole type)

• Young Grab Sampler
• Hand spade
• Bucket
• Sampling bags

Figure 14: Post Auger Figure 15: Grab Sampler

7.7.3 Essential measures

1. Sampling at several locations in a zig-zag pattern ensures homogeneity.

2. Fields or water bodies, which are similar in appearance, production and past-management practices,
can be grouped into a single sampling unit.
3. Collect separate samples from fields that differ in color, slope, drainage, past management practices
like liming, gypsum application, fertilization, cropping system etc.
4. In case of soil sampling, avoid sampling in dead furrows, wet spots, areas near main bund, trees, and
manure heaps and irrigation channels.
5. Collect samples at minimum 15 cm depth for soil & 6 cm for sediment. Consultants may advice to
collect sample at various depth depending on the affected area.
6. Always collect the soil sample in the presence of specialist/consultant.

7.7.4 Analysis Principle

APHA Standard methods for the examination of soil & sediment is considered to be the best available guidance
for analysis, which covers all the necessary aspects, techniques and it certainly is EPA approved.

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Inductively coupled plasma mass spectrometry (ICP-MS) is an analytical technique that can be used to measure
elements at trace levels in biological samples. Atomic elements are lead through a plasma source where they
become ionized. Then, these ions are sorted on account of their mass. The ion source, ICP is an ideal ionization
source for mass spectrometry, and can ionize over 90% of many elements. Ions produced in the ICP are led
through the sampling interface to the mass analysis unit. The sampling interface unit consists of two metallic
cones, the sampling cone (orifice radius about 0.5 to 1mm) and the skimmer cone (orifice radius about 0.5 to
1mm), and a rotary gear pump ventilates between the two into several hundred Pa condition. The path of the
ions pulled through by the sampling cone and the skimmer cone converge into the mass spectrophotometer
through the ion lens. The ion lens and the mass spectrophotometer unit are ventilated to 10-3 and 10-4 Pa
respectively, by the turbo molecular pump. The ions sorted by mass with the mass spectrophotometer are
detected by the ion detector.

Colorimetry refers to the technique where the absorption takes place in the visible region and the substance is
colored, which leads to the measurement of the quantity of the absorbing material present done by
comparison with known color standards. The process of determining the absorption of radiant energy by a
substance in solution relative to that by its solvent in the ultraviolet or infrared regions is usually referred to as
ultraviolet or infrared spectrophotometry respectively. The measurements may be made qualitatively to
determine the nature of the absorbing material or quantitatively for estimating the amount present in the
given preparation.

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8.0 Work Schedule

Patuakhali 1320 (660*2) MW Coal Based Super Thermal Power Plant Project
Month
1 2 3 4 5 6 7 8 9 10 11 12
2020 2021
Monthly Environmental Monitoring

November
September
December

December
February
January

October
March

August
April

May

June

July
Activity
1 Work Worder Issued
2 Kick off meeting
3 Initial site visit
4 Preparation of Inception Report
5 Submission of Inception Report
6 Mobilization of team for Environmental Monitioring
7 Preparation & Submission of Monthly Environmental Monitoring Report
8 Mobilization of team for Environmental Monitioring
9 Preparation & Submission of Monthly Environmental Monitoring Report
10 Mobilization of team for Environmental Monitioring
11 Preparation & Submission of Monthly Environmental Monitoring Report
12 Submission of 1st Quarterly Environmental Progress report
13 Mobilization of team for Environmental Monitioring
14 Preparation & Submission of Monthly Environmental Monitoring Report
15 Mobilization of team for Environmental Monitioring
16 Preparation & Submission of Monthly Environmental Monitoring Report

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Patuakhali 1320 (660*2) MW Coal Based Super Thermal Power Plant Project
Month
1 2 3 4 5 6 7 8 9 10 11 12

2020 2021
Monthly Environmental Monitoring

November
September
December

December
February
January

October
March

August
April

May

June

July
22 Mobilization of team for Environmental Monitioring
23 Preparation & Submission of Monthly Environmental Monitoring Report
24 Mobilization of team for Environmental Monitioring
25 Preparation & Submission of Monthly Environmental Monitoring Report
26 Submission of 3rd Quarterly Environmental Progress report
27 Mobilization of team for Environmental Monitioring
28 Preparation & Submission of Monthly Environmental Monitoring Report
29 Mobilization of team for Environmental Monitioring
30 Preparation & Submission of Monthly Environmental Monitoring Report
31 Mobilization of team for Environmental Monitioring
32 Preparation & Submission of Monthly Environmental Monitoring Report
Submission of 4th Quarterly Environmental Progress report and Draft Environmental Monitoring
33
Compliance report
34 Final Environmental Monitoring Compliance report and DoE Clearance

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9.0 Current & Future Activities to be Performed

➢ Submission of inception Report.

➢ Submission of Monthly Environmental Monitoring Report.
➢ Submission of Quarterly Environmental Progress Report.
➢ Submission of Draft Environmental Monitoring Compliance Report.
➢ Submission of Final Environmental Monitoring Compliance Report.

10.0 Conclusion

The Inception Report has been prepared as the deliverable in reference to the Monthly Environmental
Monitoring activities of Patuakhali 2x660 MW Ultra Super Critical Coal Fired Power Plant Project at
Kalapara Upazila, Patuakhali District, Bangladesh. The proponent of this project is Ashuganj Power
Station Company Ltd., Ministry of Power, Energy and Mineral Resources (MoPEMR), Government of
Bangladesh. The core objective of the study is to setup an overlay for the monthly environmental
monitoring of the corresponding environmental variables.

Two-day field visit was planned for reconnaissance survey to the study area from 2nd January to 3rd
January, 2021. The team member of AECL visited the site thoroughly, collected information regarding
physical environment, identified sampling location sites, recorded GPS coordinates and planned heir
monitoring strategy which will be on for a monthly basis.

This particular inception report upon submission, marks the initiation of monthly environmental
monitoring of the site followed by submission of monthly report, quarterly progress report, draft
compliance report and the final environmental monitoring compliance report.

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11.0 References

1. Munn, R.E. (1979), "Environmental Impact Assessment: Principal and Procedures." Jhon Wiley &
Sons
2. Canter, G. T. (1983), “Environmental Impact Assessment Handbook”. McGraw Hill, England
3. A.K De (1989), “Environmental Chemistry”, Wiley Eastern Ltd., New Delhi, India.
4. GOB, (1992), “Bangladesh Environmental Policy”.
5. GOB, (1995), “National Environmental Management Action Plan (NEMAP)”.
6. S.S Dara (1995), “Environmental Chemistry and Pollution Control”, S. Chand & Company Ltd., New
Delhi, India.
7. DOE (1995) "Environmental Conservation Act", Department of Environment, Govt. of Bangladesh.

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