Final EIA Drilling Kadanwari Block

ENVIRONMENTAL IMPACT ASSESSMENT (EIA)
Development Well Drilling and

Associated Activities in Kadanwari
Block 2768-13, Sindh
June 2022
Doc. No.: Eni/EIA/01
EMC PAKISTAN PVT. LTD.

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REVISION
Rev. Date Issue, Modification Prepared Checked Approved

A 20.03.2022 1st Draft EMC Study Team Muhammad Nadeem Arif
Haseeb
B 18.05.2022 2nd Draft EMC Study Team Muhammad Nadeem Arif
Haseeb
C 31.05.2022 3rd Draft EMC Study Team Muhammad Nadeem Arif
Haseeb
D 03.06.2022 Final Report EMC Study Team Muhammad Nadeem Arif
Haseeb
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accordance with the instructions of Eni Pakistan Limited for their sole and specific use. Any
other persons who use any information contained herein do so at their own risk. This report
cannot be used in the court of law for any negotiation or standardization.
© EMC Pakistan Pvt. Ltd. 2022

Environmental Impact Assessment (EIA)
Development Well Drilling and Associated Activities in Kadanwari Block 2768-13
Doc. No.: Eni/EIA/01 Rev.: D Executive Summary
Executive Summary
Eni Pakistan plans to drill 05 Development wells in the Kadanwari Block located inside the
protected Nara Desert Wildlife Sanctuary (see figure ES2). Kadanwari Block has been
awarded to Eni Pakistan by Government of Pakistan for carrying out oil and gas exploration
activities. Kadanwari block is located in districts Khairpur and Sukkur. Since the proposed
activities are inside the notified protected areas i.e., Nara Wildlife Sanctuary, therefore, an
Environmental Impact Assessment (EIA) study has been conducted and its findings have been
presented in this report.
The main objective of the EIA is to study, in detail, the project area in accordance with the
requirements of section 17 of Sindh Environmental Protection Act, 2014. This project EIA
report is aimed at identifying potential impacts of the proposed well drilling activities on the
sensitive receptors and recommend mitigation measures to eliminate or reduce those potential
impacts to acceptable level. The methodology adopted include review of available literature,
site visits to the project area and the surrounding area, meetings and consultations with local
stakeholders, meetings and consultation with the relevant institutions, discussion with relevant
experts and environmental practitioners and the application of professional knowledge and
experience.
The project scope includes drilling of 05 development wells, construction of access tracks,
construction of campsite and laying of flow line (in case oil/gas discovery is made) inside the
Nara Wildlife Sanctuary. A development well is drilled in a proven producing area to increase
the yield.
The existing natural and socioeconomic environments of the project area have been studied
in detail and the report covers the area's physical and biological resources, including
geomorphology, water resources, climate and air quality, vegetation, wildlife and wildlife
habitat.
Description of the socioeconomic environment includes details of the area's population and
households, education, health, gender issues, water supply, agriculture, transport and
communications, and occupations and income.
Figure ES1: Field Survey Activities
Potential impacts of well drilling and its associated activities on the physical, biological,
ecological environment of the project area and socio-economic and cultural environment of
area have been assessed through this study and mitigation measures have been proposed
which shall be adopted to alleviate the impacts on the environment.
The Environmental Impact Assessment study ensures that:
 All aspects of the existing project area are examined and data is collected to form a
comprehensive environmental and socioeconomic baseline.
 All major and minor positive or negative impacts on the environment (physical, social and
ecological) during the different stages of project are identified.
 A list of mitigation measures covering all possible impacts is included along with their
implementation procedures and guidelines.
 A detailed Environmental Management Plan (EMP) is provided for sustainable operation

of the project and forms an essential part of the EIA document.
For the effective implementation and management of mitigation measures, an Environmental

Management Plan (EMP) has been prepared which complies the requirements of Sindh
Environmental Protection Act 2014.
The EMP provides mitigation measures to address potential impacts of project activities, to
enhance project benefits and to introduce standards of best practice in all project activities. It
defines the legislative requirements, guidelines and best industry practices. Furthermore, it
formulates roles and responsibilities of the project proponent in terms of safeguarding the
environmental and social well-being of the area and its inhabitants.
The EIA concludes that the proposed operation will not lead to significant adverse
environmental impacts and careful implementation of the EMP will ensure that potential
impacts are managed and minimized and Eni Pakistan will comply all statutory requirements.
Figure ES2: Proposed Well sites and Kadanwari Block location map
Environmental Aspect Register
The EIA provides identification of environmental aspects and evaluation of the impacts associated with the proposed drilling and associated
activities. The register identifies the potential impacts of project activities on various environmental resources.
Table ES1: Environmental Aspect Register

No. Environmental Description of Impact Areas of Environmental Impact Assessment of Management Program
Aspect Significance
People/amenity/ heritage/
cultural//archaeological
Likelihood/ Frequency
Flora & Fauna
Consequence
Significance
Water
Land
1. Equipment & Dust and vehicular Air L L L ▪ Regulate and monitor vehicle speeds
crew Emissions ▪ Maintain vehicles in a good condition
mobilization/ ▪ Prohibit off-road travel
demobilization Noise and vibration L L L ▪ Minimize use of horns by project vehicles
▪ The use of pressure horns will not be allowed
Safety hazards M L M ▪ Drivers should be trained for safe driving
practices
▪ Night traveling will be strictly prohibited and
will only be allowed in case of emergency
2. Construction/ Soil erosion L M M ▪ Minimize use of dust track
improvement of ▪ paved access tracks should be used for
access tracks transportation
▪ Maintain photographic records of all activities
to monitor any changes and soil conditions
▪ Train drivers on mitigation measures related
to off-road travel and speeds limits

Aspect Significance
Flora & Fauna
Consequence
Significance
Water
Land
Air
▪ Prohibit off-road travel
Soil & Water Contamination M M M ▪ Vehicles will be checked for fuel or oil leaks
▪ Fuel and oil transfer operations will be done
using a dedicated fuel vehicle
▪ Drip pans will be used to avoid drips and spills
Noise & Vibration L M L ▪ Minimize use of horns by project vehicles
▪ Use of pressure horns will be avoided
▪ Properly maintain vehicles and construction
equipment
Dust and Vehicular Emission L M L ▪ Regulate and monitor vehicle speeds
▪ Minimize dust emissions by employing good
management practices
▪ Strictly prohibit off-road travel
Loss of Vegetation or Habitats L M L ▪ Minimize total land uptake by access roads
▪ Minimize vegetation clearance
▪ Prohibit use of local vegetation as fuel
▪ Minimize preparation of new access tracks
▪ Width of new tracks should not exceed 8 m
▪ Avoid clearing of trees by selecting routes that
require least vegetation removal

Aspect Significance
Flora & Fauna
Consequence
Significance
Water
Land
Air
Safety hazards M M M ▪ Train the drivers on mitigation measures
related to off-road travel and speeds limits
▪ Comply with all EIA mitigation related to
waste, noise and dust emissions
▪ Repair any damage caused by project
activities to local infrastructure
▪ Observe strict compliance with Eni Pakistan’s
HSE guidelines
Disturbance to wildlife M L M ▪ Minimize preparation of new access tracks
▪ Prohibit hunting or poaching of wildlife
▪ Select routes with minimum vegetation
clearing
▪ Avoid dense patches of vegetation
▪ Maintain construction vehicles and equipment
in good condition
▪ Area of operation should be fenced to prevent
animal entry
▪ open dumping of waste should be strictly
prohibited to avoid hazard to animals
3. Camp(s) Soil erosion / L L L ▪ Minimize vegetation clearing
construction / Physical scarring ▪ Avoid cutting of trees

Aspect Significance
Flora & Fauna
Consequence
Significance
Water
Land
Air
establishment ▪ Locate camp site in existing clearings and on
operation leveled land
▪ Minimize total land uptake by the camps
to monitor any changes in soil conditions
Safety hazards M M M ▪ Sensitize drivers on mitigation measures
▪ Local sources of drinking water will be used
only after complying with relevant
requirements of the EIA,
HSE guidelines
▪ Project staff to respect all cultural norms
▪ Provide offsets will from sites of religious,
cultural or archaeological significance
Disturbance to wildlife L L L ▪ Prohibit hunting or harassment of wildlife
▪ Select land for establishing camp where
minimum land clearance is required

Aspect Significance
Flora & Fauna
Consequence
Significance
Water
Land
Air
clearing
Soil / Water L M L ▪ Dispose sewage generated at the campsite in
contamination septic systems comprising septic tanks and
soak pits
▪ Dispose wastewater from laundry, kitchen
washings, and showers into separate soak
pits
▪ Build soak pits in absorbent soil
▪ Keep septic systems at minimum distances of
300 m from surface water sources
▪ Design and construct soak pits to prevent
surface run-off
▪ Design soak pits to accommodate wastewater
generated during the total duration of the
operation
▪ Solid wastes at the campsite will be disposed
of in waste bins
▪ Wash vehicles in designated areas within
campsite and route the wastewater to pits

Aspect Significance
Flora & Fauna
Consequence
Significance
Water
Land
Air
▪ Regularly check vehicles for fuel or oil leaks
▪ All fuel and oil storage areas will have
secondary containment that can be in the
form of a concrete pad underneath to prevent
soil contamination in case of leaks or spills
▪ All fuel tanks will be properly marked to
highlight their contents
▪ Ensure provisions for proper fuel and oil
storage and handling
Dust / exhaust L M L ▪ Maintain vehicles and equipment in good
Emissions condition
▪ Select campsite locations at least 500 m
away from communities
▪ Employ good management practice to
minimize dust emissions
Noise and vibration L L L ▪ Ensure that generators, vehicles and other
potentially noisy equipment are in good
condition
▪ Minimize use of horns by project vehicles
▪ Use of pressure horns will not be allowed

Aspect Significance
Flora & Fauna
Consequence
Significance
Water
Land
Air
▪ Restrict all project vehicles and personnel
within work areas
Resource depletion L M M ▪ Adopt water conservation measures
▪ Keep complete record of water consumption
during project
4. Clearing and Soil erosion / M M M ▪ Minimize vegetation clearance
leveling Physical scarring ▪ Maintain photographic records of all activities
▪ Minimize disturbance to natural topography /
soils
▪ Regulate and monitor vehicle speeds
▪ Train the drivers on mitigation measures
Soil contamination L L L ▪ Prohibit solid waste disposal in the field
▪ Regularly check vehicle for fuel or oil leaks
▪ Use a dedicated fuel vehicle for fuel and oil
transfer operation
▪ Use Drip pans to avoid drips and spills
▪ The soil contaminated from minor and
moderate spills will be removed
Noise and vibration L M L ▪ Minimize use of horns by project vehicles

Aspect Significance
Flora & Fauna
Consequence
Significance
Water
Land
Air
▪ The use of pressure horns will be avoided
Dust/exhaust L M L ▪ Maintain vehicles in good condition
Emissions ▪ Dust emissions during land clearance
activities will be minimized by good
Loss of vegetation M M M ▪ Minimize clearing of vegetation
▪ Prohibit use of local vegetation as fuel by
crew personnel
▪ Avoid clearing of trees
Disturbance to M M M ▪ Prohibit hunting or poaching of wildlife
Wildlife ▪ Minimize vegetation clearing and land uptake
▪ Avoid clearing of dense patches of vegetation
▪ Food wastes will not be left in the open
▪ Maintain vehicles in good condition to reduce
noise
activities local infrastructure

Aspect Significance
Flora & Fauna
Consequence
Significance
Water
Land
Air
▪ Observe strict compliance with Eni Pakistan
HSE guidelines
5. Drilling activity Safety hazards and L L L ▪ Train drivers on mitigation measures related
disturbance to communities to off-road travel and speeds limits
activities to canals, watercourses, local roads
or other infrastructure
HSE guidelines
Disturbance to wildlife L M L ▪ Prohibit hunting or poaching of wildlife
▪ Avoid disturbance to live bird nests, reptile
and small mammal holes during project
activities
▪ A minimum distance of 50 m to be maintained
from surface water bodies
▪ Maintain compressors and vehicles in good
condition
▪ Minimize the use of horns by project vehicles
Noise and vibration ▪ Minimize the use of horns by project vehicles

Aspect Significance
Flora & Fauna
Consequence
Significance
Water
Land
Air
▪ Restrict movement of all project vehicles and
personnel within work areas
Dust/exhaust Emissions L M L ▪ Maintain vehicles in good condition
▪ Minimize dust emissions by good
▪ Regulate vehicle speeds
Soil contamination M M M ▪ No solid waste will be disposed of in the field
▪ Regularly check vehicle for fuel and oil leaks
▪ Use dedicated vehicle for fuel and oil transfer
Loss of vegetation L L L ▪ Avoid cutting of trees
▪ Prohibit use of vegetation as fuel
▪ Contain crew personnel within work areas
Resource depletion M M M ▪ Prohibit use of water from surface water
resources
▪ Employ diligent water conservation measures
▪ Keep complete records of water consumption
during project

Aspect Significance
Flora & Fauna
Consequence
Significance
Water
Land
Air
Soil erosion / Physical scarring L M L ▪ Maintain photographic records of all activities
6. Waste Air, soil & Water contamination M M M ▪ Implementation of waste management plan
management ▪ Monitoring of implementation of waste
management plan.
Doc. No.: Eni/EIA/01 Rev.: D Table of Contents
Contents
Chapter 1 Introduction .................................................................................................... 1
1.1. Brief Description of the project ................................................................................ 1
1.2. Project Proponent ................................................................................................... 1
1.3. Environmental Consultant ....................................................................................... 1
1.4. Eni Pakistan - The Proponent ................................................................................. 3
1.5. Scope and Objectives of EIA .................................................................................. 3
1.6. Project Categorization............................................................................................. 4
1.7. EIA Methodology .................................................................................................... 5
1.7.1. Collection and Review of Project activities ....................................................... 5
1.7.2. Review of Applicable Legislations and Guidelines ........................................... 6
1.7.3. Secondary Data Collection............................................................................... 6
1.7.4. Field Data Collection ........................................................................................ 6
1.7.5. Impact Identification and Assessment .............................................................. 7
1.7.6. Recommendations to Mitigate Impacts ............................................................ 7
1.7.7. Framework of Environmental Management Plan (EMP) ................................... 7
1.7.8. Reporting ......................................................................................................... 7
1.8. Composition of this Report ...................................................................................... 7
1.9. EIA Study Team ...................................................................................................... 8
Chapter 2 Policy, Legal and Administrative Framework .............................................. 9
2.1. Introduction ............................................................................................................. 9
2.2. Eni Pakistan HSE Policy ......................................................................................... 9
2.3. Institutional Setup for Environmental Management ............................................... 10
2.4. Administrative Framework..................................................................................... 10
2.5. National Environmental Assessment Guidelines ................................................... 11
2.5.1. Pakistan Environmental Assessment Procedures .......................................... 11
2.6. National Laws, Policies and Regulations............................................................... 13
2.6.1. National Conservation Strategy ..................................................................... 13
2.6.2. National Environmental Policy, 2005 .............................................................. 13
2.6.3. The Biodiversity Action Plan .......................................................................... 13
2.6.4. Antiquities Act, 1975 ...................................................................................... 14
2.6.5. The Forest Act, 1927 ..................................................................................... 14
2.6.6. Pakistan Penal Code, 1860............................................................................ 14
2.6.7. The Land Acquisition Act, 1894 ..................................................................... 15
2.6.8. Pakistan Climate Change Act, 2016............................................................... 15
2.6.9. Guidelines for Sensitive and Critical Areas .................................................... 16

2.7. National Legislation on Oil and Gas Exploration and Production ........................... 16
2.7.1. The Regulation of Mines and Oilfields and Mineral Development (Government
Control) Act, 1978 ........................................................................................................ 16
2.7.2. The Model Petroleum Concession Agreement, 2013 ..................................... 16
2.7.3. The Pakistan Onshore Petroleum (Exploration & Production) Rules, 2013 .... 17
2.7.4. The Oil and Gas (Safety in Drilling and Production) Regulations, 1974 .......... 17
2.7.5. Petroleum Exploration and Production Policy, 2012 ....................................... 18
2.7.6. Sectoral Guidelines for Environmental Reports – Oil and Gas Exploration and
Production.................................................................................................................... 18
2.8. Statutory Framework............................................................................................. 18
2.8.1. Sindh Environmental Protection Act, 2014 ..................................................... 19
2.8.2. Sindh EPA (Environmental Assessment) Regulations, 2021 .......................... 20
2.8.3. Sindh Environmental Quality Standards (SEQS)............................................ 22
2.8.4. Self-Monitoring & Reporting Rules, 2014 ....................................................... 22
2.8.5. Sindh wildlife Protection, Preservation, conservation and Management Act, 2020
22
2.8.6. The Forest Act (Sindh Amendment) Act, 1994 ............................................... 24
2.8.7. The Sindh Cultural Heritage (Preservation) Act, 1994 .................................... 24
2.8.8. Hazardous Substance Rule, 2014.................................................................. 24
2.9. International Treaties and Guidelines .................................................................... 25
2.9.1. The Convention on Biological Diversity .......................................................... 25
2.9.2. The Convention on Conservation of Migratory Species of Wild Animals, 1979
26
2.9.3. Convention on International Trade in Endangered Species of Wild Fauna and
Flora (CITES) ............................................................................................................... 27
2.9.4. IUCN Red List ................................................................................................ 27
2.10. Other Relevant Laws and Policies ..................................................................... 28
2.10.1. Oil and Gas Regulatory Authority Ordinance, 2002 .................................... 28
2.11. International Environmental Guidelines ............................................................. 28
2.11.1. World Bank Guidelines on Environment ..................................................... 28
2.11.2. IFC Environmental, Health, and Safety Guidelines for Onshore Oil and Gas
Development................................................................................................................ 28
Chapter 3 Project Description ...................................................................................... 30
3.1. The Project ........................................................................................................... 30
3.2. Project Need ......................................................................................................... 30
3.3. Project objectives .................................................................................................. 32
3.4. Drilling Operation .................................................................................................. 32

3.4.1. Proposed Project Activities. ........................................................................... 32
3.4.2. Schedule........................................................................................................ 34
3.4.3. Drilling Activities ............................................................................................. 34
3.4.4. Demobilization and Site Restoration .............................................................. 40
3.4.5. General requirements for drilling activities ..................................................... 40
3.4.6. Staffing & Supplies ........................................................................................ 41
3.5. Flow lines Installation ............................................................................................ 41
3.5.1. Construction standards .................................................................................. 41
3.5.2. Typical details of Flow Line Laying activities .................................................. 41
3.6. Noise, Air Emissions, Effluents and Solid Waste Generation ................................ 43
3.6.1. Noise ............................................................................................................. 43
3.6.2. Emissions ...................................................................................................... 43
3.6.3. Effluents and Solid Waste .............................................................................. 44
3.6.4. Wastewater Management .............................................................................. 45
3.7. Project alternatives ............................................................................................... 46
3.7.1. Introduction .................................................................................................... 46
3.7.2. Management Options..................................................................................... 46
3.7.3. Technology Options ....................................................................................... 46
3.7.4. Conclusion ..................................................................................................... 48
3.8. Land-Use .............................................................................................................. 48
Chapter 4 Environmental Baseline .............................................................................. 50
4.1. General ................................................................................................................. 50
4.1.1. The Aim of Baseline Study ............................................................................. 50
4.1.2. Methodology .................................................................................................. 50
4.2. Physical Environment ........................................................................................... 50
4.2.1. Geographical location .................................................................................... 50
4.3. Micro environment ................................................................................................ 52
4.4. Macro environment ............................................................................................... 53
4.4.1. Physiography ................................................................................................. 53
4.4.2. Geology and Topography .............................................................................. 54
4.4.3. Soil Morphology ............................................................................................. 56
4.5. Protected areas .................................................................................................... 56
4.5.1. Nara Desert Wildlife Sanctuary ...................................................................... 56
4.5.2. Nara Canal Game Reserve ............................................................................ 57
4.6. Climate ................................................................................................................. 57
4.6.1. Temperature .................................................................................................. 58

4.6.2. Rainfall........................................................................................................... 58
4.6.3. Humidity......................................................................................................... 59
4.6.4. Wind .............................................................................................................. 59
4.7. Seismicity ............................................................................................................. 60
4.7.1. Surjan Fault ................................................................................................... 61
4.7.2. Pab Fault ....................................................................................................... 62
4.7.3. Hub Fault ....................................................................................................... 62
4.7.4. Rann of Kutch Fault ....................................................................................... 62
4.8. Ambient Air Quality & Noise .................................................................................. 62
4.9. Water Resources & Quality ................................................................................... 65
4.9.1. Surface Water ................................................................................................ 65
4.9.2. Ground Water ................................................................................................ 66
4.9.3. Water Quality ................................................................................................. 67
4.10. Ecological Environment ..................................................................................... 70
4.10.1. Well Site 1 .................................................................................................. 73
4.10.2. Well Site 2 .................................................................................................. 73
4.10.3. Well Site 3 .................................................................................................. 73
4.10.4. Well Site 4 .................................................................................................. 74
4.10.5. Well Site 5 .................................................................................................. 74
4.10.6. Overall Summary of Ecological Survey....................................................... 75
4.10.7. Nara Desert Wildlife Sanctuary................................................................... 75
4.10.8. Vegetation Recorded in the project area .................................................... 77
4.10.9. Threats ....................................................................................................... 78
4.10.10. Importance of Protected Areas in the Project Area ..................................... 79
4.10.11. Conclusion ................................................................................................. 79
Chapter 5 Social Baseline ............................................................................................ 84
5.1. Macro Environmental ............................................................................................ 84
5.1.1. Demographic Profile- Khairpur ....................................................................... 84
5.1.2. HISTORY & CULTURE .................................................................................. 85
5.1.3. Housing ......................................................................................................... 86
5.1.4. Utilities ........................................................................................................... 86
5.1.5. Health ............................................................................................................ 87
5.1.6. Education....................................................................................................... 89
5.1.7. MPI (Multi-Dimensional Poverty Index) .......................................................... 90
5.1.8. Economic Profile ............................................................................................ 90
5.2. Microenvironmental............................................................................................... 92
5.2.1. Community Profile ......................................................................................... 92
5.2.2. Education....................................................................................................... 92
5.2.3. Health ............................................................................................................ 92
5.2.4. Livelihood ...................................................................................................... 92
5.2.5. Source of Drinking Water ............................................................................... 93
5.2.6. Utilities ........................................................................................................... 93
Chapter 6 Stakeholder Consultation............................................................................ 94
6.1. Public Consultation in EIA Process ....................................................................... 94
6.2. Objectives of Stakeholder Consultation................................................................. 94
6.3. Methodology of Consultations ............................................................................... 95
6.3.1. Identification of Stakeholder ........................................................................... 95
6.3.2. Consultation Approach & Feedback ............................................................... 95
Chapter 7 Screening of Potential Environmental Impacts and Proposed Mitigation
Measures 100
7.1. Introduction ......................................................................................................... 100
7.2. Methodology for Impact Assessment .................................................................. 100
7.3. Screening of Potential Environmental Impacts at different stages of project
development .................................................................................................................. 102
7.4. Social and Environmental Impacts from Drilling Activities ................................... 102
7.4.1. Impacts due to land and Soil Erosion ........................................................... 102
7.4.2. Soil and Water Contamination from Waste / Spills ....................................... 105
7.4.3. Impacts on the ambient air quality................................................................ 108
7.4.4. Impacts due to noise pollution ...................................................................... 110
7.4.5. Use and Availability of Water ....................................................................... 111
7.4.6. Impacts due to Hazardous Material and Solid Waste Generated ................. 113
7.4.7. Site Restoration after drilling activities ......................................................... 114
7.5. Potential Impacts during Pre-Commissioning & Commissioning of Flow line....... 116
7.5.1. Wastewater from Hydrostatic Testing .......................................................... 116
7.5.2. Noise ........................................................................................................... 117
7.6. Potential Impacts during Operation Phase of the Flow line ................................. 118
7.6.2. Small scale hydrocarbon emissions in the event of pipeline leakage ........... 118
7.6.3. Emergency Scenarios (Earthquake) ............................................................ 118
7.7. Impacts on Occupational Health and Safety........................................................ 119
7.8. Impacts on the Ecology, Fauna and Flora ........................................................... 119
7.9. Impact on Socio-economic, Cultural and Archaeological Resource..................... 122
Chapter 8 ENVIRONMENTAL MANAGEMENT PLAN (EMP) ..................................... 126

8.1. Introduction ......................................................................................................... 126
8.2. Objectives of the Environmental Management Plan ............................................ 127
8.3. Scope and Priority............................................................................................... 127
8.4. Maintenance of the EMP ..................................................................................... 129
8.5. Legislations and Guidelines ................................................................................ 129
8.6. Organizational Structure and Responsibilities ..................................................... 129
8.6.1. Organizational Structure .............................................................................. 129
8.6.2. Roles and Responsibilities of Eni Pakistan .................................................. 130
8.6.3. Roles and Responsibilities of Project Contractors ........................................ 130
8.7. Implementation of Environmental Management Plan .......................................... 144
8.7.1. Approvals..................................................................................................... 145
8.7.2. Contractual Provisions ................................................................................. 145
8.7.3. Training........................................................................................................ 145
8.7.4. Minimum Distances...................................................................................... 146
8.7.5. Communication and Documentation ............................................................ 146
8.8. Mitigation Management Matrix ............................................................................ 146
8.9. Environmental Monitoring Program ..................................................................... 168
8.9.1. Objectives of environmental monitoring ....................................................... 168
8.9.2. Compliance Monitoring ................................................................................ 168
8.9.3. Effects Monitoring ........................................................................................ 168
8.9.4. Post project Monitoring ................................................................................ 168
8.10. Communication and Documentation ................................................................ 168
8.11. Environmental Training.................................................................................... 172
8.11.1. Objectives ................................................................................................ 172
8.11.2. Roles and Responsibilities ....................................................................... 172
8.11.3. Training Program...................................................................................... 172
8.11.4. Training log .............................................................................................. 173
8.11.5. Training Need Assessment ...................................................................... 173
8.11.6. Training Material ...................................................................................... 173
8.12. Emergency Response Plan ............................................................................. 173
8.13. Waste Management ........................................................................................ 174
8.13.1. Management of Drilling Wastes ................................................................ 174
8.13.2. Effluents and Sewage .............................................................................. 175
8.14. Risk Management ........................................................................................... 175
8.15. Site Restoration Plan ....................................................................................... 177
8.16. Change Management Plan .............................................................................. 178

8.16.1. Changes in the EMP ................................................................................ 178
8.16.2. Changes in the Operation......................................................................... 178
Chapter 9 Conclusion & Recommendations ............................................................. 180
Annexures
Annex – I Sindh Environmental Quality Standards (SEQS), 2016

Annex – II Eni Pakistan HSE Policy
Annex – III Environmental Analysis Reports
List of Tables
Table 1.1: List of EIA Team Members ................................................................................... 8

Table 2.1: International Treaties signed by Pakistan ........................................................... 27
Table 3.1: Location Coordinates of Proposed well sites in Kadanwari Block ....................... 30
Table 3.2: Tentative durations of Drilling phase activities .................................................... 34
Table 3.3: Constituents for Water Based Mud ..................................................................... 38
Table 3.4: Special Additives and their Function in Water Based Drilling Fluid ..................... 38
Table 3.5: Typical Emissions from 920 KW Diesel Generator ............................................. 44
Table 3.6: Summary of Construction Waste Generation and Disposal ................................ 45
Table 4.1: Noise level monitoring locations ......................................................................... 65
Table 4.2: Indus River Water Quality................................................................................... 67
Table 4.3: Results of surface water analysis ....................................................................... 68
Table 4.4: List of Mammals recorded/reported in Nara Desert Wildlife Sanctuary ............... 75
Table 4.5: List of Birds recorded in/near the Nara Desert Wildlife Sanctuary ....................... 76
Table 4.6: List of Reptiles Observed in the Nara Desert Wildlife Sanctuary ......................... 77
Table 4.7: List of Floral Species Observed in the Project Area ............................................ 78
Table 5.1: Population Distribution by gender and urban/Rural Census-2017 Khairpur ........ 85
Table 5.2: Ownership of Housing of district Khairpur (Sindh District Profile-2021)............... 86
Table 5.3: Source to Drinking Water of district Khairpur (Sindh District Profile-2021) .......... 87
Table 5.4: Access to Sanitation (Sindh District Profile-2021) ............................................... 87
Table 5.5: Number of Health Facilities of district Khairpur (Sindh District Profile-2021) ....... 87
Table 5.6: Patients Record of district Khairpur (Sindh Districts Profile-2021) ...................... 88
Table 5.7: Population served by Doctor/Nurse of district Khairpur (Sindh District Profile-2021)
........................................................................................................................................... 89
Table 5.8: List of Number of Schools in district Khairpur (Sindh District Profile-2021) ......... 89
Table 5.9: Enrollments of Students in district Khairpur (Sindh District Profile-2021) ............ 89
Table 5.10: Male and Female literacy rate of district Khairpur (Sindh District Profile-2021) . 90
Table 5.11: Multidimensional Poverty Index of district Khairpur (Sindh District Profile-2021)
........................................................................................................................................... 90
Table 5.12: Irrigation and Un-irrigation Area of district Khairpur (Sindh District Profile-2021)
........................................................................................................................................... 91
Table 5.13: Livestock Count of district Khairpur (Sindh District Profile-2021) ...................... 91
Table 6.1: List of Primary stakeholders consulted ............................................................... 96
Table 6.2: Secondary Stakeholders Consultation ................................................................ 97
Table 7.1: Secondary Screening Consequence Level Criteria........................................... 101
Table 7.2: Likelihood Evaluation Criteria ........................................................................... 101
Table 8.1: Responsibilities of Eni Pakistan and drilling and flow line construction contractor
......................................................................................................................................... 131
Table 8.2: Environmental Aspect Register .......................................................................... 133
Table 8.3: Minimum distance from sensitive receptor during Drilling Activity ..................... 146
Table 8.4: Mitigation Management Matrix for Drilling Activities .......................................... 147
Table 8.5: Mitigation Management Matrix for Flow Line Laying and Commissioning Activities
......................................................................................................................................... 156
Table 8.6: Impact on Ecology, flora and fauna .................................................................. 165
Table 8.7: Environmental Monitoring Plan for Well Site Construction and Well Drilling ...... 169
Table 8.8: Environmental Monitoring Plan for Construction and Commissioning Phases of
Flow Lines......................................................................................................................... 170
Table 8.9: Suggested Training Program for exploratory activities ...................................... 172
List of Figures
Figure 1.1: Location of proposed Development well sites ...................................................... 2

Figure 1.2: EIA process overview .......................................................................................... 5
Figure 1.3: Field survey Activities .......................................................................................... 6
Figure 3.1: Location of proposed well sites in Kadanwari Block .......................................... 31
Figure 3.2: Drilling Rig......................................................................................................... 37
Figure 3.3: Blowout Preventer ............................................................................................. 39
Figure 3.4: Diesel generators with mechanical transmission ............................................... 40
Figure 3.5: Land Use and Land cover Map of Kadanwari Block .......................................... 49
Figure 4.1: Geographical Location of Kadanwari Block ....................................................... 51
Figure 4.2: Physiographical features of the project area...................................................... 52
Figure 4.3: District map of Sindh ......................................................................................... 53
Figure 4.4: Geological map of Sindh ................................................................................... 54
Figure 4.5: Topography of the project area ......................................................................... 55
Figure 4.6: Location of project area in Nara Desert Wildlife Sanctuary, District Khairpur ..... 57
Figure 4.7: The daily average high (red line) and low (blue line) temperature. The thin dotted
lines are the corresponding average perceived temperatures. (Source:
www.weatherspark.com) ..................................................................................................... 58
Figure 4.8: The average rainfall. (Source: www.weatherspark.com) .................................... 59
Figure 4.9: Humidity levels. (Source: www.weatherspark.com) ........................................... 59
Figure 4.10: The average wind speeds (dark gray line). (Source: www.weatherspark.com) 60
Figure 4.11: Mean Wind direction. (Source: www.weatherspark.com) ................................. 60
Figure 4.12: Seismicity & Natural Disasters- Pakistan, 1990-2000 ...................................... 61
Figure 4.13: Graphical representation of observations of Ambient Air Quality conducted near
Eni Well-03 ......................................................................................................................... 63
Figure 4.14: Graphical representation of observations of Ambient Air Quality conducted
between well-01 and well-02 ............................................................................................... 64
Figure 4.15: Ambient Air Quality Monitoring at project sites in Kadanwari Block ................. 64
Figure 4.16: Noise Level Monitoring in project area ............................................................ 65
Figure 4.17: Irrigation water canal near Well-03 .................................................................. 66
Figure 4.18: Ground water sampling ................................................................................... 69
Figure 4.19: Graphical representation of pH, TDS and TH of ground water samples .......... 70
Figure 4.20: Microenvironment of the proposed well sites ................................................... 72
Figure 4.21: Views of ecological footprints near well site 1 .................................................. 73

Figure 4.23: Views of well site 3 showing agriculture area .................................................. 74
Figure 4.26: Project area boundary and Protected areas .................................................... 79
Figure 6.1: Consultation Pictures of Primary and Secondary Stakeholders ......................... 99
Figure 8.1: Typical EMP Model ......................................................................................... 126
List of Acronyms
dB (A) Decibel (A) (Unit of Noise)

DC Drilling Contractor
EIA Environmental Impact Assessment
EMMP Environmental Management and Monitoring Plan
EPA Environmental Protection Agency
ERP Emergency Response Plan
GOS Government of Sindh
GRM Grievance Redress Mechanism
HSE Health, Safety and Environment
IEE Initial Environmental Examination
ILO International Labor Organization
IMC Independent Monitoring Consultant
NGO Non-Governmental Organization
NOC No objection Certificate
OHS Occupational Health and Safety
PPE Personal Protection Equipment
ROW Right Of Way
RPF Resettlement Policy Framework
SEPA Sindh Environmental Protection Act
SEQS Sindh Environmental Quality Standards
SSDWQ Sindh Standard for Drinking Water Quality
Doc. No.: Eni/EIA/01 Rev.: D Page 1
Chapter 1 Introduction
1.1. Brief Description of the project
This report presents the findings of Environmental Impact Assessment study carried out by
EMC Pakistan Private Limited for the proposed drilling activities located in Kadanwari Block
within Nara Wildlife Sanctuary. Kadanwari block, lies mainly in district Khairpur and small
northern part lies in district Sukkur, covers a total area of 458 sq km. Geologically, the
Kadanwari block is part of Central Indus Platform Basin.
The proposed project comprises of drilling of 05 development wells inside the Nara Desert
Wildlife Sanctuary in District Khairpur.
The EIA has been prepared in compliance with the mandatory requirement of the Section 17
of Sindh Environmental Protection Act (SEPA) 2014. Compliance with provisions of SEPA
2014, Section 17 requires that “no proponent of a project will commence construction or
operation unless he has filed with the Agency an environmental impact assessment, and has
obtained from the Agency approval in respect thereof”.
Field surveys were conducted in the study area by EMC Pakistan Pvt. Limited team which
included environmentalist, sociologist, ecologists and wildlife specialist. Field data collection
included observational surveys; consultations and meetings for data collection with
government departments, NGOs and communities. Secondary information was collected from
proponent, in-house sources, Government Departments and NGOs. Applicable international
guidelines, conventions and environmental assessment procedures prepared by the Pakistan
EPA have been reviewed while preparing this document.
1.2. Project Proponent

Eni Pakistan
Jahanzaib Akhtar HSE Manager
5th Floor, The Forum, G-20, Block 9, Khayaban-e-
Address
Jami, Clifton, Karachi,
Landline +92 21 35838401
Fax +92 21 3583 8493
Website www.eni.com
1.3. Environmental Consultant

EMC Pakistan
Syed Nadeem Arif Managing Director / CEO
503, Anum Estate, Shahrah-e-Faisal,
Address
Karachi, Pakistan
Phone +92-21-34311466 & 34382860,
Fax No +92 21 34311467
Email mail@emc.com.pk
Doc. No.: Eni/EIA/01 Rev.: C Page 2
Figure 1.1: Location of proposed Development well sites

1.4. Eni Pakistan - The Proponent1

Eni Pakistan is an energy company. We concretely support a just energy transition, with the
objective of preserving our planet and promoting an efficient and sustainable access to energy
for all. Our work is based on passion and innovation, on our unique strengths and skills, on
the equal dignity of each person, recognizing diversity as a key value for human development,
on the responsibility, integrity and transparency of our actions. We believe in the value of long-
term partnerships with the countries and communities where we operate, bringing long-lasting
prosperity for all.
Eni Pakistan has been operating in Pakistan since 2000 in the Exploration & Production and
Gas & Power sectors. However, Eni Pakistan contribution for local development support in the
Pakistan began in the 1970s.
Eni operations in Pakistan
The main permits Eni Pakistan works in are Bhit/Badhra (40%) and Kadanwari (18.42%). Eni
Pakistan also shared in the permits Latif (33.3%), Zamzama (17.75%) and Sawan (23.7%).
Development in 2019 included drilling new wells in producing fields to optimize production,
improving existing onshore facilities and rigless operations to combat a decline in production.
At the end of 2019 Eni Pakistan have installed a solar plant at Bhit, integrating the photovoltaic
installation with an existing electricity-generating system, which enables to turn off one of the
gas turbines and make savings in operating costs. The project being one of its kind makes it
possible to conserve the natural gas and supply it to the gas distribution network. The solar
plant has a peak capacity of 10 MW and produces approximately 20 GWh of energy per
annum. This energy is used directly by the associated gas processing plant, thus reducing the
overall gas consumption and avoiding the release of 144,000 tons of CO2 into the environment
over lifetime of plant.
Vision statement
Creating sustainable value, ethical corporate behavior, building human capacity and
promoting technological innovation.
Corporate Social Responsibility
Eni Pakistan since its inception till date, supported local populous lacking basic facilities in the
remotest area of the desert by providing drinking water in the purpose-built water storage
tanks to facilitate the community at their door step. Moreover, Solar operated Reverse
Osmosis Plant and Filter Plants were installed in different villages. To provide health and
education facilities, Eni Pakistan had constructed and is operating 2 Community Health
Centre, 1 Pathological Laboratories, 12 Community Based Primary Schools, 1 Community
Based Middle School and 1 Veterinary Hospital (handed over to Sindh Government).
1.5. Scope and Objectives of EIA

The EIA study is aimed at developing the environmental and social profile of the project area
so as to evaluate the existing physical, biological and socioeconomic aspects leading to
1 https://www.eni.com/en-IT/global-presence/asia-pacific/pakistan.html
respective impacts due to construction and operation activities of the proposed project. Other
objectives of the EIA study are to ensure that:
 Any major adverse impact on the environment (physical, ecological and social) during
different phases of projects viz. siting, design, construction, and operation are identified.
 Adverse impacts are appropriately addressed and adequate mitigation measures are
incorporated in the siting, design, construction, and operation phases of project.
 Socioeconomic aspects are identified and mitigated.
 Alternatives to achieve the objectives are analyzed.
 Environmental Management Plan (EMP) for sustainable development and operation of

the project is developed for implementation and monitoring of the project activities.
This EIA report has been prepared after identifying the environmental aspects and screening
the potential impacts of the proposed project to ensure that the proposed activities in
Kadanwari Block are environmentally conducive and compliant to local environmental laws,
most important is the Sindh Environmental Protection Act, 2014. Scope of EIA study included:
 Description of project activities

 Review of legislative framework for the project
 Description of environmental and social baseline of project area
 Stakeholder Consultation
 Analysis of project alternatives
 Impact Assessment and Mitigation measures
 Development of Environmental Management and Monitoring Plan
1.6. Project Categorization

The Sindh Environmental Protection Agency (Environmental Assessment) Regulations, 2021
have been notified under section 37 of SEPA Act, 2014 and classifies projects on the basis of
expected degree of adverse environmental impacts and list them in three different schedules.
Sindh Environmental Protection Agency (Environmental Assessment) Regulations, 2021 is
the revised version of the previous regulation i.e., Sindh Environmental Protection Agency
(Review of IEE and EIA) Regulations, 2014. The revised regulation was published and
enforced in September 2021.
Schedule I: A project falling in any category listed in Schedule-I shall file environmental
checklist with the Agency and the provisions of section 17 shall apply to such projects.
Schedule II: A project falls in Schedule II if it is likely to have adverse environmental impacts,
but of lesser degree or significance than those for category ‘A’ and all the mitigation measures
to handle the impact is manageable. Such types of projects need IEE report including EMP.
Schedule III: Projects are categorized in Schedule III if they generate significant adverse
environmental impacts that require a comprehensive management plan, or if the project is
located within or passes through: a) Areas declared by the Government of Pakistan as
environmentally sensitive (National Parks/Sanctuaries/Game Reserve), b) Areas of

international significance (e.g. protected wetland as designated by the RAMSAR Convention),
or c) Areas designated by the United Nations Educational, Scientific, and Cultural Organization
(UNESCO) as cultural heritage sites.
The proposed project activities are inside the Environmentally Protected area (i.e., Nara
Desert Wildlife Sanctuary), therefore project falls in Schedule III and requires Environmental
Impact Assessment (EIA). Accordingly, this EIA study was conducted and its report is being
filed with the Sindh Environmental Protection Agency for approval.
1.7. EIA Methodology
Figure 1.2: EIA process overview
Brief description of the different steps taken during the EIA study are given below.
1.7.1. Collection and Review of Project activities

At the outset of EIA, necessary project information was collected from client to acquire an
understanding of the project activities and to determine the extent and scope of field surveys
and impact assessment.
1.7.2. Review of Applicable Legislations and Guidelines

National legislation, international agreements, environmental guidelines, and best industry
practices were reviewed to identify the legal requirements and international applicable
guidelines that Eni Pakistan is required to meet during the project.
1.7.3. Secondary Data Collection

All available secondary data including previous studies in the area, case studies, baseline
studies, census reports, and reports by geological survey of Pakistan etc. were gathered and
reviewed. Previous studies conducted by EMC in the area were also reviewed during this task.
The information collected from secondary sources included information related to physical,
biological and socio-economic environment of the project area.
1.7.4. Field Data Collection

Field surveys of project area were conducted by EMC team. During the site visit, primary
information on the physical, biological and socio-economic background conditions of the
project area were collected. Discussions were held with the members of the community
resident in the area to collect area-specific primary information along with their views and
concerns regarding the project and its activities. A visit was also conducted with a Wildlife
expert for ecological survey of the project area inside the Nara Wildlife Sanctuary and to get
expert advice from them regarding the mitigation measures to eliminate and/or reduce the
adverse impacts to the ecology and wildlife.
Figure 1.3: Field survey Activities

1.7.5. Impact Identification and Assessment

Potential consequences that may occur from proposed actions were identified after field data
was collected during surveys. These include effects on physical, biological, socio-economic,
archaeological and cultural environment. Impacts were identified in particular on the
biodiversity and assessed on the basis of field data collected from project area, secondary
data, expert’s opinion, and monitoring results of previous oil and gas exploration projects in
Pakistan.
1.7.6. Recommendations to Mitigate Impacts

Keeping in view the baseline data collected and impacts identified; mitigation measures have
been recommended to minimize, reduce, eliminate, or compensate for the potential
environmental and social impacts on the project zone of influence. Mitigation measures
recommended here are based on past experience, best industry practices, legislative
requirements and professional judgment.
1.7.7. Framework of Environmental Management Plan (EMP)

Environmental Management Plan (EMP) was developed for effective implementation of the
recommended mitigation measures. EMP includes controls to minimize the identified impacts,
and monitoring program to monitor residual impacts, if any, during the operation. The EMP
has laid down procedures to be followed during the drilling operation and has identified roles
and responsibilities for all concerned personnel during the operation, including post project
reporting.
1.7.8. Reporting
The Report has been prepared according to Pakistan Environmental Protection Agency
(PEPA) guidelines for environmental assessment. This report includes the findings of the
assessment, the project impacts, and the mitigation measures to be implemented during the
execution of the proposed activities.
1.8. Composition of this Report

This report consists of eight sections including this introductory section. Sequence wise
sectional brief is given as follows:
 Chapter 1 gives introduction of project and overview of process;
 Chapter 2 contains an overview of applicable national regulatory requirements as well

as international conventions, guidelines which are relevant to Oil & Gas industry and
applicable in the scenario of Pakistan;
 Chapter 3 describes the proposed project activities;
 Chapter 4 describes environmental baseline of project area that includes existing
environmental conditions such as physical environment as well as ecological;
 Chapter 5 describes socioeconomic baseline of project area that includes district profile
and microenvironment socioeconomic profile;
 Chapter 6 details on primary and secondary stakeholder consultation that was carried
out during field visits for this study. It further contains the responses received from
representatives of concerned departments and local inhabitants respective to proposed
project;
 Chapter 7 presents assessment of potential impacts of proposed drilling operations
along with appropriate mitigation measures for mitigation of these impacts;
 Chapter 8 provides a comprehensive Environmental Management Plan (EMP) and
defines the changes in management criteria for the environmental assessment and
identifies the steps that need to be taken if there is a change in project activities or in the
area where the project activities would be conducted;
 Chapter 9 concludes the EIA study and its outcome.
1.9. EIA Study Team

Table 1.1: List of EIA Team Members
S# Name Position in EIA Study Team
1. Mr. Syed Nadeem Arif Project Manager
2. Mr. Muhammad Haseeb Team Leader
3. Mr. Khurram Shams Khan Senior Sociologist
4. Mr. Shamim Fakhri Wildlife Expert
5. Mr. Abdul Rauf Siddiqui Environmental Scientist
6. Mr. Toufeeq Ahmed Environmental Engineer
7. Mr. Imran Khan Environmental Scientist
8. Mr. Wajai Kumar Sociologist
9. Mr. Sajid Ali Field Officer
Chapter 2 Policy, Legal and Administrative

Framework
2.1. Introduction
This section describes the current legal responsibilities of the proponent in the context of the
environment and sustainable development, and the institutions that exist in the country that
may influence the environmental management of the proposed project. Eni Pakistan, the
proponent of this project will comprehensively follow the relevant requirements of the policy
documents and legislative framework as well as recommendations as described in the national
and international guidelines in relevance to the proposed project. Provisions of many of these
guidelines have been incorporated in the mitigation measures and the Environmental
Management & Monitoring Plan (EMMP) which have been formulated for the better
management of environmental and social impacts. The section discusses following laws and
legislations and their applicability w.r.t the project:
 Eni Pakistan HSE Policy;

 National Environmental Laws & Legislations;
 Provincial Environmental Laws & Legislations;
 Environmental and Social Guidelines;
 International Treaties and Conventions;
2.2. Eni Pakistan HSE Policy

Eni Pakistan’s Health, Safety and Environmental (HSE) policy (attached the policy in this
document) is the principal policy document and is committed to give priority to health and
safety of all its employees and of other personnel affected by its activities. Emphasis is given
on the recognition and elimination of risk rather than blaming it to someone. Eni Pakistan also
confers its overriding commitment towards minimizing impact of its activities on the natural
environment of the area. The policy also encourages an active participation with government
and other responsible institutions in meeting applicable national as well as international health,
safety and environmental rules and regulations.
The policy emphasizes on adaptation of advanced and best industrial practices in order to
minimize adverse detrimental impacts on the environmental receptors. The policy highlights a
need to seek economic ways to minimize environmental degradation and sustaining the
environment. Improvement of business processes, in conformity with defined strategic goals
and objectives for achieving technological excellence in day-to-day activities is also
accentuated. In addition, maintaining knowledge throughout organization by effective
communication of information through education and training of staff and maintaining updated
contingency plans is to be exercised throughout the company. In the end, measuring and
analyzing the HSE performance and implementation of management systems is stressed to
ensure effective feedback of information for continual improvement.
2.3. Institutional Setup for Environmental Management

The highest environmental body in the country is the Pakistan Environmental Protection
Council (PEPC), which is presided over by the Chief Executive of the country. Other bodies
include the Pakistan Environmental Protection Agency (Pak-EPA), provincial EPAs (for four
provinces, AJK and Northern Areas), and Environmental Tribunals. The roles, responsibilities
and authorities of PEPC and the EPAs are defined in the PEPA 1997. The PEPC has been
formed by the Federal Government. Its members include the President of Pakistan, or
someone appointed by the President, as the Chairperson; the Minister of the Ministry of
Environment, Local Government and Rural Development as the vice-Chairperson; Governors
of the Provinces; Ministers in charge of the subject of environment in the Provinces; Secretary
to the Federal Government in charge of the Ministry of Environment, Local Government and
Rural Development; Director General Federal EPA; heads of other federal and provincial
departments; environmentalists and community representatives including scientists.
The functions and powers of the Council include formulation of national environmental policy,
enforcement of PEPA 1997, approval of the NEQS, incorporation of environmental
considerations into national development plans and policies and provide guidelines for the
protection and conservation of biodiversity in general and for the conservation of renewable
and nonrenewable resources.
2.4. Administrative Framework

The Government of Sindh (GOS) has designated its Ministry of Environment and Alternative
Energy, to administer matters related to the environment in Sindh. The Sindh EPA is directly
under the Ministry of Environment and Alternative Energy.
SEPA is headed by Director General (DG) with the aim to exercise the powers and perform
the functions assigned to it under the provisions of this Act and the rules and regulations made
there under. The Agency is responsible to administer and implement the provisions of Sindh
Environmental Protection Act 2014 and other provincial environmental laws and regulations.
Under the Sindh Environmental Protection Act 2014, SEPA has powers to enter or inspect
under a search warrant issued by Environmental Protection Tribunal or a Court search at any
time, any land or building etc. where there are reasonable grounds to believe that an offence
under this Act has been or is being or likely to be committed. SEPA may also take samples,
arrange for testing or confiscate any article in discharge of their duties.
Environmental Protection Council (EPC)
It has been formed consisting of Chief Minister as Chairman with Minister in charge of
Environment Protection Department, Addl. Chief Secretary, Planning & Development
Department, Government of Sindh and Secretaries of Environment, Finance, Public Health
Engineering, Irrigation, Health, Agriculture, Local Government, Industries, Livestock &
Fisheries Forest & Wildlife, Energy, Education Departments Government of Sindh and
Divisional Commissioners of Sindh. Non-official members are also included (i.e.,
representatives of Chamber of Commerce & Industry and from medical or legal professions
etc.) along with DG EPA & two Members of Provincial Assembly also form part of EPC.
The functions and powers of EPC include coordination & supervision of provisions of Act,
approving provincial environmental & sustainable development policies & SEQS, provide
guidance for protection & conservation, consider annual Sindh Environmental Report, deal
with interprovincial and federal provincial issues, provide guidance for bio safety and assist
Federal Government in implementation of various provisions of UN Convention on laws on
Seas (UNCLOS).
2.5. National Environmental Assessment Guidelines
2.5.1. Pakistan Environmental Assessment Procedures

Pak EPA has prepared a set of guidelines for conducting environmental and social
assessments. The guidelines derive from much of the existing work done by international
donor agencies and NGOs. The package of regulations, of which the environmental and social
guidelines form a part, includes the PEPA 1997 and the NEQS. These guidelines are
discussed below followed by discussion on their relevance to proposed project:
Policy and Procedures for Filing, Review & Approval of Environmental Assessments, Pakistan
Environmental Protection Agency, September 1997:
These guidelines define the policy context and the administrative procedures that govern the
environmental assessment process from the project pre-feasibility stage to the approval of the
environmental report. The package of regulations prepared by PEPA with relevance to this
EIA includes:
 Guidelines for the Preparation and Review of Environmental Reports;

 Sectoral Guidelines for Environmental Reports-Oil and Gas Exploration and production
 Guidelines for Public Consultation
Guidelines for the preparation and review of environmental reports:
It requires proponents to prepare terms of reference for the environmental assessment

reports. It requires that all studies should contain baseline data on the area and must contain
an assessment of the potential environmental impacts and the recommended mitigation
measures.
Sectoral guidelines for environmental reports- Oil and Gas Exploration Projects
These guidelines identify and explain issues that should be addressed for a proposal involving
exploration for, or production of, oil and gas. It is important to focus on key issues for specific
proposals. The matters identified in this guideline should provide guidance for preparation and
assessment of most exploration and production proposals. It is intended that companies
involved in Oil and Gas Exploration and Production will self-regulate and undertake monitoring
to meet or exceed the provisions of the Package and these sectoral guidelines. Part A of these
guidelines deals with exploration and part B deals with Production.
Guidelines for public consultation
These guidelines are intended to provide assistance throughout the environmental

assessment of project by involving the public which can lead to better and more acceptable
decision-making. Public involvement, undertaken in a positive manner and supported by a real
desire to use the information gained to improve the proposal, will lead to better outcomes, and
lay the basis for ongoing positive relationships between the participants.
The guidelines define the "objectives of consultation" as follows: Public involvement is a

feature of environmental assessment and can lead to better and more acceptable decision-
making. It can be time consuming and demanding, yet without it, proposals are seldom
soundly based, and there is likely to be antagonism from affected people. Public involvement,
undertaken in a positive manner and supported by a real desire to use the information gained
to improve the proposal, will lead to better outcomes, and lay the basis for ongoing positive
relationships between the participants.
The Guidelines for Public Consultation introduces effective ways to inform the contents of the
project to the general public during the planning stage & that eventually consensus building
toward the implementation of project is reached.
Incorporating public involvement into the stages of environmental assessment is explained in

the guidelines that public consultation meeting has to be carried out after the works on
"developing options, and assessing and mitigating impacts" for comments and assessment.
The submission and approval procedure for the EIA is summarized below:
 The EIA report shall be submitted, together with a review fee and form included as
Schedule-V of the Sindh EPA (Environmental Assessment) Regulations, 2021.
 The SEPA shall conduct a preliminary scrutiny and reply within 15 working days of the
submittal of the report a) confirming completeness, or b) asking for additional information,
if needed, or c) returning the report requiring additional studies, if necessary.
 The SEPA is required to make every effort to complete the EIA review process within
four months of the issue of confirmation of completeness.
 SEPA shall call for a Public Hearing for the project to invite all the concerned persons to
raise concerns on the project.
 Following the Public Hearing, SEPA shall constitute a Committee of Experts to assist the
agency in review of the EIA.
 The approval granted at the end of the review process is valid for three years for start of
construction.
 Once project construction has been completed, the proponent is required to submit a
request to the SEPA for confirmation of compliance. An environmental management plan
for the operation phase is to accompany the request
 The SEPA is required to communicate its decision within four months of receipt of the
request. The project can commence operation only after it has received approval from
the SEPA.
2.6. National Laws, Policies and Regulations
2.6.1. National Conservation Strategy

The Pakistan National Conservation Strategy (NCS), which was approved by the Federal
Cabinet in March 1992, is the principal policy document for environmental issues in the
country. The NCS signifies the country’s primary approach towards encouraging sustainable
development, conserving natural resources, and improving efficiency in the use and
management of resources. The NCS has 68 specific programs in 14 core areas in which policy
intervention is considered crucial for the preservation of Pakistan’s natural and physical
environment. The core areas that are relevant to the proposed project are biodiversity
conservation, restoration of rangelands, pollution prevention and abatement, and the
preservation of cultural heritage.
Pakistan is a signatory to the Convention on Biological Diversity, and is thereby obligated to

develop a national strategy for the conservation of biodiversity. The Government of Pakistan
constituted a Biodiversity Working Group, under the auspices of the Ministry of Environment,
to develop a Biodiversity Action Plan for the country, which was completed after an extensive
consultative exercise. The plan, which has been designed to complement the NCS and the
proposed provincial conservation strategies, identifies the causes of biodiversity loss in
Pakistan and suggests a series of proposals for action to conserve biodiversity in the country.
The Pakistan Environmental Protection Council (PEPC) has approved the action plan and
steering committees at the federal and provincial levels have been formed to implement it.
2.6.2. National Environmental Policy, 2005

The National Environmental Policy aims to protect, conserve and restore Pakistan’s
environment in order to improve the quality of life for the citizens through sustainable
development. It provides an overreaching framework for addressing the environmental issues
facing Pakistan, particularly pollution of fresh water bodies and coastal waters, air pollution of
fresh water bodies and coastal waters, air pollution, lack of proper waste management,
deforestation, and loss of biodiversity, desertification, natural disasters and climate change.
It also gives direction for addressing the cross-sectional issues as well as the underlying
causes of environmental degradation and meeting international obligations.
The National Environmental Policy, while recognizing the goals and objectives of the National
Conservation Strategy, National Environmental Action Plan and other existing environmental
related national policies, strategies and action plans, provide broad guidelines to the Federal
Government, Provincial Governments, Federally Administrated, Territories and Local
Governments for addressing environmental concerns and ensuring effective management for
their environmental resources.
2.6.3. The Biodiversity Action Plan

The Biodiversity Action Plan, 2000 has been the most significant direct step towards
addressing the issue of loss of biodiversity. It details the current status, trends, direct & indirect
causes of loss of biodiversity; its principles, goals and aims; proposals for an action plan
including planning & policies, legislation, identification and monitoring, in situ & ex situ
conservation, sustainable use, research and training, public education and awareness,
Environmental Impact Assessment, information extraction and financial resources etc.
The Wild Birds and Animals Protection Act 19125, the West Pakistan Wildlife Protection
Ordinance 1959, the Wildlife Protection Rules 1972, provide for the protection of flora and
fauna in the territory, including vegetation and protected forests. Ecological survey was
conducted by the team of ecologist and junior biologists to determine the ecological baseline
of the area. This EIA study has addressed different aspects of conservation of wildlife, and
forest.
2.6.4. Antiquities Act, 1975

The Act provides for protection of Pakistan’s cultural resources. The Act defines “antiquities”
as ancient products of human activity, historical sites or sites of anthropological or cultural
interest, national monuments, etc. The Act is designed to protect these antiquities from
destruction, theft, negligence, unlawful excavation, trade, and export. The law prohibits new
construction in the proximity of a protected antiquity and empowers the GoP to prohibit
excavation in any area that may contain articles of archaeological significance. Under the Act,
the Project proponents are obligated to ensure that no activity is undertaken within 61 m (200
ft.) of a protected antiquity, and to report to the GoP’s Department of Archaeology any
archaeological discovery made during the course of the project.
The federal Department of Archaeology maintains a master register containing basic and vital
information on the protected monuments and sites including full measurements of the
protected area, description, location and Government Notification number with date of
protection. The central directorate general of Archaeology has a separate list which is
continuously updated as and when new sites are declared as protected.
In Pakistan at present there are 387 notified sites which are covered by Federal Antiquities
Act. None of the notified protected sites are located close to the proposed well sites.
2.6.5. The Forest Act, 1927

The Forest Act deals with the matters related with protection and conservation of natural
vegetation/habitats. In this regard, it empowers the concerned agency to declare protected
and reserved forest areas and maintaining the same. In spite of the fact that it recognizes the
right of people for access to the natural resources for their household use, it prohibits unlawful
cutting of trees and other vegetation. The permission is required prior to undertaking any tree
cutting from the area under the charge of Forest Department of Sindh. The Kadanwari Block
does not fall under any reserve / protected forest areas within its boundaries.
2.6.6. Pakistan Penal Code, 1860

The Pakistan Penal Code deals with offences where public or private property and/or human
lives are affected due to the intentional or accidental misconduct of an individual or body of
people. In the context of environment, the Penal Code empowers the local authorities to
control noise, noxious emissions and disposal of effluents. The environmental quality
standards enforced by the EPAs supersede the application of this legislation on industries and
municipalities. The Penal Code, however, can provide a basis for the client to coordinate its
activities with the local authorities to ensure that its construction activities do not become a
cause of public nuisance or inconvenience.
2.6.7. The Land Acquisition Act, 1894

This Act provides law for the acquisition of land needed for public purposes and for companies
and for determining the amount of compensation to be made on account of such acquisitions.
The law provides details of various peculiarities involved in acquisition of land such as
preliminary investigation, objection to acquisition, declaration of intended acquisition, enquiry.
This Act provides law for the acquisition of land needed for public purposes and for companies
and for determining the amount of compensation to be made on account of such acquisitions.
The law provides details of various peculiarities involved in acquisition of land such as
preliminary investigation, objection to acquisition, declaration of intended acquisition, enquiry
into measurements, value & claims, taking possession, reference to court and procedure
thereon, apportionment of compensation, payment, temporary occupation of land, acquisition
of land for companies, disputes resolutions, penalties and exemptions etc. This Act has 55
sections addressing different areas. Such as section 4(2) mentions that it shall be lawful for
any official authorized by the Collector to enter upon and survey, to dig or to do all other acts
necessary to ascertain that whether the land is adapted for such purpose. Eni Pakistan makes
judicious land compensation to the legitimate private landowners and acquires state land from
the Government on lease.
2.6.8. Pakistan Climate Change Act, 2016

Federal Cabinet of Government of Pakistan approved Pakistan Climate Change Act 2016 in
November. It was enacted in 2017 after it was passed by the National Assembly. Consequent
to the Act, three relevant institutions have been setup namely Pakistan Climate Change
Council, Pakistan Climate Change Authority, and Pakistan Climate Change Fund.
Pakistan Climate Change Council: The institutional make-up of the council is highlighted under
section 3, whereby it is provided that the council will have representations from the leadership
of all avenues of the Federation. Section 4 highlights the functions and powers of the council
which extends to supervising the enforcement of the CCA. Moreover, it has the following
prerogatives: the international treaties Pakistan is a part of, giving strategic direction for the
implementation of the United Nations Sustainable Development Goals (‘SDGs’), giving
guidelines for the protection of ecology, and considering the National Climate Change Report.
To analyse these functions, while the CCA gives the council the power to monitor the progress
of climate change reports and policy outside the institution, there is a lack of punitive measures
with regards to the progress of climate change legislation.
PAKISTAN CLIMATE CHANGE AUTHORITY
Section 5(2) establishes the Pakistan Climate Change Authority (‘PCCA’), with the prerogative
of being a corporate body, which is capable of being sued and can pursue a suo moto case,
acquire assets, loans, and can enter into contracts whenever required. Section 8 defines the
function of the authority. The main ones include formulation of mitigation policies and
programs, in order to curb the crisis of climate change in the country. The technical aspects
of compliance to the Paris Agreement also fall within this body’s ambit, as it is responsible for
the submission of the Nationally Determined Contributions to the United Nations Framework
Convention on Climate. This aspect raises a question of accountability, as upper Pakistan
Climate Change Council members do not have a mandate to check the findings and technical
aspects of the Nationally Determined Contributions as compiled by the PCCA.
PAKISTAN CLIMATE CHANGE FUND
Section 12 ordains the formation of a fund pertaining to climate change to be established, in

order to provide a financial base by which the PCCA shall undertake its functioning. Section
(12) (2) highlights that ‘donations, endowments, grants and gifts’ may be used as a pool for
the fund to draw its funding. However, an important question to consider is section (12) (b)’s
relationship with section (10) (2)(b), which requires permission from higher officials of the
government before accepting any sort of foreign-based aid from organizations and
governments. A key feature of the major revenue that comes for developmental projects is
that they are foreign in nature, highlighting an issue with bureaucratic bottlenecks.
2.6.9. Guidelines for Sensitive and Critical Areas

The objective of the guideline is to provide guidance to project proponents and other
stakeholders in the environmental assessment process, so that the proposed projects are
planned and sited in a way that protects the values of sensitive and critical areas.
These guidelines will help proponents of projects requiring Environmental Reports:
 In identifying what are the officially notified protected areas in Pakistan. These may
include critical ecosystems including wildlife reserves and forests, archaeological sites,
monuments, buildings, antiquities, or cultural heritage sites;
 If a proposed development is on a notified protected area or within the vicinity of such an

area, then the approach detailed in this guideline should be adopted.
The proposed well sites are located inside the Nara Desert Wildlife Sanctuary. Mitigation
measures have been proposed in this EIA report to ensure that the drilling activities are carried
out in safe and responsible manner.
2.7. National Legislation on Oil and Gas Exploration and Production
2.7.1. The Regulation of Mines and Oilfields and Mineral Development

(Government Control) Act, 1978
The Regulations of Mines and Oilfields and Mineral Development (Government Control) Act,
1948 and the Pakistan Petroleum (Production) Rules, 1949 and Pakistan Petroleum
(Exploration and Production) Rules, 1986 empowers the Ministry of Petroleum to oversee the
petroleum exploration, development and production operations.
2.7.2. The Model Petroleum Concession Agreement, 2013

As for safety, the Model Petroleum Concession Agreement (2013) implementing the 1986
Exploration and Production Rules, specifically required observance of the 1974 Safety
regulations. The penalties imposed in the 1986 Exploration and Production Rules allow the
Director General Petroleum Concession to revoke a license if the rules are not satisfied by the
operator. The Mines and Oil Fields Act also specifies penalties including imposition of fines
and/or imprisonment.
2.7.3. The Pakistan Onshore Petroleum (Exploration & Production) Rules, 2013
These rules contain provisions related to reconnaissance surveys; license for petroleum
exploration, lease for petroleum development and production; accounts, records, inspection,
reports; and, miscellaneous matters. The rules allow any company incorporated inside or
outside Pakistan to apply for reconnaissance permit, exploration license or a development and
production lease. The manner in which application may be made has also been prescribed
i.e. in writing, mentioning principle place of business of applicant, furnishing of guarantee and
deposit of fees etc. The petroleum right, if not exercised within three months, shall lapse. Every
permit, license or lease shall be subject to terms and conditions mentioned in these rules
included in second schedule and any other conditions which Government may deem fit to
insert.
Permit for reconnaissance survey, petroleum exploration would be granted by the Government
to any company in accordance with the rules and the holder must perform the work program
stipulated in the license. The holder would not be entitled to extract any petroleum from
discoveries other than such test production as the Government may in its discretion permit.
Initial period of license shall not exceed three years.
The grant of lease for development and production, not exceeding twenty-five years, with
certain terms and conditions including the work program shall be granted by the Government
on being satisfied that the deposit can be commercially produced. The lease holder shall have
exclusive right to perform activities in connection with the development and production
including the right to undertake transportation subject to approval. The holder shall pay royalty
at the rate of 12.5 percent of the wellhead value of the petroleum produced and saved. In
addition to these powers of Government for recovering yearly lease rent, surface rent and
revocation of lease have also been described.
The lease or license holder shall maintain full and accurate accounts, and shall submit periodic
or occasional reports to DG, Petroleum Concessions. Any person authorized by Director
General, Petroleum Concessions, or any other competent authority shall have power to
examine the wells, plants, appliances etc. The lease or license holder shall maintain safety in
operations including non-interference with navigation, fisheries and agriculture. All reasonable
precautions shall be taken to prevent pollution or accumulation of trash and to prevent damage
to the environment and surroundings. Pakistani goods and services should be used subject to
their quality, employment and training of Pakistani personnel to develop the capability should
be ensured. Indemnity and force majeure have also been provided.
2.7.4. The Oil and Gas (Safety in Drilling and Production) Regulations, 1974
The 1974 Safety Regulations requires operators to send to the Chief Inspector of Mines,
Ministry of Labor and Manpower information on safety issues including provisions of protective
equipment and identification of safety personnel and emergency measures, designation of
safety personnel including Warfare and Safety Officer, and accident reporting.
The regulation identifies and explains issues that should be taken into consideration by the
proponent for a project involving exploration or production of oil and gas.
2.7.5. Petroleum Exploration and Production Policy, 2012

The purpose of this Petroleum Exploration and Production policy 2012 (Policy) is to establish
the policies procedures, tax and pricing regime in respect of petroleum exploration and
production (E&P) sector.
The principal objectives of this Policy are:
 To accelerate E&P activities in Pakistan with a view to achieve maximum self –

sufficiency in energy by increasing oil and gas production.
 To promote direct foreign investment in Pakistan by increasing the competitiveness of its

terms of investment in the upstream sector.
 To promote the involvement of Pakistani oil and gas companies in the country’s upstream
investment opportunities.
 To train the Pakistani professionals in E&P sector to international standards and create
favorable conditions for their retaining within the country.
 To promote increased E&P activity in the onshore frontier areas by providing globally
competitive incentives.
 To enable a more proactive management of resources though establishment of a

strengthened Directorate General of Petroleum Concessions (DGPC) and providing the
necessary control and procedures to enhance the effective management of Pakistan’s
petroleum reserves.
 To ensure the energy secure of the country by enhancing domestic exploration.
 To decrease reliance on imported energy by providing additional incentives to exploration
and production companies for enhancing indigenous production.
 To undertake exploitation of oil and gas resources in a socially, economically and
environmentally sustainable and responsible manner.
2.7.6. Sectoral Guidelines for Environmental Reports – Oil and Gas Exploration
and Production
These guidelines identify and explain issues that should be addressed for a proposal involving
exploration for, or production of, oil and gas. It is important to focus on key issues for specific
proposals. The matters identified in this guideline should provide guidance for the preparation
and assessment of most exploration and production proposals. It is intended that Companies
involved in Oil and Gas Exploration and Production will self-regulate and undertake monitoring
to meet or exceed the provisions of the Package and these sectorial guidelines; the
Responsible Authority reserves the right to spot check field operations from time to time.
2.8. Statutory Framework

The constitution of Pakistan contains provision for environmental protection and resource
conservation. The constitution mentions environmental pollution and the ecology as a subject
in the concurrent legislative list, meaning that both the provincial and federal government may
initiate and make legislation for the purpose. Article 9 of the Constitution defines the right to
life as a “fundamental right” in these words “No person shall be deprived of life or liberty save
in accordance with law”.
Several laws exist for the protection of the environment. Some of these laws are Federal and
the rest Provincial in character. The promulgation of the Environmental Protection Ordinance
1983 was the first codifying legislation on the issue of environmental protection. This was
indeed a consolidated enactment to plug the gaps and remove defects/deficiencies in the
legislation. The promulgation of this ordinance was followed, in 1984, by the establishment of
the Pakistan Environmental Protection Agency, the primary government institution dealing
with environmental issues. Significant work on developing environmental policy was carried
out in the late 1980s, which culminated in the drafting of the Pakistan National Conservation
Strategy. Provincial environmental protection agencies were also established at about the
same time. The National Environmental Quality Standards were established in 1993.
Prior to the 18th Amendment to the Constitution of Pakistan in 2010, the legislative powers
were distributed between the federal and provincial governments through two ‘lists’ attached
to the Constitution as Schedules. The Federal list covered the subjects over which the federal
government had exclusive legislative power, while the ‘Concurrent List’ contained subjects
regarding which both the federal and provincial governments could enact laws. The subject of
‘environmental pollution and ecology’ was included in the Concurrent List and hence allowed
both the national and provincial governments to enact laws on the subject. However, as a
result of the 18th Amendment this subject is now in the exclusive domain of the provincial
government. The main consequences of this change are as follows: i) The Ministry of
Environment at the federal level has been abolished. Its functions related to the national
environmental management haves been transferred to the provinces. The international
obligations in the context of environment will be managed by various ministries and
departments of the federal government, ii) The Pakistan Environmental Protection Act 1997
(PEPA 1997) is technically no longer applicable to the provinces. The provinces have enacted
their own legislation for environmental protection.
2.8.1. Sindh Environmental Protection Act, 2014

Sindh Environmental Protection Act 2014 envisages protection, improvement, conservation
and rehabilitation of environment of Sindh with the help of legal action against polluters and
green awakening of communities. It equally lays emphasis for the preservation of the natural
resources of Sindh and to adopt ways and means for restoring the balance in its eco-system
by avoiding all types of environmental hazards.
This act has also provided for Sindh Sustainable Fund derived from various sources such as
voluntary contributions or fees generated etc. This fund is utilized for protection, conservation
or improvement of environment.
Salient Features
Section-11: No person shall discharge or emit or allow the discharge or emission of any
effluent waste, pollutant, noise or adverse environmental effects in an amount, concentration
or level which is in excess to that specified in Sindh Environmental Quality Standards.
Section-12 & 13: No person shall import hazardous waste into Sindh province and handle
hazardous substances except under licenses etc.
Section 14: No person shall undertake any action which adversely affects environment or
which lead to pollute or impairment of or damage to biodiversity, ecosystem, aesthetics or any
damage to environment etc.
Section 15: This section deals with regulation of motor vehicles banning emission of air or
noise pollutants being emitted from them in excess of allowable standards.
Section 17: This section states that no proponent of a project shall commence construction or
operation unless he has filed with the Agency an initial environmental examination or
environmental impact assessment and has obtained from Agency approval in respect thereof.
SEPA shall review the IEE & EIA and accord approval subject to such terms and conditions
as it may prescribe or require. The agency shall communicate within four (04) months its
approval or otherwise from the date EIA is filed failing which the EIA shall deemed to have
been approved.
Section 21: Where agency is satisfied that the discharge or emission has occurred in violation
of any provision of this act or rules etc. then it may, after giving an opportunity to person
responsible, by order direct such person to take such measures within specified period. The
agency under this section has been empowered to immediately stop, prevent or minimize
emission, disposal etc. for remedying adverse environmental effects.
Section 22: The person who fails to comply with section 11, 17, 18 and 21 shall be punishable
with a fine which may extend to five million rupees, to the damage caused to environment and
in the case of a continuing contravention or failure, with an additional fine which may extend
to one hundred thousand rupees for every day during which such contravention or failure
continues. And, where a person convicted under sub-sections 1&2 had been previously
convicted for any contravention of this Act, the Environmental Protection Tribunal (EPT) may,
in addition to punishment, award imprisonment for a term that may extend up to three years,
or order confiscation or closure of facility etc.
Section 23: Where any violation of this Act has been committed by any of employee of any
corporate body, then, that employee shall be considered to be guilty of environmental
pollution.
Section 25: This section allows for establishment of Environmental Protection Tribunals.
2.8.2. Sindh EPA (Environmental Assessment) Regulations, 2021

The Sindh Environmental Protection Agency (Environmental Assessment) Regulations, 2021
prepared by SEPA under the powers conferred by section 37 of Sindh Environmental
Protection Act, 2014, provide the necessary details on the preparation, submission, and review
of the Initial Environmental Examination (IEE) and the Environmental Impact Assessment
(EIA). This revised edition of the Environmental Assessment was published and enforced in
September 2021, superseding the previous version titled Sindh Environmental Protection
Agency (Review of Initial Environmental Examination and Environmental Impact Assessment)
Regulations, 2014. The Sindh Environmental Protection Agency (Environmental Assessment)
Regulations, 2021 is attached as Annexure-II in this report.
The Sindh Environmental Protection Agency (Review of IEE/EIA) Regulations 2021 divides
projects in Schedules I, II & III depending upon the severity of environmental impact of the
project as follows:
Schedule I: A project falling in any category listed in Schedule-I shall file environmental
checklist with the Agency and the provisions of section 17 shall apply to such projects.
Schedule II: A project falls in Schedule II if it is likely to have adverse environmental impacts,
but of lesser degree or significance than those for category ‘A’ and all the mitigation measures
to handle the impact is manageable. Such types of projects need IEE report including EMP.
Schedule III: Projects categorized in Schedule III require an EIA if they generate significant
adverse environmental impacts that require a comprehensive management plan, or if the
project is located within or passes through: a) Areas declared by the Government of Pakistan
as environmentally sensitive (National Parks/Sanctuaries/Game Reserve), b) Areas of
international significance (e.g. protected wetland as designated by the RAMSAR Convention),
or c) Areas designated by the United Nations Educational, Scientific, and Cultural Organization
(UNESCO) as cultural heritage sites.
Oil and gas Exploration projects fall in Schedule II except those that are located within
environmentally sensitive areas in which case such projects fall in Schedule III requiring an
EIA. Since the proposed project in located in environmentally sensitive area viz. Nara
Desert Wildlife Sanctuary, therefore, an EIA study is required for this project.
Filing of report: Regulation 9 requires submission of two hardcopies and two electronic copies
accompanied by an application form (Schedule-V), copy of receipt of payment of review fee,
NOC from relevant departments (where applicable) and environmental checklist (if project falls
in schedule I).
Preliminary scrutiny: Regulation 10 of Sindh Environmental Protection Agency (Environmental

Assessment) Regulations, 2021 states;
(1) Any report filed by the proponent or applicant shall be returned, if found incomplete in terms
of Regulation 9.
(2) Notwithstanding anything contained in sub-regulation (1) of regulation 12, the Agency may
require the proponent to submit an additional information at any stage during the review
process. Regulation 10 states.
Review: The Agency shall make every effort to conclude its review process of the EA, EMP or
environmental checklist within fifteen days, of the IEE within thirty days, and of the EIA within
sixty days after receiving of complete case.
Validity: (1) The approval accorded by the Agency under section 17 read with sub-regulation
(2) of regulation 15 shall be valid, for commencement of construction, for a period of three
years from the date of issue.
(2) If construction is commenced during the initial three years validity period, the validity of the
approval shall stand extended for a further period of three year.
(3) The proponent may apply to the Agency for extension in the validity periods mentioned in
sub-regulations (1), (2), which may be granted by the Agency in its discretion for such period
not exceeding three years at a time, if the conditions of the approval do not require significant
change:
Provided that the Agency may require the proponent to submit a fresh IEE or EIA, if in its
opinion changes in location, design, construction and operation of the project so warrant.
2.8.3. Sindh Environmental Quality Standards (SEQS)

With the SEPA Act, 2014 the Sindh EPA revised the Environmental Quality Standards (EQS)
with full consultation of the private sector, industrialist, trade and business associations and
NGOs and approval of Sindh Environmental Protection Council has developed Sindh
Environmental Industrial Wastewater, Effluent, Domestic Sewerage, Industrial Air Emission,
Ambient Air, Noise for vehicles, Air Emissions for Vehicles and Drinking Water Quality
Standards 2016. Eni Pakistan is committed to comply with the applicable SEQS.
2.8.4. Self-Monitoring & Reporting Rules, 2014

The official name of the Rule is, “Sindh Environmental Quality Standards (Self-Monitoring and
Reporting by Industry) Rules, 2014”. The Government of Sindh in exercise of the powers
conferred by Section 36 of the Sindh Environmental Protection Act, 2014 promulgated these
rules in December, 2014. As per the rules set by this system, industries have to monitor
effluents and emissions in compliance with the SEQS and report it to provincial Environmental
Protection Agencies. This system classifies industry into three categories A, B and C each
corresponding to a specified reporting frequency. By virtue of these Rules, all the industrial
units are responsible for correct and timely submission of Environmental Monitoring Reports
to the Federal Agency.
2.8.5. Sindh wildlife Protection, Preservation, conservation and Management

Act, 2020
The Sindh Wildlife Protection, Preservation, Conservation and Management Bill, 2020 having
been passed by the Provincial Assembly of Sindh on 27th July, 2020 and assented to by the
Government of Sindh on 25th August, 2020 is hereby published as an Act of the Legislature
of Sindh.
This Act provide the protection, conservation, preservation, sustainable use of wild life for
establishment, management and maintenance of protected areas in the Province of Sindh and
to provide for matters connected therewith. This legislation has wider coverage, protecting
even those wild animals that enter Sindh via trans-boundary migration or as a result of human
activity.
Section 2(ii) addresses the Protected Animals of Sindh as listed in the First Schedule of this
Act including Sindh Ibex, Sindh Wild Goat (Capra aegagrus), Urial (Ovis orientalis), Chinkara
Gazelle (Gazella gazelle) and Hog Deer (Axis porcinus).
Section 2(xxxi) addresses the Game Animals as specified in Second Schedule of this Act.
These game animals include ducks, coots and moorhens, plovers, sandpipers, snipe and
certain other waders, stone curlews and stone plovers, partridges and quails, sand grouses,
pigeons and doves, and mammals. Among these game birds, the specific animals which are
found in the Nara Desert Wildlife Sanctuary are mentioned in the baseline chapter.
Section 9 (1) of this Act prohibits the following activities in Protected Areas of Sindh.
(a) hunting, shooting, killing, injuring, trapping, snaring and poisoning of wildlife;
(b) polluting, poisoning, draining or diverting the water resource for the purpose other
than the purpose which is essential for health of wildlife;
(c) cutting, girdling, damaging, injuring or destroying floral resources or burning and
collecting the plants;
(d) damaging the infrastructure & culturally significant natural structures, defacing,
counterfeiting the boundary' marks, encroachment, cultivation or changing the land
use;
(e) breaking the land for oil and gas exploration, seismic surveyor any kind of other
survey;
(f) drilling, kindling fire or abating in setting fire;
(g) grazing, fishing, trespassing;
(h) blowing pressure horn and playing electronic instruments such as television, radio
or tape-recorder, loudspeaker causing noise and' car racing or other noise related
sports; and
(i) quarrying, causing or fashioning of natural stones, exploration and exploitation of
mines and minerals.
Section 9(2) states that any person who contravenes or breaches any of the acts under Sub-
Section (1) shall be dealt as mentioned in Third Schedule as per Section 71.
Section 9(3) addresses that the Department with the previous sanction of competent authority
may, for scientific purpose, improvement of aesthetic, scenic beauty, and in the larger public
interest, relax to undertake any of the acts prohibited under Sub-Section (1) particularly in
wildlife protected areas, subject to fulfillment of the requirements provided in Section 86.
Section 12(1) also addresses the Protected Area and states that the department may with the
previous approval of the competent authority, by notification in the official Gazette, declare
any area to be a national park with a view to protection of wildlife and outstanding scenery,
flora and fauna (habitat) in the natural state in such manner as may be prescribed.
Section 13(1) The Department may with the previous approval of the competent authority may;
by notification in the official Gazette, declare any area to be a wildlife sanctuary and may
demarcate it in such manner as may be prescribed.
Section 13(2) states that the Wildlife Sanctuary shall be set-aside as undisturbed breeding
ground for the protection of wildlife and access for public shall, except in accordance with the
rules, be prohibited and no exploitation of forest therein shall be allowed except for reducing
fire hazards, epidemic or insect attacks or other natural calamities.
Section 14 states that the Department may, on the recommendations of Council Game
Reserve declare any area to be a game reserve, where hunting and shooting of wildlife shall
not be allowed, except under a special permit issued by Conservator Wildlife, which may
specify the maximum number of animals or birds that may be hunted or captured in the area,
duration for which such permits shall be valid.
Section 71 states that whosoever contravenes or attempts to contravene the provisions of this
Act or the rules and regulations made thereunder shall be punishable as provided in Third
Schedule of the Act.
Section 86 addresses the value of loss or degradation of habitat and states that the
Department shall determine through a committee of experts, the value of loss to habitat
caused as a result of any development activity of important nature, oil spill in coastal waters,
flood disaster, un-authorized land use in a protected area or wildlife habitat owned by
Government, to be recovered; and same amount shall be utilized for improvement.
All the 05 proposed drilling locations fall under the Protected Area, Nara Desert Wildlife
Sanctuary. As per section 9(3) of this Act as mentioned above; considering the need of oil and
gas for the country and to bridge the gap of supply and demand; in larger public interest, Eni
Pakistan will apply for the NOC for the proposed project from Sindh Wildlife department.
The proposed well sites are located inside the Nara Wildlife Sanctuary. However, the proposed
drilling activities shall be carried out following the recommended mitigation measures to
ensure that no harm or damage is done to the flora, fauna and the ecology of these protected
area. Part of Nara Canal Game Reserve is also inside the Kadanwari Block area however, the
nearest proposed well is at approximately 10 km away from the Nara Canal. Therefore, no
impact of the proposed activity is foreseen on the Nara Canal and its inhabitant.
2.8.6. The Forest Act (Sindh Amendment) Act, 1994

The Act empowers the provincial forest departments to declare any forest area as reserved or
protected. This Act prohibits the tree cutting in reserved and protected forest designated under
the Act. Permission must be taken from the Sindh Forest department to execute the cutting of
any tree. Section 1(1) of this Act mentions that illegal tree cutting is subjected to pose liability
or punishment to the project owner.
There is no protected or reserved forest at the proposed well sites designated under this Act.
2.8.7. The Sindh Cultural Heritage (Preservation) Act, 1994

It is the provincial law for the protection of cultural assets. Its objectives are similar to those of
the Antiquity Act.
No protected antiquity/cultural heritage site was identified within or near the impact zone of
the proposed Project. However, in case of discovery of any such object or infrastructure is
made during the proposed project activities, then activities shall be halted and concerned
government department shall be informed.
2.8.8. Hazardous Substance Rule, 2014

These Rules were notified to streamline procedures for issuance of licenses to industries /
businesses that generate hazardous waste, safety precautions for workers and devices them
methods for the removal of hazardous wastes in an environment friendly manner. The rules
also specify procedures to be adopted for import, transport, storage and disposal of hazardous
waste; and identify two hundred and forty-three hazardous substances and synthetic
chemicals.
The rules also specify the requirement of obtaining license from Sindh EPA for the import,
transport, storage and disposal of hazardous substances as specified in Schedule I of the
rules. No such substance as specified in Schedule I is anticipated to be used during the
proposed drilling project. Therefore, these rules will not be applicable.
2.9. International Treaties and Guidelines
2.9.1. The Convention on Biological Diversity

The Convention on Biological Diversity was opened for signature on 5 June 1992 during the
United Nations Conference on Environment and Development (UNCED) held in Rio de
Janeiro. The Convention entered into force on its thirtieth ratification on 29 December 1993.
Since then, it has received 168 signatures and 190 ratifications. In 1994, the United Nations
General Assembly declared May 22nd as the International Day for Biological Diversity. The
Convention on Biological Diversity was signed by Pakistan on 5 June 1992, and was ratified
by the Cabinet during 1994. Through the Convention, Pakistan and other signatory countries
are involved in an international partnership to help halt the global loss of biological diversity.
The Convention addresses biological diversity at the genetic and ecosystem level, and
provides a framework for its conservation and sustainable use.
The overall objectives of the Convention are the conservation of biological diversity, the
sustainable use of its components, and the fair and equitable sharing of the benefits arising
from the utilization of genetic resources. The Convention was developed in recognition of the
environmental, social, cultural and economic value of biological diversity, both now and in the
future, and its significant on-going reduction around the world.
Pakistan’s Obligations
As a Party to the Convention, Pakistan is obliged to the following general commitments:
 Take general measures for the conservation and sustainable use of biological diversity;
 Identify and monitor components of biological diversity, and activities that have an
adverse effect on biological diversity;
 Adopt measures for in-situ conservation, including a system of protected areas, the
restoration and rehabilitation of degraded areas, and the development of legislation and
other regulatory provisions for the protection of threatened species and their populations;
 Adopt measures for ex-situ conservation, including research on plants, animals, and
microorganisms, and measures for the rehabilitation and reintroduction of threatened
species;
 Integrate the consideration of sustainable use of the components of biological diversity
into national decision making;
 Adopt measures that act as incentives for the conservation and sustainable use of
biological diversity;
 Establish and maintain program for scientific and technical education and training in
measures for biological diversity conservation. Promote and encourage research and
training that contributes to biological diversity conservation;
 Promote understanding of the importance of, and the measures required for, the
conservation of biological diversity;
 Ensure environmental impact assessment of projects likely to adversely affect biological

diversity with a view to avoiding or minimizing adverse impacts;
 Endeavour to facilitate access to genetic resources for environmentally sound measures;
 Facilitate access of other Contracting Parties to technologies relevant to the conservation

and sustainable use of biological diversity;
 Facilitate the exchange of information relevant to the conservation and sustainable use
of biological diversity;
 Promote international, technical, and scientific co-operation in the field of conservation

and the sustainable use of biological diversity;
 Take measures to provide for participation in technical and scientific co-operation;
 Provide financial support and incentives for activities that are intended to achieve the
objectives of this convention.
 The preparation of the Biodiversity Action Plan by the MOE has been the first major step
towards the implementation of the CBD.
2.9.2. The Convention on Conservation of Migratory Species of Wild Animals,

1979
The Convention on the Conservation of Migratory Species of Wild Animals (CMS), 1979,
requires countries to take action to avoid endangering migratory species. The term "migratory
species" refers to the species of wild animals, a significant proportion of whose members
cyclically and predictably cross one or more national jurisdictional boundaries. The parties are
also required to promote or co-operate with other countries in matters of research on migratory
species.
The Convention contains two appendices. Appendix I contain the list of migratory species that
are endangered according to the best scientific evidence available. For these species, the
member states to the Convention are required to endeavor to:
 Conserve and restore their habitats.
 Prohibit their hunting, fishing, capturing, harassing and deliberate killing.

 Remove obstacles and minimize activities that seriously hinder their migration.
 Control other factors that might endanger them, including control of introduced exotic
species.
Appendix II lists the migratory species, or groups of species, that have an unfavorable
conservation status as well as those that would benefit significantly from the international co-
operation that could be achieved through intergovernmental agreements.
2.9.3. Convention on International Trade in Endangered Species of Wild Fauna

and Flora (CITES)
This convention came into effect on 03 March 1973 in Washington. In all 130 countries are
signatory to this convention with Pakistan signing the convention in 1976. The convention
requires the signatories to impose strict regulations (including penalization, confiscation of the
specimen etc.) regarding trade of all species threatened with extinction or that may become
so, in order not to further endanger their survival.
The Convention contains three appendices. Appendix I include all species threatened with
extinction which are or may be affected by trade. The Convention requires that trade in these
species should be subject to strict regulation. Appendix II includes species that are not
necessarily threatened presently but may become so unless trade in specimens of these
species is subject to strict regulation. Appendix III includes species which any contracting party
identifies as subject to regulations in trade and requires other parties to co-operate in this
matter.
2.9.4. IUCN Red List

The red list is published by IUCN and includes those species that are under potential threat of
extinction. These species have been categorized as:
 Endangered: species that are or may be facing a very high risk of extinction in the wild
in the near future; reduction of 50% or more either in the last 10 years or over the last
three generations, survive only in small numbers; or have very small populations.
 Vulnerable in Decline: species that are seen to be facing a risk of extinction in the wild,
having apparent reductions of 20% or more in the last 10 years or three generations.
 Vulnerable: species that are seen to be facing a high risk of extinction in the wild, but not
necessarily experiencing recent reductions in population size.
 Lower Risk: species that are seen to be facing a risk of extinction that is lesser in extent
that for any of the above categories.
 Data Deficient: species that may be at risk of extinction in the wild but at the present time
there is insufficient information available to make a firm decision about its status.
Other International Treaties signed by Pakistan relevant to Environmental Protection are:
Table 2.1: International Treaties signed by Pakistan

Subject Treaties signed
Climate Change & UN Framework Convention on Climate Change, 1992
the Ozone Layer • Vienna Convention for the Protection of the Ozone Layer, 1985
• The Montreal Protocol on Substances that Deplete Ozone Layer
and associated amendments, 1987
Waste & Pollution Basel Convention on the Control of Trans boundary Movement of
Hazardous Wastes and their Disposal, 1989.
2.10. Other Relevant Laws and Policies
2.10.1. Oil and Gas Regulatory Authority Ordinance, 2002

Oil and Gas Regulatory Authority (OGRA) issues all the licenses related to Oil & Gas setup.
Section 23 states that no person shall construct or operate any installation relating to oil,
undertake storage of oil, or undertake marketing of refined oil products unless a general or
specific license to undertake such activity has been issued and in in full force and effect and
the person is the licensee. The authority may grant a license subject to such conditions,
restrictions or stipulations as may be set out in, or attached to, the license.
2.11. International Environmental Guidelines
2.11.1. World Bank Guidelines on Environment

The principal World Bank publications that contain environmental guidelines are listed below.
 Environmental Assessment-Operational Policy 4.01. Washington, DC, USA. World Bank

1999.
 Environmental Assessment Sourcebook, Volume I: Policies, Procedures, and Cross
Sectoral Issues. World Bank Technical Paper Number 139, Environment Department,
the World Bank, 1991,
 Environmental Assessment Sourcebook, Volume III: Guidelines for Environmental
Assessment of Energy and Industry Projects. World Bank Technical Paper No. 154,
Environment Department, the World Bank, 1991.
 Pollution Prevention and Abatement Handbook: Towards Cleaner Production,
Environment Department, the World Bank, United Nations Industrial Development
Organization and the United Nations Environment Program, 1998.
The first two publications listed here provide general guidelines for the conduct of an EIA, and
address the EIA practitioners themselves as well as project designers. While the Sourcebook
in particular has been designed with Bank projects in mind, and is especially relevant for the
impact assessment of large-scale infrastructure projects, it contains a wealth of information
which is useful to environmentalists and project proponents.
The Sourcebook identifies a number of areas of concern, which should be addressed during
impact assessment. It sets out guidelines for the determination of impacts, provides a checklist
of tools to identify possible biodiversity issues and suggests possible mitigation measures.
Possible development project impacts on wild lands, wetlands, forests etc. are also identified
and mitigation measures suggested. The Sourcebook also highlights concerns in social impact
assessment, and emphasizes the need to incorporate socio-economic issues in EIA
exercises. The EHS guidelines are technical reference documents with general and industry-
specific examples of Good International Industry Practice (GIIP).
2.11.2. IFC Environmental, Health, and Safety Guidelines for Onshore Oil
and Gas Development
The EHS Guidelines for Onshore Oil and Gas Development include information relevant to
seismic exploration; exploration and production drilling; development and production activities;
transportation activities including pipelines; other facilities including pump stations, metering
stations, pigging stations, compressor stations and storage facilities; ancillary and support
operations; and decommissioning. The guidelines especially emphasize on the following items
and provides guidelines to cater the following issues:
 Air quality
 Hazardous Materials Management
 Noise
 Terrestrial Impacts and Project Footprint

 Spills
 Fire and Explosion
 Emergency preparedness and response

 Performance Indicators and Monitoring
Chapter 3 Project Description

3.1. The Project
Eni Pakistan plans to conduct drilling of 05 Development wells and lay associated flow lines
in case oil/gas discovery is made, inside the protected areas of Kadanwari Block (Nara Desert
Wildlife Sanctuary) – district Khairpur, for the purpose of oil and gas exploration and
production. Kadanwari Block is spread on an area of 458 Km2 and is located in Sukkur and
Khairpur districts.
The proposed well sites are situated in tehsil Nara of district Khairpur. The location coordinates
of the proposed well sites are given in table below while the location map is attached as figure
3.1.
Table 3.1: Location Coordinates of Proposed well sites in

Kadanwari Block
Well ID Location Coordinates
Eni Well 1 27° 5'8.92"N, 69°12'51.57"E
Eni Well 2 27° 5'35.31"N, 69°17'43.82"E
Eni Well 3 27°11'53.32"N, 69° 7'33.14"E
Eni Well 4 27° 2'46.75"N, 69°15'32.77"E
Eni Well 5 27° 3'52.13"N, 69°12'58.09"E
NOTE: These location coordinates are tentative & subject to change
depending on ground conditions
The area within 5 km radius of the proposed drilling and associated construction activities is
referred to as the project area. Actual wells can be relocated within 05 km radius from the
proposed well locations.
3.2. Project Need

Energy, being lifeline of socio-economic development of a country, holds a dominant position
in the development plan as ensuring energy security is one of the important themes of the
Vision along with water and food. Pakistan is facing a formidable challenge of energy shortage
with the demand outweighing its supply. The energy shortage has adversely affected all
sectors of the economy.
Pakistan’s existing energy mix is highly dependent on expensive fuels, like oil and gas, instead
of coal and hydel. At the moment, the country is termed as an energy deficient nation and
relies heavily on imported fossil fuels2. According to estimates around 60% of the total foreign
exchange of the Pakistanis is spent on importing the fossil fuels. The country is importing an
estimated 308.9 thousand barrels of oil per day while the domestic production is less than
63,000 barrels per day3.
2 Rehman, S.A et. al.; The Future of Sustainable Energy Production in Pakistan: A System Dynamics-Based
Approach for Estimating Hubbert Peaks, 2017
3 Ibid.
Figure 3.1: Location of proposed well sites in Kadanwari Block

3.3. Project objectives

The goal of the proposed drilling activities is;
• Exploration of new hydrocarbon reserves through drilling of development wells on the

basis of promising geological features.
• To enhance the production of hydrocarbons in order to reduce energy deficiencies of

the Pakistan.
The project will help increase the production of hydrocarbons and thus overcome the energy
crisis in the country and support the economic growth.
3.4. Drilling Operation
3.4.1. Proposed Project Activities.

This operation will comprise of drilling of development wells within prospective areas based
on the seismic data interpretations. The proposed drilling project will entail the following
activities:
 Phase I – Construction
− Civil contractor’s mobilization,
− Development of access road,
− Rig camp construction,

− Security camp construction,
− Well site construction,
− Civil contractor’s demobilization,

 Phase II – Well Drilling
− Rig mobilization and rig camp establishment
− Well drilling and testing

− Vertical Seismic Profiling (VSP)
− Rig demobilization
 Phase III - Site Restoration (depending on the failure or success of the well)
Development Wells
Well-01 27° 5'8.92"N, 69°12'51.57"E
1 Desert & sparse vegetation
Land Attributes:
shrub, grass small trees
Well Location Eni Well-1 and surrounding land

Eni Well-02 27° 5'35.31"N, 69°17'43.82"E
Land Attributes: Desert and sparse shrub & grass

Eni Well-03 27°11'53.32"N, 69° 7'33.14"E
Land Attributes: Irrigated agricultural land

Eni Well-04 27° 2'46.75"N, 69°15'32.77"E
Land Attributes: Desert and sparse shrub, grass

Eni Well-05 27° 3'52.13"N, 69°12'58.09"E

Land Attributes: Desert and sparse shrub, grass and trees
3.4.2. Schedule
The drilling operation of each well, from civil works to plugging and abandonment is expected
to take about approximately 3 months. The tentative duration of key activities is provided
below;
Table 3.2: Tentative durations of Drilling phase activities

Activity Duration
Mobilization 12 days
Civil works 50 days
Drilling 32 days
Testing and demobilization 08 days
3.4.3. Drilling Activities
3.4.3.1. Construction
A well site, rig camp and access track will be developed for the drilling of well. The construction
contractor will develop its own camp for construction purposes. The contractor will also hire
local people for unskilled jobs.
3.4.3.2. Well Site

Construction works to develop a well location will involve the following:
 Clearing, leveling and compaction;

 Construction of the drilling rig pad and cellar;
 Construction of cuttings pit, water pit and waste water pit;

 Construction of septic tanks and soak pits; lined holding tanks (instead of soak pit) to be
constructed if depth of ground water table (seasonally high) is less than 4 feet from the
bottom of the pit;
 Construction of platform for fuel storage tank with sump & loading/un-loading pad;
 Installation of a chain link fence around the well site.
3.4.3.3. Rig Camp

The rig camp site will consist of portable cabins, kitchens, mess rooms, bathrooms and laundry
area, etc. for which limited construction works including leveling, grading, filling and
compaction will be required. Development of campsite includes, but not limited to the following:
 Leveling and compaction of area for the campsite;

 Provision of drainage works in and around the campsite;
 Laying and compaction of the gravel topping in the campsite;
 Construction of fuel storage tank with sump and loading/un-loading pad;
 Provision of fence, access and emergency gates;

 Construction of septic tanks and soak pits; lined holding tanks (instead of soak pit) to be
constructed if depth of ground water table (seasonally high) is less than 4 feet from the
bottom of the pit;
 Installation of security guard wooden cabins; and
 Installation of sewerage pipeline with manholes for the septic system.
3.4.3.4. Access Track

Construction works to develop the access road includes, but not limited to the following:
 Cutting and filling;

 Leveling, grading and compaction of sub grade;
 Laying and gravel compaction;
 Construction of pipe culverts and Fjord crossing;

 Provision of earthen catch drains;
 Provision of pass points at every 1,000 meters; and
 Provision of milestones and road safety signs.
Existing tracks (if any) will be used as much as possible to access the selected drilling
locations. The access roads will be upgraded / built to a standard that is suitable for movement
of 40 ft. flatbed trucks. The road will be 9 – 10 m wide for safe movement of vehicles during
normal operation and rig movement and compacted with gravel.
Water required during construction phase will be obtained from either local tube wells
predominantly from Water Well, or new water wells installed by Eni Pakistan in the area of
operation. Approximately 656,000 liters of water would be required per day during construction
phase for both construction and domestic purposes.
After completion of construction activities, all except for a few machineries, equipment and
personnel required for maintenance of the access road will be demobilized form the area.
3.4.3.5. Rig Mobilization

Following the construction of the well site, rig camp and access road, mobilization of the rig
and related machinery and equipment will commence. Mobilization will involve the
transportation of the following to the designated drilling location.
 The drilling rig;

 Ancillary equipment such as power generators, mud pumps, mud tanks, shale shakers,
cementing unit, drill pipes and collars;
 Porta-cabin style camp, complete with all catering, power generation, laundry and other
facilities;
 Drilling and other necessary support personnel; and

 Drilling materials such as casing and associated accessories, well heads, drill bits, drilling
fluid chemicals and liner hanger equipment etc.
The drilling rig will be transported to the site using 40-ft long trailers. Depending on the type of
rig, approximately 160 rig load of equipment will be transported during mobilization. The rig
will be assembled and erected over the well location.
3.4.3.6. Drilling
Drilling will be carried out using conventional equipment, techniques and practices for
hydrocarbon exploration. In this operation, a rotary drilling rig will be employed. The derrick
will be positioned on a steel platform known as the rig floor.. The rig floor will provide working
area for the drilling operations and personnel. A hoisting drum called draw works will be
mounted on the rig floor at the base of the derrick. A wire rope called the drilling line will pass
from the draw works to the top of the derrick through a system of pulleys called the crown
block and will be attached to a further system of pulleys known as the hook and block. The
whole system of wire rope and pulleys will operate like a crane. A drill string made up of
uniform lengths of hollow steel pipes will be suspended from the hooks. Suspended from the
drill string will be the drill bit. The drill bit will drill through the formations by the combined effect
of the weight of the drill collar and the rotary action provided to the bit by a rotary table mounted
on the rig floor. Rotation of the drilling bit and string is achieved by means of powerful electric
motors on the surface.
As drilling progresses in a given section of the well the length of the drill string will be increased
by the addition of new lengths of pipes. Steel pipes known as casing will be lowered into the
hole to line the sides of the well and prevent the hole from collapsing. At the end of drilling
each section, these steel casings will be cemented into place by pumping cement into the
space between the casing and the surrounding strata. The sections of the well will be drilled
in this manner until the desired target depth is achieved. A workforce of 100 - 150 including
security guards and casual labors will be employed for drilling activity at one well location and
it will take around 2 to 3 months to complete the drilling at one location. Anatomy of a generic
rotary drilling rig is shown in Figure 3.2.
3.4.3.7. Drilling Mud

Water based Drilling mud will be used during the operation to serve the following functions:
 Flushing out drilled solids from the bottom of the hole and transporting them to the
surface;
 Lubrication and cooling of the drill bit and string;
 Deposition of an impermeable layer on the wall of the well-bore so as to seal the drilled
formations; and
 Countering the natural formation pressures and preventing uncontrolled flow of fluid from
the formations.
Figure 3.2: Drilling Rig
The drilling mud will consist of slurry of formation cuttings suspended in a liquid phase. Fresh
water mud at the time of spud will comprise of bentonite, Sodium hydroxide (NaOH), Sodium
carbonate (Na2CO3) and lime in water. The additives such as bentonite, barite and salts will
be used for initial mud formulation and subsequent changes as required during the operation.
The exact constituents and concentrations will be finalized before and during each proposed
drilling operation. The quantity of drilling mud used and the cuttings generated will depend
upon the well geology, depth of the well and other operating factors.
Conventional drilling waste management involves discharging the mud and cuttings into a
lined waste pit. After completion of drilling, the cuttings in the waste pit will be allowed to dry
out. The cuttings will then be encapsulated within the HDPE liner and the waste pit will be
backfilled leaving a top soil cover over the pit at the time of site restoration.
The constituents for a general water-based mud (WBM) are given in table 3.3 and special
additives and their functions in WBM are shown in table 3.4.
Table 3.3: Constituents for Water Based Mud

S. No Chemicals
1 Barite
2 Bentonite
3 Carboxy Methyl Cellulose
4 Mud Thinner/Conditioner
5 Resinated Lignite
6 Non-Weighted Spotting Fluid
7 Weighted Spotting Fluid
8 EP Lube
9 Drilling Detergent
10 Caustic Soda
11 Potassium Chloride
12 Soda Ash
Note: Barite and water are the major constituent of Water Based Drilling Mud and other
constituent are in very minor quantity.
Table 3.4: Special Additives and their Function in Water Based Drilling Fluid
S. No Discharge Category Exploration
1 Sodium bicarbonate Eliminate excess calcium ions due to cement
contamination
2 Sodium Chloride Minimize borehole washout in salt zone
3 Groundnut shells, mica Minimize loss of drilling mud to formation
of cellethane
4 Cellulose polymers or Counter thick, sticky filter cake, decrease filter loss to
starch formation
5 Aluminum stearate Minimize foaming
6 Vegetable Oil lubricant Reduce torque and drag on drill string
7 Pill of oil-based mud Counter differential pressure sticking of drilling string.
spotting fluid Pill is placed down hole opposite contact zone to free
pipe
3.4.3.8. Coring and Well Logging

In the potential reservoir section, cores of rock will be taken from the borehole and a number
of well logs are performed. Cores and well logs will be used to confirm geology of the structures
being bored through and assess the accuracy of the seismic survey data interpretation done
before drilling. Coring and well logging will also help identify possible hydrocarbon.
3.4.3.9. Well Evaluation

After having drilled to the specified depth, a number of logs for hydrocarbon bearing strata will
be taken to accurately measure the pressure and fluid content of the zone. The main
objectives of the logs will be to determine the fluid composition (gas, oil, or water), whether or
not it will flow, and its pressure regime.
If test results show that oil/gas has been encountered, it becomes necessary to conduct further
tests to determine whether it is feasible to develop the well. Tests are conducted to determine
the gas composition and the reservoir's permeability.
Once the temporary or permanent valves are in place, it is ensured that the mud column is
more than adequate to counteract any formation pressures that could be released. Hydraulic
surface safety valve (SSV) or a Blowout Preventer (BOP) is kept in place throughout the test.
Once these steps have been taken, gas is allowed to flow to the surface, and is passed through
a 3-phase separator that segregates the fluid into oil, water and gas (if present) or condensate.
Metering devices and valves are used to estimate the gas production rate, after which the gas
and associated condensate are flared, and water discharged into the lined pit / storage tank.
3.4.3.10. Well Completion

If data collected from coring, logging and well testing shows that the well can be used as a
producing well then a completion string consisting of subsurface equipment i.e. production
packer, flow measuring devices, circulation devices and sub-surface safety valve, runs
downhole to enable production from the well to surface facilities through flow line etc. to
enable production from the well will be installed just above the producing formation. The mud
in the well will be displaced by completion fluid, which typically consist of solid free brine,
containing small volumes of chemicals designed to protect the formation and tubulars. These
chemicals will include a corrosion inhibitor, an oxygen scavenger, biocide, and a chemical for
pH control. The final design of the completion equipment will depend on the fluid composition,
pressure and temperature regime and flow rates.
3.4.3.11. Well Control & Blow out Preventer

In addition to careful monitoring and control of the mud system and the installation of casing
in each section of the well, a surface wellhead consisting Blow out Preventer (BOP) will be
installed at the top of the casing. The function of the BOP is to prevent uncontrolled flow from
the well by positively closing in the well bore as and when required. The BOP is made up of a
series of hydraulically operated rams, and is designed to withstand pressures well in excess
of those expected to be encountered.
Figure 3.3: Blowout Preventer

3.4.4. Demobilization and Site Restoration

After completion of the drilling and testing operations, the rig will be dismantled and
demobilized off the site. The wellhead will remain in situ, but all other equipment and materials
including empty drums used and unused chemicals, fuels and lubricants will be removed from
the well site by their respective suppliers. After well evaluation, a decision on whether to
abandon or further develop the well will be taken. If it is decided that the well is to be
abandoned, the site will be restored, as far as possible, to its original condition. All the concrete
will be broken up and removed, the fencing will be removed, and the area levelled. All the
broken concrete may be taken outside of the project area for disposal, reused for backfilling
of pits or provided to locals for re-use. All waste products, solid and liquid will be disposed of
in accordance with the requirements of the EIA. All pits will be backfilled with at least 1 meter
of top soil cover. Drill cuttings will be disposed of within the lined cuttings pit at the well site.
Liquids / wastewater will be allowed to evaporate or treated and disposed of through waste
contractor. The access roads and other construction works / foundations etc. may be left intact
if local people desire to use them. If not, they too will be restored and the land returned to its
original use.
An alternative situation is if commercial quantities of oil and gas are discovered, before or after
testing then the well will be suspended while testing results are analyzed, reservoir modelling
conducted and production equipment ordered. In this case, the oil and gas bearing zones in
the well will be squeeze-cemented and further cement plugs and permanent packer /cement
retainers will be set above the perforation, the casing shoes and at surface.
3.4.5. General requirements for drilling activities
3.4.5.1. Power Generation

The drilling process required movement of drill bit through draws works which requires power.
The power requirement of the drilling rig will be met by using the diesel generators. The
exhaust stack of the diesel generator is likely to vent the emissions.
Figure 3.4: Diesel generators with mechanical transmission

3.4.5.2. Chemical Storage

The drilling rig will have normal storage facilities for fuel oil, required chemicals and the
necessary tubular and equipment. The storage places will be clearly marked with safe
operating facilities and practices.
3.4.6. Staffing & Supplies

The drilling rig will be operated by approximately 170 persons on the rig at any time. The
manpower will operate in two shifts with continuous operations on the rig. Local people will be
given priority for unskilled jobs. During the drilling program, the supplies, with the exception of
casing, will be transported to the rig in smaller trucks. Casing will be carried to the rig in 40 ft
flatbed trucks. General supplies transported will include camp supplies (food, etc.), fuels, oils
and chemicals, and equipment maintenance parts. Project personnel will travel to and from
the rig in smaller vehicles, mostly four-wheel drive pickups.
Water for rig and rig camp operation will be transported to the well sites from local water wells
or water wells installed by Eni Pakistan in the project area in consultation with local
communities. A maximum of 80m3 of water will be required per day during the drilling
operation, which may exceed to 150m3 during peak drilling activity. Water may be obtained
from water wells installed by Eni Pakistan or existing local tube wells in the area by following
the requirements of EIA. The surface water resources will not be used during drilling phase.
3.5. Flow lines Installation

In case of successful drilling and discovery of oil or gas reserve is made, flow lines will be laid
from respective wells to the gas plant facility. Route and length of the flow lines will be finalized
later after successful drilling. The flow lines will be buried at a depth of approximately 01 meter.
Diameter of the flow line will be 6” and 10" depend on flow, and Cathodic Protection will be
installed on the flow lines for detection of leakage or damage to the flow line.
3.5.1. Construction standards

The Flow line shall be constructed according to the standards of API (American Petroleum
Institute), NACE (National Association of Corrosion Engineers) and ASME (American Society
of Mechanical Engineers) and Eni Pakistan procedures & guideline.
3.5.2. Typical details of Flow Line Laying activities

The laying of flow lines involves various steps. Below are the steps that are typically followed
for laying of flow lines.
3.5.2.1. Construction Staging Areas & Storage Yards

In order to construct the flow lines, staging areas and storage yards are cleared, strategically
located along the planned right-of-way. These areas are used to stockpile pipe and to store
fuel tanks, sand bags, silt fencing, stakes, and equipment parts. They provide parking for
construction equipment, trucks and vehicles, and locations for office trailers.
3.5.2.2. Clear Cutting the ROW

After the equipment is accessible in the staging area, work begins to clear cut the flow line
right-of-way. Topsoil is removed carefully before the trench digging begins. The goal is to
preserve the original topsoil from the site to return it to its natural condition without losing the
rich top layer of soil.
This permanent Right-of-Way (RoW) is purchased or leased on a long-term basis from its
current owners. Standard 24 meter with additional working area to be taken either side of track
is required during the construction period and will be temporarily leased from the individual
local owners.
3.5.2.3. Excavating the Trench

The trench for the flow line is dug after the ROW is cleared. Particular care must be taken to
prevent any damage to the existing infrastructure. The soil removed during trenching goes into
storage throughout the construction process. That soil goes back into the ground to fill in
around the pipe. These practices help maintain the original state of the area while conserving
resources.
3.5.2.4. Pipe Transport, Stringing, & Assembly

When the trench is completed, pre-coated segments of pipe are transported from stockpiles
in the staging area to the right-of-way. Pipes are laid below ground beside the trench, or within
the trench on top of supportive sandbags in steep terrain. Certain pipe sections are bent using
a pipe bending tool to allow the pipeline to follow the planned route and the terrain. The pipe
sections are then welded together, Cathodic protection is provided to prevent corrosion.
Finally, the weld joints are inspected to ensure their quality. Connected lengths of pipe can
then be lowered into the trench.
3.5.2.5. Obstacles: Roads & Canals

Crossings in flow line route for example road, canal/water channel, utility line etc. are mostly
avoided. Typically, pipelines are constructed underneath these obstacles by either boring for
shallow depth or using horizontal directional drilling (HDD) for deeper placement.
3.5.2.6. Testing
Before completing the project, the flow line integrity is verified through Radiography testing
followed by hydrostatic testing. In hydrostatic testing water is sent through the pipelines and
the pressure is increased to above the maximum operational level. If the pipeline remains
intact during this test, it is deemed operational. Water for the hydrotesting will be acquired
from local bore well or brought from remote source through water bowser. No chemical would
be added in the water. After hydrotesting, the water will be collected in wastewater pit and
allowed to evaporate.
3.5.2.7. Site Restoration

After the pipe is inspected, the trench is filled in. With the flow line in position, the crew begins
backfilling the trench to cover the flow line. The original soil goes back into the trench in the
reverse order of how it was removed. This means the subsoil goes in first to keep the layering
and composition the same as it was originally. Keeping great caution to ensure no damage
occurs to the flow line or the coating. Once the subsoil fills in the trench, the topsoil goes back
on top.
3.6. Noise, Air Emissions, Effluents and Solid Waste Generation

This section provides the details of noise generation sources and waste streams during the
various phases of the project. Details of each of these are provided as follows:
3.6.1. Noise
Noise that could be generated during the drilling operations include those generated by field
machinery (bulldozer and support vehicles), machinery for drilling and generators and work
yard at the camp site. The proponent will ensure the compliance of SEQS standards for Noise.
Noise is likely to be generated by the following activities:
 Vehicular traffic on the access road;
 The operation of drilling rig at the well site; and

 The operation of diesel generators and other equipment at the well site and the camp.
Sources of noise during construction and drilling phases are listed below:
Construction phase
 Operation of generator at construction base camp;

 Movement of vehicles;
 Construction works along access track and at the well site and rig camp
Drilling phase
 Operations of generators at the rig camp;

 Drilling rig;
 Movement of vehicles
3.6.2. Emissions
Emissions during construction and drilling will include:
 Dust emissions during construction – these will be controlled by proper water sprinkling
and good construction management
 Dust emissions during road travel – these will be controlled by avoiding off road travel,
observing speed limits and track maintenance
 Exhaust emissions from vehicles and generators – these will be controlled by proper
maintenance (exhaust emissions from generators at the construction base camp, well
site and rig camp will generally meet the SEQS)
 Emissions during flaring and H2S release during drilling and testing – the effects of these
emissions will be controlled by maintaining a safe distance of 500m from communities
and adhering to company’s emergency response plans in case of H2S release.
 Fugitive emissions – the effects of these volatile organic content (VOC) emissions will be
controlled by maintaining safe distances. Volatile hydrocarbon levels will be regularly
checked/monitored as part of safety program. During operation, areas with higher
concentration levels will be identified and appropriately mitigated.
The emissions produced by the power generators at the well site and camp are listed in tables
below.
Table 3.5: Typical Emissions from 920 KW Diesel Generator

Generator 75% Load
Size 920 KW
Fuel consumption 192 liters /hour
Sulphur Dioxide (SO2) emission 3,169 g/h
Carbon monoxide (CO) emissions 2,666 g/h
Nitrogen oxides (NOx) emissions 6,024 g/h
Particulate matter emissions 314 g/h
Exhaust flow rate 64 Nm3/min
Exhaust stack temperatures 448 oC
* Fuel consumption and exhaust temperature based upon data sheet of Caterpillar Diesel Generator
Model CAT 3512. Emissions calculated based on the emissions factors given in AP42 (USEPA1996).
3.6.3. Effluents and Solid Waste

All Categories of wastes generated during construction and drilling and their proposed
methods of disposal are discussed below:
 Clinical wastes – these will be stored separately from other wastes and sent to an offsite
commercial or private incinerator approved by Sindh EPA.
 Combustible wastes – combustible wastes will include paper, packaging material etc. It
will be stored separately in waste segregation containers. All types of combustible wastes
will be provided to waste contractor for recycling or appropriate disposal. Construction of
burning pit or burning of combustible wastes will not be allowed on site.
 Recyclable or re-usable wastes – these will include used oil, papers, glass, tin, metals,
workshop wastes etc. All recyclable wastes will be sent to waste contractors for recycling
or re-use.
 Drill cuttings and mud – a Water Based Mud will be used during drilling. The drill cuttings
and mud will be stored at the well site in lined pit. The drilling mud will be allowed to
evaporate inside the mud pit. The drill cuttings will also be allowed to dry out. After that,
the mud pit and the cuttings pit will be backfilled.
 Hazardous wastes – these will include paint and solvents, mercury containing wastes
e.g., fluorescent lighting and batteries etc. All types of hazardous waste shall be
separately stored onsite and will be sent to Sindh EPA approved waste contractors for
disposal.
 Food wastes – all kinds of food waste will be dumped in garbage pit.
 Produced formation fluids – produced formation fluids during testing will be flared along
with the gas or collected inside the lined waste pits. Produced water can also be
reinjected into the deep subsurface formations wherever possible and feasible.
 Condensate – if condensate is encountered during the drilling of proposed wells, it will

be transported offsite and sold to the nearest refinery.
 Domestic effluents – Sewage Treatment Plant (STP) shall be the most preferred option
for handling of black/grey water due to its most environment friendly option, but in case
of unavailability of STP, septic tank and soak pits shall be provided. Septic tank and soak
pit shall be covered properly to avoid obnoxious smells in surrounding areas.
Furthermore, sprinkling of grey water will not be allowed, in case if septic tank gets filled
with sludge, septic tank shall be emptied through vacuum truck and material shall be
transferred to treatment facility or approved municipal drain for appropriate disposal.
3.6.4. Wastewater Management

The main concept for waste management will be that the environmental impacts associated
with the disposal of project-generated waste are within acceptable limits. Concrete pads will
be built to collect grey water from kitchens and washing areas. Grey water will flow from the
concrete pads into pits where it will be treated before being sprayed over the ground to
compact the dust.
Solid waste will be segregated. Most of the garbage plastic, glass, and other non- combustible
and recyclable waste will be segregated and supplied to vendors for recycling.
Anything potentially dangerous such as batteries and aerosols will be placed in a separate
container, appropriately marked, and disposed of with the proper authority.
Medical waste will be bagged and binned in a separate container appropriately labeled and
will be sent to SEPA approved waste contractor for safe disposal. Table 3.6 lists the types of
wastes that are expected to be produced during the project activities and their planned
disposal options.
Table 3.6: Summary of Construction Waste Generation and Disposal

Category Waste Generated Disposal
Liquid Waste
Hazardous Waste oils, lubricants Stored and transported offsite for recycling
and reuse through approved contractor
Sewage/black water Black water will be disposed-off through
septic tanks
Non- Grey Water Will be disposed of through soak
hazardous pits/sprinkling on access tracks
Solid Waste
Hazardous Paint tins, batteries, rubber tires, used oil Hold at on-site hazardous waste storage
filters, chemical containers, contaminated facility and disposal through an authorized
soil (chemical) grease trap sludge and waste disposal contractor
other hazardous waste
Product and chemical containers Return to vendor
(including partially full)
Non- Cable drums, wood, paper packaging, Recycling via approved vendors
hazardous building material, plastic sheeting, cement
recyclable bags, scrap metal, recyclable plastic
waste sheeting, construction debris etc.
Non- Food waste, non-recyclable Disposed via waste management contractor.
recyclable wood/packaging Food waste will be dumped in garbage pit.
Construction debris and inert waste Recycled as fill material or landfill
3.7. Project alternatives
3.7.1. Introduction
An analysis of available alternatives to the proposed drilling operations have been carried out
in this section to ensure that the best possible management and technology options will be
employed during project implementation. The analyses of alternatives have been discussed
under two headings, management alternatives and technological alternatives.
3.7.2. Management Options
3.7.2.1. No Project Option

The energy sector plays a key role in the development and growth of Pakistan's economy.
Because of its importance, the energy sector has been selected by the present government
as one of the four drivers of economic growth. Pakistan spends billions of dollars on the import
of crude oil and other petroleum products and as a result total import bill is rising for every
consecutive fiscal year. To reduce this loss of foreign exchange the government is committed
to maximum replacement of imported furnace oil and diesel oil with indigenous natural gas.
In view of Pakistan's current balance of payments difficulties, it has become imperative for the
country to explore indigenous resources in the energy sector, as a reliable supply of energy is
crucial to the achieving the national development targets in the commodity producing sectors.
Natural gas is a particularly attractive option as the environmental effects associated with its
usage are also minimal in comparison to other fossil fuels.
An oil or gas discovery in the area of operation will augment the present oil & gas supplies of
the country and reduce Pakistan's reliance on imported fuel. In view of the above the No
Project Option seems to be a highly unfavorable option.
3.7.2.2. Well-site Alternatives

As exploration activities involve large investments, the area of the operation is carefully
selected after assessing that the geological characteristics conducive to the presence of oil
and gas reserves are present in the area.
Eni Pakistan already has few producing wells in the project area. Therefore, the prospects of
discovering new reserves in the Kadanwari block are quite high.
3.7.3. Technology Options
3.7.3.1. Drilling Technique

Conventional rotary drilling has been historically used for the drilling of oil and gas wells. Other
drilling techniques include coiled tubing and slim holes. Despite some environmental gains in
the use of coiled tubing and slim holes (reduced well site area, reduced waste volumes etc.)
both techniques seem to share a number of technical disadvantages and operational
limitations. Moreover, the rigs are not available in Pakistan and in case of a breakdown
required back-up and service’ facilities may not be available as readily as for conventional
rigs. Advantages of the two techniques therefore do not outweigh their disadvantages.
Conventional drilling technique is therefore evaluated to be the best alternative.
3.7.3.2. Drilling Mud

Generally, two broad categories of mud are used for drilling of oil or gas wells; oil based and
water-based. Oil based mud is formulated by mixing chemicals with diesel. This mud is not
considered to be environment friendly due to the risk of contamination of subsurface
formations during drilling and the generation of oily drilled cuttings which require specialized
handling and treatment. A water-based mud system will be used which due to the above-
mentioned reasons has environmental preference over oil-based mud and is, therefore,
considered to be the preferred alternative.
3.7.3.3. Disposal of Drilling Wastes

lined waste pit. Cuttings segregation and fluid recovery unit will be used for better
management and disposal of drilling wastes. This will further allow:
 Additional drying of the cuttings making their disposal into the lined waste pit easier;
 Recovery of the excess mud associated with the cuttings. The mud can be re‐used
thereby reducing the overall water consumption and chemicals usage for mud
formulation; and
 Reduction in the size of the waste pit due to the reduction in the mud content associated
with the cuttings and due to less water consumption and mud formulation.
The waste management system is considered to be technologically and environmentally the

most preferred option. After completion of drilling, the cuttings remaining in the waste pit will
be allowed to dry out. The cuttings will then be encapsulated within the HDPE liner and the
waste pit will be backfilled leaving a top soil cover over the pit at the time of site restoration.
3.7.3.4. Treatment / Disposal of Water Based Mud Cuttings

Below mentioned Procedure for waste, management should be followed. If on-site burial is
the only option, the following minimum conditions should be met:
 The pit contents should be dried out as far as possible;

 If necessary, the waste should be mixed with an appropriate quantity of subsoil;
 A minimum of one meter of clean subsoil should be placed over the mix;
 Topsoil should not be used for mixing, but it should be placed over the subsoil to fully
reinstate the area;
 The pit waste should be analyzed and tested, in order to define any possible restriction
to further land use, due to poor geotechnical properties of the resulting soil; a risk-based
assessment may also be necessary to demonstrate that internationally recognized
thresholds for chemical exposure are not exceeded; and
 Provisions should be made for closure and aftercare (including records of location and
content).
3.7.4. Conclusion
Well drilling is a specialized technical area, and alternative methods and technologies are
limited. Impacts that are associated with the drilling activities will be minimal and measures
have been put in place in the EMP to mitigate any potential impact that may occur during the
exercise.
3.8. Land-Use
Land use of the Kadanwari Block is a mix of rural, semi urban and desert. Nara Canal is a
major source of fresh water for irrigation in the villages in the Kadanwari Block. Regions in
close proximity of Nara Canal have fertile land and support agriculture. Due to fertile land and
availability of water, there is a significant size population settled on and near the bank of Nara
canal. The population is rural and semi-urban in nature. Solid waste management is a
significant problem of the villages / towns of the area. By the passage of time, the population
is growing and moving deep into the Nara Wildlife Sanctuary.
Far from Nara Canal, inside the Nara Wildlife Sanctuary, where freshwater of Nara Canal
cannot reach, the land is typical desert with huge sand dunes and vegetation typical to the dry
desert ecology.
Eni Pakistan make judicious land compensation to the legitimate private landowners and
acquires state land from the government on lease. Eni Well – 3 is located in the agricultural
land in the west of the Kadanwari Block. There are few villages in the surrounding and the
land is used for agriculture purpose. Major crops are sugar cane, wheat, mustard and fodder.
On the contrary, the other wells i.e., Eni Well – 1, Eni Well –2, Eni Well –4 and Eni Well –5
are located in the desert surrounded by undulating terrain, large sand dunes and vast
interdunal valleys. The vegetation cover includes shrubs on the sand dunes and large number
of Tamarix trees in the valley.
Figure 3.5: Land Use and Land cover Map of Kadanwari Block
Chapter 4 Environmental Baseline

4.1. General
This section describes the project area's existing natural and socioeconomic setting.
Description of the natural environment covers the area's biotic and abiotic components,
including geology, geomorphology, water resources, climate and air quality, vegetation and
wildlife habitat. Description of the socioeconomic environment includes details of the area's
population and households, education and health facilities, gender issues, water supply,
agriculture, transport and communications, and occupations and income sources.
Description of the environmental and socioeconomic conditions of “Kadanwari Block” requires

baseline data on the existing biotic and abiotic component of its microenvironment and macro
environment as well as the following in particular:
1. Physical Resources,
2. Ecological Resources,
3. Social, Economic Development and Cultural Resources.
4.1.1. The Aim of Baseline Study

The aim of establishing the baseline of the project area, where the proposed wells will be
drilled, is to understand the existing physical, ecological and socioeconomic conditions prior
to the commencement of various activities and assess the potential impacts of the proposed
activities on these parameters.
It assists the environmental assessment team in defining the mitigation measures that would
be required to eliminate and/or minimize the adverse impacts identified.
4.1.2. Methodology
The baseline data collected in this section is based on primary and secondary sources.
Primary data has been obtained through field visits, site surveys and assessment of the
existing environmental conditions on site by EMC experts. The secondary data has been
acquired from the review of past studies, research studies conducted in the areas, electronic
and print media information, maps prepared by the Geological survey of Pakistan and Soil
survey of Pakistan, District Census Reports (DCRs) and other information in districts and
archives of the experts.
4.2. Physical Environment
4.2.1. Geographical location

The Kadanwari block is situated in the Sukkur and Khairpur districts. The total area of block is
approximately 460 sq. km.
District
Sukkur
District
Khairpur
Figure 4.1: Geographical Location of Kadanwari Block

4.3. Micro environment

The microenvironment comprises of the specific site of project i.e., the proposed well sites
which is taluka Nara of district Khairpur and taluka Saleh Pat of district Sukkur.
The project area lies in District Sukkur and District Khairpur. District Sukkur has five talukas,
named: New Sukkur, Sukkur city, Pano Aqil, Rohri and Saleh Pat and covers an area of 5126
Km2. District Khairpur has eight talukas namely, Khairpur, Faiz Gunj, Gambat, Kingri, Kot Diji,
Nara, Thari Mir Wah and Sobho Dero and spans over an area of 15,925Km2.
Kadanwari Block is situated on the left bank of Nara Canal inside the Nara Desert Wildlife
Sanctuary. Major portion of the block is composed of desert with undulating terrain of large
sand dunes and large flat land in between. Elevation ranges between 40 meters to 80 meters.
Figure 4.2: Physiographical features of the project area4
4 Paolo et.al., The Bronze age Indus quarries of the Rohri hills and Ongar in Sindh (Pakistan), 2008
4.4. Macro environment

The Macro environment of the project area includes districts Sukkur and Khairpur and Sindh
province on large scale. Khairpur district is located in north-eastern Sindh and is bounded on
the north by Shikarpur and Sukkur, on the east by India, on the south by Sanghar and Shaheed
Benazirabad and on the west by Larkana and Noshero Feroz. The district lies from 68°10’ to
70°10’ east longitude and 26° 9’ to 27° 42’ north Latitude. The climate of Khairpur is typically
that of the upper Sindh region. There are two well defined seasons, hot and cold. The summer
spans from the end of March till October. May, June and July are the hottest months.
December, January and February are the coldest months.
District Sukkur is bounded by district Ghotki and India on the east, district Kashmore on the
north, district Shikarpur on the north-west, and district Khairpur on the west and south. Indus
River flows on the north-western side of this district. Sukkur is the narrowest part of the Indus
River course. The climate of this district is hot during summer while dry and cold in winter.
During January, the temperature ranges from 7°C to 22°C. The summer temperature averages
35 °C though it often reaches up to 52°C. Generally, the summer season commences in March
- April and ends before October. The average rainfall of the district is 88 mm, per annum (with
monthly ranges from 0.59 mm to 25.62 mm).
Figure 4.3: District map of Sindh
4.4.1. Physiography
Sindh can be divided into four distinct parts; the Kirthar range in the west; a central alluvial
plain bisected by the Indus River; the desert to the east; and the Indus Delta in the south. The
project area lies in the North eastern part of the Sindh province in talukas Rohri, Saleh Pat of
district Sukkur and Talukas Nara and Thari Mirwah of district Khairpur.
4.4.2. Geology and Topography

The Kadanwari block is located in the Central Indus Basin in between two regional extensive
highs, i.e., the Mari-Kandhkot High to the northeast and Jacobabad-Khairpur High to the
southwest. (Saif et. al. 2020). (Fig. 4.4)
Nara desert consists of sandy hills, steep slopes and low-lying flat areas locally known as Patt.
The Nara canal flowing through the desert is associated with wetlands. The wetlands are
natural, formed as a result of seepage from the Nara Canal. In general, the area around the
Nara Canal is stable and the desert comprises of sand dunes having typical flat-bottomed
valleys between the dunes termed as 'Tars' or 'Tals'. The canal provides a perennial source
of water to the agriculture land extending 4 to 5 km on either side of the canal. Numerous
dhands (pockets of water) are formed on either side of the canal recharged by either canal
seepage or rain water.
Figure 4.4: Geological map of Sindh

Figure 4.5: Topography of the project area

4.4.3. Soil Morphology

The project area has two prominent land types, fertile land in the west and Desert barren area
in the east and south. The Nara canal flows along the western boundary of the Kadanwari
block.
Large part of the project area lies in the Nara Desert region which falls in Taluka Nara of
District Khairpur and Taluka Saleh Pat of district Sukkur. The area forms a part of Indo-
gangetic plain formed by the gradual filling up of the trough lying between the foothills of
Himalaya and central core of the sub-continent. On regional scale the area is a part of the
Indus basin and is composed of alluvial sediments deposited by ancestral and present rivers
and their tributaries crossing the alluvial plain. The alluvium brought by the Indus River lies
over the basement of tertiary Shales and limestone. The other contributing rocks are granites,
schists, gneisses and slates. The alluvium is quite rich in weathered minerals with soils deep
and calcareous. The rocks belong to the Paleozoic, Mesozoic and Tertiary geological time
scale. The soils of the study area were formed in acolian sands originally deposited in
Pleistocene age but reworked by wind until recently to take the form of sand dunes. A minor
extent of soils has been formed in a narrow alluvial plain of Nara Canal which has its origin in
a small inundation river. The texture of the soils ranges from sandy to loamy fine sand but
rarely very fine sandy loam in some areas along the Nara Canal. Soils are generally brown to
greyish brown in color with CaCO3 content between 5 to 15%. Soils in the desert are generally
non-saline, non-sodic and deficient in organic matter with a pH between 7.8 and 8.4. Salinity
and waterlogging are common in irrigated areas particularly near the canal5.
4.5. Protected areas

The Kadanwari Block is part of two ecologically protected areas viz. the Nara Desert Wildlife
Sanctuary and Nara Game Reserve. Almost entire Kadanwari Block is situated inside the Nara
Desert Wildlife Sanctuary while small western portion of Kadanwari Block is situated in Nara
Game Reserve.
However, the proposed well sites are situated only in the Nara Desert Wildlife Sanctuary.
4.5.1. Nara Desert Wildlife Sanctuary

The Nara Desert Wildlife Sanctuary (NDWS) is located in the eastern part of Sindh (Fig.4.6),
in the talukas Rohri, Saleh pat, Khangarh, Mirpur Mathelo and Nara. The total area of the
Sanctuary is about 6300 km2 covering parts of the Sukkur, Ghotki and Khairpur districts. Nara
desert wildlife sanctuary was declared a protected site in year 19806.
The significant feature of Nara Desert Wildlife Sanctuary is that it has four different habitats
viz. desert, agriculture areas, wetlands and human habitations. As many as 28 species of
mammals, 78 species of birds, 16 species of reptiles and 25 species of dominant flora have
been recorded. Chinkara, wolf, desert fox, marbled teal, houbara bustard, grey partridge,
5 Ecological Assessment of Fauna at Nara Wetland Complex, District Khairpur, Sindh Baseline Survey 2010 –
2011, Indus for All Program, WWF-Pakistan
6 S. Ali Ghalib et. al, Bioecology of Nara Desert Wildlife Sanctuary, Districts Ghotki, Sukkur and Khairpur, Sindh,
PJZ vol 40(1), 2008

imperial sand grouse and white-backed vulture are the key species of the area. The area is
under development and gas exploration activities7.
Details of ecology, flora and fauna of the Nara Desert Wildlife Sanctuary has been discussed
in details later in this chapter.
4.5.2. Nara Canal Game Reserve

The Nara canal and a belt of land along the canal totaling an area of 2,000,000 acres starting
from Sorah to Jamrao Head is a game reserve. It was established in 1972. The ecosystem of
the game reserve is a mixture of desert and wetlands. The game reserve was established for
the protection of hog deer, gray and black partridges and the crocodiles in the canal and the
dhands.
Nara Canal Game Reserve is situated 3.5 km in the west from the nearest proposed well (Eni
Well-3) see figure below, therefore it is not threatened by the proposed well drilling activities.
Figure 4.6: Location of project area in Nara Desert Wildlife Sanctuary, District Khairpur
Figure 4.6: Location of project area in Nara Desert Wildlife Sanctuary, District Khairpur
4.6. Climate
Major portion of the Kadanwari block and all of the proposed well sites are located in District
Khairpur, therefore, meteorological data of district Khairpur is discussed here.
7 Ibid.
4.6.1. Temperature
In Khairpur, the summers are blistering and humid, the winters are short and cool, and it is dry
and mostly clear year-round. Over the course of the year, the temperature typically varies from
8°C to 44°C and is rarely below 4°C or above 47°C.
The hot season lasts for 3.2 months, from April 22 to July 29, with an average daily high
temperature above 40°C. The hottest day of the year is May 27, with an average high of 44°C
and low of 28°C.
The cool season lasts for 2.6 months, from December 3 to February 22, with an average daily
high temperature below 27°C. The coldest day of the year is January 7, with an average low
of 8°C and high of 23°C.
Figure 4.7: The daily average high (red line) and low (blue line) temperature. The thin dotted lines are the
corresponding average perceived temperatures. (Source: www.weatherspark.com)
4.6.2. Rainfall
The rainy period of the year lasts for 1.8 months, from July 9 to September 1, with a sliding
31-day rainfall of at least 13 millimeters. The most rain falls during the 31 days centered around
August 2, with an average total accumulation of 21 millimeters.
The rainless period of the year lasts for 10 months, from September 1 to July 9. The least rain
falls around October 22, with an average total accumulation of 1 millimeter.
Figure 4.8: The average rainfall. (Source: www.weatherspark.com)
4.6.3. Humidity
Khairpur experiences extreme seasonal variation in the perceived humidity. The damper
period of the year lasts for 3.9 months, from May 27 to September 24, during which time the
comfort level is humid, oppressive, or miserable at least 20% of the time. The most humid day
of the year is July 31, with humid conditions 80% of the time.
The least humid day of the year is December 17, when humid conditions are essentially
unheard of.
Figure 4.9: Humidity levels. (Source: www.weatherspark.com)
4.6.4. Wind
The average hourly wind speed in Khairpur experiences significant seasonal variation over
the course of the year.
The windier part of the year lasts for 3.9 months, from May 15 to September 10, with average
wind speeds of more than 3.8 meters per second. The windiest day of the year is June 29,
with an average hourly wind speed of 5.3 meters per second.
The calmer time of year lasts for 8.1 months, from September 10 to May 15. The calmest day
of the year is November 7, with an average hourly wind speed of 2.2 meters per second.
Figure 4.10: The average wind speeds (dark gray line). (Source: www.weatherspark.com)
The predominant average hourly wind direction in Khairpur varies throughout the year. The
wind is most often from the south for 7.4 months, from March 26 to November 8, with a peak
percentage of 83% on July 5. The wind is most often from the north for 4.6 months, from
November 8 to March 26, with a peak percentage of 36% on January 1.
Figure 4.11: Mean Wind direction. (Source: www.weatherspark.com)
4.7. Seismicity
The seismicity map of Pakistan shows that the earthquake zones have been hit by
earthquakes a number of times, but the depth of their epicenter is not usually lower than 33
km. The map also shows the yellow line, which marks the frequency zones as well as the fault
lines. It also shows that the yellow line on entering the Arabian Sea bifurcates into a line that
travels along the coastline while the other goes southwest. This indicates that there are quite
a few other active faults in Lower Sindh, including a thrust and- fold belt extending northward
parallel to the transform fault separating India from Asia, and the Rann of Kutch fault system
trending westward towards Karachi city and Makran Coast bordering the Arabian Sea.
Figure 4.12: Seismicity & Natural Disasters- Pakistan, 1990-2000
Following faults are located within the province of Sindh:
A. Karachi-Jati Fault
B. Surjani Fault
C. Pab Fault
D. Hub Fault
E. Allah Bund-Rann of Kutch Fault
4.7.1. Surjan Fault

These N-S trending dip-slip or bedding-plane faults are active along the Kirthar Range Front.
This fault cuts across the Quaternary deposits on the north of Karachi and west of Mirpur
Sakro. The southern end of this fault is intersected by the northwest trending Surjani Fault on
the west of Jhimpir. The interaction of these two faults is characterized by at least four tele-
seismic events of shallow focal depth and magnitude 3.6. The maximum magnitude of the
earthquake associated with the Surjani Fault is of the order of M ≈ 6.1.
A number of epicenters are located on this N-W trending fault. The fault has produced an
earthquake of M ≈ 5.6 on Richter scale.
4.7.2. Pab Fault

This NNW-SSE trending is 135 km in length and is located in the eastern part of the Pab
Range and has dislocated vertically the Quaternary alluvial fans. The maximum magnitude of
the earthquake associated with this fault is of the order M ≈ 7.0 on Richter scale.
4.7.3. Hub Fault

The Hub valley is traversed by this fault.
4.7.4. Rann of Kutch Fault

This E-W trending fault has produced earthquake of the order of M ~ 7.6 on Richter scale. In
1819 and 1956, this fault was responsible for severe earthquakes in Gujarat, Thar Parkar and
Indus delta. This fault system also known as Allah Bund Fault passes in the proximity of the
Steel Mills and Karachi Nuclear Power plant. It is 225 km in length and is responsible for the
production of earthquake of considerably high magnitude of up to 7.6 M on Richter scale and
of IX to X intensity on the Modified Mercalli, MM scale on June 16, 1819.
Additionally, a complex series of faults generally oriented easterly and slightly concave to the
north have been identified through aerial photographs. They are roughly parallel to the inferred
zone of rupture for the 1819 earthquake event.
The Kadanwari block is located in the Central Indus Basin between two regional extensive
highs, i.e., the Mari-Kandhkot High to the northeast and Jacobabad-Khairpur High to the
southwest. Central Indus Basin can be further classified into three broad tectonic units: (1)
Sulaiman Fold Belt, (2) Sulaiman Foredeep, and (3) Punjab Platform. It is bounded by Indian
shield to the east and highly folded mountain belts to the west.
In Kadanwari block, the quality of the seismic lines is of poor to fair quality. The presence of
normal faults to the level of Chiltan Limestone have been observed, except one fault which
seems to be penetrating across the base Chiltan Limestone of Jurassic age and may likely be
of strike-slip origin. However, the dominance of normal faults in the Cretaceous strata is
interpreted throughout the area (Saif et. al., 2020).
4.8. Ambient Air Quality & Noise

The proposed well sites are situated in Kadanwari block in taluka Nara, district Khairpur. Vast
area of the Kadanwari block is barren and thinly populated while the western part of the block
along the Nara canal till the proposed site for Eni Well 03 (village Faqir Allah Rakhio Mehar)
is fertile agricultural land. However, these areas are not urbanized therefore, the air quality in
the area is generally good, with very few sources of pollution like emissions from vehicles and
wood burning for cooking and heating purpose. Vehicular traffic causes dust emissions whose
effect is localized. The main pollutants emitted by vehicle exhaust pipes are particulate matter,
carbon monoxide, sulfur dioxide, and nitrogen oxides. These emissions generally may affect
the air quality in the vicinity of the roads.
Ambient Air Quality Monitoring was conducted at 02 locations near the proposed well sites by
EMC. The parameters observed were according to the SEQS for Ambient Air Quality.
One location of ambient air monitoring was at the proposed site of Eni Well-3. The location is
an agricultural land surrounded by vast agricultural fields. All the parameters of Ambient Air
Quality i.e., Sulfur Dioxide, Nitrous Oxides, Carbon Monoxide, Suspended Particulate Matter,
Particulate Matter all were observed to be complying the SEQS standards. Average results of
parameters observed have been represented graphically below.
Figure 4.13: Graphical representation of observations of Ambient Air Quality conducted near Eni Well-03
Other location was in Nara desert between the proposed well sites of well 01 and well 02. The
monitoring site location was in open ground far from any high dunes or tree that could have
impact on the air quality and wind speed. There are no anthropogenic source of emissions.
The air quality is absolutely pristine. Average results of air monitoring parameters are
presented in graph below and complete analysis report is attached in annexure.
Figure 4.14: Graphical representation of observations of Ambient Air Quality conducted between well-01 and well-
02
Figure 4.15: Ambient Air Quality Monitoring at project sites in Kadanwari Block
Noise level Monitoring
No high noise activities were observed in the project area. Generally, noise sources were the
vehicles and other activity in the residential areas and high wind noise and noise from bird
chirping in the open areas. Noise level observed at different locations in the project area are
given below and analysis report has been attached in annexure.
Table 4.1: Noise level monitoring locations

S# Location Coordinate Minimum Maximum Mean SEQS
(dBA) (dBA) (dBA)
1 Eni Well 1 27° 5'8.92"N, 56 57 55 75 dBA
69°12'51.57"E
2 Eni Well 2 27° 5'35.31"N, 54 56 55
69°17'43.82"E
3 Eni Well 3 27°11'53.32"N, 52 55 53
69° 7'33.14"E
4 Eni Well 4 27° 2'46.75"N, 62 60 61
69°15'32.77"E
5 Eni Well 5 27° 3'52.13"N, 65 67 66
69°12'58.09"E
Figure 4.16: Noise Level Monitoring in project area
4.9. Water Resources & Quality
4.9.1. Surface Water

The irrigation system of Sindh is entirely dependent on the River Indus for supplies of water
downstream of the area. Riverine tract of the River Indus occupies a special significance in
the ecology of Sindh. The hydrograph of the river is strongly seasonal with a long low water
season between October and March and a high-water season between April and September
– driven primarily by snowmelt in the upper catchment and monsoon rainfall. The river usually
peaks in mid-August or early September. The river carries large sediment loads due to
widespread and rapid erosion in its upper catchments. It is estimated that about 1 billion m3
of sediment is deposited in its floodplain each year. Because of this continuing deposition, the
river has developed natural levees along its length.
Expansion of agriculture and subsequent industrial development led to the need for conserving
water for agriculture purpose and power generation through construction of reservoirs on the
River Indus and its tributaries with associated irrigation canal networks. A number of Dams,
head works barrages and diversion canals have been constructed on Indus and its tributaries
from 1886 to 1993. The first barrage on the Indus was commissioned in 1932 (Sukkur Barrage)
followed by Kotri (Ghulam Muhammad barrage) and Guddu in 1955 and 1962 respectively
(Osmani, 2003). Indus River and Irrigation canals from Sukkur Barrage are the source of water
in the macro environment i.e. district Khairpur and Sukkur. Six canals take off from Sukkur
barrage for irrigation purposes. These include Dadu Canal, Nara Canal, Rohri Canal, Rice
Canal, N.W Canal and Khirthar Canal.
Surface water source inside the project area are the branch canals originating from the Nara
canal, seasonal water bodies/ponds formed from the flood water. Water from canal and branch
canals is utilized for agriculture, domestic and livestock feeding.
Figure 4.17: Irrigation water canal near Well-03
4.9.2. Ground Water

Sindh’s groundwater resources comprise a vast aquifer underlying the Indus Basin, recharged
by the river flows, irrigation water and precipitation. In Sindh, fresh water invariably occurred
in areas where river had its courses during the past 800 years.
Estimates of groundwater resources have been made by different agencies at different times,
which vary significantly. Estimated ground water resources for the Sindh province varies
between 16 to 20 m3 (13 to 16.2 MAF) with an estimates safe yield between 5.4 to 10 m3 (4.4
to 8.1 MAF). More than 78% of the irrigated land in Sindh is underlain with saline or brackish
water, which is unfit for agriculture8.
8Sindh water resources management – Issues and options, FAO investment center Occasional paper series no.
15, Dec 2003
Groundwater in the Kadanwari block is found in the western part, in the region near Nara
canal. The water table ranges from 40ft to 50ft. Groundwater for domestic consumption is
abstracted through shallow hand pumps.
4.9.3. Water Quality

A detailed study was conducted to evaluate the Indus River water quality and published by
Aziz & Chughtai in 2014. During the study water samples were collected from river Indus and
analyzed for water quality variables including physical and chemical parameters. Water quality
parameters of Indus River were monitored at Indus link 1km downstream from Latifabad, River
Indus after Indus link outfall and Kotri barrage at main bridge. The water quality results are
showing in the table and it can be seen that all parameters’ values defined in the drinking
water standards are within the limits.
Table 4.2: Indus River Water Quality

Parameters Sindh Standard for Indus link 1 km River Indus Kotri Barrage
Drinking Water downstream from after Indus at main bridge
Quality 2016 Latifabad link outfall
pH 6.5-8.5 7.8 7.6 7.7
Alkalinity - 89 91.2 45
(mg/L)
TSS (mg/L) - 63.3 167 60.3
TDS (mg/L) <1000 233.7 237.1 207.1
Cl-1 (mg/L) <250 39.3 39.3 37
HCO3-1 - 93.3 92.7 73.0
(mg/L)
SO4-2 - 33.3 35 37.3
(mg/L)
Ca+2 (mg/L) - 37 37.7 37.5
Mg+2 (mg/L) - 6.1 6 2.9
Na+1 (mg/L) - 22.1 23 24.6
K+1 (mg/L) - 2.2 2.2 3
Source: Regional interpretation of River Indus water quality data using regression model by Aziz-
ur-Rahman & Muhammad Owais Chughtai, 2014
EMC also conducted water analysis for this study. EMC representatives collected water
samples during field survey, which include 02 groundwater samples and 01 surface water
samples.
Surface water analysis
01 surface water sample was collected from the irrigation Canal in village Faqir Allah Rakhio
Mehar near Well 03. The water sample was analyzed for basic parameters. Test report of the
analysis has been attached in the annexure. Graphical representations have been shown
below.
The analysis results reveal that the water sample has acceptable physical parameters i.e.,
color, turbidity and odor. The pH is 7.8, while the Total Dissolved Solids, Total Suspended
Solids, and other mineral/salt content is also on lower side. Chemical and Biochemical Oxygen
Demand are also low inferring low level of chemical and biological contamination. There are
no threshold limit or standard value defined in the SEQS for the surface water to compare
with.
Table 4.3: Results of surface water analysis

S No. Parameter Unit Results
1 Odor - Acceptable
2 Color Pt-Co 10
3 Turbidity NTU 1.0
4 pH value - 7.8
5 Total Dissolved Solids (TDS) mg/L 210
6 Total Suspended Solids (TSS) mg/L 05
7 Chemical Oxygen Demand (COD) mg/L 100
8 Biochemical Oxygen Demand (BOD) at 20 mg/L 21
9 Total Hardness (as CaCO3) mg/L 55
10 Nitrate (NO3) mg/L 0.22
11 Nitrite (NO2) mg/L 0.041
12 Phenolic compounds (as phenol) mg/L BDL
13 Chloride (as Cl-) mg/L 71
14 Fluoride (as F-) mg/L 0.11
15 Cyanide (as CN-) total mg/L BDL
16 Chromium, Total mg/L 0.41
17 Copper mg/L 0.55
18 Zinc mg/L 0.32
19 Manganese mg/L 0.017
20 Barium mg/L BDL
Surface water sampling from canal

Ground water sampling Village Allah Rakhio Ground water sampling Village Jamal uddin
Mehar Rajar
Figure 4.18: Ground water sampling
The groundwater samples were collected from villages in the Kadanwari block for analysis
and comparison with the Sindh Standards for Drinking Water Quality (SSDWQ).
The analysis results are presented below in graphical presentation while the complete analysis
report is attached in annexure.
Figure 4.19: Graphical representation of pH, TDS and TH of ground water samples
pH of both the ground water samples are 6.5 and 7.0 which is within the SSDWQ limit (6.5-
8.5). TDS concentration was found to be 680 mg/L and 430 mg/L in the ground water samples
which is within the SSDWQ limit of <1000 mg/L. Total Hardness of these ground water
samples are 210 mg/L and 152 mg/L which also within the limit <500 mg/L. Chloride are
chlorine ion is slightly higher i.e., 220 mg/L in sample drawn from village Jamal Uddin Rajar
which may be due to the natural causes. Chloride in the other sample i.e., drawn from village
Faqeer Allah Rahkio Mehar is 142 mg/L. Both the samples do not contain phenolic
compounds. Other parameters i.e., salt, minerals and metal content are also within the
prescribed limits of SSDWQ except the barium.
4.10. Ecological Environment

In order to study the ecological environment of the Kadanwari Block which is situated in the
Nara Desert Wildlife Sanctuary, a team of wildlife expert and EMC personnel visited the study
area. The team visited the study area (Kadanwari block) to note the physical features such as
flat plains, sand dunes and hills, hydrology, soil type etc. focusing on the types of flora and
fauna existing and their habitat. The study area (located in Nara Desert, Tehsil Nara) is almost
completely arid desert land. River Indus is at a distance of 90 km or more from the western
boundary of the block. The Nara canal flows in the west of the block at distance of less than a
km. Nara canal is the major source of water for the agricultural fields situated in the west of
the block. It is the largest canal in Sindh and has played significant role in transforming the
area from a desert to irrigated area where agricultural activities are in full swing. As a result,
there is a significant human population settled in numerous small villages along the Nara
Canal where commercial and industrial activities are blooming. Following section provides a
detailed overview of ecological survey at each well-site.
The project area i.e., Kadanwari Block can be ecologically divided in prominent part viz.
irrigated part and dry desert part. These parts provide habitat to diverse species and families
of fauna, avifauna and flora. Commonly observed habitats are mentioned below.
1. Cultivated and vegetated land,

2. Desert; large sand dunes and flat interdunal valley
Eni Well-1
Eni Well-2
Eni Well-3
Eni Well-4
Eni Well-5
Figure 4.20: Microenvironment of the proposed well sites

4.10.1. Well Site 1

Well-1 is located at the latitude 27° 5'8.92"N and longitude 69°12'51.57"E. Microenvironment
of the well-1 site comprises of sand dunes which majorly covered with vegetation of Kandi
(Prosopis cineraria) and Khabar (Salvadora oleoides). Overall, the vegetation of Well-1
microenvironment comprised with 80% of Khabar (Salvadora oleoides), 1 % with Kandi
(Prosopis cineraria) and other remaining part of the area was all covered with shrubs precisely
vegetated with Booh (Panicum turgidum) and Phog (Calligonum Polygonoides). Fauna
observed and reported in the microenvironment was dominant with Doves, Sand Lizard and
Fox. The footprints of birds of prey were also observed during the survey. The
microenvironment also serves as habitats for Houbara Bustard, Rabbits and Grey Partridges.
Figure 4.21: Views of ecological footprints near well site 1
4.10.2. Well Site 2

This well site is located on the slope of the sand dune which is on the elevation from south to
north. In the distance of 200 meters towards south from the well site, few Khabar (Salvadora
oleoides) bushes are found however, surrounding dunes were sparsely covered with shrubs
of Booh (Panicum turgidum) and Phog (Calligonum Polygonoides). The fauna reported in the
microenvironment is Fox, Sand Lizard, Porcupines and Indian Monitor Lizards. The
microenvironment possesses the similar ecological features as of well site no.1.
4.10.3. Well Site 3

This Well site is located within the sugarcane field (agriculture area). In the East of this well
site there is a village of Faqir Allah Rakhio Mahar. In North and South of this well site, sand
dunes were present covered with Khabar (Salvadora oleoides) and trees of Kandi (Prosopis
cineraria).
Figure 4.23: Views of well site 3 showing agriculture area
4.10.4. Well Site 4

The microenvironment of well site was sparsely covered with vegetation occupied with few
trees of Khabar (Salvadora oleoides) and shrub Phog (Calligonum Polygonoides). The site is
located in the slope region where small sized sand dunes were present. The microenvironment
serves as a habitat of birds, wild cat, foxes & other reptiles.
4.10.5. Well Site 5

In the microenvironment of well site, vegetation observed were dominated by Kandi (Prosopis
cineraria) and Khabar (Salvadora oleoides). While in shrubs, Booh (Panicum turgidum) and
Phog (Calligonum Polygonoides) were majorly observed. The microenvironment serves as a
habitat of birds including babbler, Eagle, Sparrow, Nightingle, Houbara Bustard, Partridge and
Dove. The fauna in the microenvironment include; Fox, Wild Cat, Spiny Lizard, Hedgehog,
Porcupine, Viper snake and various other reptile species. The microenvironment has an
ecological significance owing to the purpose of having various habitats of number of animals.

4.10.6. Overall Summary of Ecological Survey

The ecology of the block is too dynamic with sand dunes all around which serve as the habitats
for various numbers of animals and also the area is predominantly occupied with the shrubs
of Khabar (Salvadora oleoides) and remaining land is covered with other shrubs. There are
05 proposed well sites in the Kadanwari block in which all four (04) wells sites possess similar
ecological features except Well 03 which have agriculture land use and human disturbance.
4.10.7. Nara Desert Wildlife Sanctuary

The Nara Desert Wildlife Sanctuary (NDWS) is located in the eastern part of Sindh (Fig.4.6),
in the talukas Rohri, Saleh pat, Khangarh, Mirpur Mathelo and Nara. The total area of the
Sanctuary is about 6,300 km2 covering parts of the Sukkur, Ghotki and Khairpur districts. Nara
desert wildlife sanctuary was declared a protected site in year 1980.
In the old days before construction of Nara canal, wildlife was in abundance in this area. But
after the advent of the canal system, wildlife has moved to the desert and aquatic life has
thrived in the Nara Canal.
The habitat of wildlife along the Nara Canal has been turned into an excellent agricultural land.
Banana, guava, vegetables and chillies are grown there. In the Nara Canal, crocodiles and
Otters are found. In the vicinity, fox, Jackal and various species of cat family are found.
Mammals present in the Nara Desert Wildlife Sanctuary
A total of 16 species of mammals were recorded/reported.
Table 4.4: List of Mammals recorded/reported in Nara Desert Wildlife Sanctuary

S Common Name Scientific name Listing
No. Local IUCN CITES
Act Red list9 Appendix10
1 Asiatic jackal Canis aureus LC III
2 Chinkara Gazella bennettii LC
3 Balochistan gerbil Gerbillus nanus LC
4 Common red fox Vulpes vulpes LC III
5 Desert hare Lepus nigricollis LC
6 Five striped-palm squirrel Funambulus pennantii LC
7 House mouse Mus musculus LC
8 House rat Rattus rattus LC
9 Indian crested porcupine Hystrix indica LC
10 Indian desert jird Meriones hurrianae LC
11 Indian desert wild cat Felis silverstris ornata LC II
12 Indian gerbil Tatera indica LC
13 Indian/Bengal fox Vulpes bengalensis LC III
14 Little Indian field mouse Mus booduga LC
15 Long-eared desert Hemiechinus collaris LC
hedgehog
16 Small Indian mongoose Herpestes javanicus X LC III
LC = Least Concern
9https://www.iucnredlist.org/
10https://cites.org/eng/app/index.php - Convention on International Trade in Endangered Species of Wild Fauna
and Flora
Birds Recorded
A total of 46 species of birds are reported in the area.
Table 4.5: List of Birds recorded in/near the Nara Desert Wildlife Sanctuary
Listing
CITES Appendix
CMS Appendix
IUCN Red list
Local Act
S
Common Name Scientific name
No.
1 Bank myna Acridotheres ginginianus

2 Bay-backed shrike Lanius vittatus
3 Black crowned finch lark Eremopterix nigreceps
4 Black bellied sandgrouse Pterocles orientalis
5 Black drongo/King crow Dicrurus macrocercus
6 Black kite Milvus migrans X II
7 Black-shouldered kite Elanus caeruleus / E.leucurus X II
8 Black partridge Francolinus francolinus
9 Blue rock pigeon Columba livia III
10 Cattle egret Bubulcus ibis X III
11 Chestnut shouldered Petronia Petronia xanthocollis
12 Collared dove Streptopelia decaocto
13 Common babbler Turdoides caudatus
14 Common kestrel Falco tinnunculus X II II
15 Common swallow Hirundo rustica
16 Crested lark Galerida cristata
17 Desert lark Ammomanes deserti
18 Southern Grey shrike Lanius excubitor
19 Green bee-eater Merops orientalis
20 Grey partridge Francolinus pondicerianus
21 Hoopoe Upupa epops
22 House crow Corvus splendens
23 House sparrow Passer domesticus
24 Indian myna/Common myna Acridotheres tristis
25 Indian robin Saxicoloides fulicata
26 Indian roller Coracias benghalensis
27 Indian Moorhen Gallinula chloropus
28 Indian sand martin Riparia paludicola
29 Indian tree-pie Dendrocitta vagabunda
30 Jungle babbler Turdoides striatus
31 Little brown dove Streptopelia senegalensis III
32 Long-tailed grass warbler Prinia burnesii V
U
33 Pied bushchat Saxicola caprata
34 Purple sunbird Nectarinia asiatica
35 Raven Corvus corax
36 Red turtle dove Streptopelia transquebarica
37 Rosy starling Sturnus roseus
38 Red vented bulbul Acrocephalus agricola
39 Rufous tailed scrub robin Cercotrichas galactotes
40 Red-wattled lapwing Hoplopterus indicus
Table 4.5: List of Birds recorded in/near the Nara Desert Wildlife Sanctuary
Listing
CITES Appendix
CMS Appendix
IUCN Red list
Local Act
S
No.
41 Short toed eagle Circaetus gallicus X II

42 Sindh ped woodpecker Dendrocopos assimilis L
C
43 Sindh jungle sparrow Passer pyrrhonotus
44 Spotted owlet Athene brama II
45 White-cheeked bulbul Pycnonotus leucogenys
46 Wire tailed swallows Hirundo smithii
Reptiles Recorded
A total of 17 species of reptiles are reported in the area.
Table 4.6: List of Reptiles Observed in the Nara Desert Wildlife Sanctuary
Listing
CITES Appendix
IUCN Red list
WPO/Act
S
No.
1 Brilliant agama Trapelus agilus isolepis

2 Dhaman/Rat snake Ptyas mucosus X II
3 Fat tailed/Leopard gecko Eublepharis macularius III
4 Garden lizard Calotes versicolor
5 Glossy bellied racer Coluber ventromaculatus X
6 Indian desert monitor Varanus bengalensis I
7 Indian fringe-toed sand lizard Acanthodactylus cantoris
cantoris
8 Indian or Bengal monitor Varanus bengalensis X I
9 Indian sand boa Eryx johnii johnii II
10 Indian sand swimmer Ophiomorus raithmai
11 Indian spiny-tailed lizard Uromastyx hardwickii X II
12 Pakistan ribbon snake Psammophis leithii X
13 Saw scaled viper Echis carinatus pyramidum
14 Sindh sand gecko Crossobamon orientalis
15 Spotted Indian house gecko Hemidactylus brookii brookii
16 Streaked kukri snake Oligodon taeniolatus X
17 Yellow bellied house gecko Hemidactylus flaviviridis
4.10.8. Vegetation Recorded in the project area

A total of 30 species of flora are reported from the area.
Table 4.7: List of Floral Species Observed in the Project Area

S Family Name / Plant Specie Local Name Life form / Habit
No.
1 Cyperus conglomeratus Moniah gaah Sedge
2 Aristida adscensionis . Lumb gaah Grass
3 Aristida funiculata Lumb gaah Grass
4 Cymbopogon jawarancusa Kattan Grass
5 Dactyloctenium aegyptium Gandheer gaah Grass
6 Lasiurus sindicus Booro Grass
7 Ochthochloa compressa (Forssk.) Gandheer gaah Grass
8 Panicum turgidum Sewan Grass
9 Stipagrostis plumose Lumb gaah Grass
10 Limeum indicum Dhoor chhapri Herb
11 Calotropis procera. Ak Shrub
12 Aerva javanica Booh Subshrub
13 Heliotropium crispum Kharsun Herb
14 Leptadenia pyrotechnica Khip Shrub
15 Cassia italic Ghora wal Herb
16 Capparis decidua Kirar Shrub
17 Dipterygium glaucum Phair Bushy subshrub
18 Citrullus colocynthis Trooh Prostrate subshrub
19 Saueda fruticose Lano Shrub
20 Alhagi maurorum . Kandero Herb
21 Indigofera oblongifolia Jhil Subshrub
22 Crotolaria burhia Chag Subshrub
23 Tephrosia falciformis Andhri/Siringh Herb
24 Prosopis juliflora Devi Shrub
25 Acacia nilotica Babur Tree
26 Prosopis cineraria Kandi Tree
27 Calligonium polygonoides Phog Shrub
28 Zizyphus nummularia Jhangoori ber Shrub
29 Salvadora oleoides Jar/Peroon Shrub
Tamaricaceae
30 Tamarix aphylla Lai Tree
4.10.9. Threats
The area is under pressure due to the increasing human population and habitation, impact of
developmental, hunting activities for Houbara Bustard, wood cutting for coal production,
firewood collection, and degradation of land etc.
Overgrazing
There is large scale grazing by livestock in the desert area.
Wood Cutting
The communities depend on the woodland for acquisition of firewood and construction of their
homes.
VIP Hunting
Hunting of Houbara Bustard takes place by the foreign dignities during the Houbara Bustard
hunting season from November to February. Houbara is hunted by using Saker Falcons and
Perigrine Falcons. Large areas in Houbara Bustard habitat are allocated to the Arab Shaikhs
who establish their provisional camps in the area with about 1000 peoples employed for
managing the hunting and the camping facilities. This causes large scale disturbance in the
area due to vehicle movement.
The less disturbed desert area of Nara Desert Wildlife Sanctuary provides most favorable
habitat for the Houbara Bustard.
Protected Area
The project area is situated in protected area, Nara Desert Wildlife Sanctuary.
Figure 4.26: Project area boundary and Protected areas
4.10.10. Importance of Protected Areas in the Project Area

Nara Desert Wildlife Sanctuary
It is important for Chinkara and Houbara Bustard (VU).
4.10.11. Conclusion
The EIA team visited the project area which is part of Nara Desert Wildlife Sanctuary to
observe the ecology and wildlife. Although, the Nara Desert has considerable number of
Wildlife species exist but, the footprints of proposed drilling activities are confined in a very
small are compared to the whole wildlife sanctuary. There was no habitat of birds, mammals,
reptiles found inside the proposed drilling site. Also, the wildlife is sparsely populated in the
microenvironment. However, localized and temporary nature of impacts having low
significance will be present during drilling activities which will be mitigated through
administrative and restoration measures.
Gallery 1: Pictorial record of the Fauna present/reported in the project area
Asiatic jackal Desert hare
Indian crested porcupine Chinkara
Common red fox Foot marks of Fox recorded during Survey
Indian desert Jird Colony of reptile recorded during survey

Long-eared desert hedgehog Indian desert wild cat
Five Striped Squirrel Indian Monitor Lizard
Indian Garden Lizard Small Indian mongoose
Foot and tail marks of Indian Spiny Tail Lizard

Indian Spiny Tail Lizard
recorded during the survey
Gallery 2: Pictorial record of the Avifauna present in the project area
Cattle Egret Collared Dove
Common Myna Crested Lark
Crow Pheasant Glossy Ibis
Great Grey Shrike Indian Robin

Indian Roller Red Shank
Pied Bushchat Purple Sunbird
Red Turtle Dove Red Wattled Lapwing
Sindh Pied Woodpecker Spotted Owl
White Browed Fantail Common Buzzard

Chapter 5 Social Baseline

5.1. Macro Environmental
This social baseline chapter provides a detailed review of the socio-economic conditions for
the Kadanwari Block. This section describes the key socio-economic and cultural features of
the project area i.e., district Khairpur as macro environment including the history,
administrative set-up, demography, infrastructure facilities (education, health, water supply
and road network), cultural heritage, economic scenario and major hurdles in the development
of proposed project site to its potential.
The project area macro-environment encompasses regions of district Khairpur of Sindh having
diverse geographic and ethnic features thus the study requires a robust and well- informed
social baseline developed from various primary and secondary sources. The purpose of this
social baseline is to provide a comprehensive overview of the social and cultural context of
the project area which will help in identification of the positive and negative impacts of the
project on the local community and contribute towards providing plausible mitigation measures
that can become part of the Social Management Plan for the Project.
The major secondary sources used to develop the baseline include the Population Census-
2017, Provincial Development Statistics, Pakistan Social and Living Standards Measurements
(PSLM) Report, Provincial Agricultural Statistics and the Planning Commission’s Multi-
Dimensional Poverty Index report.
Primary sources of information are the stakeholder consultation. The stakeholder

consultations were conducted with the representative of villages located within the EIA study
area. The purpose of the consultation was to acquaint the locals about the project interventions
and also to identify the socio-economic conditions of the nearby local communities.
5.1.1. Demographic Profile- Khairpur
5.1.1.1. Location
District Khairpur is part of the Sukkur Division. Khairpur district is located in north-eastern
Sindh and is bounded on the north by Shikarpur and Sukkur, on the east by India, on the south
by Sanghar and Shaheed Benazirabad and on the west by Larkana and Naushahro Feroz.
The district lies from 68° 10’ Kot Diji Fortto 70° 10’ east longitude and 26° 9’ to 27° 42’ north
Latitude. Source: Sindh Districts Profile-2021.
5.1.1.2. Administration Background

District of Khairpur’s population is about 2,404,334 which is almost 5.0% of Sindh’s population
of about 47.9 million. With 412,857 households, the average household size in the district of
Khairpur is 5.82 as per the Census of 2017 compared to average household size of 5.58 in
Sindh. According to MICS 201819, mean household size of Khairpur is 7.6 as compared to
mean household size of 6.5 in Sindh. 68.0% of Khairpur’s population resides in rural areas
and 32.0% resides in the urban areas.
Khairpur’s population comprises of 1,240,424 males and 1,163,806 females with 51.6% and
48.4% of the district’s population respectively. District of Khairpur spans over an area of
15,925 sq. km which is 11.3% of Sindh’s total area of 140,914 sq. km. The population density
of the district is 151/sq. km. District Khairpur comprises of 8 talukas, namely: -Faiz Ganj
Taluka, Gambat Taluka, Khairpur Taluka Kingri Taluka, Kot Diji Taluka, Mirwah Taluka, Nara
Taluka and Sobho Dero Taluka. District Khairpur has 8 Urban Centers, 88 Union Councils
and 411 Revenue Villages.
Table 5.1: Population Distribution by gender and urban/Rural Census-2017 Khairpur
5.1.2. HISTORY & CULTURE
5.1.2.1. HISTORY
According to Sindh Districts Profile 2021, Khairpur state was ruled by Talpur Mirs (ameers) of
the Talpur dynasty from 1783 to 1955. In 1947, when Pakistan gained independence, Khairpur
Mir's was one of the princely states that opted to join Pakistan. In 1955, the Government of
Pakistan announced the abolition of all the princely states and Khairpur Mir's was annexed
into the then province of West Pakistan.
5.1.2.2. CULTURE
Kot Diji Fort
According to Sindh Districts Profile 2021, hundreds of years ago, at the edge of a desert in
Sindh, the Talpurs constructed a pompous fort atop a hill. This emblematic fort, dominating
the town of Kot Diji in Khairpur district and known as Kot Diji Fort, was built between 1785 to
1795. The fort sits atop a 110 feet tall high hill that rises above the city of Kot Diji. The fort's
30 feet tall walls encircle the uppermost portion of the fort, resulting a narrow-width fortress
with perimeter of 1.8 kilometers. The fort contains three strategically placed towers that are
each 50 feet tall. The fort contains several sites for cannon placement, and contains numerous
inner passages for protection.
Faiz Mahal
According to Sindh Districts Profile 2021, It was built in Khairpur Mirs in 1798 as the principal
building serving as the sovereign's court for the royal palace complex of Talpur monarchs of
the Khairpur dynasty. Originally it included the ruler's chambers along with 16 waiting rooms
for courtiers and guest rooms for royal guests alongside the durbar and dining halls11.
Shrine of Sachal Sarmast
According to Sindh Districts Profile 2021, Shrine of Sachal Sarmast is located at 40 km

southwest of Khairpur, Sindh. Sachal was born in Daraza, near Ranipur, Sindh. He spread the
message of love for humanity through poetry, during the Talpur era of Sindh. He is regarded
as ‘Shair-e-Haft Zaban’ (poet of seven languages).
5.1.3. Housing
Housing characteristics including household size, ownership status, roofing, walls and assets
provide a holistic description of the overall well-being of the household. Description of
household characteristics provide a snapshot for the government to improve target housing
conditions as per district-wise deprivations.
In District Khairpur, 93.6% of population owns houses while 6.4% don’t own their houses
(3.7% rented) compared to 77.7% of the population in Sindh province who own their houses.
According to MICS 2018-19, the average number of persons per room in Khairpur is 5.0
compared 4.1 persons per room in Sindh. Similarly, the mean household size of District
Khairpur is 7.6 compared to mean household size of 6.5 in Sindh. 72.5% of households in
Khairpur have Pacca roofing compared to 70.7% households in province that have Pacca
roofing. Similarly, 62.2% households in Khairpur have Pacca walls compared to 70.7%
households in the province that have Pacca walls.
Table 5.2: Ownership of Housing of district Khairpur (Sindh District Profile-2021)
5.1.4. Utilities
Access to basic facilities like clean drinking water, toilets and sanitation services provide a
holistic
supply-side service provision coverage in a district. In District Khairpur, 100% of households

have improved sources of drinking water compared to 96.0% households in Sindh having
improved sources of drinking water. In terms of access to sanitation services, 55.6% of
households in Khairpur have access to improved sanitation services compared to 65.9% of
households in Sindh with access to improved sanitation services. The prevalence of open
defecation in Khairpur is 33.2% compared to 24.0% in Sindh.
11 Source: Sindh Districts Profile-2021

To ascertain whether environment-friendly practices are adopted at household level for

cooking,
heating and lighting, it is essential to gauge the prevalence of reliance on clean fuels. In
District
Khairpur, 24.2% of the households rely primarily on clean fuels for cooking compared to 50.2%
of households relying on clean fuel for cooking in Sindh. 26.0% of households in District
Khairpur rely primarily on clean fuels for space heating compared to 30.2% of households in
Sindh.
Table 5.3: Source to Drinking Water of district Khairpur (Sindh District Profile-2021)
Table 5.4: Access to Sanitation (Sindh District Profile-2021)
5.1.5. Health
According to Sindh Districts Profile-2021, district Khairpur has a total of 19 Government,
Departmental, Private and Local Bodies Hospitals
with a capacity of 450 beds out of 648 Hospitals in Sindh with a capacity of 30,126 beds.
Khairpur
has a total of 83 Basic Health Units (BHUs) with a capacity of 166 beds out of 800 BHUs in
Sindh with a capacity of 1615 beds. Khairpur has a total of 11 Rural Health Centers (RHCs)
with a capacity of 106 beds out of 133 RHCs in Sindh with a capacity of 1703 beds in Sindh.
District Khairpur has a total of 95 Dispensaries with 52 beds out of 2996 Dispensaries with a
capacity of 715 beds in Sindh. District Khairpur has a total of 11 TB Clinics with 0 beds out of
228 TB Clinics with total capacity of 42 beds in Sindh. Khairpur has 5 Mother & Child Health
Centers (MCHCs) with 10 beds out of 227 MCHCs with a total of 181 beds. Khairpur has 4
Maternity Homes out of 42 Maternity Homes in the province.
Table 5.5: Number of Health Facilities of district Khairpur (Sindh District Profile-2021)
Number of indoor patients served in District Khairpur are 16,336 out of 744,618 indoor patients
in the province. Similarly, number of outdoor patients served in District Khairpur are 3,386,706
out of 43,718,506 outdoor patients in Sindh.
Table 5.6: Patients Record of district Khairpur (Sindh Districts Profile-2021)
The patients per bed in District Khairpur are 3,193 compared to 1,455 patients per bed in
Sindh. The patients per doctor in Khairpur are 3,881 compared to 3,159 patients per doctor in
Sindh. Patients per nurse in Khairpur are 36,275 compared to 12,411 patients per nurse in
Sindh. Total Number of Government Medical, Nursing & Para-Medical Staff is 1,151 in District
Khairpur out of 18,429 Government Staff in Sindh. The total number of Semi-Government
Medical, Nursing & Para-Medical Staff is 52 out of 2,985 Semi Government Staff in Sindh. The
total number of Local Bodies Medical, Nursing & Para-Medical Staff in District Khairpur is 91
out of 4,119 in Sindh. There are 173 reported Private/Missionary Staff in Khairpur out of 15,051
in Sindh.
Table 5.7: Population served by Doctor/Nurse of district Khairpur (Sindh District Profile-2021)
5.1.6. Education
District of Khairpur has a total of 3,617 schools out of a total of 49,103 schools in the province
of
Sindh. Out of 3,617 schools, there are 471 schools for boys, 483 schools for girls, and 2,663
mixed schools.
Table 5.8: List of Number of Schools in district Khairpur (Sindh District Profile-2021)
3,617 schools in District Khairpur have a total enrollment of 350,611 with 217,215 boys
(62.0%) and 133,396 girls (38.0%). There are 6,805 male teachers (75.2%) and 2,246 female
teachers (24.2%) in the schools in Khairpur. Total number of rooms in 3,617 schools in
Khairpur amount to 10,689 out of which 8,064 are classrooms. There are 3,032 functional
schools in Khairpur while 585 schools are dysfunctional, non-functional, non-viable or closed.
Table 5.9: Enrollments of Students in district Khairpur (Sindh District Profile-2021)
Male literacy rate (15-49 years) in Khairpur is 60.0% compared to 59% in Sindh while the
female literacy rate is 35.5% compared to 40.9% in Sindh.
Table 5.10: Male and Female literacy rate of district Khairpur (Sindh District Profile-2021)
5.1.7. MPI (Multi-Dimensional Poverty Index)

Multi-Dimensional Poverty Index measures the number of people/households that are
‘multidimensionally’ poor. Essentially, it means the number of people (or HHs) deprived in at
least one third of the weighted indicators (H) along with the weighted average number of
deprivations poor people experience at the same time (A). The weighted indicators are along
three broad dimensions: -Education, -Health, and -Living Standards.
In District Khairpur, the MPI value is 0.2 which is slightly lower than the average MPI Value of
0.25 in Sindh. The headcount of households that are multidimensionally poor in Khairpur is
46.1% compared to the headcount of 47% in Sindh.
In District Khairpur, 20.1% of household members are vulnerable to poverty (i.e., deprived in
one-fifth to one-third of weighted indicators). Similarly, 25.7% of household members are in
severe multidimensional poverty (i.e., deprived in more than one-half of weighted indicators).
Table 5.11: Multidimensional Poverty Index of district Khairpur (Sindh District Profile-2021)
5.1.8. Economic Profile
5.1.8.1. Agriculture
Out of the area under cultivation for major crops, District Khairpur contributes to 213,962
hectares (7.1%) out of 3,028,496 hectares in Sindh. In terms of highest proportions of area
under cultivation for major crops, Wheat, Cotton and Sugarcane are at the forefront in Khairpur
with 103,850 hectares, 80,647 hectares and 22,762 hectares under cultivation respectively in
the district. Similarly, the production of Wheat, Cotton and Sugarcane is 385,607 M. Tons,
478,782 M. Tons and 1,417,429 M. Tons. Irrigated Area in District Khairpur is 162,289
hectares and Un-Irrigated area is 28,002 hectares. Canals are the mode of irrigation for
135,432 hectares in District Khairpur out of 1,287,845 hectares irrigated by Canals in Sindh
(10.5%). Tube-wells are the mode of irrigation for 26,857 hectares in Khairpur out of 361,199
hectares irrigated by Tube-wells in Sindh (7.4%).
Table 5.12: Irrigation and Un-irrigation Area of district Khairpur (Sindh District Profile-2021)
5.1.8.2. Livestock & Fisheries

The livestock head-count in District Khairpur is 3,546,697 out of the total livestock count of
46,279,313 in Sindh (7.7%). District Khairpur has 493,427 cattle, 527,875 buffaloes, 900,463
goats, and 1,449,101 poultry.
Fish production in Khairpur is 1,989 M. Tons out of 133,150 M. Tons in Sindh (1.5%). Khairpur
has a total of 441 fishermen out of 45,013 in Sindh (1.0%). Similarly, Khairpur has 40 boats
out of 7,215 boats in Sindh (0.6%).
Table 5.13: Livestock Count of district Khairpur (Sindh District Profile-2021)

5.2. Microenvironmental
A number of consultation and focus group discussion meetings were conducted with primary
stakeholders, which included male and female community members and Non-Governmental
Organization (NGO). The consultations were carried out of in the nearby villages which are
falling within the Project Area of Influence in district Khairpur. Information collected from these
local stakeholders provided a socio-economic overview of the micro-environment.
5.2.1. Community Profile

The majority of the population in the settlements within the study area are Muslims while
Hindus are the largest minority group in the area. The most commonly spoken language is
Sindhi, while other languages spoken in the area Balochi. The locals are mostly involved in
agriculture. Cultivation depends upon water from the Nara Indus, however seasonal rainfalls
are also important for seeding and quality outputs. The secondary source of income is
livestock rearing and the majority of households in the area own cows, buffalos, sheep and
goats. The main Rabi crops are wheat and gram, while Kharif crops include cotton, oil seeds
and sugarcane.
5.2.2. Education
As far as education opportunities, almost all the nearby villages have primary schools,
however, the larger villages have primary and middle schools and town/city have high schools.
The overall literacy rate is very low for both males and females. Many boys are not able to go
to school after the completion of their primary education because there is no middle or high
school in the villages nearby. Girls are not allowed to go to school after primary schooling
because of cultural barriers and non-availability of girls’ middle and high school at village level.
According to local people of project areas, previously Oil and Gas Companies had supported
by opening of primary and secondary schools and hiring of local teaches. The community
appreciated such kind of development taken by companies. Student dropout ratio will be
decreased providing quality education at their door step.
5.2.3. Health
The people of area don’t have access to good health facilities in their villages and depend on
nearby health facilities. However, Rural Health Centers (RHCs), Basic Health Units (BHUs)
and Dispensaries are located in some of the villages and towns, but due to non-availability of
trained doctors, lady health doctors and technical facilities, people prefer to go to Gambat and
District Head Quarters Hospital and private clinics for getting proper treatment.
5.2.4. Livelihood
The major source of income is agriculture and secondary is livestock. Cultivation depends
upon water from the Nara Canal, however seasonal rainfalls are also important for seeding
and quality outputs. The main Rabi crops are wheat and gram, while Kharif crops include
cotton, oil seeds and sugarcane. Community persons also have gone to nearest cities or out
of district for labor work to earn money.
The majority of women are engaged in household chores and upbringing of children. There is
no concept of involving women in decision making because mostly males take decisions in
community meetings at the village level. In a few villages, a handful of women are involved in
embroidery work and stitching clothes which they sell in nearby villages to supplement the
household income.
5.2.5. Source of Drinking Water

The main source of drinking water is hand pump (boring water). These hand pumps are
installed at household level. Villagers have also installed the hand pumps at community level
so those households who do not have hand pumps can fetch the water from it. The quality of
the water is satisfactory. Water quality does not change throughout the year.
5.2.6. Utilities
They don’t have access to basic services such as gas connections and electricity (if available
they face long load-shedding of 12 to 15 hours daily). They use solar panels if they can afford.
Sukkur Electric Power Company (SEPCO) is the distribution company responsible for
supplying electricity to project area. There are no gas connections in any of the villages. There
is no proper sewerage system in the area. Most of the villages reported open defecation due
to unavailability of latrines in their houses. There is no solid waste management system in
villages. The majority of people throw their waste in the open area while towns and city have
access to municipal waste collection
Chapter 6 Stakeholder Consultation

Stakeholder Consultation and Public Participation are two effective tools of social interaction.
Stakeholder Consultation plays important role to build up good rapport and confidence
between the stakeholders and the project designers to minimize the risk of delay of the project
implementation. It also counters erroneous information, if any, about the project. It helps the
project proponent to make assessments of public opinion about the project, and the nature
and extent of opposition likely to occur during the implementation stage.
6.1. Public Consultation in EIA Process

The process of stakeholder participation and consultation has been endorsed in the United
Nations Conference on Environment and Development (UNCED) in 1992 through Agenda 21,
one of the key documents of the UNCED. Agenda 21 was adopted as a comprehensive
strategy for global action on sustainable development to deal with issues regarding human
interaction with the environment. It emphasizes the role of public participation in environmental
decision-making for achieving the goals of sustainable development.
The participation of stakeholders in project planning, design and implementation is now

universally recognized as an integral part of environmental & social impact assessment. Local
communities, their representatives, government, national and international NGOs and the civil
society at large may be able to contribute to, and benefit from, the dialogue directed at
identifying and resolving key project-related issues. Stakeholder consultation presents an
opportunity for mutual information-sharing and dialogue between the project proponent and
stakeholders. An effective public consultation process provides concrete suggestions that can
help improve project design, resolve conflicts at an early stage, identify management solutions
to mitigate potentially adverse consequences and enhance positive impacts, and develop
guidelines for effective monitoring and reporting of project activities throughout the project
cycle.
Providing the public with adequate, reliable information of the planned project is of significant
importance in creating public trust and acceptance. Moreover, experience reveals that
unexpected project impacts on the local community generally give rise to significant issues
and concerns. Such problems are avoided and reduced if people are properly informed and
consulted about the project and given the opportunity of being heard.
This section provides an overview of the public consultation process adopted by the project
proponent and presents the findings of the stakeholder consultations. The key aspects,
including consultation objectives, consultation framework and stages of the consultation
process have been outlined here.
6.2. Objectives of Stakeholder Consultation

The stakeholder consultation process developed for the proposed project is in line with the
key objectives of stakeholder consultation identified below:
 Provide information related to proposed project activities;

 Facilitate and maintain dialogue;
 Seek participation of all interested parties;

 Identify stakeholder interests and issues;
 Identify solutions for addressing these concerns and integrating them into project design,
operations, and management;
 Improve the project by learning from, and incorporating, the expertise of individuals,
professionals, communities and organizations
6.3. Methodology of Consultations
6.3.1. Identification of Stakeholder

Comprehensive identification of stakeholders is one of the major steps of designing an
effective consultation process. Stakeholders are individuals, groups, or institutions that may
be affected by and can significantly influence, or are important to the achievement of the
proposed objectives of a project.
The main purpose of this exercise was to disseminate information on proposed project
activities to stakeholders so that any feedback received could be used to address the issues
at an early stage. Consultation meeting were conducted with the stakeholders linked with the
concerned area for the oil/gas well drilling. The stakeholders were briefed during meeting
sessions about the objectives of the Eni Pakistan’s proposed project. Observations of the
respondents were noted and have been incorporated in the text of the EIA.
The proposed well drilling activities will be carried out inside the Nara Wildlife Sanctuary which
is part of the Kadanwari Block situated in district Khairpur.
The project micro environment almost entirely desert with large sand dunes and vast inter-
dunal flat lands. The project area is very sparsely populated due to desert ecology and
unavailability of water. Many villages are present in the Kadanwari Block that too in the west
near the Nara canal where water is available from Nara canal. The human settlements are
mostly rural and related to agriculture and animal rearing activities.
Due to rural setup of the microenvironment, there are limited utilities infrastructure in the
proposed project area i.e., there is no electricity transmission lines, telecommunication line,
natural gas supply line etc. However, in the agricultural area there is a network of narrow
irrigation canals.
Consultation meetings were also conducted with the stakeholders settled in the project area.
Complete list of settlements in the project area has been mentioned in table 6.1. The
stakeholders were briefed about the objectives of the proposed drilling activities verbally and
through project brief. Concerns raised & suggestions proposed by the stakeholders were
recorded and have been incorporated in the EIA report.
6.3.2. Consultation Approach & Feedback
6.3.2.1. Consultation with Primary Stakeholders

A Neighborhood Survey was conducted to identify the residential and commercial interests in
the area that may face direct impacts from the proposed project. The survey was conducted
in two stages. In the first stage, several site visits were carried out to identify all stakeholders
that either reside or work in the project vicinity and conduct an initial identification of potential
positive and negative impacts.
During the second stage, a social survey field team used a pre-designed semi-structured
template to engage the area residents, commercial interests and public service institutions.
Those stakeholders, who were not available at the first attempt, were re-visited on the same
day or followed-up for their comments during the next few days. During each meeting, the
project team introduced the project to the stakeholders, recorded their concerns and
suggestions and provided contact details to enable stakeholders to share further comments
over email or in writing. A ‘Project Brief’ providing the salient features of the project were also
handed over the available stakeholders as part of the information disclosure process. The
stakeholder engagements were conducted in month of January, 2022.
Moreover, the team inquired about the current situation of the area such as the status of
utilities, security and law and order situation in the project area from the residents near the
project site. Several open-ended questions were also included in the questionnaire to ensure
that the respondents could openly share their opinions and suggestions relevant to the study.
The following table shows the stakeholders that were consulted for this study.
Table 6.1: List of Primary stakeholders consulted

Stakeholder
S# Village/Area Name Coordinates UC/Tehsil District
Type
27 12’ 16’’N, Sikandarabad,
1 Village Shibano Fqaqeer Village Elders Khairpur
69 07’ 11” E Nara
Village Faqeer Allah Rakhio
27 12’ 11” N, Sikandarabad,
2 Village Elders Khairpur
69 08’ 33” E Nara
Mehar
27 1 1 ’ 59” N, Sikandarabad,
3 Village Jamal-din- Rajar Village Elders Khairpur
69 07’ 48” E Nara
6.3.2.2. Concerns and Suggestion from Primary Stakeholders

The responses from residents of some of the villages that are located in the microenvironment
of the project area were as follows:
 Company is already providing jobs and economic opportunities to locals of the

concession areas. Company is paying land compensations according to land acquisition
procedures & policy more than the market value to its lands owners.
 Company has developed community infrastructure in the project area. The villagers said
oil and gas companies provided well-furnished schools and health facility in the area
where children acquire quality education at their door step and now dropout ratio has
been decreased. Moreover, villagers suggest to focus on decreasing the unemployment
in the area. Because their area is underdeveloped and there are not many income
generation opportunity in the area.
 They suggested that disturbance to the land shall be minimized and rehabilitation after
completion of work shall be undertaken.
6.3.2.3. Consultation with Secondary Stakeholders

The purpose of conducting consultation meetings with NGOs was to share the salient features
of the project do that they are able to share their concerns and suggestions regarding the
project. Since the NGOs and CSOs are involved directly and indirectly with the community at
the grass root level they have a better understanding of the concerns of the community and
hence their feedback is crucial for the formulation of Social Management Plan. Various
organization were invited but only few organizations were participated in the meeting.
However, NGOs ensured to convey messages and decisions of the meeting to remaining
NGOs who were not part of the meeting.
A district level meeting held with NGOs and CSOs in Khairpur district. A short presentation
was given to all participates on the salient features of the project by an EMC representative.
Table 6.2 shows details of the location of IDIs held in district Khairpur.
Table 6.2: Secondary Stakeholders Consultation

Type Venue Name of Stakeholders
NGO Khairpur • Goth Seengar Foundation (GSF)
• Bhittai Social Watch & Advocacy (BSWA)
• Sewa Development Organization
• Indus Resource Center (IRC)
Sindh Wildlife Sindh Wildlife Department • Mr. Javed Meher
Department Office, Karachi
Sindh Sindh EPA Office, Korangi, • Mr. Imran Sabir
Environmental Karachi
Protection Agency
6.3.2.4. Concerns and Suggestions of Secondary Stakeholders

Local NGOs
The NGOs have been working in various sectors such as education, health and nutrition, skill
development and livelihood, reproductive health, community mobilization, youth
empowerment, gender mainstreaming, poverty eradication, rights of minorities and person
with disability, and emergency relief in the areas.
Following are the concerns and suggestions regarding the project:
 Compensation should be provided timely and as per government rule to the project
affected people if any land or community asset is affected. The EIA team ensured that
the Company will compensate accordingly if any agriculture land is acquired. Company
undertakes a complete study before initiating any project to make sure that no damage
is done to any property or land. In case of any effect caused by activities on the
community asset, the company pays the compensation accordingly.
 The project will help in reducing poverty in the local areas. More jobs will be created for
the local community.
 They said that oil and gas companies are doing a fabulous work for betterment of
community. Eni is already having social welfare project in the area Community Health
Centers, Primary Schools, Secondary school and Water supply to local community.
Sindh Wildlife Department
Meeting with Conservator Wildlife Mr. Javed Meher was held on 16 May, 2022, in which the
main features of the project were presented to the Conservator. Mr. Meher said that since the
proposed project falls in Wildlife Sanctuary, provisions of Sindh wildlife Protection,
Preservation, Conservation and Management Act will be applicable. Eni Pakistan has already
applied for the NOC from wildlife department and summary of the case has been moved from
Conservator office to Secretary, Forest & Wildlife for necessary action.
Sindh Environmental Protection Agency
Meeting with Deputy Director Sindh EPA was held on 27 May, 2022 in which the main features
of the project were presented to the Deputy Director SEPA. Mr. Imran said that Sindh
Environmental Protection Act 2014 and all regulations thereunder shall be followed and we
will review the project as described in the EIA and seek public concerns also through a public
hearing at project site.
Figure 6.1: Consultation Pictures of Primary and Secondary Stakeholders

Chapter 7 Screening of Potential

Environmental Impacts and
Proposed Mitigation Measures
7.1. Introduction
This chapter presents the screening of potential environmental and social impacts of different
activities of the proposed Project during different stages. Using the general guidelines as well
as professional judgment, it evaluates the positive and negative impact of emissions and
waste discharges on the aesthetics, airshed, watershed, fauna, flora and the living
environment at project site. The chapter, besides identifying significant environmental impacts
and residual impact, also suggests mitigation measures that are to be adopted in order to
eliminate, minimize or compensate for the impact.
7.2. Methodology for Impact Assessment

The screening methodology that was adopted for the EIA study comprises impact screening
followed by detailed assessment process. It includes literature research and review of Oil and
Gas Exploration projects implemented in other parts of the world as well as in Pakistan. The
screening highlighted the major impacts that might be associated with normal operations
based on the literature research and the nature of the surrounding environment.
The key issues identified were further investigated and evaluated based on planned project
operations including proposed project activities, time duration, national and provincial
environmental regulations, Proponent’s HSE policies and commitment, and the environmental
baseline conditions. The general evaluation process include the following stages:
 Step 1: Identification of project related activities (sources) and environmental aspects;

 Step 2: Identification of potential impacts to the environment (physical, biological, human
and cultural);
 Step 3: Evaluation and assessment of the related unmitigated impact significance;
 Step 4: Identification of Good Industry Practices and Best Practicable Environmental

Options (BPEO); and
 Step 5: Re-evaluation and assessment of the mitigated impact significance.
The nature and severity of impacts were first assessed for current project plans. This identifies
the potential unmitigated impacts and the residual impacts under project designs and control
measures which are already part of the design.
After having identified and characterized the potential significant impacts during each phase
using the screening procedure identified above, an impact rating Matrix was developed to
summarize all identified impacts during each phase of the project (refer to Table 7-1). The
impact severity was derived from:
 Scoring exercise for each environmental impact,

 Results from primary data collection e.g., environmental monitoring, analysis and
calculations, and Scientific predictions based on similar projects conducted abroad or
locally.
Table 7.1: Secondary Screening Consequence Level Criteria
CRITERIA CONSEQUENCE
Massive impact over a large area resulting in extensive, potentially irreparable 5. Catastrophic
damage to a VEC*. Has a measurable effect on the livelihood of those using a
resource over a period of years. Massive impact over a large area resulting in
extensive, potentially irreparable damage to a site of social and/or cultural
importance.
Long term or continuous impact resulting in substantial adverse changes in a VEC, 4. Significant
well outside the range of natural variation. Unassisted recovery could be protracted.
Area of effect is extensive and/or encompasses an area that supports a statistically
significant proportion of a VEC population or ecosystem.
Has a measurable effect on the livelihood of those using a resource over a period of
months.
Significant damage / impact to a site of social and/or cultural importance.
Moderate adverse changes in a VEC or area that supports a VEC population. 3. Moderate
Changes may exceed the range of natural variation though potential for recovery
within a few years without intervention is good.
Area of effect encompasses an area that supports either a moderate or minor
proportion of a VEC population or ecosystem.
Long term (> 5 yrs) changes over an area which is not considered to be a VEC.
Has a measurable effect on the livelihood of those using a resource over a period of
weeks.
Moderate damage to a site of social and/or cultural importance.
Minor adverse changes in a VEC. Changes will be noticeable but fall within the range 2. Minor
of normal variation and be typically short-lived, with unassisted recovery possible in
the near term. However, it is recognized that a low level of impact may remain.
Medium term impact (1-5 yrs) in an area that does not encompass a VEC or whose
impact is highly localized within a VEC.
Long term impact over a discrete, small area which does not support a VEC.
May be noticed but does not affect the livelihood of those utilizing a resource.
Minor impact to a site of social and/or cultural importance.
Short term changes in an ecosystem that are unlikely to be noticeable (i.e., fall within 1. Negligible
the scope of natural variation). Area of effect is restricted to the immediate vicinity of
the source.
Has no discernible effect on the environmental resource as a whole and is likely to
go unnoticed by those who already use it.
Negligible impact to a site of social and/or cultural importance.
Changes that result in a net positive impact to an ecosystem, environment or Beneficial
population.
*VEC means Valuable Ecosystem Component, used to refer to components of the environment that
are considered to be of commercial and/or ecological importance.
Table 7.2: Likelihood Evaluation Criteria

LIKELIHOOD TO OCCUR CATEGORY SCORE
Impact is highly likely or certain to occur under normal operating / Certain C
construction conditions
Impact may possibly occur under operating / construction conditions. Possible B
Impact is unlikely to occur under normal operating / construction Unlikely A
conditions but may occur in exceptional circumstances.
7.3. Screening of Potential Environmental Impacts at different stages

of project development
Screening of potential environmental and socio-economic impacts resulting from various
activities performed during well drilling activities identifies following environmental constraints
that need to be addressed during project implementation:
 Soil Erosion
 Changes in Ambient Air Quality (dust and gaseous emissions)
 Impact on water resources (groundwater and surface water)
 Noise and Vibration
 Soil contamination
 Site runoff
 Waste Management
 Solid Waste
 Impact on ecology (fauna and flora)
 Visual and Aesthetics
 Impacts on socioeconomic environment, and
 Archaeology and Cultural Heritage
7.4. Social and Environmental Impacts from Drilling Activities
7.4.1. Impacts due to land and Soil Erosion
7.4.1.1. Potential impacts

Land use impacts are linked with land disturbance, habitat destruction, and soil erosion due
to proposed project activities include changes in runoff patterns, hydrological alterations,
project emissions and sediment runoff due to preparation of camp sites, construction of access
road, construction of well site, quarrying of gravel or sand, use of project access road, off road
travel and development of new access tracks. Many impacts can be reduced or avoided when
considered during siting and design of the project.
7.4.1.2. Impact Assessment

Soil erosion can be defined as the rate of soil loss greater than natural conditions. It is a two
phase process consisting of the detachment of individual particles from the soil mass and their
transport by erosive agents such wind and water (Morgan, 1988). In the context of soil erosion
due to anthropogenic activities, the detachment part may occur due to various activities such
as cropping, livestock grazing or similar activities due to which soil or the land scape of an
area is disturbed from its natural state. Construction of tracks or other facilities has also been
historically perceived and is some cases has actually led to soil erosion. The proposed project
activities for drilling involve construction/improvement of track and other facilities.
The possibility of soil erosion from human activity increases when soil particles are detached
from the soil mass. This is true for lands where the landscape is changed and the area is left
exposed to wind and water erosion. However, the case is different when the soil surface
initially disturbed is sealed or compacted by engineering means. For example, metaled roads
are not subject to soil erosion similarly neither would the gravel-topped tracks proposed for
the well sites, which will be compacted to sustain loads of heavy vehicles.
Construction of access road
A gravel top access track will be prepared to access the well sites (where required) and
existing black top road network will be used as much as possible. Construction of the access
road in the flat area will not involve any major cutting and filling. Since the entire access road
will be topped with compacted gravel, the chances of soil erosion will be reduced. The topping
can be done with in-situ or imported gravel. Mitigation measures to minimize chances of soil
erosion have been recommended at the end of this section. This will primarily be due to wind
erosion from earth-fill stockpiles and loose road surface during construction.
During development of Drilling Site
The existing land and land use pattern of the project area surrounding will get affected from
the construction of drilling site and associated activities, like leveling of land, installation of rig
& machineries, temporary storage of domestic waste and other kind of waste material etc.
These impacts may occur in terms of temporary clearing land (as this much area is required
for well drilling), changes in the aesthetic looks of the area, changes in soil characteristics from
temporary dumping of the earth and fill material required for site elevation etc.
During Well Drilling
The entire drilling operation, being a temporary activity, will not require any kind of land
acquisition (as it involves temporary leasing of land) and neither involves clearing of any trees
and vegetation. The drilling activity would require a land of around 600 ft. x 600 ft., which
involves cleaning of undergrowth for movement of truck loaded with drilling rig and associated
machineries and crews. During the entire drilling operations, drill cuttings and domestic waste
and sewage from labor camps etc. may cause soil contamination. The road within the project
area may get affected from heavy vehicular movement, as the regular movement of
approximately 20-25 truckloads will be there during drilling operation phase. The truck
movement is not likely to cause traffic congestion in the village level road as well as in the
nearby roads since the microenvironment is sparsely populated and entirely rural in nature.
Most land use impacts that occur during the drilling phase would continue throughout the life
of the oil and gas field. Overall, land use impacts could range from minimal to significant
depending upon both the spatial extent of the oil and gas field, the number of wells and other
ancillary facilities.
Quarrying of sand and gravel
Limited volumes of gravel or sand may be quarried from the project area. Because potential
for soil erosion exists if quarrying is done by excavating along or across unstable slopes.
Quarries should be selected after assessing site conditions that there will be no possibility of
soil erosion or changes in landscape due to quarrying of gravel or sand from the location.
Road Travel during project
The use of the track during the project may result in erosion of soil from the track surface. In
arid environment such erosion is quite common but is more pronounced on dirt tracks. On
gravel-topped tracks, erosion is less significant due to the compacted gravel topping. During
the project, erosion from track surface will be minimized by sprinkling of water over the project
access track and compacting loose surface wherever required. However, as water is a
precious resource in the area there will have to be some rationing of its use.
Off road Travel and Development of new tracks
In drilling operations, off road travel is minimal as activities are not scattered and only one
access track suffices during the project.
Excavation of trench for underground Flow line
Excavation of approx. 1-1.5-meter-wide and 1-1.5-meter-deep will be done for laying of flow
line. Generally, the exposed soil, after site clearance and trenching, is vulnerable to erosions
and runoff by rains. Such a situation will be of temporary nature and short duration and lasts
only during construction phase. Since the flow line will be underground and site restoration
work can adequately restore the ROW to its natural condition. Therefore, there will be no
significant change in existing land use of the area due to laying of proposed flow line.
7.4.1.3. Mitigation Measures

 Total land uptake by the camps, and access road will be kept to the minimum required.
 During construction, movement of construction equipment will be restricted to work areas

only to avoid unnecessary disturbance to soils in the project area.
 Access tracks (other than the main access track for the project) to be used by water
tankers, dumper trucks and other vehicles shall be monitored by the IMC / Eni Pakistan
HSE Dept.
 Stream crossings, when built, shall be such that the slopes of the stream bank are
properly adjusted and compacted resulting in a stabilized and sealed surface.
 Photographs will be taken at intervals throughout the project activities to monitor any
changes in soil and its conditions.
 Good engineering practices will be adopted during construction activities to ensure that
unnecessary clearing of vegetation and disturbance to soils outside work areas are
avoided
 Where improvement of existing tracks or development of short lengths of new tracks is
unavoidable the width of the access track will not exceed 24ft / 8 m.
 Well site, Flow line ROW and campsite areas will be kept to a minimum.
 The construction of well site and campsites on leveled land to minimize disturbance to
soils and landscape shall be ensured.
 The access track shall be properly compacted at the time of construction and thereafter
properly maintained by watering and compaction (where required) throughout the entire
construction and drilling operation.
 Areas along the access track, well site and campsite shall be visually monitored and any
area showing signs of soil erosion shall be watered and compacted.
 During construction phase, a single track shall be identified and approved along sections
of the main track on which work is in progress. Vehicles shall be allowed to travel only
on the approved track.
 During construction stage, dumping of gravel on or close to the access track being
improved or constructed shall not be allowed.
 Sediment barriers such as silt fencing can be utilized at construction sites to help prevent
sediment from washing offsite, from washing into irrigation canal/channels and
agricultural fields.
 The excavated soil will be contained in an enclosure to reduce the chances of runoff
during the seasons of precipitation.
7.4.1.4. Residual Impacts

It is believed that after applying the recommended mitigation measures, impact of project
activity on soil and land will not occur.
Characteristics Drilling Activity Flow Line Laying

Likelihood Possible Possible
Consequence Minor Minor
Significance Low Low
Reversibility Reversible Reversible
7.4.2. Soil and Water Contamination from Waste / Spills
7.4.2.1. Potential sources of impacts

Domestic wastes
Domestic wastes generated during drilling will include sewage, grey water (from kitchen,
laundry and showers), kitchen wastes, combustible wastes and recyclable wastes. Sewage
will be treated and disposed of by means of a septic tank and soak pit. Grey water will also be
collected in soak pits. Soak pits will be designed to accommodate wastewater generated
during total duration of the operation. In case the soak pits get filled during operation, grey
water will be sprinkled over access tracks after analyzing to ensure it meets the SEQS limit of
oil and grease. Sprinkling of grey water will be done in such a manner that the ponding of
water is avoided. In case soak pits cannot be built large enough due to high water table,
additional pits may be built in a nearby area where water table is low.
Combustible material will be handed over to certified waste contractor for appropriate disposal.
All kind of food wastes will be disposed of properly.
Medical wastes
Medical Waste will be handed over to waste contractor for its proper disposal.
Recyclable and reusable wastes
Recyclable and reusable wastes include glass, metals etc. These wastes will be sent to a
certified waste contractor, in order to ensure the wastes are recycled or reused properly,
without having any effect on the environment.
Oil Stains and spills
Fuel or oil stains, leakage or spill during exploration activities can result in contamination of
soil and water. From a management perspective these have been categorized as minor,
moderate or major and detailed below along with the recommended mitigation measures.
 Minor Spills: Leaks from vehicles, equipment, or storage containers at campsites or work
areas outside the campsite or oil or fuel stains produced during handling and transfer
operations such that the spill is less than 100 cubic meters.
 Moderate Spills: Oil spills during transfer or handling operations resulting in spillage
between 100 - 1000 cubic meters.
 Major Spills: These may occur during transportation of oil to the camp sites or failure of
the oil containment arrangement at the camp sites resulting in spillage of oil significantly
more than 1000 cubic meters in volume.
At a given time and location of the project, activities will be undertaken in a confined area of
land demarcated by fences/fringes. During the proposed project activities, there is a possibility
of
a) Soil contamination through oil spills and other chemical spills like solvents etc.
b) Water contamination by the runoff from project site which takes away the traces of
oil, chemicals or other drilling waste thus contaminating the receiving water bodies
mainly the water streams.
Drilling mud and cuttings
A water-based mud will be used to drill the well. The drill cuttings and mud will be disposed
into a pit lined with an impermeable geo-membrane. The pit will be of volume larger than the
required capacity to accommodate overflows. At the time of restoration, the pit will be
backfilled with the cuttings encapsulated within the liner and with a topsoil cover. Since the
mud and cuttings will be non-hazardous, no impacts on soil or groundwater will occur.
Produced water:
Produced formation fluids during testing will be flared along with the gas or collected inside
the lined waste pits. Produced water can also be re‐injected into the deep subsurface
formations wherever possible and feasible.

 Sewage Treatment Plant (STP) shall be the most preferred option for handling of
black/grey water due to its most environment friendly option.
 In case of unavailability of STP, septic tank and soak pits shall be provided. Septic tank
and soak pit shall be covered properly to avoid obnoxious smells in surrounding areas.
 Sewage generated at the campsites will be disposed off in septic system comprising of
septic tanks and soak pits.
 Wastewater from laundry, kitchen washings and showers will be disposed of into
separate soak pits.
 Soak pits will be built on absorbent soil and located preferably 300 m away from a surface
water source or ground water well.
 Soak pits will be constructed such that surface runoff cannot enter into the pits.
 In case if septic tank gets filled with sludge, septic tank shall be emptied through vacuum
truck and material shall be transferred to treatment facility or approved municipal drain
for appropriate disposal.
 At the time of restoration, the septic tanks will be dismantled in place and backfilled with
at least 1 m of soil cover above the surrounding natural surface level.
 At the time of restoration soak pits will be backfilled with at least 1 m of soil cover above
the surrounding natural surface level.
 It will be ensured that after restoration activities the campsites are clean and that no
refuse has been left behind.
 All concrete structures at the campsites will be removed and buried in soak pits and the
pit is backfilled with at least 1m of soil cover above the surrounding natural surface level.
 Implement plans for hazardous materials management and waste management.
 Develop a spill prevention and response plan for addressing storage locations of
hazardous wastes, spill prevention measures, training requirements, waste-specific spill
response actions, spill response kits, and notifications to authorities.
 Provide secondary containment for all on-site hazardous materials and waste storage,
including fuel. Fuel storage should be a temporary activity and fuel storage facilities
should be removed immediately upon completion of the construction and
decommissioning phases.
 Document accidental releases so that corrective actions can be taken.

 Vehicles will only be washed in designated areas within campsites.
 Vehicles will be daily checked for fuel or oil leaks. Vehicles with leaks will not be operated
until repaired.
 All fuel and oil storage areas will have a concrete pad underneath to prevent soil
contamination in case of leaks or spills.
 All fuel tanks will be properly marked to highlight their contents.
 Fuel and oil storage areas will have secondary containment in the form of concrete or
brick masonry bunds. The volume of the containment area should be equal to 110% of
the total volume of fuel stored.
 Fuel tanks will be daily checked for leaks and all such leaks will be plugged immediately.
 A spill prevention and contingency plan will be prepared to deal with moderate and major
spills.
 Spill Kits will be present near fuel and oil storage or handling areas to attend spills and
leaks.
 Used oil shall be given to an OGRA license holder used oil recycler or disposed of
through EPA approved waste contractor.
 Waste pit at the site will be lined with a HDPE liner.
Drilling
 A water-based mud system will be used for drilling.

 Waste pit at the well sites will be lined with an HDPE liner.
 The drill cuttings and mud will be disposed into a pit lined with an impermeable geo-
membrane. The pit will be larger than the required capacity to accommodate overflows.
At the time of restoration, the pit will be backfilled with cuttings encapsulated within a
liner and with a top soil cover.
 Produced formation fluids will be flared along with the gas or collected inside the lined
produced water pit at the well sites. In case the fluids discharge into the flare pit the soil
at the sides of the flare pit will be excavated and disposed of into the lined waste pit at
the well sites.
7.4.2.3. Residual Impact

It is believed that after applying the recommended mitigation measures, soil and water
contamination will not occur.

Likelihood Unlikely Unlikely
Significance Negligible Negligible
7.4.3. Impacts on the ambient air quality
7.4.3.1. Potential Sources of Impact

During the drilling operations potential sources of impact may include generation of dust from
vehicle movement, exhaust emissions from generator and vehicles. Moreover, additional
sources will include emissions during construction and possible H2S emissions.

The source of emissions during drilling will not be significant enough to alter the ambient air
quality. Monitoring of air emissions from generator used in exploration activities shows that
the emissions remain within the SEQS limits. The emissions will also disperse quickly with the
prevalent wind currents.
Exhaust emissions from generators and vehicles
As discussed earlier, stack emissions from generator, used at the campsite and the well site
will, generally remain within the SEQS limits. Any slight deviation from the SEQS will not have
any impact on the environment, as the emissions will quickly disperse with the prevailing wind
currents. Control over black smoke from vehicles and construction machinery shall be kept by
maintaining visual monitoring and tuning or maintenance of the vehicles/machinery.
Dust emissions due to construction and road travel.
Dust emissions due to construction activities and road travel will deteriorate the ambient air
quality. Since the construction activity will be confined to a specified area and vehicle
movement will on a specified track, therefore, the scale and duration of effect on air quality
will be very limited and will disappear when the activity stops due to prevailing wind.
Emissions from Flaring
Emissions in the form of oxides of carbon, nitrogen and sulfur will be produced during flaring.
Emissions from flaring will have no effects on communities or rig site workers and local air
quality because the flare pit will be kept down-wind of the well sites and more than 500m from
communities, and the emissions will disperse and dilute with prevalent wind currents.
Possible H2S Emissions in case of Emergency
In the event of any release of hydrogen sulphide gas above safe acceptable limits emergency
response procedures will be adopted.

 Minimize the amount of disturbance and areas cleared of vegetation.
 Require emission control devices on drilling and other equipment and specify use of low-
sulfur fuels to reduce emissions.
 Cover construction materials and stockpiled soils if they are a source of fugitive dust.
 Keep soil moist while loading into dump trucks and cover it before traveling on public
roads.
 Keep soil loads below the freeboard of the truck.

 Minimize drop heights when loaders dump soil into trucks.
 Tighten gate seals on dump trucks.
 Campsites will be located preferably 500 m away from communities.
 Dust emissions due to road travel will be minimized by regulating vehicle speeds and
watering of the access track.
 Generators and vehicles used during construction and drilling operation will be
maintained in good condition to ensure that emissions are kept to a minimum level.
 During operation phase, emissions from all point sources and ambient air quality should
also be monitored to check compliance with SEQS.
 Dust emissions during construction activities should be minimized by good management

practices such as locating stock piles out of the wind direction, keeping the height of the
stock piles to a minimum, keeping earthwork areas damp etc.
 During construction, leveling or widening along the access road will be done in sections,
immediately followed by sprinkling of water and also preferably compaction (where
required).
 In the event of any release of Hydrogen Sulfide gas above safe acceptable limits
emergency response procedures will be adopted. In this regard H2S will be continuously
monitored at the well location and safety drills will be conducted on regular basis to deal
with the emergency situation.
7.4.3.4. Residual Impacts

It is believed that after applying the recommended mitigation measures, no deterioration of air
quality will occur.

Likelihood Possible Possible
Significance Low Low
7.4.4. Impacts due to noise pollution
7.4.4.1. Potential sources

Sources of noise during construction and drilling related activities will be generators, vehicles,
construction equipment and machinery and drilling rig. These sources of noise can be
categorized as short term and intermittent arising from activities associated with drilling.

Although increased noise levels during drilling operations will not accumulate but can
individually be a source of nuisance for locals and source of disturbance to wildlife. Monitoring
of actual noise level during construction and drilling operation has shown that noise attenuates
to ambient level after approximately 300 m from the source.
As the well site and campsite will be located at a safe distance from major communities, the
impact of noise generated from activity areas or the campsite on the settlements will not be
considerable. Similarly, effects of vehicle noise on communities will also not occur if the access
tracks maintain a reasonable safe distance from communities. Any effects of noise during the
operation shall be mitigated by the measure listed below.

 Well site, Flow Line route and camp site will be located 500 m away from the nearest
community.
 Position all stationary sound-generating equipment (i.e. pumps and generators) and
exploratory wells as far as possible from nearby residences and other sensitive
receptors.
 Whenever feasible, schedule diverse noisy activities (e.g. earthmoving) to occur at the
same time, since it will be less irritating to have less frequent loud activities than frequent
less loud activities.
 All equipment should have sound-control devices.
 Noise levels at communities nearest to the well site, campsites and access tracks shall
be monitored by Site Health, Safety and Environmental Officer (HSE). In case these are
found to exceed acceptable limits, appropriate mitigation shall be taken.
 Route heavy truck traffic supporting construction and drilling activities, away from
residences and other sensitive receptors.
 It shall be ensured that generators, vehicles and other potentially noisy equipment used
will be in good condition.
 The use of pressure horns shall not be allowed.
 Movement of all project and personnel vehicles shall be restricted within work areas.
 Generators will be kept within enclosures to minimize dispersion of noise.
 In areas with higher noise levels or longer shifts, use of ear plugs and earmuffs will be
ensured among the workers.

It is believed that after applying the recommended mitigation measures, impacts due to high
noise level will be controlled.

7.4.5. Use and Availability of Water
7.4.5.1. Potential sources of Impact

Surface water resource and groundwater resource in the villages, situated near the proposed
well 3, are irrigation canal (originating from Nara canal) and tubewells respectively. The
villagers are dependent on groundwater for drinking and other domestic purposes and water
from Nara canal is used for irrigation purposes. The extraction of water for project activities
can affect groundwater availability in the short term, which implies that the groundwater
available to the communities may fall. This should not however, affect the long-term availability
of the area’s water resources.
Impacts on water resources quality are related to land disturbance, erosion, changes in runoff
patterns, and hydrological alterations, project effluents, and resource use.
7.4.5.2. Impact assessment

During drilling, impacts to water resources could occur due to water quality degradation from
increases in turbidity, sedimentation, and salinity; spills; cross-aquifer mixing; and water
quantity depletion. Water would be required for dust control, making concrete, consumptive
use by the construction crew, and in drilling of wells. Depending on availability, it may be
trucked in from off-site or obtained from local groundwater wells or nearby surface water
bodies. Where surface waters are used to meet drilling and development needs, depletion of
stream flows could occur.
Drilling activities may affect surface and groundwater flows. If a well is completed improperly
such that subsurface formations are not sealed off by the well casing and cement, aquifers
can be impacted by other non-potable formation waters. The interaction between surface
water and groundwater may also be affected if the two are hydro-logically connected,
potentially resulting in unwanted dewatering or recharging.
Also, hydrotesting of pipeline is essential to ensure the integrity of the pipeline. For this
purpose, large volume of water required. If that quantity is abstracted from a resource used
by locals for their domestic and agriculture needs, water shortage may occur for the locals,
although for short duration. Therefore, the water for hydrotesting should be acquired from a
surface water source.

 The quantity of water used during construction, drilling and flow line hydrotesting will be
kept to the minimum required by taking prudent water conservation measures on site.
 A complete record of water consumption during construction and drilling operations will
be maintained.
 Marginally sweet water wells will be used for drilling, flow line hydrotesting and other
project related activities.
 Water from a local well will only be used (if such case arises), after ensuring that the
available capacity at the tube well (safe yield minus local demand) is at least 50% greater
than the project demand. Discharge from the tube well will be regularly monitored to
monitor any changes in the yield of the wells. If a single well fails to meet this requirement,
water will be obtained from multiple wells such that each well meets the above-mentioned
requirement. Incase water well is to be drilled by Eni Pakistan, this should be drilled in
deep aquifer and at least 300 m from nearest community water well.
 Proper and justified compensation for water utilized will be paid by Eni Pakistan and the
contractors to the owner of the water wells.

It is believed that after applying the recommended mitigation measures, issues of water
availability and use will not arise.

7.4.6. Impacts due to Hazardous Material and Solid Waste Generated

Hazardous materials and solid waste impacts are related to the types and amount of
equipment, machinery and chemicals used during the project construction and operation
phases. Solid and industrial waste would be generated during drilling activities. Much of the
solid wastes generated would be expected to be non-hazardous; consisting of containers and
packaging materials, miscellaneous wastes from equipment assembly and domestic waste
(food wrappers and scraps) and woody vegetation. Drilling wastes include hydraulic fluids,
pipe dope, used oils and oil filters, rig wash, spilled fuel, drill cuttings and associated
wastewater, drums and containers, solid waste and garbage. Adverse impacts could result if
hazardous wastes are not properly handled and are released to the environment.
In some locations, drilling mud may carry Naturally Occurring Radioactive Materials (NORM)
to the surface. Typically, the NORM radio nuclides (primarily radium-226, radium-228, and
their progeny) are dissolved in the drilling mud but a portion of the NORM can precipitate into
solid form in scales and sludge that accumulates in pipelines and storage vessels. Proper
management of NORM-bearing produced water and solid wastes are critical to prevent both
occupational and public human health risks and environmental contamination. NORM wastes
are a problem generally associated with long-term operation of an oil or gas field, but can also
be associated with the drilling/development phase.
Flow line
It is envisaged that site clearing, trenching, painting of pipeline and laying of flow line
operations produce excavated earth, wood remains, bitumen drums, waste paint drums etc.
This waste has the potential to cause adverse impact on the surroundings if not properly
managed and disposed to approved dumpsites. For example, it could destroy the aesthetic
appearance of a location/site.

Adverse impacts include contamination of water sources and soil which could subsequently
result in impact on humans, fauna and flora, if hazardous wastes are not properly handled and
are released to the environment. Following is the list of hazardous material and waste which
will be handled carefully.
Naturally Occurring Radioactive Materials Hydraulic fluids

(NORM)
Drill cuttings Pipe dope
Used oils and oil filters Rig wash
Spilled fuel Bulbs and batteries
Diesel fuel

 Develop a hazardous materials management plan addressing storage, use,
transportation and disposal (interim and final) for each item in the comprehensive list.
 Develop a waste management plan identifying anticipated solid and liquid waste streams
and addressing determination, inspection and waste minimization procedures, storage
locations and waste-specific management and disposal requirements.
 Include a recycling strategy to be practiced by workers during all project phases.
 Develop a spill prevention and response plan for addressing storage locations of
hazardous wastes, training requirements, waste-specific spill response actions, spill
response kits, and notifications to authorities.
 Train employees to promptly contain, report and/or clean up any oil or hazardous material
spill.
 Provide secondary containment around all the fuel storage tanks and chemical storage
area of suitable size (110% of the storage area/ tank capacity). Fuel storage should be a
temporary activity and fuel storage facilities should be removed upon completion of the
project activities
 Containerize and periodically remove wastes for disposal at appropriate off-site permitted
disposal facilities. The goal would be to minimize the amount of hazardous materials and
waste onsite.
 Isolate surface reserve pits where drill mud and drill cuttings and produced water are
stored or where they are ultimately disposed of, from both surface and ground water
resources (through use of appropriate top and bottom liners and top soil and vegetative
cover).
 Employ a long-term monitoring program to ensure that mitigation measures employed
throughout the project are effective.

After implementation of the recommended mitigation measures, issues arising due to waste
management will be less significant.
Characteristic Impact
Likelihood Unlikely
Consequence Minor
Reversibility Reversible
Significance Negligible
7.4.7. Site Restoration after drilling activities

In environmentally sensitive areas restoration of well site and associated facilities (including
access track and campsite) is of utmost importance. As these facilities do not occupy large
areas of the wildlife and vegetation habitat, retention of these sites or improper disposal of
wastes left at the end of the drilling or construction activities would not be in conflict with the
principle of least environment disturbance over the least possible time period in these areas.
Restoration of the well site, access track and campsite will depend on whether the drilled well
is a success or failure. The restoration measures that will be carried out have been separately
listed as follows for the two possibilities;
Complete restoration – Dry well
If there are no indications of a commercial quantity of oil and gas then the well will be declared
dry and will be plugged and abandoned in line with the local regulations, Eni Procedures and
good industrial practices. The well site, camp and portion of access track which leads to the
well site from the main community track will be restored.
7.4.7.1. Mitigation measure

 All equipment and machinery at the well site will be demobilized.
 All wastes at the well site will be disposed of according to the requirement of the EIA.
 All concrete structures at the well site will be broken and either transported out of the
project area by site restoration contractor for sale or reused or disposed of into the pits.
 All pits at the well site will be backfilled.
 Drill cuttings will be disposed of within the lined cuttings pit at the well site. Drilling mud
and other liquids will be allowed to evaporate or wastewater will be treated and disposed
of through waste contractor.
 The areas covered by the portion of the access track that will be of no use for other wells
will be restored, in that all gravel topping will be removed. This scenario will be applicable
only if the locals require the portion of the track to be restored or otherwise it will be left
on the site on the consent of the locals.
Partial Restoration – Producing Well
An alternative situation is if commercial quantities of oil and gas are discovered then the well
will be suspended while testing results are analyzed, reservoir modelling conducted and
production equipment ordered. In this case, the oil and gas bearing zones in the well will be
squeeze-cemented and further cement plugs and permanent packer /cement retainers will be
set above the perforation, the casing shoes and at surface.
7.4.7.2. Mitigation measure – Partial restoration

 All wastes at the well site will be disposed of according to the requirement of the EIA.
 The well site and access roads will be retained to support well access work for further
testing.
 The outer chain link fence will be retained as a safety measure to keep wildlife away from
the pit areas.
 The wellhead will be enclosed by a locked steel cage. This will serve as both a safety
and security measure as the site will be down-manned pending further development
operations work.
 The constructed pit areas will be backfilled with at least 1 meter of soil cover.
 All wastes at the well site will be disposed of in environment friendly manner.
7.5. Potential Impacts during Pre-Commissioning & Commissioning of

Flow line
Following completion of construction work, pipeline commissioning will be carried out to check
whether pipeline and associated facilities are complete in all respect. Activities performed
during commissioning would include:
Pre-commissioning
 Hydrotesting of pipeline
 Flushing and cleaning of pipeline;

 System dry-out; and
 Inerting.
Commissioning
 Systematic conformity checks of equipment;

 Static, de-energized test of equipment;
 Preliminary check;
 Functional check;
 Operational test; and

 Pre-start-up activities
During pre-commissioning and commissioning activities, the main environmental concerns
pertain to:
 Wastewater from hydrotesting

 Noise
7.5.1. Wastewater from Hydrostatic Testing

Hydrotesting (or hydrostatic testing) is the most common method for testing the integrity of the
pipeline and checking for any potential leaks (e.g., from faulty welds or cracked pipe) prior to
commissioning. The test involves placing water inside the pipeline at a certain pressure to
check that the pipeline is not damaged and will not leak during operation. After hydrostatic
testing the pipeline will be dewatered and dried.
International Finance Corporation (IFC) has issued guidelines for Hydrostatic Testing Water
and recommends meeting following requirements for Hydrostatic Testing:
 Water sourcing for hydrotesting purposes should not adversely affect the water level or
flow rate of a natural water body, and the test water withdrawal rate (or volume) should
not exceed 10 percent of the water source.
 The disposal alternatives for test waters following hydrotesting include (1) injection into
a disposal well if one is available or (2) discharge to surface waters or land surface.
 If a disposal well is unavailable and discharge to surface waters or land surface is

necessary, the following pollution prevention and control measures should be
considered:
− Reduce the need for chemicals by minimizing the time that test water remains in the
equipment or pipeline;
− If chemical use is necessary, carefully select chemical additives in terms of dose

concentration, toxicity, biodegradability, bioavailability, and bioaccumulation
potential;
 Hydrostatic test water quality should be monitored before use and discharged into the
land and should be treated to meet the discharge limits of SEQS for effluents.

The water required for hydrotesting will probably be local groundwater. It is planned that no
chemical additives will be added to the hydrotesting water. Hence, water after hydrotesting
can be safely disposed of without treatment. Other measures that will be adopted in this regard
include the following:
 Water source will be carefully selected so as not to impact water availability for the local
users.
 It will be ensured that the used water from hydrotesting is not discharged in nearby canals
or other surface water body.

Characteristic Flow Line pre-commissioning
Likelihood Unlikely
Consequence Minor
Significance Low
7.5.2. Noise
During cleaning, Gauging and Hydrostatic Testing activities, ambient noise levels may
significantly increase from baseline noise levels. The increase is due to the noise emissions
expected from the equipment used during the commissioning and start-up activities.
The impact from noise during commissioning activities will be temporary since the high-
pressure discharges during hydrotesting are one-off events at a given testing flow line section
and in general the commissioning and start-up works would be moving along the pipeline route
alignment and thus would be at a single location for a short period of time.

 It is recommended the IFC guidelines for Hydrotesting activity be considered and
adopted
 The contractor should not exceed scheduled period for hydrotesting and this should be
minimized as far as practicable.

Characteristic Flow Line pre-commissioning
Likelihood Unlikely
Consequence Minor
Significance Low
7.6. Potential Impacts during Operation Phase of the Flow line

Activities during operation phase of the flow line will be limited including gas/oil transmission,
maintenance and monitoring. Consequently, very few environmental impacts are envisaged
on the ambient environment during operation. Main scenarios in this regard include:
a) Small scale hydrocarbon emissions in the event of flow line leakage

b) Emergency scenarios (Fire and Explosion)
7.6.2. Small scale hydrocarbon emissions in the event of pipeline leakage

During potential leakage, small scale liquid / gaseous emissions may be release to ambient
air. Main constitute of leaked gas include mainly methane along with hydrocarbon
constituents. The probability of these emissions is small since leak detection and control will
be done as part of regular monitoring and maintenance.

 Regular maintenance and leak detection will be part of monitoring during operation
phase.
 Any leaks detected will be immediately fixed.
 Site to be restored immediately after repair.

Characteristic Flow Line Operation
Extent Local
Likelihood Unlikely
Consequence Minor
Significance Low
7.6.3. Emergency Scenarios (Earthquake)

The Geological Survey of Pakistan categorizes the project area in Seismic Zone 2A region.
This suggests the possibility of moderate to major seismic hazard i.e. probability of
earthquakes of intensity VII to IX MM scale. The peak ground level acceleration (PGA) for this
zone is 0.98-1.96 m/s2.

Natural hazards will be managed by robust Emergency preparedness and response plan.

Characteristic Flow Line Operation
Extent Local
Likelihood Unlikely
Consequence Minor
Significance Low
7.7. Impacts on Occupational Health and Safety

Potential for occupational accidents and mortality would vary during the various phases of the
project and would be mitigated easily if a competent and vigilant team is present to manage
the issues appropriately.
Potential impacts to workers’ health and safety during the drilling phase would be similar to
other projects that involve earthmoving, use of large equipment, transportation of heavy and
huge materials, and contact with wastes from rig, construction and installation of industrial
facilities.

 Develop and implement a health and safety management program for workers,
addressing all of the safety issues identified and all applicable safety standards.
 Local complaints of dust emissions shall be noted and addressed immediately.
 Although all project drivers will adopt safe driving practices, special care will be taken
while passing by the settlements, and will reduce speed as required.
 If alternative routes exist, existing tracks passing close to settlements will not be used.
 Camps will be established away from the communities (preferably 500m away).

Characteristic Project activity
Likelihood Unlikely
Consequence Minor
Significance Low
7.8. Impacts on the Ecology, Fauna and Flora
7.8.1.1. Potential sources

Drilling of well involve mobilization of a large number of workers, vehicles and also removal of
vegetation during land clearance. These activities can disturb the wildlife in the project area.
Small animals, birds and reptiles can be forced to move to other places due to increased
human intervention, destruction of burrows and nests and indirectly by noise and vibrations
due to movement of heavy vehicles.
The potential effects on vegetation will include:
 Loss of vegetation due to land clearing for well site; camp sites; access roads (new short
reaches of access tracks prepared during to access the well site location);
 Effects of dust emissions on road side vegetation;

 Effects on vegetation due to obstruction of natural drainage.
 Effect on the habitats of the wildlife

During construction and road travel during drilling operation, dust will be generated which may
accumulate on the road side vegetation. This can in certain cases possibly hinder the plant
growth and metabolism. The EIA recommends regulation of vehicle speeds, sprinkling of
access tracks, and compaction and maintenance of permanent tracks to further reduce the
likelihood and consequence of any adverse effect.
Clearing of land areas for the project facilities will not have a cumulative effect on vegetation
or the habitats of the local wildlife as the project area is not heavily vegetated. With the
implementation of provided mitigation measures recommended in this EIA are any impacts, if
occur, will have minor significance.
Mammals
Though areas with dense vegetation will be avoided while clearing the land for access track,
yet there will be some impact on the small mammals of the area, such as damage to their
burrows and dens that may need protective measures. Project impact on these species is
expected to have considerably reduced significance, since large mammals will temporarily
leave the specific area of the project activity, and will come back once the disturbance level
decreases.
Birds
Birds, being highly mobile and therefore capable of avoiding project activity areas, are
generally the least vulnerable species of wildlife to the long-term impacts of anthropogenic
activities. Two avian species, the Houbara bustard and the partridge are included in the project
area's species of special significance. The Houbara bustard is a winter visitor, whereas the
partridge is a resident of the area.
Reptiles and Amphibians
The project activities’ impacts on the reptiles and amphibians of the project area will be similar
to those on the small mammals discussed earlier. The leveling/clearing of land and operation
of truck may destroy the burrows of these animals. Though avoiding areas of dense vegetation
will reduce this impact, yet a certain degree of residual effects is expected to persist over a
period when the new generation attains maturity. However, in view of the subsistent population
of these species in the area, the unmitigated residual impacts could be considered
insignificant.
Small Mammals and Reptiles
It is expected that small mammals, mainly rodents and reptiles will displace from a corridor of
5-25 m (or more depending on the species and local conditions) along the access road and
around the well site and campsites. However, owing to the large and wide spread population
size of these species and the large area otherwise available to them, no significant effect of
the project on small mammals and reptiles will occur. Mortality of small mammals and reptiles
during construction or due to road travel will be avoided by adopting mitigation measures.

 Vehicle speeds will be regulated and monitored to avoid excessive dust emissions.
 Access tracks will be avoided from passing through patches of dense vegetation.
 Off-road travel, required at sections of the road where construction work is in progress,
will be minimized and if required will be allowed only after approval from Eni Pakistan.
 Prior to commencement of any activity, awareness trainings will be provided to

contractor’s management and field crew on matters related to the importance of Nara
Desert Wildlife Sanctuary and requirements of the EMP in this regard.
 All mitigation measures to minimize noise levels, dust emissions, air emissions, and
waste management required by the EIA will be adhered to.
 Construction work near areas which show small mammal and reptile populations will
commence after a soft start up and will be randomly monitored.
 Vehicle speeds on access road will be controlled to avoid incidental mortalities of wildlife.
Any such incident will be reported to the Eni Pakistan.
 Cutting of trees/bushes will be minimized.
 Movement of all project personnel will be restricted to work areas.
 Movement of project vehicles will be restricted only to the project access road or to routes
approved by the Eni Pakistan.
 Night work will be prohibited; night traveling will not be allowed unless absolutely
necessary.
 Campsites will be located preferably 500m from perennial water bodies.
 Well site and campsite areas will be kept to a minimum.

 Earthen pits for preparation and disposal of mud and drill cuttings will be located in an
area where minimum vegetation removal is involved.
 The beauty of the landscape should not be affected/damaged.
 Special attention should be paid to safety of reptiles while working in their Habitat area.
Their burrow should not be damaged during land clearing and drilling activities. After the
completion of activity, the area should be restored to as much close to the original
condition as possible.
 Natural drains that carry rainwater from the area should not be blocked or diverted.
Where necessary, after work, the flow of these drains should be brought back to its
original condition.
 Great care should be taken that no tree or vegetative covers are cut and the removal of
vegetation outside the core habitats is kept to be minimum. Where removing vegetation
is unavoidable, action will be taken only after approval from the SFD.
 Do not dump leftover food / food waste in the open.

 Wastewater from the camp site will be collected in soak pit and septic tank.
 Chemical contaminated water from the drilling site should not be drained in the project
area without treatment.
 Prohibit unnecessary use of horns.
 Any wild animal or their cub should not be caught to make pet.
 Proponent will facilitate wild life expert visit during the project execution for monitoring
compliance with regulatory requirements.
 Nests of birds present in the grass lands should not be destroyed.
 Maintain safe distance from the breeding locations of birds and mammals. The wildlife,
especially their offspring should not be threatened.
 Sightings of wildlife in the project area should be reported.
 Wildlife may come in contact with the project personnel. They should not be chased or
scared.
7.9. Impact on Socio-economic, Cultural and Archaeological Resource

All development initiatives give rise to secondary impacts that affect socio-economic receptors
in the project area. Socio-economic impacts vary from project to project and are not easily
quantifiable. These are consequences of project activities on the human population that alter
the ways in which people live, work, interact, relate to one another, organize to meet their
needs and generally exist as members of society.
These also include more long-term impacts such as cultural impacts involving changes to the
norms, values, and beliefs that guide and rationalize their cognition of themselves and their
society. In the past socio-economic impacts of large development projects were mitigated
through monetary compensation, or job opportunities for unskilled labor. However, the
importance of these impacts have been recognized, and it is very strongly felt that impacts on
communities, cultural activities, local practices, and day-to-day activities have far reaching
impacts on their psychological, emotional and social well-being, whereby having an effect on
their quality of life. This section identifies, assesses and proposes mitigation for potential
impacts of the project on key parameters, which define the well-being of the communities.

Sustenance income
The livelihood of local communities largely depends on agricultural, livestock farming and
other land related activities. For the well site land availability for the project needs to ensured
and therefore land for other purposes will not be available. The land for the project has been
leased as per Petroleum Concession Agreement (PCA), by Ministry of Energy (Petroleum

Division).
Other social impacts are discussed below:
Local Economy
 Increased turnover of local businesses and shops due to an increased demand from
project contractors and their employees.
 An increase in the income of locals may occur due to employment in the projects.
Drinking water
 Sharing of limited local domestic water sources.
Employment
 Distribution of employment opportunities during project activities.
Health
 Effect on health of local communities due to project wastes and dust emissions
Safety and Security
 Potential risk for road accidents, conflicts with locals and safety of local employees
Mobility and transportation
 Ease/difficulty in mobility and transportation
Culture and Religion
 Damage to cultural, archaeological or religious sites

Sources of Income: Potential issues related to sustenance incomes have been assessed
below:
Leasing of Agricultural Lands/Uptake of livestock grazing area/effect on mobility of livestock

herds/potential for loss of livestock due to road accidents
The land for the project has been leased as per Petroleum Concession Agreement (PCA), by
Ministry of Energy (Petroleum Division). The project area may cover livestock grazing areas.
Compared to the total available grazing area, the uptake by the project will not be significant
and will not have any measurable significant affect. Project vehicles will follow safe speed
limits, especially on seeing a livestock herd near the road to avoid any road accidents.
Sharing of Water Source
As discussed earlier the project water usage will not affect the accessibility of locals to the
water source in the long or short term as project’s water demand will be met through external
sources. Water from local source will only be used after ensuring that the abstraction process
will not result in any water shortages and approval from concerned department.
Effects on Local Businesses
Local businesses (such as shops and tea stalls) will experience a rise in sales as junior level
project staff and local employees will purchase items of general use from shops and will
patronize local tea stalls and eateries on a regular basis. This will have a positive impact on
the local businesses.
Employment
Opportunities for wage labor in the project area are very few. As a consequence, the
expectations of local residents in relation to employment during the project will be high.
Unskilled and some semi-skilled workforce shall be hired equitably on merit from within the
local communities.
Safety and Security
The operations may affect the safety and security of the inhabitants of the areas in the
following ways: issues of road safety, conflicts between residents and the construction
contractors, safety and security issues pertaining to the carriage of fire arms on the site.
Community sensitive project planning and implementation as prescribed through the
recommended mitigation measures will minimize the occurrence of any such impacts.
Disturbance from Noise
The camps will be located preferably more than 500 m from communities. Project activities
need to be carefully planned to avoid impact on local communities.
Mobility and Transportation
The project activities may affect mobility of local women. Project personnel will be given
gender sensitization briefings and will be instructed to respect local norms, the local culture,
particularly in relation to the womenfolk of the area. In connection to the usage of the access
track by the women of the area, they will not be restricted in any way, and will be given due
right to crossing the road in pursuit of the daily chores, such as collection of fuel wood and
fetching water.
Community Grievances
Communities that are located close to the access road will be exposed to dust emissions,
wastes from the labor camps, and any accidental spillage of fuel or oil. If the mitigation
measures relating to the control of dust emissions, oil or fuel spills, and project wastes are
followed, no impacts will occur. Local complaints of dust emissions shall be noted and
addressed immediately. Community Complaints shall be duly recorded, addressed and
appropriately resolved.

 Local sources of drinking water will not be exploited without taking steps listed in water
use mitigation measures,
 The access road will be watered regularly to minimize dust emissions (if required),
 Drivers will be trained in responsible and safe driving practices, a speed limit shall be set
and maintained; in addition, vehicle logbooks will be maintained and inspected for
compliance,
 Labor from local communities will be recruited equitably, avenues for conflict resolution
will be open, and the employment procedures will be transparent,
 Use of local firewood for cooking by contractor staff will be prohibited,
 The vehicle speed for traveling along the access road will be limited,
 Generators and vehicles will be regularly maintained to minimize emissions,
 Damage to any artifacts (if present) will be prohibited and any construction activities near
these areas will be monitored by Eni Pakistan,
 A safe distance will be maintained from sites of archaeological significance (if present),
 The road will be re-aligned to maintain safe distance from the edge of any graveyard (if
found),
 All community grievances will be addressed and resolved accordingly,
 If any archeological site is discovered during the survey / construction, Eni Pakistan shall
be liable to halt all the work activities, demarcate the area & notify the department.
Chapter 8 ENVIRONMENTAL MANAGEMENT

PLAN (EMP)
8.1. Introduction
The Environmental Management Plan (EMP) elaborates the principles, practices and
procedures to be implemented by the Eni Pakistan, Drilling Contractor (DC) and Flow Line
construction contractor (if flow line is laid) for the proposed project to manage and mitigate
potential adverse environmental effects during construction and operation phase. These
principles, practices and procedures meet resource consents and designation conditions,
relevant legislation and the environmental objectives of the EPA.
An EMP establishes what an organization need to do in order to manage itself so as to meet

its environmental, economic and social goals. A typical EMP model is represented
diagrammatically below.
Management
Policy
Review
Checking
Corrective Planning
Action
Implementat
ion
Figure 8.1: Typical EMP Model
Monitoring measures have been recommended to monitor any residual impacts (impacts
remaining after applying the recommended mitigation measures) or for impacts in which there
has been a level of uncertainly in prediction. Advice on monitoring measures required was
sought from experts involved in the EIA and case studies of similar development activities at
national and international level.
For the effective implementation and management of the mitigation measures and monitoring
requirements an Environmental Management Plan (EMP) has been prepared and presented
in this section. The EMP has been prepared following all the applicable Sindh Environmental
Protection Agency guidelines and satisfies the requirements of guidelines for the preparation
and review of environmental reports.
Environmental Monitoring Plan (EMP) has been made part of this document, which defines all
the impacts and their mitigation measures and has highlighted the responsible personnel to
work for the implementation of this EMP.
8.2. Objectives of the Environmental Management Plan

The purpose of this EMP is to describe the environmental management and monitoring
procedures to be implemented during the Project’s construction and operation phase. The
EMP will ensure that appropriate environmental management practices are followed during
the project’s construction phase.
The EMP will enable Eni Pakistan Project team and DC to construct and operate project with
the least adverse environmental effect. Overall, implementation of this EMP will ensure.
 Compliance with the conditions of resource consents and designations

 Compliance with environmental legislation
 Adherence to the alliance’s environmental objectives.
 Environmental risks associated with the project to be properly managed.
 Take up each environmental impact identified in the EIA & then suggesting corrective
measures and mentioning the agencies responsible for implementing these measures;
 Build up a monitoring and verification system by setting standards that can validate the
performance of these mitigation measures;
 Describe the roles and responsibilities of the project proponents for the implementation
of EMP and suggesting coordination with other stakeholders; and
 Point out the actions essential for compliance with EMP and communicating it to the
relevant regulatory authorities
The EMP sits alongside the Stakeholder of this project and identifies the key stakeholder
groups and methods for engaging with them as well as individual members of the public
throughout the construction and operation phase of the project.
Thus, the format of EMP would consist of mentioning against each impact, the person(s) or
offices responsible for taking action, standards that would form the criteria for monitoring and
time it would take to execute that mitigation measure.
8.3. Scope and Priority

This is the main step to identify the areas for environmental management and priorities to be
given based on the risk involved. Following criteria will be used to determine priorities for
attention:
 Impacts on physical and biological environment:

 Contribution to innovation and definition of best environment practice;
 Compliance with statutory requirements and other environmental commitments;
 Availability of resources.
The scope of EMP includes the following functional areas:
Management System
Those systems employed in the management of the operational activities which includes
financial systems; engagements and supervision of contractors; purchasing policies etc.
Knowledge System
Those processes which build knowledge and capacity on environmental issues, principles and
sustainable behaviors including training and communications.
Biodiversity
It includes aspects of management and maintenance which support conservation and

enhancement of biodiversity and environmentally sustainable use of open space.
Energy Management
It includes energy related aspects of the planning, design, construction, operation and
maintenance of the project.
Water Management
It includes aspects of supply usage and disposal of water pertinent to the planning, design,
construction, operation and maintenance of the project facilities.
Material Management
Those services and activities which support the avoidance, resource recovery (e.g. reuse
recycling) and environmentally responsible disposal of solid and liquid waste materials will be
included in material management.
Planning, Design and Development
The planning, design and development of the project includes associated infrastructure.
Compliance and Pollution Prevention
Those aspects of planning and management which support minimization of air and water
pollution and contamination of land resulting from activities.
Transportation Management
It includes programs, and procedures for safe vehicles maneuvering inside and outside the
project footprints.
Health and Safety Management
This management is recommended to carry out a complete assessment, evaluate, monitor,

identify and control all potential hazards and risks arising during the construction and operation
phases of the proposed project. The management needs to ensure the Health and Safety Plan
(HSP) along with the Facility Health and Safety Rules is established and enforced. The Facility
Health and Safety Rules should include provisions for, impediment of and response to noxious
chemicals and gases. It is also the responsibility of the management to provide the following
basic information:
 Description of all potential hazards/risks.
 Health and safety implications about all hazards.
 Description about management techniques including inspections, maintenance follow-

up, reports, personnel protective gears and medical monitoring.
 Outline of emergency response procedures including organizational structure of key

training personnel to act as emergency responders, action steps for entering and working
within zone of hazards, evacuation procedures, protective gear requirements,
decontamination procedures, lines of communication, emergency call centers’ telephone
numbers, map nearest medical centers’ route, etc.
 A follow-up procedure after the emergency is over.
8.4. Maintenance of the EMP

EMP needs to be revised on periodic basis to maintain up-to-date environmental management
requirements with the changing physical and regulatory constraints. Therefore, outlining and
defining the responsibilities of personnel and activities under the project’s operation execution,
implementation, mining, operation & monitoring and decommissioning phase are integral part
of maintenance of the EMP. Dissemination of reviewed and revised EMP need to be ensured
to all stakeholders particularly, relevant government and municipal agencies so that their
modified role is also redefined and re-established in the overall environmental management
process.
8.5. Legislations and Guidelines

The EIA has discussed national and international legislation and guidelines that are relevant
to the project (Refer Chapter 3). Eni Pakistan will ensure that the project is conducted in
conformance to Eni Pakistan’s corporate environmental policy, national legislation and
relevant international conventions and the guidance is sought from national and international
guidelines. Eni Pakistan will also ensure that its key project management staff and all its
assigned contractors are aware of these legislation and guidelines prior to the start of project
activities.
8.6. Organizational Structure and Responsibilities
8.6.1. Organizational Structure

The proposed project includes the following two organizations:
 Eni Pakistan as the project proponent and owners of the EMP;

 Project Drilling Contractor (DC) as the executor of the EMP
In addition to the above organizations, Independent Monitoring Consultant (IMC) will also be
involved for compliance and effects monitoring. The general roles and responsibilities of Eni
Pakistan and the Contractors are detailed in the following sections.
8.6.2. Roles and Responsibilities of Eni Pakistan

As project proponent, Eni Pakistan will be responsible for ensuring the implementation of the
EMP and the overall environmental performance of the operations. The Eni Pakistan Drilling /
HSE Manager will hold the responsibility within the organization and may delegate his
authorities to a Health, Safety and Environment Supervisor (HSE Supervisor). The HSE
Supervisor will ensure that the provisions of the EMP are translated into the contractor’s
requirements and these requirements are implemented to the full extent.
8.6.3. Roles and Responsibilities of Project Contractors

For the proposed project, Eni Pakistan will appoint contractor(s) for the drilling and associated
activities. The contractor(s) will be responsible for implementation of, or adherence to, all
provisions of the EIA recommendations and the EMP and with any environmental and other
codes of conduct required by Eni Pakistan. Overall responsibility for the contractor’s
environmental performance will rest with the person holding the highest management position
within the contractor’s organization in Pakistan. Reporting to their management the
contractor’s site manager will be responsible for the effective implementation of the mitigation
measures stated in EIA report and the EMP. The contractor’s HSE Supervisor will have
functional responsibilities to ensure implementation or adherence to the requirements of the
EMP.
8.6.3.1. Planning and Design of the Proposed Operation

Design of the Operation
Design of the operation includes drilling of development wells and other ancillary operations
discussed in the EIA. Following approval, if any design parameter is changed the proponent
will assess the environmental impacts that may arise from such change(s). If the impacts are
found to be different and in excess of those mentioned in the report, Eni Pakistan will develop
mitigation measures to minimize these impacts.
Approvals
Obtaining Approval from SEPA does not relieve the Proponent of other obligations and hence
Eni Pakistan will obtain all relevant clearances and necessary approvals required by the
government prior to commencement of activities.
Contractual Provisions
The requirements of this EIA in terms of environmental mitigation shall be incorporated into
the operational plans and bidding documents with DC.
8.6.3.2. Implementation of the Drilling and Associated Activities

Co-ordination with Stakeholders
Eni Pakistan will ensure that co-ordination with the project stakeholders and regulators on
environmental and social matters, as required by the EMP are maintained throughout the
operation.
Training
The Eni Pakistan-HSE Supervisor will determine the training requirements for the drilling and
flow line laying crew necessary for understanding and effective implementation of the EMP.
The Eni Pakistan’s HSE Supervisor and DC will then disseminate the necessary training to
the relevant personnel. Record of training provided should be maintained.
Objectives
The key objective of the training program is to ensure that the requirements of the EMP are
clearly understood and followed throughout the project. The trainings to the staff will help in
communicating environmental related restrictions specified in the EIA and EMP.
Roles and Responsibilities
The contractor will be primarily responsible for providing environmental training to all project
personnel on potential environmental issues of the project. The contractor will be responsible
for arranging trainings and ensuring the presence of targeted staff. However, overall
responsibility to ensure provision of training lies with the proponent.
Table 8.1: Responsibilities of Eni Pakistan and drilling and flow line construction contractor
Organization Designation Responsibilities Operating Documents
Eni Pakistan Drilling & • Ensure that the proposed drilling • Contracts with GoP
Wells project is carried out within the • Relevant environmental laws
agreed timeframe according to • EIA for the Drilling &
Operation
satisfactory HSE and technical Associated Activities, and
Manager standards conditions of approvals from
Sindh EPA
• Eni Pakistan’s HSE policy
HSE • Ensure that the entire project is • Contract with GoP
Manager conducted in an environment- • Relevant environmental laws
friendly manner. • EIA for the Drilling &
• Ensure compliance with all relevant Associated Activities, and
environmental laws. conditions of approvals from
• Assist the Drilling Manager in Sindh EPA
fulfilling Eni Pakistan’s • Eni Pakistan HSE policy
environmental responsibilities and • Environmental documentation
keep him updated on received from the field
environmental matters relating to
the operation
• Review environmental
documentation received from the
field, and ensure implementation of
corrective measures, if any
• Coordinate with other stakeholders,
including SWD and Sindh EPA.
HSE • Ensure that mitigation measures • EIA for the Drilling &
Supervisor included in the EIA and EMP are Associated Activities, and
fully Implemented
• Ensure compliance of the EMP, conditions of approvals from

EIA and Sindh EPA’s conditions for Sindh EPA
approval • The present document
• Ensure compliance with Eni • Eni Pakistan HSE policy
Pakistan’s HSE policy
• Coordinate and supervise
contractors
Drilling and Country • Manage operations of field crew • Contract with Eni Pakistan
flow line Manager
laying
Contractor Rig Manager / • Manage drilling activities and • Contract with Eni Pakistan
Tool Pusher drilling crew • EIA for the Drilling &
• Liaise with Eni Pakistan’s Site Associated Activities, and
Representative and report to the conditions of approvals from
Contractor’s country manager Sindh EPA
• Eni Pakistan’s and
Contractor’s HSE policies
Sr. HSE • Manage and implement • EIA for the Drilling &
Specialist environmental mitigation Associated Activities, and
measures, as well as Eni conditions of approvals from
(Environment)
Pakistan’s and Contractor’s HSE Sindh EPA
policies • Eni Pakistan’s & Contractor’s
• Liaise with HSE Supervisor HSE policies
Photographic Record
Eni Pakistan will ensure that a photographic record including the following is maintained.
 All areas used by the project activities; before use, during use and after restoration.
 Key non-compliances.
 Key project activities.
Environmental Aspect Register
The EIA provides identification of environmental aspects and evaluation of the impacts
associated with the proposed drilling and associated activities. The register identifies the
potential impacts of project activities on various environmental resources. The register also
categorizes the significance of the impacts on the basis of their severity of consequence and
the probability of occurrence. The impact significance has been categorized on the basis of
the following criteria:
Frequency Consequence Severity

Low Moderate High
High (almost certain) M H H
Moderate (Likely) L M H
Low (unlikely/rare) L M M
Where impact significance ‘H’ implies high risk, ‘M’ implies moderate risk; and ‘L’ implies low
risk.
Table 8.2: Environmental Aspect Register

Aspect Significance
Flora & Fauna
Consequence
Significance
Water
Land
Air
1. Equipment & Dust and vehicular L L L ▪ Regulate and monitor vehicle speeds
crew Emissions ▪ Maintain vehicles in a good condition
mobilization/ ▪ Prohibit off-road travel
demobilization Noise and vibration L L L ▪ Minimize use of horns by project vehicles
Safety hazards M L M ▪ Drivers should be trained for safe driving
practices
▪ Night traveling will be strictly prohibited and
will only be allowed in case of emergency
2. Construction/ Soil erosion L M M ▪ Minimize use of dust track
improvement of ▪ paved access tracks should be used for
access tracks transportation
to monitor any changes and soil conditions
Soil & Water Contamination M M M ▪ Vehicles will be checked for fuel or oil leaks
▪ Fuel and oil transfer operations will be done
using a dedicated fuel vehicle
▪ Drip pans will be used to avoid drips and spills

Aspect Significance
Flora & Fauna
Consequence
Significance
Water
Land
Air
Noise & Vibration L M L ▪ Minimize use of horns by project vehicles
▪ Use of pressure horns will be avoided
▪ Properly maintain vehicles and construction
equipment
Dust and Vehicular Emission L M L ▪ Regulate and monitor vehicle speeds
▪ Minimize dust emissions by employing good
Loss of Vegetation or Habitats L M L ▪ Minimize total land uptake by access roads
▪ Minimize vegetation clearance
▪ Prohibit use of local vegetation as fuel
▪ Minimize preparation of new access tracks
▪ Avoid clearing of trees by selecting routes that
require least vegetation removal

Aspect Significance
Flora & Fauna
Consequence
Significance
Water
Land
Air
HSE guidelines
Disturbance to wildlife M L M ▪ Minimize preparation of new access tracks
▪ Prohibit hunting or poaching of wildlife
clearing
in good condition
▪ Area of operation should be fenced to prevent
animal entry
▪ open dumping of waste should be strictly
prohibited to avoid hazard to animals
3. Camp(s) Soil erosion / L L L ▪ Minimize vegetation clearing
construction / Physical scarring ▪ Avoid cutting of trees
establishment ▪ Locate camp site in existing clearings and on
operation leveled land
▪ Minimize total land uptake by the camps

Aspect Significance
Flora & Fauna
Consequence
Significance
Water
Land
Air
Safety hazards M M M ▪ Sensitize drivers on mitigation measures
▪ Local sources of drinking water will be used
only after complying with relevant
requirements of the EIA,
HSE guidelines
▪ Project staff to respect all cultural norms
▪ Provide offsets will from sites of religious,
cultural or archaeological significance
Disturbance to wildlife L L L ▪ Prohibit hunting or harassment of wildlife
▪ Select land for establishing camp where
minimum land clearance is required
clearing

Aspect Significance
Flora & Fauna
Consequence
Significance
Water
Land
Air
Soil / Water L M L ▪ Dispose sewage generated at the campsite in
contamination septic systems comprising septic tanks and
soak pits
▪ Dispose wastewater from laundry, kitchen
washings, and showers into separate soak
pits
▪ Build soak pits in absorbent soil
▪ Keep septic systems at minimum distances of
300 m from surface water sources
▪ Design and construct soak pits to prevent
surface run-off
▪ Design soak pits to accommodate wastewater
generated during the total duration of the
operation
▪ Solid wastes at the campsite will be disposed
of in waste bins
▪ Wash vehicles in designated areas within
campsite and route the wastewater to pits
▪ Regularly check vehicles for fuel or oil leaks
▪ All fuel and oil storage areas will have
secondary containment that can be in the

Aspect Significance
Flora & Fauna
Consequence
Significance
Water
Land
Air
form of a concrete pad underneath to prevent
soil contamination in case of leaks or spills
▪ All fuel tanks will be properly marked to
highlight their contents
▪ Ensure provisions for proper fuel and oil
storage and handling
Dust / exhaust L M L ▪ Maintain vehicles and equipment in good
Emissions condition
▪ Employ good management practice to
minimize dust emissions
Noise and vibration L L L ▪ Ensure that generators, vehicles and other
potentially noisy equipment are in good
condition
▪ Minimize use of horns by project vehicles
▪ Use of pressure horns will not be allowed
▪ Restrict all project vehicles and personnel
within work areas
Resource depletion L M M ▪ Adopt water conservation measures

Aspect Significance
Flora & Fauna
Consequence
Significance
Water
Land
Air
▪ Keep complete record of water consumption
during project
4. Clearing and Soil erosion / M M M ▪ Minimize vegetation clearance
leveling Physical scarring ▪ Maintain photographic records of all activities
▪ Minimize disturbance to natural topography /
soils
▪ Regulate and monitor vehicle speeds
▪ Train the drivers on mitigation measures
Soil contamination L L L ▪ Prohibit solid waste disposal in the field
▪ Regularly check vehicle for fuel or oil leaks
▪ Use a dedicated fuel vehicle for fuel and oil
transfer operation
▪ Use Drip pans to avoid drips and spills
Noise and vibration L M L ▪ Minimize use of horns by project vehicles
▪ The use of pressure horns will be avoided
Dust/exhaust L M L ▪ Maintain vehicles in good condition
Emissions

Aspect Significance
Flora & Fauna
Consequence
Significance
Water
Land
Air
▪ Dust emissions during land clearance
activities will be minimized by good
Loss of vegetation M M M ▪ Minimize clearing of vegetation
▪ Prohibit use of local vegetation as fuel by
crew personnel
▪ Avoid clearing of trees
Disturbance to M M M ▪ Prohibit hunting or poaching of wildlife
Wildlife ▪ Minimize vegetation clearing and land uptake
▪ Avoid clearing of dense patches of vegetation
▪ Food wastes will not be left in the open
▪ Maintain vehicles in good condition to reduce
noise
activities local infrastructure
HSE guidelines

Aspect Significance
Flora & Fauna
Consequence
Significance
Water
Land
Air
5. Drilling activity Safety hazards and L L L ▪ Train drivers on mitigation measures related
disturbance to communities to off-road travel and speeds limits
activities to canals, watercourses, local roads
or other infrastructure
HSE guidelines
Disturbance to wildlife L M L ▪ Prohibit hunting or poaching of wildlife
▪ Avoid disturbance to live bird nests, reptile
and small mammal holes during project
activities
▪ A minimum distance of 50 m to be maintained
from surface water bodies
▪ Maintain compressors and vehicles in good
condition
▪ Minimize the use of horns by project vehicles
Noise and vibration ▪ Minimize the use of horns by project vehicles

Aspect Significance
Flora & Fauna
Consequence
Significance
Water
Land
Air
▪ Restrict movement of all project vehicles and
personnel within work areas
Dust/exhaust Emissions L M L ▪ Maintain vehicles in good condition
▪ Minimize dust emissions by good
Soil contamination M M M ▪ No solid waste will be disposed of in the field
▪ Regularly check vehicle for fuel and oil leaks
▪ Use dedicated vehicle for fuel and oil transfer
Loss of vegetation L L L ▪ Avoid cutting of trees
▪ Prohibit use of vegetation as fuel
▪ Contain crew personnel within work areas
Resource depletion M M M ▪ Prohibit use of water from surface water
resources
▪ Employ diligent water conservation measures
▪ Keep complete records of water consumption
during project
Soil erosion / Physical scarring L M L ▪ Maintain photographic records of all activities

Aspect Significance
Flora & Fauna
Consequence
Significance
Water
Land
Air
6. Waste Air, soil & Water contamination M M M ▪ Implementation of waste management plan
management ▪ Monitoring of implementation of waste
management plan.
Monitoring
The HSE Supervisor will monitor the activities of the drilling and construction contractor while
working in the project area. He will keep a record of all non-conformances observed and report
these along with actions to Eni Pakistan management for further action. The HSE Supervisor
will also report any impacts anticipated along with his recommendations for further action. The
DC shall take account of any recommendation relating to the operation arising during the
monitoring.
A monitoring plan is provided in table 8.7 & 8.8.
Emergency Procedures
The proponent and the DC will prepare contingency plans to deal with any emergency situation
that may arise during the operation e.g., medical evacuation, major oil spill, etc. and
communicate these to the regulatory agencies, if required by these agencies.
Restoration
Once the entire operation is completed, restoration and rehabilitation of the campsites and
access tracks will be undertaken. The following procedures will be adopted during the process.
 All concrete structures at the campsites will be removed and buried in garbage or soak
pits and the pits backfilled with at least 1 m of soil cover below the surrounding natural
surface level.
 All holes, ditches, and sumps will be backfilled; an extra cap of soil will be added to cater
for compaction.
 At the time of restoration, septic tanks will be dismantled in place and backfilled with at
least 1 m of soil cover below the surrounding natural surface level.
 All signs and refuse will be removed from survey lines
 It will be ensured that after restoration activities the campsites are clean and that no
refuse has been left behind.
 If any damage to tracks, slopes, drainage paths, stream banks, or other topographical
feature is caused by survey related activities, proper repairs will be carried out.
 Re-vegetation measures will be carried out where necessary.
8.7. Implementation of Environmental Management Plan

The implementation of EMP will be the responsibility of Eni Pakistan’s management,
supervisory staff and operations staff etc. and will be implemented during all stages of the well
construction and drilling activities. The information to be included regarding EMP would be
risk assessment, environmental management plans, environmental management activities
and controls and environmental schedules.
8.7.1. Approvals
Obtaining Environmental Approval from SEPA does not relieve the Proponent of other
obligations and hence Eni will obtain all relevant clearances and necessary approvals required
by the government prior to commencing the operations.
8.7.2. Contractual Provisions

The requirements of this EIA in terms of environmental mitigation shall be incorporated into
the operational plans and bridging documents with DC.
8.7.3. Training
The key objective of the training program is to ensure that the requirements of the EMP are
clearly understood and followed throughout the project. The trainings to the staff will help in
communicating environment related restrictions specified in the EIA and EMP.
The Eni Pakistan HSE Supervisor will determine the training requirements necessary for
understanding and effective implementation of the EMP. The Eni Pakistan HSE Supervisor or
DC HSE Supervisor to disseminate the necessary training to relevant personnel.
To ensure sound management of occupational safety issues, project workers will be trained
on many areas of job safety. They will also be taught how to protect environmental
characteristics that are likely to be harmed by project activities, such as indigenous flora and
fauna, wildlife, water bodies, and ecological resources etc. Trainings shall be organized by the
training coordinator in conjunction with the Sr. HSE Specialist (Environment). It will ensure
that employees are aware of the issues that may arise as a result of the proposed activity.
Trainings will be scheduled on a regular basis, and all employees will be required to attend.
Trainings identified in EMP are given below:
 Site orientation course

 Training for emergency response and preparedness
 Training for awareness of significance of the Wildlife Sanctuary, Flora and fauna there
 Training for familiarization with site environmental controls.
 Specific environmental training for relevant employees e.g., installing erosion and
sedimentation controls, daily checks to maintain controls, cleaning up spills, waste
minimization etc.
 A firefighting system shall be installed at camp site and well site, which will include
firefighting water, foam generators and portable fire extinguishers. The personnel shall
be trained on the use and operation of these systems. Equipment such as firefighting
equipment, trained First Aiders, ambulances and environmental protection and spill
control equipment shall also be provided so that they are available in the event of an
emergency. The aim is to instruct all personnel on the operation of this equipment and
on the procedure to be followed in the event of spills, fire or explosions.
8.7.4. Minimum Distances

The EIA specifies minimum distances to be maintained from environmental features including
communities, water sources, wildlife sensitive areas and archaeological / cultural / religious
sites etc. These minimum distances are provided in the Environmental Management and
Monitoring Plan. Eni Pakistan and the contractors will ensure that these minimum distances
are adhered to during the execution of the project. Highlighting the minimum distances of the
drilling and associated activities from various environmental features in the project area is
shown Table 8.3.
Table 8.3: Minimum distance from sensitive receptor during Drilling Activity
Area/ Facility Distance (m)
Settlement Community water well Archaeological /
cultural site
Well site 500 300 300
Construction and 500 300 300
rig camp
Soak pits N.A - Should not be less than 100 m from surface N.A
/ groundwater resources.
- A separate assessment is required if it
builds within 100 – 300m from ground /
surface water resources
- Ideal location if it builds more than 300 m
away from ground/ surface water resources.
Note: Minimum distance of various project activities from sensitive receptors (not mentioned in this
table) will be decided during project execution phase
8.7.5. Communication and Documentation

Proponent and the contractors will ensure that the communication and documentation
requirements specified in the EMP are fulfilled during the operations.
8.8. Mitigation Management Matrix

 The mitigation measures recommended in the EIA.
 The person/organization directly responsible for adhering to or executing the required
mitigation measures.
 The parameters, which will be monitored to ensure compliance with the mitigation
measures.
 The timing at which the mitigation or monitoring has to be carried out. Table 8.4, 8.5 and
8.6 show the mitigation management matrix for the proposed project activities. It is
highlighted that although responsibilities for executing and monitoring mitigation
measures have been delegated to different persons/organizations, Eni Pakistan will hold
the primary and overall responsibility for ensuring full implementation of the EMP.
Table 8.4: Mitigation Management Matrix for Drilling Activities

No. Impact and Mitigation Measures Execution Monitoring Action Timing
1. Changes in Landscape and Soil Erosion.
1.1 Well site and campsite areas will be kept to a minimum. Eni Pak Eni Pak Check compliance After marking of the site
layout on ground by the
CC and prior to clearing of
land at these areas.
1.2 The construction of well sites and campsites on leveled land Eni Pak Eni Pak Location of camp site and Prior to site layout in
to minimize disturbance to soils and landscape well site in level areas. ground
1.3 Existing access roads will be used as much as possible. CC Eni Pak Monitor off road travel and During construction
Development of new track lengths will be avoided as much record non-compliances.
as possible Development & marking of
access track during
construction
1.4 The width of the improved track will be kept at 9-10 m, for CC Eni Pak Randomly check the width of During construction
safe movement of vehicle and rig during normal operation. the improved access track
1.5 The access track will be properly compacted at the time of CC Eni Pak Check compliance Compaction during
construction and thereafter properly maintained by watering construction, dust
and compaction (where required) throughout the entire emissions and loose
construction and drilling operation. sections of the track for the
entire period of use of the
track for this operation
1.6 Off-road travel will be strictly prohibited and observance of CC, DC, Eni Pak Advise all personnel, During the entire operation
this will be monitored during the operation. Eni Pak address any staff complaints
and ban off road travel
1.7 Vehicle speeds will be regulated and monitored to avoid CC, DC, Eni Pak Set speed limits, train drivers During the entire operation
excessive dust emissions. Eni Pak and monitor non-
compliances
1.8 Areas along the access track, well site and campsites will be CC Eni Pak Check compliance During drilling activities
visually monitored and any area showing signs of soil
erosion will be watered and compacted.
1.9 Cutting of vegetation will be kept to the minimum required. CC Eni Pak Monitor land clearing During construction
Unnecessary clearing within the corridors along the access activities
track or on the periphery of the well site and campsites will
be avoided.

1.10 Movement of construction equipment will be restricted to CC Eni Pak Monitor movement of During Construction
work areas only to avoid unnecessary disturbance to soils in vehicles and off-road travel activity
the project area.
1.11 When tracks are to be used for obtaining water from water CC Eni Pak Sprinkling of water on During the entire operation
wells, the tracks will be regularly sprinkled with water for dust access track to water wells
suppression (where required)
1.12 During construction, a single track will be identified and CC Eni Pak Check compliance During Construction
approved along sections of the main track on which work is
in progress. Vehicles will be allowed to travel only on the
approved track.
1.13 Dumping of gravel on or close to the access track being CC Eni Pak Gravel or sand dumping on During Construction
improved or constructed will not be allowed access track
1.14 Periodic trainings will be provided to drivers on mitigation Eni Pak, Eni Pak Check training log, provide During the entire project
measures related to off road travel and speeds limits. CC, trainings
2. Contamination of Soil and Water
2.1 Approvals to start construction or drilling will only be given by CC, DC, Eni Pak Approval for waste Before construction and
Eni Pak HSE deptt. after ensuring that all waste Eni Pak contractor, waste drilling activity
management facilities (waste segregation units, soak pits, management systems and
septic tanks etc.), equipment (waste bins, drip pans, start of work
tarpaulins etc.) and procedures (approvals for waste
contractors etc.), prescribed in the EIA are in a state
acceptable to the Eni Pak HSE.
2.2 Food waste and combustible packaging wastes that have no CC, DC Eni Pak Provision of sufficient waste During the entire operation
re-use will be stored temporarily onsite within designated bins, segregation of waste,
waste segregation areas and will be handed over to Waste disposal through third party
Management Contractor. contractor.
2.3 Dedicated waste segregation units / containers will be built CC, DC Eni Pak Construction and monitoring During entire project
or placed at campsites and well site. of waste segregation units
2.4 Recyclable wastes including glass and metal scrap will be CC, DC Eni Pak Eni Pak HSE to approve During the entire operation
handed over to SEPA approved recycling contractors. waste contractors. Monitor
waste segregation and safe
transportation to the
recycling contractor's facility

2.5 Waste oil will be handed over to contractors approved by CC, DC Eni Pak Eni Pak HSE to approve During the entire operation
the SEPA. waste contractor and monitor
safe transportation of the
waste oil
2.6 Medical wastes will temporarily be stored onsite separately CC, DC Eni Pak Eni Pak HSE to approve During the entire operation
and incinerated at a suitable location through waste disposal arrangement.
contractor approved by Eni Pak HSE. Monitor waste segregation
and safe storage onsite
2.7 Wastes will not be disposed of in the open area. CC, DC Eni Pak Monitor during routine visits During the entire operation
2.8 Adequate number of waste bins will be provided for CC, DC Eni Pak Monitor provision of During the entire operation
collection of wastes at the well site and campsites. sufficient waste bins
2.9 Grey wastewater will be collected in soak pits. The CC, DC Eni Pak Check provision of soak pits During the entire operation
wastewater, if found to meet the SEQS could be sprinkled and quality of waste water.
over the access road. Alternatively it will be transferred from Monitor sprinkling of
the site in tankers and disposed of into municipal drains in wastewater
the nearest major city
2.10 Sewage generated from the toilets will be collected and CC, DC Eni Pak Check provision of septic During the entire operation
treated in septic tanks. The septic tanks will be built of tank and soak pit. Monitor
concrete and brick masonry to avoid leaching of wastewater wastewater levels in the
from the tanks. soak pits.
2.11 Soak pits will be built in absorbent soil and located CC Eni Pak Check soil condition and During design and
preferably 300 m away from a perennial surface water distance between the soak construction
source or ground water well. pits and the nearest water
bodies
2.12 Soak pits will be covered and constructed such that surface CC, DC Eni Pak Monitor provision of covers Provision of berms during
runoff cannot enter the pits. and berms construction and proper
covers during the entire
operation
2.14 A spill prevention and contingency plan will be prepared to CC, DC Eni Pak Study and examine the plan Before the
deal with moderate and major spills. and identify any flaws, if any commencement of project
before its approval.
Ensure provision of During the entire operation
equipment and material to

control and handle such
spills on site.
2.15 All fuel and oil storage areas will have a concrete pad CC, DC Eni Pak Ensure provision of concrete During construction
underneath to prevent soil contamination in case of leaks or pad activity
spills.
2.16 All fuel tanks will be properly marked to highlight their CC, DC Eni Pak Ensure that proper signs are During the entire operation
contents. placed with the tanks
2.17 Fuel and oil storage areas will have secondary containment CC, DC Eni Pak Check containment volume At the time of construction
in the form of concrete or brick masonry bunds. The volume of the bounded area
of the containment area will be equal to at least 110% of the
total volume of fuel or oil stored.
2.18 During fuel and oil transfer operations such as refueling, CC, DC Eni Pak Ensure provision of drips During the entire operation
drips and spills will be avoided and drip pans will be used. pans, provide training on
safe refueling practices,
monitor oil or fuel stains
2.19 Fuel tanks will be daily checked for leaks and all such leaks CC, DC Eni Pak Inspect fuel tanks for leaks During the entire operation
will be plugged immediately.
2.20 Shovels, plastic bags, and absorbent material will be present CC, DC Eni Pak Monitor presence of During the entire operation
near fuel and oil storage or handling areas to attend spills materials and equipment
and leaks.
2.21 Vehicles will only be washed within designated areas within CC, DC, Eni Pak Ensure provision of washing During the entire operation
campsites. Mechanical maintenance works will be done Eni Pak areas and maintenance
only in workshops workshops and monitor any
non-compliances with the
EIA requirement during
routine monitoring
2.22 Vehicles will be daily checked for fuel or oil leaks. Vehicles CC, DC, Eni Pak Randomly inspect vehicles During the entire operation
with leaks will not be operated until repaired. Eni Pak and designated parking
areas
2.23 Chemicals used during the drilling operation will be stored on CC Eni Pak Ensure provision of brick During construction
brick masonry pads with periphery drains discharging into masonry pads with drains activity
the waste pit.

2.24 Produced formation fluids during testing will be disposed-off Eni Pak Eni Pak Check compliance Prior to and during
according the environmentally sound practice. disposal of waste fluids
2.25 Wastewater produced during hydrotesting will be collected in Eni Pak Eni Pak Check compliance During flow line
lined pits for natural evaporation. commissioning
3. Deterioration of air quality
3.1 Generators and vehicles used during the operation will be CC, DC Eni Pak Check 3rd party Certificates During the entire
properly tuned and maintained to minimize air emissions operation
3.2 Well site and campsites will be located at least 500 m away Eni Pak, Eni Pak Check distances of well site Prior to construction of
from communities. CC & camp site from well site and camp sites
communities
3.3 Dust emissions due to road travel will be minimized by CC, DC Eni Pak Set and monitor speed During the entire
regulating vehicle speeds and watering of the access track limits. Monitor sprinkling of operation
access track
3.4 Dust emissions during construction activities will be CC Eni Pak Monitor dust emissions During the construction
minimized by good management practices such as locating during earthworks. Train CC operation
stock piles out of the wind direction, keeping the height of the on good management
stock piles to a minimum, keeping earthwork areas damp practices
etc.
3.5 During construction, leveling or widening along the access CC Eni Pak Access road construction During construction
road will be done in sections, immediately followed by activity
sprinkling of water and also preferably compaction (where
required)
4. Noise Pollution
4.1 It will be ensured that the generators, vehicles and other CC, DC Eni Pak Monitor noise levels Prior to use of machinery
potentially noisy machinery used are in good condition. and vehicles
4.2 Noise levels at communities nearest to the well site, camp Eni Pak Eni Pak Monitor noise levels During Construction,
site and access tracks will be monitored by Contractor. In Drilling and Operation
case these are found to exceed safe acceptable limits
appropriate mitigation will be taken.
4.3 Well site and camp sites will be located 500 m away from Eni Pak, Eni Pak Check distances from the Prior to construction of the
nearest communities. CC community well site and camp sites
4.4 The use of horns by project vehicles will be minimized. The CC, DC, Eni Pak Train drivers, check vehicles During the entire
use of pressure horns will not be allowed Eni Pak and record non-compliances operation

4.5 Movement of all project vehicles and personnel will be CC, DC, Eni Pak Advise all drivers and During the entire
restricted to within work areas. Eni Pak investigate non-compliances operation
from staff
5. Use of Water
5.1 Avoid abstraction of water from surface water resources CC, DC Eni Pak Check compliance During the entire
operation
5.2 The quantity of water used during construction and drilling CC, DC Eni Pak Monitor water consumption, During the entire
will be kept to the minimum required by taking prudent water advise water conservation operation
conservation measures on site. A complete record of water measures
consumption will be maintained by Eni Pak.
6. Blockage of Natural Drainage
6.1 Area around the well and camp site will be landscaped to CC Eni Pak Monitor landscaping and During the construction
avoid blocking natural drainage. any obstruction caused to activity
natural drainage
6.2 Crossings will be provided at all stream crossings to avoid CC Eni Pak Ensure construction of Fjord During construction of the
blocking of natural drainage. Pipe culverts will be provided at crossings and pipe culverts access track
small drainage channels if any. and randomly check along
the access track
7. Site Restoration- Dry Well
7.1 All equipment and machinery at the well site will be DC Eni Pak Check compliance During site restoration
demobilized.
7.2 All wastes at the well site will be disposed of according to the DC Eni Pak Check compliance During site restoration
requirements of the EIA.
7.3 Re-vegetation and continued monitoring of the site after CC, Eni Eni Pak Check compliance After site restoration
closure. Pak
7.4 All concrete structures at the well site will be broken and CC Eni Pak Check compliance During site restoration
either transported out of the project area by the site
restoration contractors for sale or reuse or disposed of into
the pits
7.5 All pits at the well site will be backfilled CC Eni Pak Check compliance During site restoration
7.6 The areas covered by the portion of the access track that will CC Eni Pak Check compliance During site restoration
be of no use for other wells will be restored, in that all gravel
topping will be removed. This scenario will be applicable only

if the locals require the portions of the track to be restored or
otherwise it will be left on the site on the consent of the locals
8. Partial Restoration - Producing Well
8.1 The well site and access roads will be retained to support Eni Pak Eni Pak Check compliance During site restoration
well access work for further testing or during the
development phase.
8.2 The outer chain link fence will be retained as a safety Eni Pak Eni Pak Check compliance During site restoration
measure to keep wildlife away from the pit areas.
8.3 The wellhead will be enclosed by a locked steel cage. This Eni Pak Eni Pak Inspect well head is During site restoration
will serve as both a safety and security measure as the site enclosed by locked steel
will be down-manned pending further development cage
operations work.
8.4 The constructed pit areas will be retained but all liquid and Eni Pak Eni Pak Ensure that all liquid and During site restoration
solid waste material will be removed from the site and solid waste is removed
disposed of in line with the requirements of this EIA.
9. Clearing of vegetation and loss of habitat
9.1 Clearing of vegetation will be minimized by keeping the road CC Eni Pak Check width During the construction
width to minimum requirement and by keeping the length of activity
new sections of the road to a minimum.
9.2 Off-road travel, required at sections of the road where CC, DC Eni Pak Train drivers and investigate During the entire
construction work is in progress, will be minimized and if non-compliances operation
required will be allowed only after approval from Eni Pak
HSE
9.3 During construction good management practices will be CC Eni Pak Train construction During construction
adopted to avoid disturbance to areas adjacent to work areas supervisors, monitor operation
including the access track, well site and camp sites. construction activities
9.4 Well site and campsite areas will be kept to a minimum. Eni Pak, Eni Pak Check compliance After marking of the site
CC layout on ground by the
CC and prior to clearing of
9.5 Camp sites established for the purpose of construction will CC Eni Pak Supervise camp setup During setup of the
be located in existing clearing. Vegetation clearing from construction camps
these sites will be kept to a minimum.

9.6 Cutting of trees / bushes will be minimized. CC Eni Pak Supervise land clearing During land clearing for
activities the access track, well site
and drilling camp site
9.7 Use of local vegetation as fuel will not be allowed. CC Eni Pak Check compliance Compliance during the
entire operation
10. Socio-economic, archaeology and cultural Environment
10.1 Local source of drinking water will not be exploited unless Eni Pak, Eni Pak Monitor adherence with the During the entire project
measures listed in water use mitigation measures are DC, CC requirements
followed.
Water for hydrotesting of flow line will be sourced from
outside the populated area.
10.2 The access road will be watered regularly to minimize the Eni Pak, Eni Pak Check alignment of access During construction
dust emissions (if required). CC, DC routes activity
10.3 Construction of bypass to all major settlements and where Eni Pak, Eni Pak Check alignment of access During construction
necessary rerouting the access road so that a safe distance CC routes activity
is maintained from a settlement.
10.4 Drivers will be trained in responsible and safe driving Eni Pak, Eni Pak Provide training and monitor During the entire
practices, a speed limit will be set and maintained; in DC, CC compliance operation
addition, vehicle logbooks will be maintained and inspected
for compliance.
10.5 Labor from local communities will be recruited equitably Eni Pak, Eni Pak Monitor adherence with the During the entire
amongst the various tribes, avenues for conflict resolution DC, CC requirement and maintain operation
will be open, and the employment procedures will be record of labor
transparent
10.6 Use of local firewood for cooking by contractor staff will be DC, CC Eni Pak Monitor adherence with the During the entire
prohibited requirement operation
10.7 The vehicle speed for traveling along the access road will Eni Pak, Eni Pak Monitor speed limits During the entire
be limited CC, DC operation
10.8 The well site will be located at minimum distance of 500m Eni Pak, Eni Pak Check the alignment of Before construction
from major residential communities. Thereby mitigating the CC access route activity
effect of noise and emissions.
10.9 Generators and vehicles will be regularly maintained to Eni Pak, Eni Pak Monitor air emissions During the entire
minimize emissions. DC, CC operation

10.10 Any land acquired and distribution of compensation will be Eni Pak Eni Pak Check compliance During the entire
carried out transparently, in consultation with the local operation
notables and in accordance with the Eni Pak compensation
procedures.
10.11 Project staff will respect cultural norms Eni Pak, Eni Pak Check compliance During the entire
DC, CC operation
10.12 Damage to any artifacts/local old sites during construction Eni Pak Eni Pak Check compliance Before and during the
will be prohibited and construction activities near these areas construction activity
will be monitored by Eni Pak executing dept.
10.13 The road will be re-aligned to maintain safe distance from the Eni Pak, Eni Pak Check distance Before and during
edge of any graveyard and shrine (if any). CC construction
10.14 All community grievances will be addressed Eni Pak, Eni Pak Check compliance During the entire
DC, CC operation
DC = Drilling Contractor; CC = Construction Contractor
1. Changes in Landscape and Soil Erosion.
1.1 Minimum land clearance for flow line ROW Eni Eni Pakistan Check compliance After marking of the site
Pakistan / layout on ground by the
CC CC and prior to clearing of
1.2 Cutting of vegetation will be kept to the minimum required. Eni Eni Pakistan Monitor land clearing During construction
Unnecessary clearing within the corridors along the flow line Pakistan / activities
route or on the periphery of the campsite(s) will be avoided. CC
1.3 The access track / ROW will be properly levelled & graded / Eni Eni Pakistan Check compliance Compaction during
compacted at the time of construction and thereafter properly Pakistan / construction, dust
maintained by watering and compaction (where required) CC emissions and loose
during pipeline laying operation. sections of the track for
the entire period of use of
the track for this operation
1.4 Off-road travel will be strictly prohibited and observance of Eni Eni Pakistan Advise all personnel, During the entire operation
this will be monitored during the operation. Pakistan / address any staff complaints
CC & ban off road travel
1.5 Vehicle speeds will be regulated and monitored to avoid Eni Eni Pakistan Set speed limits, train drivers During the entire operation
excessive dust emissions. Pakistan / and monitor non-
CC compliances
1.6 Areas along the access track and campsite(s) (if developed) Eni Eni Pakistan Check compliance During FL laying activities
will be visually monitored and any area showing signs of soil Pakistan /
erosion will be watered and compacted. The contractor may CC
use already developed area / local hotel for housing of their
employees.
1.7 Movement of construction equipment will be restricted to Eni Eni Pakistan Monitor movement of During Construction
work areas only to avoid unnecessary disturbance to soils in Pakistan / vehicles and off road travel activity
the project area. CC
1.8 When tracks are to be used for obtaining water from water Eni Eni Pakistan Sprinkling of water on During the entire operation
wells, the tracks will be regularly sprinkled with water for dust Pakistan / access track to water wells
suppression (where required) CC
1.9 During construction, a single track will be identified and Eni Eni Pakistan Check compliance During Construction
approved along sections of the main track on which work is Pakistan /
in progress. Vehicles will be allowed to travel only on the CC
approved track.
2. Contamination of Soil and Water
2.1 Approvals to start construction will only be given by Eni Eni Eni Pakistan Approval for waste Before construction and
Pakistan after ensuring that all waste management facilities Pakistan contractor, waste FL laying activity
(waste segregation units, soak pits, septic tanks etc.), management systems and
equipment (waste bins, drip pans, tarpaulins etc.) and start of work
procedures (approvals for waste contractors etc.) are as per
the EIA requirements.
2.2 Hydrostatic test water quality should be monitored before Eni Eni Pakistan Check compliance, Before use and before
discharge (if discharges into any water bodies / nallahs). If Pakistan / monitoring reports discharge
water quality is exceeding SEQS limits for effluents then it CC
should be treated to comply with SEQS.
Wastewater disposal to local nallah will only be carried out
after taken approval from relevant authority / TMA.
2.3 Reduce the need for chemicals by minimizing the time that Eni Eni Pakistan Check compliance, At the time of testing
test water remains in the pipeline. Pakistan /
CC
2.4 It will be ensured that the used water from hydrotesting is not Eni Eni Pakistan Check compliance, At the time of discharge
discharged in nearby canals or other surface water body. Pakistan /
CC
2.5 Food waste will not be disposed of in an open land. Food Eni Eni Pakistan Provision of sufficient waste During the entire
waste collected in waste segregation units will be buried on Pakistan / bins, segregation of waste, operation
site or disposed of through contractor. CC disposal through third party
2.6 Combustible packaging wastes that have no re-use will be Eni Eni Pakistan contractor.
stored temporarily onsite within designated waste Pakistan /
segregation areas and will be handed over to third party CC
waste contractor / vendor for appropriate disposal.
2.7 Dedicated waste segregation units / containers will be built Eni Eni Pakistan Eni Pakistan’s concerned During the entire
or placed at campsites. Pakistan / Depts. to approve waste operation
CC contractors. Monitor waste
segregation and safe
transportation to the
recycling contractor's facility
2.8 Recyclable wastes including glass, tins and metal scrap will Eni Eni Pakistan Eni Pakistan’s concerned During the entire
be handed over to recycling contractors. Pakistan / Depts. to approve waste operation
CC contractor and monitor safe
transportation of the waste
oil
2.9 Used oil shall be provided to OGRA reclamation license Eni Eni Pakistan Eni Pakistan’s concerned During the entire
holder lubricant plant for reclamation or disposed off through Pakistan / Depts. to approve waste operation
SEPA approved waste contractor. CC contractor and monitor safe
transportation of the waste
oil
2.10 Medical wastes will temporarily be stored onsite separately Eni Eni Pakistan Eni Pakistan’s concerned During the entire
and incinerated at a suitable location through SEPA Pakistan / Depts. to approved disposal operation
approved waste contractor. CC arrangement. Monitor waste
segregation safe storage
onsite
2.11 Wastes will not be disposed of in the open area. Eni Eni Pakistan Monitor during routine visits During the entire
Pakistan / operation
CC
2.12 Grey wastewater will be collected in soak pits. Eni Eni Pakistan Check provision of soak pits During the entire
CC
2.13 Sewage generated from the toilets will be collected and Eni Eni Pakistan Check provision of septic During the entire
treated in septic tank and soak pit system. The septic tanks Pakistan / tank and soak pit. Monitor operation
will be built of concrete construction such that wastewater CC wastewater levels in the
will not infiltrate into the ground soak pits.
2.14 Soak pits will be built in absorbent soil and located preferably Eni Eni Pakistan Check soil condition and During design and
300 m away from a perennial surface water source or ground Pakistan / distance between the soak construction
water well. CC pits and the nearest water
bodies
2.15 Soak pits will be covered and constructed such that surface Eni Eni Pakistan Monitor provision of covers Provision of berms during
runoff cannot enter the pits. Pakistan / and berms construction and proper
CC covers during the entire
operation
2.16 Oil spills will be contained and controlled using shovels, Eni Eni Pakistan Monitor any oil leaks and During the entire
sands and native soil. The equipment and materials will be Pakistan / contamination of soil. operation
made available at camp sites and during the operation. The CC Ensure provision of
contaminated soil will be excavated and temporarily stored equipment and material to
in a metal drum or a bunded area lined with an impermeable control and handle such
base. spills on site. Monitor
Finally, the contaminated soil will be disposed of through disposal as per the
SEPA approved waste contractor. requirements of EIA.
2.17 Fuel and oil storage areas (if developed) will have secondary Eni Eni Pakistan Ensure secondary During construction
containment in the form of cemented or brick masonry bunds Pakistan / containment activity
with plastered. The volume of the containment area will be CC
equal to atleast 110 % of the total volume of fuel / oil stored
or 110% of the volume of one largest tank.
2.18 All fuel tanks will be properly marked to highlight their Eni Eni Pakistan Ensure that proper signs are During the entire
contents. Pakistan / placed with the tanks operation
CC
2.19 During fuel and oil transfer operations such as refueling, Eni Eni Pakistan Ensure provision of drips During the entire
drips and spills will be avoided and drip pans will be used. Pakistan / pans, provide training on operation
CC safe refueling practices,
monitor oil or fuel stains
2.20 Fuel tanks will be daily checked for leaks and all such leaks Eni Eni Pakistan Inspect fuel tanks for leaks During the entire
will be plugged immediately. Pakistan / operation
CC
2.21 Liquid chemicals used during the flow line laying operation Eni Eni Pakistan Ensure provision of brick During construction
will be stored on brick masonry pads with plastered and Pakistan / masonry pads with activity
contained with bunds. CC plastered and bunded.
2.22 Shovels, plastic bags, and absorbent material will be present Eni Eni Pakistan Monitor presence of During the entire
near fuel and oil storage or handling areas to attend spills Pakistan / materials and equipment operation
and leaks. CC
2.23 Vehicles will only be washed within designated areas within Eni Eni Pakistan Ensure provision of washing During the entire
campsites. Mechanical maintenance works will be done only Pakistan / areas and maintenance operation
in workshops CC workshops and monitor any
non-compliances with the
EIA requirement during
routine monitoring
2.24 Vehicles will be daily checked for fuel or oil leaks. Vehicles Eni Eni Pakistan Randomly inspect vehicles During the entire
with leaks will not be operated until repaired. Pakistan / and designated parking operation
CC areas
3. Deterioration of air quality
3.1 Generators and vehicles used during the operation will be Eni Eni Pakistan Check maintenance logs During the entire
properly tuned and maintained to minimize air emissions. Pakistan / operation
CC
3.2 Flow Line route and campsite(s) (if developed) will be Eni Eni Pakistan Check distances of well site Prior to construction of
located at safe distance away from major residential Pakistan / and camp site from well site and camp sites
communities. CC communities
3.3 Dust emissions due to road travel will be minimized by Eni Eni Pakistan Set and monitor speed limits. During the entire
regulating vehicle speeds and watering of the ROW / access Pakistan / Monitor sprinkling of access operation
track CC track
3.4 Dust emissions during construction activities will be Eni Eni Pakistan Monitor dust emissions During the construction
minimized by good management practices such as locating Pakistan / during earthworks. Train CC operation
stock piles out of the wind direction, keeping the height of the CC on good management
stock piles to a minimum, keeping earthwork areas damp practices
etc.
3.5 During construction, leveling or widening along the ROW will Eni Eni Pakistan Access road construction During construction
be done in sections, followed by sprinkling of water (if Pakistan / activity
required) and also preferably compaction (where required) CC
4. Noise Pollution
4.1 Flow Line ROW will be located at safe distance away from Eni Eni Pakistan Check distances from the Prior to construction of the
the nearest major communities. Pakistan / community well site and camp sites
CC
4.2 The well pumps, compressors and truck lorries entering and Eni Eni Pakistan Monitor noise levels Prior to use of machinery
exiting the well-site will be well-maintained and kept in good Pakistan / and vehicles
working order to minimize the noise. CC
4.3 Noise levels at communities nearest to the Flow Line Route, Eni Eni Pakistan Monitor noise levels During Construction,
camp /housing site will be monitored by Contractor. In case Pakistan / Drilling and Operation
these are found to exceed safe acceptable limits appropriate CC
mitigation will be taken.
4.4 The use of horns by project vehicles will be minimized. The Eni Eni Pakistan Train drivers, check vehicles During the entire operation
use of pressure horns will not be allowed. Pakistan / and record non-compliances
CC
4.5 Movement of all project vehicles and personnel will be Eni Eni Pakistan Advise all drivers and During the entire operation
restricted to within work areas. Pakistan / investigate non-compliances
CC from staff
5. Use of Water
5.1 Water acquisition for hydrotesting purposes should not Eni Eni Pakistan Monitor volume of water At the time of test, during
adversely affect the water level or flow rate of a natural water Pakistan / taken commissioning phase
body, and the test water volume should not exceed 50 CC
percent of the water source.
5.2 Avoid abstraction of water from surface water resources. If Eni Eni Pakistan Check compliance During the entire operation
there is no other source of water available, then for Pakistan /
abstraction of water from surface water body, prior approval CC
from relevant government department.
5.3 For all water obtained from local wells, the owner will be paid Eni Eni Pakistan Check compliance During entire operation
for water abstracted at the market rate Pakistan /
CC
5.4 Contamination of surface and groundwater resources will Eni Eni Pakistan Check compliance During the entire
be avoided. Pakistan / Operation
CC
6. Blockage of Natural Drainage
6.1 Crossings for the Flow Line will be provided at all stream Eni Eni Pakistan Ensure construction of Fjord During construction of the
crossings to avoid blocking of natural drainage. Pipe culverts Pakistan / crossings & pipe culverts & access track
will be provided at small drainage channels if any. CC randomly check along the
access track
6.2 Camp site (if built) will be constructed such that it will not Eni Eni Pakistan Monitor landscaping and any During the construction
block natural drainage. Pakistan / obstruction caused to natural activity
CC drainage
7. Restoration after Flow line laying
7.1 Demobilization of all equipment and machinery Eni Eni Pakistan Ensure compliance During restoration phase
Pakistan /
CC
7.2 Disposal of any waste material remaining at the time of Eni Eni Pakistan Ensure compliance, route During restoration phase
completion of the operation. Pakistan / visit
CC
7.3 General restoration of the site area including landscaping Eni Eni Pakistan Ensure compliance, site visit During restoration phase
and restoration of drainage where required. Pakistan / to witness restoration
CC
7.4 Relieve compacted areas to enable re-vegetation. Eni Eni Pakistan Ensure compliance During restoration phase
Pakistan /
CC
8. Clearing of vegetation and loss of habitat
8.1 Flow Line ROW access track width will be kept to minimum Eni Eni Pakistan Check compliance After marking of the site
possible. Pakistan / layout on ground by the
8.2 Cutting of trees / bushes will be minimized. Eni Eni Pakistan Supervise land clearing During land clearing for
Pakistan / activities the access track, well site
CC and drilling camp site
8.3 Camp sites established for the purpose of construction will Eni Eni Pakistan Supervise camp setup During setup of the
be located in existing clearing if possible. Vegetation clearing Pakistan / construction camps
from these sites will be kept to a minimum. CC
9. Disturbance to Wildlife
9.1 Prior to commencement of construction and trench Eni Eni Pakistan Provide environmental Before commencement of
excavation, awareness trainings will be provided to Pakistan / awareness training drilling activity
contractor’s management and field crew on matters related CC
to the wildlife protection.
9.2 Land uptake by Flow Line and associated access track / Eni Eni Pakistan Check compliance After marking of the site
ROW will be minimized Pakistan / layout on ground by the
9.3 The total duration of construction of flow line will be Eni Eni Pakistan Check compliance During the entire operation
minimized by good management. Pakistan / for the time specified
CC
9.4 Food wastes will not be disposed of in the open area. Food Eni Eni Pakistan Monitor collection and During the entire
wastes collected in waste segregation units will be buried Pakistan / disposal of food waste operation
on site or disposed off through waste contractor. CC
9.5 Construction work near areas which show small mammal Eni Eni Pakistan Check compliance During construction
and reptile populations will commence after a soft start up Pakistan / activity
and will be randomly monitored. CC
9.6 All mitigation related to minimizing the noise will be adhered Eni Eni Pakistan Check compliance During the entire project
to. Pakistan /
CC
9.7 Light used at the work site and camp / housing site will be Eni Eni Pakistan Ensure that EIA During the entire project
kept to the minimum requirement Pakistan / requirements should meet
CC
9.8 Hunting and trapping of wildlife will be prohibited. Eni Eni Pakistan Check compliance During the entire
CC
9.9 Feeding or harassment of wildlife will not be allowed Eni Eni Pakistan Check Compliance During the entire
CC
10. Socio-economic, archaeology and cultural Environment
10.1 The road and Flow Line route will be aligned to maintain safe Eni Eni Pakistan Check distance Before and during
distance from the edge of any graveyard and shrine (if any). Pakistan / construction
CC
10.2 All community grievances will be recorded, addressed and Eni Eni Pakistan Check the provision of During the entire
maintained in a Community Complaint’s Register. Pakistan / complaint register and its operation
CC access for communities
10.3 Local source of drinking water will not be exploited unless Eni Eni Pakistan Monitor adherence with the During the entire project
measures listed in water use mitigation measures are Pakistan / requirements
followed CC
10.4 The access road will be watered regularly to minimize the Eni Eni Pakistan Check aliment of access During construction
dust emissions (if required). Pakistan / routes activity
CC
10.5 Construction of bypass to all major settlements and where Eni Eni Pakistan Check alignment of access During construction
necessary rerouting the access road so that a safe distance Pakistan / routes activity
is maintained from a settlement. CC
10.6 Trench excavated for the flow line should be barricaded and Eni Eni Pakistan Ensure compliance During construction
highlighted with signage, reflective tape and light to eliminate Pakistan / activity
the fall hazard for the residents and their animals. CC
11. Hazardous material and solid waste
11.1 Prepare a comprehensive list of all hazardous materials to Eni Eni Pakistan Check Compliance Before the
be used, stored, transported and disposed of during Flow Pakistan / commencement of
line laying and associated activities. CC activities
11.2 Include a recycling strategy to be practiced by workers Eni Eni Pakistan Check Compliance Before the
during all project phases. Pakistan / commencement of
CC activities
11.3 Develop a spill prevention and response plan for Eni Eni Pakistan Check Compliance Before the
addressing spill prevention measures, training Pakistan / commencement of
requirements, waste-specific spill response actions and CC activities
spill response kits,
11.4 Train employees to promptly contain, report and/or clean Eni Eni Pakistan Check Compliance During the entire project
up any oil or hazardous material spill. Pakistan /
CC
11.5 Provide secondary containment around all the fuel storage Eni Eni Pakistan Check Compliance During the construction of
tanks and chemical storage area (if built) of suitable size Pakistan / the storage tanks
(110% of the fuel storage area/ largest tank capacity). Fuel CC
storage should be a temporary activity and fuel storage
facilities should be removed upon completion of the
required activities.
CC = Construction Contractor
Table 8.6: Impact on Ecology, flora and fauna

No. Mitigation Measures Execution Monitoring Action Timing
1.1 Vehicle speeds will be regulated and monitored to avoid CC, DC, Eni Pak Monitor speed limits, Check During entire operation
excessive dust emissions. Eni Pak compliance
1.2 Access tracks will be prohibited from passing through Eni Pak, Eni Pak Check compliance During construction
patches of dense vegetation. CC
1.3 Off-road travel, required at sections of the road where Eni Pak Eni Pak Check compliance During the entire
construction work is in progress, will be minimized and if operation
required will be allowed only after approval from Eni Pak.
1.4 Prior to commencement of any exploration activity, Eni Pak Eni Pak Check compliance Before the
awareness trainings will be provided to contractor’s commencement of
management and field crew on matters related to the activities
requirements of the EMP in this regard.
1.5 All mitigation measures to minimize noise levels, dust CC, DC Eni Pak Check compliance During the entire
emissions, air emissions, and waste management required operation
by the EIA will be adhered to.
1.6 Construction work near areas which show small mammal CC Eni Pak Check compliance During construction
and reptile populations will commence after a soft start up activity
and will be randomly monitored.
1.7 Vehicle speeds on access road will be controlled to avoid Eni Pak, Eni Pak Monitor speed limits During the entire
incidental mortalities of reptiles. Any such incident will be DC, CC operation
reported to the HSE Supervisor. Vehicle speeds will be
monitored.
1.8 Cutting of trees/bushes will be minimized. CC Eni Pak Check compliance During Construction
activity
1.9 Movement of all project personnel will be restricted to Eni Pak, Eni Pak Check compliance During entire project
work areas. DC, CC
1.10 Movement of project vehicles will be restricted only to the Eni Pak, Eni Pak Check compliance During entire project
project access road or to routes approved by the HSE DC, CC
Supervisor
1.11 Night work will be done after proper approval from Eni Pak; Eni Pak, Eni Pak Check Compliance During entire project
night traveling will not be allowed unless absolutely DC, CC
necessary.

1.12 Campsites will be located preferably 500m from perennial Eni Pak, Eni Pak Check compliance Before construction
water bodies. CC
1.15 Water contaminated during the field activities will not be Eni Pak, Eni Pak Check Compliance During the entire
released on the open land, as this may be harmful to DC operation
vegetation and wildlife. All such effluents will be directed to
the appropriate disposal points, e.g., lined evaporation pits.
1.16 Well site and campsite areas will be kept to a minimum. Eni Pak, Eni Pak Check Compliance During design phase
CC
1.17 Earthen pits for preparation and disposal of bentonite mud DC, Eni Eni Pak Check Compliance Before construction
and drill cuttings will be located in an area where minimum Pak
vegetation removal is involved.
1.18 Special attention should be paid to safety of reptiles while DC, Eni Eni Pak Check Compliance During and after the
working in their Habitat area. Their burrow should not be Pak activity
damaged during activities. After the completion of activities,
the area should be restored to as much close to the original
condition as possible.
1.20 Avoid unnecessary digging and tree cutting. Where it is Eni Pak Eni Pak Check Compliance During construction
necessary to cut down trees and remove vegetation, the
proponent should set up tree plantation programs as a
mitigation measure.
1.21 Do not dump leftover food / food waste in the open CC, DC Eni Pak Monitor collection and During the entire
disposal of food waste operation
1.22 Wastewater from the camp site will be collected in soak pit Eni Pak, Eni Pak Check Compliance During the drilling
and will be stored in lined evaporation pits. DC operation
1.23 Prohibit unnecessary use of horns. Eni Pak Eni Pak Check Compliance During entire activity
1.24 In the rainy season, vehicle movement should be reduced. Eni Pak Eni Pak Check Compliance During rainy season
Blockages in the flow of rain water in major canals should
be removed to prevent flooding in the surrounding.
1.25 Any wild animal or their cub should not be caught to make DC, Eni Eni Pak Check Compliance During entire activity
pet. Pak
1.26 Nests of birds present in the grass lands should not be CC, Eni Eni Pak Check Compliance During land clearing
destroyed. Pak

1.27 The dens and burrows of wildlife should be protected and CC, Eni Eni Pak Check Compliance During land clearing /
access track should be at safe distance from them. Pak construction of access
track
1.28 Maintain safe distance from the breeding locations of birds CC, Eni Eni Pak Check Compliance During land clearing /
and mammals. The wildlife, especially their offspring should Pak construction of access
not be threatened. track
1.29 Sightings of wildlife in the project area should be reported. CC, DC, Eni Pak Check Compliance During entire activity
Eni Pak
1.30 Wildlife may come in contact with the project personnel. CC, DC, Eni Pak Check Compliance During entire activity
They should not be chased or scared. Eni Pak
8.9. Environmental Monitoring Program
8.9.1. Objectives of environmental monitoring

The environmental monitoring program will fulfill the following objectives.
 Compliance monitoring: to check compliance of the contractors and Eni Pakistan with
the EMP on a regular basis.
 Effects monitoring: to monitor impacts of the operation in which there has been a level of
uncertainty in prediction, such as impacts on wildlife and to recommend mitigation
measures if the impacts are assessed to be in excess of or different from those assessed
in the EIA.
 Post project Monitoring: to monitor residual impacts and complete restoration of sites.
8.9.2. Compliance Monitoring

Compliance monitoring will be carried out to ensure compliance with the requirements of the
EIA and to document and report all non-compliances. The Mitigation Management Matrix
provided in the EMP will be used as a management and monitoring tool, inspection may be
done using checklist provided in the EMP. The contractors HSE Rep will be responsible for
monitoring the compliance of their organization with the relevant EMP requirements. Eni
Pakistan will also monitor the contractor’s compliance and will also ensure that during each
activity, system and plan is in place for effective compliance monitoring. The Eni Pakistan HSE
representative will make regular checks on the contractor’s works; keep records of all non-
compliances observed during the execution of the project activities; and the details of all
remedial actions taken to mitigate the project impacts.
8.9.3. Effects Monitoring

The effects monitoring requirement for drilling phase has been detailed in Table 8.7 and 8.8.
Eni Pakistan will involve independent monitoring team to carry out the required effects
monitoring during drilling and associated activities.
8.9.4. Post project Monitoring

The objective of this monitoring will be to determine the level of residual impacts of the project
activities on physical, biological and socio-economic receptors of the project area. The
monitoring may be carried out within one month after the end of all activities in the project
area. As part of the post-project monitoring restoration of sites will also be checked.
8.10. Communication and Documentation

For effective implementation of Environmental Management Plan, HSE matters will be
discussed during daily meetings held on-site. Environmental concerns raised during the
meetings will be mitigated after discussions between the Eni Pakistan HSE and Drilling
Contractor (DC). Any issues that require attention of Eni Pakistan’s higher management will
be communicated to them for action. Copies of the report will be provided to the Eni Pakistan
and DC higher management respectively.
Table 8.7: Environmental Monitoring Plan for Well Site Construction and Well Drilling
S. No. Monitoring Monitoring locations Parameters Frequency Responsibility Documentation
Aspects
1 Ambient air Well site, camp site SO2, NO, NO2, SPM, PM10, Once during the well Contractor Laboratory test
Quality Monitoring surrounding PM2.5, O3, Pb, CO drilling Reports
2 Exhaust & Vehicles, Generators & CO, Smoke, Noise for vehicle Once during the project Contractor Laboratory test
Emissions Fuel operated CO, NOx, Sox and PM for Reports
Monitoring Machinery engines / generator
3 Waste water Campsite Effluent Flow, Temperature, pH, Quarterly (if wastewater Contractor Laboratory test
COD, BOD5, TSS, TDS, Oil & discharged into any Reports
Grease, Chloride & Phenolic nullah)
Compounds
4 Noise level Boundaries of the well Noise level (dBA) Once in a project during Contractor Internally /
and camp sites construction and drilling externally
operations (when work is
started)
5 Solid Waste Project site Solid waste collection, storage, During routine monitoring Contractor Complete record
transportation and disposal waste generation
record, waste
disposal record &
disposal
certificate)
6 Drilling Mud Drilling Site Collection, storage, During routine monitoring Contractor / Complete record
transportation and disposal HSE Monitor
7 Occupational Survey sites, campsite, HSE Records, During routine monitoring Contractor Record of
Safety project roads Incidents and injuries observations.
Table 8.8: Environmental Monitoring Plan for Construction and Commissioning Phases of Flow Lines
S. No. Monitoring Monitoring locations Parameters Frequency Responsibility Documentation
Aspects
1 Exhaust and Vehicles, Generators & CO, Smoke, Noise for vehicles Once during the project Contractor Laboratory test
Emissions Fuel operated CO, NOx, Sox and PM for Reports
Monitoring Machinery engines / generators
2 Noise Levels Along pipeline route, Noise Level dBA Once in a project when Contractor Internally /
nearest to sensitive work is started. externally
receptors like
communities and at
boundary of camp site.
3 Flow line Waste discharge point Effluent Flow, Temperature, pH, One time during Contractor Laboratory test
Hydrostatic COD, BOD5, TSS, TDS, Oil & hydrostatic testing (if Reports
Testing Grease, Chloride and Phenolic wastewater discharged
Wastewater Compounds into any nullah)
(during
commissioning)
4 Solid Waste Project Site Solid waste collection, storage, During routine Contractor Complete record
transportation and disposal. monitoring (waste
generation
record, waste
disposal record &
disposal
certificate)
Kick-off Meeting
Prior to commencement of work and after set-up of the field camp for the drilling activity, a
meeting will be held on-site to discuss implementation of the EMP, show commitment to
adhere with the EMP and check readiness of the DC to start the project.
The meeting will be attended by relevant management staff from Eni Pakistan and the DC.
Monthly Reports
The purpose of these reports will be to review the performance of the operation by reviewing
the number of non-conformances and the environmental incidences that occurred during the
reporting period, progress on daily action items and to list recommendations for additional
controls, mitigation measures or monitoring requirements. The main contents of weekly report
will include the introduction, details of activities, resource use, environmental non-
compliances, H&S records, socioeconomic issues (if any), photographic records, approvals,
inspection and audits, change managements (if any) and trainings etc.
Effects Monitoring Reports
The results of effects monitoring surveys (on wildlife, use of water resources, communities
etc.) will be compiled by the independent monitoring consultant in the form of a report. This
section on effect monitoring will be included in the monthly and final environmental monitoring
report. The report as a minimum will include:
 Objectives and methodology

 Person(s) involved in the survey
 Areas surveyed
 Results of the monitoring exercise along with raw data collected on field
 Conclusion on the effects of the project activities
Social Complaints Register
The Eni Pakistan site representatives will maintain a register of complaints received from local
communities and measures taken to mitigate these concerns. Liaison with community
members including particularly the land owners/occupiers will be maintained throughout the
project to identify and address the concerns of locals. All community complaints received will
be sent to the Eni Pakistan management for further action. Appropriate compensations will be
provided to the grieved residents of the project area.
Photographic Record
Eni Pakistan will ensure that a photographic record including the following is maintained:
 All areas used before, during and after exploration;

 Key non-compliances; and
 Key project activities.
Final Monitoring Report
The project proponent will prepare a post project report describing the details of the project
activities, natural resources use by the project, machinery & equipment, any changes from the
operation for which approval was obtained, the degree to which the recommendations of the
EIA were adhered to during the operation, list of HSE non-compliances, HSE meetings and
trainings etc. The report can make use of the HSE reports prepared during the operation for
that purpose.
The main contents of final report will include the introduction, details of activities, resource
use, HSE non-compliances, HSE records, Communication and documentation, approvals
change managements (if any), trainings and drills, socioeconomic issues (if any), inspection
and audits, photographic records etc.
The report will be submitted to the Sindh EPA. Any findings and recommendations relating to
the operation that may improve future similar operations will also be reported.
8.11. Environmental Training

Environmental training will form part of the environmental management system. The training
will be directed towards all personnel for general environmental awareness.
8.11.1. Objectives
The key objective of training program is to ensure that the requirements of the EMP are clearly
understood and followed throughout the project. The trainings to the staff will help in
communicating environmental related restrictions specified in the EIA and EMP.
8.11.2. Roles and Responsibilities

The contractors will be primarily responsible for providing environmental training to all project
personnel on potential environmental issues of the project. The contractors will be responsible
to arrange trainings and ensure the presence of targeted staff.
8.11.3. Training Program

The environmental awareness, EIA and EMP training will be carried out by Eni Pakistan’s HSE
and contractors for the staff mentioned in Table 8.9.
Table 8.9: Suggested Training Program for exploratory activities

Staff Contents
Drivers − Road safety
− Road restrictions
− Vehicle restrictions
− Waste disposal
− Wildlife sanctuary and wildlife sensitivities
Land Clearing − Wildlife sensitivities
Operation − Identification and avoidance of sensitive areas
− Waste disposal
− Communication of environmental problems to appropriate officer
Repair and − Environmental control of vehicles and equipment
maintenance − Waste disposal
Camp staff − Camp operation
− Waste disposal
Restoration − Restoration requirements
8.11.4. Training log

A training log will be maintained by the contractors. The training log will include:
 Topic
 Date, time and location

 Trainer
 Participants
8.11.5. Training Need Assessment

In addition to the training specified in the training log special/ additional trainings will be
provided during the project activity. The criteria to assess the need of training will be based
on the following:
 When a specified percentage of staff is newly inducted in the project

 When any non-compliance is repeatedly reported, refresher training will be provided
regarding that issue.
 When any incident / accident of minor or major nature occurs
 Arrival of new contractor / sub-contractor
 Start of any new process / activity
8.11.6. Training Material

The contractors will develop and prepare training material regarding environmental
awareness, sensitivity of the area, EIA, EMP and restrictions to be followed during the project.
Separate training material will be prepared for each targeted staff.
8.12. Emergency Response Plan

An emergency response plan is required for all critical activities to be undertaken by Eni
Pakistan under its direct control. Accordingly, Emergency Response Plan (ERP) will be
developed for the project and implemented.
The ERP will identify the roles and responsibilities of all personnel involved in handling of
emergency situation by means of a bridging document between Eni Pakistan site management
and contractor’s emergency response procedures.
The ERP will also highlight reporting requirements and necessary actions to handle
emergency situation during drilling and associated activities in close coordination with
contractor’s emergency response procedure and Eni Pakistan emergency response
procedures.
The ERP will be implemented under following scenarios:
 Response to Fire and Explosion (Main Drilling Operation)

 Response to Fire and Explosion (Camp)
 Response to Medical Emergencies
 Response to Road Vehicle Accident

 Response to gas leak (Drilling Well)
 Response to Condensate / Diesel Spill
 Natural Disasters (earthquake and floods)

 Hydrogen Sulphide (H2S) release (Drilling Operations)
 Security emergencies
8.13. Waste Management

The Eni Pakistan has waste management plan in place. The contractor for Eni Pakistan is
engaged to collect and dispose/treat all the waste material (solid, food, camp waste packing,
medical etc.) generated during drilling.
The disposal certificates are provided by the contractor to Eni Pakistan accordingly for each
waste category.
The main types of waste that will be generated include:
 Drill cuttings and waste mud

 Effluent and Sewage
 Domestic Solid Waste
 Recyclable and reusable waste
 Fuels, oils and chemicals
 Camp waste
 Medical waste
 Packing waste
Proposed management scheme for above waste types is given below:
8.13.1. Management of Drilling Wastes

lined waste pit. Cuttings segregation and fluid recovery unit will be used for better
management and disposal of drilling wastes. This will further allow:
a) Additional drying of the cuttings making their disposal into the lined waste pit easier;
b) Recovery of the excess mud associated with the cuttings. The mud can be re-used
thereby reducing the overall water consumption and chemicals usage for mud
formulation; and
c) Reduction in the size of the waste pit due to the reduction in the mud content
associated with the cuttings and due to less water consumption and mud formulation.
The waste management system is considered to be technologically and environmentally the

most preferred option. After completion of drilling, the cuttings remaining in the waste pit will
be allowed to dry out. The cuttings will then be encapsulated within the HDPE liner and the
waste pit will be backfilled leaving a top soil cover over the pit at the time of site restoration.
8.13.2. Effluents and Sewage

 Sewage Treatment Plant (STP) is the preferred option for treating and disposing black
and grey wastewater.
 In case of unavailability of STP, septic tank and soak pits shall be provided.
 Soak pits should be designed to accommodate wastewater generated during the total
duration of the operation and will be engineered to prevent storm water runoff. Build soak
pits in absorbent soil. Design soak pits to accommodate wastewater generated during
the total duration of the operation.
 Septic tank and soak pits should be constructed at rig site and base camp for handling
and disposal of black and grey water. Septic tank and soak pit should be covered properly
to avoid obnoxious smells in surrounding areas.
 In case if septic tank gets filled with sludge, septic tank should be emptied through
vacuum truck and material should be transferred to a treatment facility.
 In case soak pits cannot be built large enough due to high water table or other
environmental or geological constrains, additional pits may be built in a nearby area
where water table is shallow.
 Storm water should be routed to temporary dykes for water storage.
8.14. Risk Management

The management of emergency situations at the project site will based on:
 Early detection
 Immediate reaction
 Confinement of emergency area
 Application of the adequate response procedure
 Follow-up and monitoring
1. Initial response
Initial response is always the most important aspect and can determine the success or failure
of emergency response management. In the event of an emergency (oil spill, fire, natural
disaster e.g., rainstorms, earthquake etc.) following steps are recommended for the
emergency response team/supervisor.
 Seize all operations
 Inform the respective authority about the incident

 Seek medical attention if required
 Assess the situation and take action according to the instructions received from the
Emergency Response Team leader
2. Site Evacuation
The following notification system will be used to notify the need for evacuation:
 Alarms/Horns/Sirens.
 Verbal Public address system.
3. Training
All employees will be trained appropriately to work on ERP effectively. Employees training will
provide workers with information on minimizing the damage to life and property. The Sr. HSE
Specialist (Environment) will determine the training requirements in consultation with senior
project management:
The staff will be trained as per following procedures:
4. Personnel Training Procedures
 Notification
 Emergency incident reporting
 Description of the Emergency event
5. Emergency Response Team members are capable of and engaged in the

following:
 Personnel rescue procedures

 Shutdown of operations
 Use, maintenance, and replacement of emergency response equipment
6. Emergency Response Training
 Develop and practice a spill clean-up procedure including where to find emergency
equipment and how to use it.
 Make sure all people on site are aware of emergency telephone numbers to call in the
case of a large spill. Spill kit equipment on site should include: booms to contain liquids,
material to prevent spills into drains, and material to absorb spills. Keep this absorbent
material in a clearly labeled and easily accessible place.
7. Response Strategy
Upon the occurrence of an emergency, the Plan will be developed under the following
conditions:
 First Stage: Notification.

 Second Stage: Initial assistance/rescue.
 Third Stage: Response operations.

 Fourth Stage: Evaluation of the Plan and damages.
Onsite staff will be notified of the emergency event. Furthermore, message forms will be
established to record at least the following information: Name of informant, location and place
of the emergency, number of people affected and, if possible, an estimate of the type of injuries
and/or damages, among others.
8. Monitoring and Review
Monitoring of different activities will be required to analyze the impacts of project activities on
the environment. Sr. HSE Specialist (Environment) will be the in charge of monitoring
procedures. Monitoring techniques will be identified and the frequency of selected parameters
for monitoring will be followed. Manager HSE will keep a record of all non-conformities
observed and report them to the senior management in HSEQ for further action. Manager
HSE will also report any impact anticipated along with his recommendations for further action.
The contractor shall take note of the recommendations relating to issues arising during
monitoring of construction activities.
8.15. Site Restoration Plan

The following activities will be carried out during site restoration:
 Demobilization of all equipment and machinery;

 Disposal of waste material;
 Backfilling of all soak pits and septic tanks;
 Dismantling and removal of fence or barriers surrounding the camp area;
 General restoration of the site area including landscaping and restoration of drainage
where required.
After completion of drilling and testing operations, the rig will be dismantled and demobilized
off the site. The wellhead will remain in situ, but all other equipment and materials including
empty drums used and unused chemicals, fuels and lubricants will be removed from the well
site by their respective suppliers.
After well evaluation, a decision on whether to abandon or further develop the well will be
taken. If it is decided that the well is to be abandoned, the site will be restored, as far as
possible, to its original condition. Any concrete structure built during the project will be
removed (if no longer useful), fencing will be removed, and the area will be leveled. All pits will
be backfilled with at least 1 m of top soil cover.
Drilling Mud Disposal
The drilling mud will be disposed of according to the Eni Pakistan’s SOP for the disposal of
drilling mud.
8.16. Change Management Plan

The EIA recognizes that changes in the operation or the EMP may be required during the
operation and therefore provides a Change Management Plan to manage such changes, the
management of changes is discussed under two separate headings, changes to the EMP and
changes to the operation.
8.16.1. Changes in the EMP

The EIA and the EMP have been developed, based on the next possible information available
at the time of the EIA study, it is possible that during the conduct of the proposed project
additional mitigation measures based on the findings of environmental monitoring during the
project execution may have to be included in the EMP. In such cases following sections will
be taken:
 A meeting will be held among Eni Pakistan, the contractors and the independent
monitoring team. During the meeting the proposed deviation from the EMP, planning and
designing will be discussed and agreed upon by all parties.
 Based on the discussion during the meeting, a change report will be produced
collectively, which will include the additional EMP clause and the reasons for the
addition/change.
 The report will be signed by all parties and will be filed at the site office. A copy of the
report will be sent to Eni Pakistan and contractor head office.
 All relevant project personnel will be informed of the addition.
8.16.2. Changes in the Operation

The change management system recognizes three orders of changes:
First-Order Change
Change leading to a significant deviation of any operation from the project described in the
report and consequently requires a reassessment of the environmental impacts associated
with the changes. In such an instance, updated environmental impacts of the proposed change
will be sent to SEPA for approval.
Examples of such change include:
 Use of oil-based mud during drilling
Second-Order Change
Change that entails project activities not significantly different from those described in the EIA
report, and which may result in project impacts whose overall magnitude would be similar to
the assessment made in this report. In case of such changes, the environmental impacts of
the activity will be reassessed. Additional mitigation measures if required will be identified and
documented for being reported to SEPA for their record.
Third-Order Change
Change that is of little consequence to the EIA findings. This type of change does not result
in impact levels exceeding those already assessed in the EIA report; rather these may be
made onsite to minimize the impact of an activity. The only action required in this regard will
be to record the details of process change in the record register.
Change in Record Register
A record register will be maintained at project site at the start of project activities. All the
changes to be made will be recorded in this register. This will assist in the step-by-step
environmental monitoring and decision-making. Record register will be the responsibility of
HSE department, and will be used internally.
Change in EMP
Changes in project design necessitate changes in the EMP. In this case, following actions will
be taken:
 A meeting will be held between project management and contractor, to discuss and agree
upon the proposed change to the EMP.
 Based on the discussion during the meeting, a report will be produced, which will include
the additional EMP clauses and the reasons for their addition.
 Additional EMP clauses will be added to the original EMP as a second volume which will
be distributed to the relevant project personnel and contractor.
Chapter 9 Conclusion & Recommendations

This Environmental Impact Assessment (EIA) study has been conducted on behalf of Eni
Pakistan for the proposed development well drilling and associated activities in Kadanwari
Block, Sindh. The findings from the study performed have been categorically recorded and
presented in the current report. To ensure compliance of the study and formulation of the
reporting, all relevant national legislations were followed and adhered to.
Pakistan is an energy deficient country; a large portion of country's energy demands are met
through imports expensive petroleum products. Hence there is a dire need to increase the
production of oil and gas from existing reserve and explore new reserves. The proposed
project will help achieve this by increasing the oil and gas production from the Kadanwari
block. The project would also have a positive impact on socioeconomic conditions as it would
provide more job opportunities to the local people and generate opportunities for more
business.
Eni Pakistan has commissioned EMC Pakistan (Pvt) Limited to undertake this extensive EIA
study that examined the current environmental, social, cultural, and physiographical setting
on the ground. To ensure compliance of both the study and formulation of the reporting, all
relevant national and international legislations were followed and adhered to. Key areas
covered in the report include a comprehensive project description, project area baseline
information, guiding legal and regulatory framework and alternatives to the proposed project.
Potential impacts of drilling activities on the physical, biological, socio-economic and cultural
environment of area are assessed through this study and mitigation measures proposed which
will be adopted to eliminate and/or reduce the impacts on the environment.
The EIA concludes that the proposed activities will not lead to significant adverse
environmental impacts and careful implementation of the EMP will ensure that potential
impacts are managed and minimized and the project proponents meet all statutory
requirements.
RECOMMENDATIONS
The proposed project will have both positive and negative impacts. The EIA team has
endeavored to give comprehensive mitigation measures and environmental management and
monitoring mechanisms which, if put in place, will minimize or completely eradicate the
possible negative impacts. The EMP provided in this report should be strictly adhered to, to
ensure that the project remains environmentally and technically sound throughout its life.
Some of the measures that need close implementation and monitoring include the following:
 Pre-survey possible access routes, and use the selected routes rather than accessing
work sites through free-ranging driving across the open country;
 Employees working in dusty conditions must use appropriate PPE;
 Use low sulphur fuels if available and where suitable;
 Ensure that all vehicles and machinery operating in the field (and in the campsite) are
properly maintained so as not to have any oil leaks that could contaminate the soils
 It is recommended that segregation of solid wastes at source is appropriately carried out

and consideration given to re-use, recycling, or disposal as appropriate;
 The communities should be informed well in advance before the commencement of

proposed drilling and associated activities.
Doc. No.: Eni/EIA/01 Rev.: C Annexures
Annexures
Annexure-I: Sindh Environmental Quality

Standards (SEQS), 2016
Annexure-II: Eni HSE Policy

HSE Guidelines for MEICP Works at Kadanwari
Eni Pakistan Limited Date of Release April, 2022
Page 65 of 77
Annexure– B: HSE POLICY
The copy, once printed out, becomes an uncontrolled document; before using it, please verify the revision status of the document.
Annexure-III: Environmental Analysis

Reports
QMS/III/018 WA
Revision : 03 Date 14.01.2021
Report Ref. No. : QTS/ENI/22/2474-A Reporting Date: 01/02/2022

Report to: EIA. Drilling Activity In Kadanwari Block, Eni Pakistan
SAMPLE DESCRIPTION
Sample ID: Ground Water (Hand Pump) Jamal-ud-din Rajar
Sampling Method: APHA-1060 B & C
Sample Type: Liquid
Sample Collected/Submitted by: QTS representative
Sampling Date : 12/01/2022
ANALYTICAL TEST REPORT

PARAMETERS TO BE STANDARD
S.NO. LDL UNITS RESULTS TEST METHOD
ANALYZED SSDWQ
PHYSICAL ANALYSIS RESULTS
Non Objectionable / -
1 Odour - Acceptable Physical
Acceptable
2 Taste - Acceptable Physical
Acceptable
3 Color <15 1.0 Pt-Co 09 APHA-2020 B/C
4 Turbidity <5.0 0.01 NTU 0.33 Turbidity Method
CHEMICAL ANALYSIS RESULTS
5 pH value 6.5-8.5 0.01 - 6.7 USEPA 150.1
6 Total Dissolved Solids(TDS) <1000 1.0 mg/L 680 Hach 8160
7 Total Hardness(as CaCO3) <500 0.1 mg/L 210 Hach 8213
8 Nitrate(NO3) <50 0.01 mg/L 0.41 Hach 8039
9 Nitrite(NO2) <3 0.001 mg/L 0.077 Hach 8153
10 Phenolic compounds(as phenol) <0.002 0.001 mg/L BDL USEPA 420.1
11 Chloride(as Cl-) <250 0.1 mg/L 220 Hach 8206
12 Fluoride(as F-) <1.5 0.01 mg/L 0.55 USEPA 340.1
13 Cyanide(as CN-)total ≤ 0.05 0.001 mg/L BDL Hach 8027
14 Copper 2 0.01 mg/L 0.20 Hach 8506
15 Zinc 5.0 0.01 mg/L 1.55 USEPA 3500 Zn B
16 Manganese ≤ 0.05 0.01 mg/L 0.32 Hach 8034
17 Barium 0.7 0.01 mg/L 04* Hach 8014
MICROBIOLOGICAL ANALYSIS RESULTS
18 Total Coliform 0 cfu/100ml Cfu 170* APHA SM-9221-B
19 Fecal Coliform 0 cfu/100ml Cfu 90* APHA SM-9221-F
20 Escherichia Coli( E-Coli) 0 cfu/100ml Cfu 20* APHA SM-9221-F
SSDWQ = Sindh Standard for Drinking Water Quality
USEPA=United State Environmental Protection Agency method
Hach USA, method
BDL=Below Detection Limit
APHA-SM = American Public Health Association- Standard Methods for Water & Waste water Examination
ND= Not Detected
LDL= Least Detectable Value
Terms & Condition:
 This report is not valid for any negotiations
 Report is valid for current batch(sample)
 The remaining portion of the sample will be discarded after 07 days unless otherwise instructed
 This report is intended only for your guidance & not for legal purpose or for advertisement.
Sample Analyzed by: Hareem Zehra Signature of Laboratory In charge:________________

Name : Ali Raza
QMS/III/018 WA
Report Ref. No. : QTS/ENI/22/2474-B Reporting Date: 01/02/2022

SAMPLE DESCRIPTION
Sample ID: Ground Water (Hand Pump) Faqeer Allah Rakhio Mehar
Sample Type: Liquid

PARAMETERS TO BE STANDARD
S.NO. LDL UNITS RESULTS TEST METHOD
ANALYZED SSDWQ
PHYSICAL ANALYSIS RESULTS
1 Odour - Acceptable Physical
Acceptable
2 Taste - Acceptable Physical
Acceptable
3 Color <15 1.0 Pt-Co 07 APHA-2020 B/C
4 Turbidity <5.0 0.01 NTU 0.39 Turbidity Method
CHEMICAL ANALYSIS RESULTS
5 pH value 6.5-8.5 0.01 - 7.0 USEPA 150.1
6 Total Dissolved Solids(TDS) <1000 1.0 mg/L 430 Hach 8160
7 Total Hardness(as CaCO3) <500 0.1 mg/L 152 Hach 8213
8 Nitrate(NO3) <50 0.01 mg/L 0.26 Hach 8039
9 Nitrite(NO2) <3 0.001 mg/L 0.081 Hach 8153
10 Phenolic compounds(as phenol) <0.002 0.001 mg/L BDL USEPA 420.1
11 Chloride(as Cl-) <250 0.1 mg/L 142 Hach 8206
12 Fluoride(as F-) <1.5 0.01 mg/L 0.64 USEPA 340.1
13 Cyanide(as CN-)total ≤ 0.05 0.001 mg/L BDL Hach 8027
14 Copper 2 0.01 mg/L 0.11 Hach 8506
15 Zinc 5.0 0.01 mg/L 1.44 USEPA 3500 Zn B
16 Manganese ≤ 0.05 0.01 mg/L 0.21 Hach 8034
17 Barium 0.7 0.01 mg/L 07* Hach 8014
MICROBIOLOGICAL ANALYSIS RESULTS
18 Total Coliform 0 cfu/100ml Cfu 230* APHA SM-9221-B
19 Fecal Coliform 0 cfu/100ml Cfu 110* APHA SM-9221-F
20 Escherichia Coli( E-Coli) 0 cfu/100ml Cfu 30* APHA SM-9221-F
SSDWQ = Sindh Standard for Drinking Water Quality
Hach USA, method
ND= Not Detected
Terms & Condition:
Sample Analyzed by: Hareem Zehra Signature of Laboratory In charge:________________

Name : Ali Raza
QMS/III/018 WA
Report Ref. No. : QTS/ENI/22/2474-C Reporting Date: 01/02/2022

SAMPLE DESCRIPTION
Sample ID: Surface Water (Well X-3)
Sample Type: Liquid
S.NO. PARAMETERS TO BE ANALYZED LDL UNITS RESULTS TEST METHOD
1 Odour - - Acceptable Physical

2 Color 1.0 Pt-Co 10 APHA-2020 B/C
3 Turbidity 0.01 NTU 1.0 Turbidity Method
4 pH value 0.01 - 7.8 USEPA 150.1
5 Total Dissolved Solids(TDS) 1.0 mg/L 210 Hach 8160
6 Total Suspended Solids (TSS) 1.0 mg/L 05 Hach 8006
7 Chemical Oxygen Demand (COD) 1.0 mg/L 100 Hach 8000
8 Biochemical Oxygen Demand (BOD) at 20oC 0.1 mg/L 21 Hach 8043
9 Total Hardness(as CaCO3) 0.1 mg/L 55 Hach 8213
10 Nitrate(NO3) 0.01 mg/L 0.22 Hach 8039
11 Nitrite(NO2) 0.001 mg/L 0.041 Hach 8153
12 Phenolic compounds(as phenol) 0.001 mg/L BDL USEPA 420.1
13 Chloride(as Cl-) 0.1 mg/L 71 Hach 8206
14 Fluoride(as F-) 0.01 mg/L 0.11 USEPA 340.1
15 Cyanide(as CN-)total 0.001 mg/L BDL Hach 8027
16 Chromium , Total 0.01 mg/L 0.41 ASTM D-1687
17 Copper 0.01 mg/L 0.55 Hach 8506
18 Zinc 0.01 mg/L 0.32 USEPA 3500 Zn B
19 Manganese 0.01 mg/L 0.017 Hach 8034
20 Barium 0.01 mg/L BDL Hach 8014
Hach USA, method
ND= Not Detected
Terms & Condition:
Signature of Laboratory In charge:________________

Sample Analyzed by: Hareem Zehra
Name : Ali Raza
QMS/III/018 WA
Ambient Air Quality Test Report

EIA. Drilling Activity In Test Report No: QTS/ENI/22/2475-A
Project Name: Kadanwari Block, Eni Pakistan Sample Duration 24hr’s
Location A, Near N 27°04'08.8"
Sample Description: Ambient Air Quality Test
Eni Well 1 & 2 E 69°14'36.1"
SEQS-PARAMETERS
NO NO2 SO2 PM 10 PM 2.5 SPM Lead
Date Time
(µg/m3) (µg/m3) (µg/m3) (µg/m3) (µg/m3) (µg/m3) (µg/m3)
11.01.2022 10:00 4.8 6.6 1.5 43 22 183
11.01.2022 11:00 5.2 6.5 1.7 47 24 189
11.01.2022 12:00 5.6 6.2 1.9 49 25 192
11.01.2022 13:00 5.5 6.0 2.2 51 26 207
11.01.2022 14:00 5.0 5.9 2.4 53 27 211
11.01.2022 15:00 4.9 5.3 2.3 55 29 214
11.01.2022 16:00 4.3 5.6 2.2 58 31 215
11.01.2022 17:00 4.2 5.8 2.3 51 33 218
11.01.2022 18:00 4.1 6.1 2.6 50 38 220
11.01.2022 19:00 4.0 6.0 2.9 48 32 224
11.01.2022 20:00 3.9 5.8 3.4 47 31 221
11.01.2022 21:00 3.6 5.3 3.1 45 30 218
11.01.2022 22:00 3.8 4.7 2.9 41 26 217
11.01.2022 23:00 4.0 4.2 2.4 40 25 216 BDL
12.01.2022 00:00 3.7 3.9 2.0 35 25 209
12.01.2022 01:00 3.1 3.6 1.9 32 24 203
12.01.2022 02:00 2.5 3.2 1.7 30 19 201
12.01.2022 03:00 2.4 3.0 1.6 28 15 200
12.01.2022 04:00 2.1 2.9 1.0 27 12 195
12.01.2022 05:00 2.5 3.1 0.9 25 15 189
12.01.2022 06:00 2.8 3.4 0.8 20 16 181
12.01.2022 07:00 3.1 3.5 1.1 23 17 178
12.01.2022 08:00 3.3 3.8 1.2 24 18 179
12.01.2022 09:00 3.6 4.5 1.4 26 20 181
MIN 2.1 2.9 0.8 20 12 178
MAX 5.6 6.6 3.4 58 38 224
AVG 3.8 4.7 1.9 39.4 24.2 202.4
SEQS 40 80 120 150 75 500 1.5
LDL-Limits 0.0 0.0 0.0 10 2.5 1.0 -
QMS/III/018 WA
EIA. Drilling Activity In Test Report No: QTS/ENI/22/2475-A

Location A, Near N 27°04'08.8"
Eni Well 1 & 2 E 69°14'36.1"

Average
Monitoring LDL-
Parameter Unit Obtained SEQS Methodology
Duration Limits
Concentration
Carbon Monoxide Non Dispersive
mg/m3 08 Hours 0.12 5.0 0.0
(CO) Intra Red (NDIR)
Nitrogen oxide
µg/m3 24 Hours 3.8 40.0 0.0
(NO)
Chemiluminescence
Nitrogen Dioxide
µg/m3 24 Hours 4.7 80.0 0.0
(NO2)
Sulphur Dioxide Ultraviolet
µg/m3 24 Hours 1.9 120.0 0.0
(SO2) Fluorescence Method
Ozone Non Dispersive UV
µg/m3 01 Hour 12.4 130.0 0.0
(O3) Absorption Method
Particulate Matter
µg/m3 24 Hours 39.4 150.0 10.0
(PM10)
Particular Matter
µg/m3 24 Hours 24.2 75.0 2.5 β Ray Absorption
(PM2.5)
Method
Suspended
Particulate Matter µg/m3 24 Hours 202.4 500.0 1.0
(SPM)
Lead
µg/m3 24 Hours ND 1.5 - ASS Method
(Pb)
*SEQS= Sindh Environmental Quality Standards.
(24 Hours Standard for all the parameters Except O3 and CO),
µg/m3= Micrograms per Cubic Meter
,mg/m3= Milligrams per Cubic Meter
ND= Not Detected
LDL=Least Detection Limit
Signature of Laboratory Incharge:_________________

Sample Analyzed By: Sajid Ali
Name : Ali Raza
QMS/III/018 WA

EIA. Drilling Activity In Test Report No: QTS/ENI/22/2475-B
Location B, Near N 27°11'54.1"
Eni Well 3 E 69°07'33.4"
SEQS-PARAMETERS
NO NO2 SO2 PM 10 PM 2.5 SPM Lead
Date Time
(µg/m3) (µg/m3) (µg/m3) (µg/m3) (µg/m3) (µg/m3) (µg/m3)
12.01.2022 11:00 3.6 4.7 2.6 31 16 186
12.01.2022 12:00 3.5 4.9 2.8 34 18 189
12.01.2022 13:00 3.2 5.0 2.9 36 19 196
12.01.2022 14:00 3.0 5.2 2.5 41 20 201
12.01.2022 15:00 2.9 5.1 2.4 49 22 212
12.01.2022 16:00 2.8 5.0 2.1 53 26 216
12.01.2022 17:00 2.5 4.9 1.9 56 29 219
12.01.2022 18:00 2.3 4.6 1.7 55 31 220
12.01.2022 19:00 2.2 4.9 1.6 50 29 221
12.01.2022 20:00 2.1 5.0 1.5 41 25 216
12.01.2022 21:00 2.0 5.1 1.4 39 21 209
12.01.2022 22:00 1.9 4.9 1.7 36 23 202
12.01.2022 23:00 1.7 4.8 1.9 33 22 194
13.01.2022 00:00 1.6 4.3 2.0 31 21 193 BDL
13.01.2022 01:00 1.4 3.9 2.1 30 20 187
13.01.2022 02:00 1.9 3.8 2.0 30 18 182
13.01.2022 03:00 2.2 3.7 1.9 28 16 178
13.01.2022 04:00 2.4 3.5 1.8 27 15 173
13.01.2022 05:00 2.5 3.2 1.7 25 14 170
13.01.2022 06:00 2.4 3.0 1.6 21 12 168
13.01.2022 07:00 2.1 3.2 1.8 26 11 165
13.01.2022 08:00 2.3 3.6 2.0 27 10 171
13.01.2022 09:00 2.8 3.8 2.1 34 12 189
13.01.2022 10:00 2.9 4.0 2.3 35 14 191
MIN 1.4 3 1.4 21 10 165
MAX 3.6 5.2 2.9 56 31 221
AVG 2.4 4.3 2.0 36.3 19.4 193.6
SEQS 40 80 120 150 75 500 1.5
LDL-Limits 0.0 0.0 0.0 10 2.5 1.0 -
QMS/III/018 WA
EIA. Drilling Activity In Test Report No: QTS/ENI/22/2475-B

Location B, Near N 27°11'54.1"
Eni Well 3 E 69°07'33.4"

Average
Monitoring LDL-
Parameter Unit Obtained SEQS Methodology
Duration Limits
Concentration
Carbon Monoxide Non Dispersive
mg/m3 08 Hours 0.08 5.0 0.0
(CO) Intra Red (NDIR)
Nitrogen oxide
µg/m3 24 Hours 2.4 40.0 0.0
(NO)
Chemiluminescence
Nitrogen Dioxide
µg/m3 24 Hours 4.3 80.0 0.0
(NO2)
Sulphur Dioxide Ultraviolet
µg/m3 24 Hours 2.0 120.0 0.0
(SO2) Fluorescence Method
Ozone Non Dispersive UV
µg/m3 01 Hour 12.2 130.0 0.0
(O3) Absorption Method
Particulate Matter
µg/m3 24 Hours 36.3 150.0 10.0
(PM10)
Particular Matter
µg/m3 24 Hours 19.4 75.0 2.5 β Ray Absorption
(PM2.5)
Method
Suspended
Particulate Matter µg/m3 24 Hours 193.6 500.0 1.0
(SPM)
Lead
µg/m3 24 Hours ND 1.5 - ASS Method
(Pb)
*SEQS= Sindh Environmental Quality Standards.
(24 Hours Standard for all the parameters Except O3 and CO),
µg/m3= Micrograms per Cubic Meter
,mg/m3= Milligrams per Cubic Meter
ND= Not Detected
LDL=Least Detection Limit
Sample Analyzed By: Sajid Ali Signature of Laboratory Incharge:_________________

Name : Ali Raza
QMS/III/018 WA
Lab Report Ref. No. : EMC/QTS/ENI/22/2476 Reporting Date: 01/02/2022

Project Name: EIA. Drilling Activity in Kadanwari Block, Eni Pakistan.
SAMPLE DESCRIPTION
Sample ID: Noise Level Test
Sample Description: Ambient Noise
No. of samples: 05
Sampling Date: 11& 12/Jan/2022
NOISE LEVEL TEST REPORT

Noise Level Readings
S.NO. LOCATION/SOURCE
Minimum Maximum Average Limits
1 Near Well X-01 55.2 58.8 57.0
2 Near Well X-02 56.0 59.6 57.8

SEQS
3 Near Well X-03 57.4 60.8 59.1 Limits:
*75dB(A)
4 Near Well X-04 54.2 58.5 56.3
5 Near Well X-05 55.0 58.7 56.8
SEQS = Sindh Environmental Quality Standards.
dB (A) Leq=Time weighted average of the level of sound in decibel on scale which is relatable to human hearing.
*75dB Noise Commercial Limits.
Term & Condition:
Comments:
The Noise Level from the sources is within acceptable level as describe in SEQS.
Signature of Laboratory In charge:________________

Sample Analyzed by: Sajid Ali
Name : Ali Raza

Final EIA Drilling Kadanwari Block

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Final EIA Drilling Kadanwari Block

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ENVIRONMENTAL IMPACT ASSESSMENT (EIA)

Development Well Drilling and

EMC PAKISTAN PVT. LTD.

Rev. Date Issue, Modification Prepared Checked Approved

© EMC Pakistan Pvt. Ltd. 2022

Figure ES1: Field Survey Activities

The Environmental Impact Assessment study ensures that:

 A detailed Environmental Management Plan (EMP) is provided for sustainable operation

For the effective implementation and management of mitigation measures, an Environmental

Environmental Aspect Register

Table ES1: Environmental Aspect Register

Table ES1: Environmental Aspect Register

Table ES1: Environmental Aspect Register

Table ES1: Environmental Aspect Register

Table ES1: Environmental Aspect Register

Table ES1: Environmental Aspect Register

Table ES1: Environmental Aspect Register

Table ES1: Environmental Aspect Register

Table ES1: Environmental Aspect Register

Table ES1: Environmental Aspect Register

Table ES1: Environmental Aspect Register

2.6.9. Guidelines for Sensitive and Critical Areas .................................................... 16

3.4. Drilling Operation .................................................................................................. 32

4.6.1. Temperature .................................................................................................. 58

Chapter 8 ENVIRONMENTAL MANAGEMENT PLAN (EMP) ..................................... 126

8.16. Change Management Plan .............................................................................. 178

Annex – I Sindh Environmental Quality Standards (SEQS), 2016

Table 1.1: List of EIA Team Members ................................................................................... 8

Figure 1.1: Location of proposed Development well sites ...................................................... 2

Figure 4.21: Views of ecological footprints near well site 1 .................................................. 73

dB (A) Decibel (A) (Unit of Noise)

1.2. Project Proponent

1.3. Environmental Consultant

Figure 1.1: Location of proposed Development well sites

1.4. Eni Pakistan - The Proponent1

Eni operations in Pakistan

Corporate Social Responsibility

1.5. Scope and Objectives of EIA

 Alternatives to achieve the objectives are analyzed.

 Environmental Management Plan (EMP) for sustainable development and operation of

 Description of project activities

 Development of Environmental Management and Monitoring Plan

1.6. Project Categorization

environmentally sensitive (National Parks/Sanctuaries/Game Reserve), b) Areas of

1.7. EIA Methodology

Figure 1.2: EIA process overview

1.7.1. Collection and Review of Project activities

1.7.2. Review of Applicable Legislations and Guidelines

1.7.3. Secondary Data Collection

1.7.4. Field Data Collection

Figure 1.3: Field survey Activities

1.7.5. Impact Identification and Assessment

1.7.6. Recommendations to Mitigate Impacts

1.7.7. Framework of Environmental Management Plan (EMP)

1.8. Composition of this Report

 Chapter 1 gives introduction of project and overview of process;

 Chapter 2 contains an overview of applicable national regulatory requirements as well

 Chapter 9 concludes the EIA study and its outcome.

1.9. EIA Study Team

Chapter 2 Policy, Legal and Administrative

 Eni Pakistan HSE Policy;

2.2. Eni Pakistan HSE Policy

2.3. Institutional Setup for Environmental Management

2.4. Administrative Framework