TOR for EIA of

Coal Mill
in the Premise of the Existing
Cement Manufacturing
Factory of
Lafarge Holcim Bangladesh
Limited
at Sunamganj, Sylhet,
Bangladesh
 TOR for the EIA

1. INTRODUCTION

Lafarge Holcim Bangladesh Ltd (LHBL) has a cement manufacturing Plant at Chatak,
Sunamganj, Sylhet in which LHBL is using natural gas in their cement kiln for clinker production.
LHBL has been sourcing for alternative fuel source to reduce the use of natural gas since the
gas reserve of Bangladesh is depleting day by day.

Now LHBL has taken a plan to set up a coal crushing Mill to supply around 40 MT/hour (312000
MT/year) of pulverized coal for the cement kiln and a Coal storage (buffer stock) of 16,000 tons.
LHBL’s existing plant already has up to date Environmental Clearance Certificate from the DoE.
Now LHBL need to conduct the EIA study for the installation of Coal crushing mill in the premise
of their existing cement manufacturing factory.

2. LEGISLATIVE REQUIREMENTS

The proposed extension project of Coal Mill falls under the "Red Category" as per The
Environment Conservation Rules, 1997, which requires submitting the Terms of Reference
(TOR) for the Environmental Impact Assessment (EIA) to the Department of Environment of
Bangladesh (DOE) of the Proposed Project for EIA approval. This will have to be followed by
the submission of report on the Environmental Impact Assessment (EIA) of the Coal Mill in the
premise of the Existing Cement Manufacturing Factory of Lafarge Holcim Bangladesh Limited
project including detail Environmental Management Plan (EMP) to obtain Environmental
Clearance from the DOE for the power project.

The EIA shall be conducted on the basis of Department of Environment of Bangladesh (DOE)
guidelines.

3. OBJECTIVES OF THE EIA

The objectives of the EIA are to:

 Assess the existing environmental conditions in the project area, including the
identification of environmentally sensitive issues.
 Assess the proposed activities to identify their potential impacts, evaluate the impacts,
and determine their significance.
 Propose appropriate mitigation and monitoring measures that can be incorporated into
the design of the proposed activities to minimize any damaging effects or any lasting
negative consequences identified by the assessment pursuant to the most stringent
requirements under guidelines of DOE.
 Prepare an EIA report that conforms to the requirements of DOE.
4. SCOPE OF THE EIA

The EIA covers assessment of the physical, biological, and socioeconomic impact of the
following:

 Construction activities at the proposed site

 Relevant off-site construction activities
 Operation of the plant

5. REFERENCE GUIDELINES AND DOCUMENTS

While conducting the EIA the consultant has to make sure the compliance of following
guidelines and standards:

 All guidelines and standards as are practiced by Department of Environment (DOE)

6. APPROACH AND METHODOLOGY

The EIA is to be performed considering the following activities:

Project Data Compilation: A generic description of the proposed activities relevant to

environmental assessment is to be compiled with the help of the proponent.

Literature Review: Secondary data on weather, soil, water resources, wildlife and vegetation
were reviewed and compiled.

Legislative Review: Information on relevant legislation, regulations, guidelines, and standards

was reviewed and compiled.

Identification of potential impacts: The information collected in the previous steps is to be

reviewed and potential environmental issues identified are to be in relation to guidelines of DOE.

Baseline Data Collection: A field visit is advised to be conducted to collect primary data to
ensure establishment of proper baseline information. Terrestrial ecological and fisheries
baseline shall be prepared.

Impact Assessment: The environmental, socioeconomic, and project information are to be

collected to assess the potential impacts of the proposed activities. The issues among others
are to be studied included potential project impacts on:

 Groundwater and surface water quality

 Ambient air quality
  The ecology of the area, including flora and fauna
 Noise
 Local communities.
 Seismic Risk assessment and Climate Change Risk assessment

Wherever possible and applicable, the discussion covers the following aspects:

 The present baseline conditions

 The potential changes in environmental parameters likely to be affected by project
related activities
 The identification of potential impacts
 The evaluation of the likelihood and significance of potential impacts
 The defining of mitigation measures to reduce impacts to as low as practicable
 The prediction of any residual impacts, including all long-term and short-term, direct and
indirect, and beneficial and adverse impacts
 The monitoring of residual impacts.

7. Structure and Basic Content of EIA Report

The EIA report is expected to contain the following major elements (but not limited):

A. Executive Summary

This section describes concisely the critical facts, significant findings, and recommended
actions.

B. Policy, Legal, and Administrative Framework

This section is expected to cover the following aspects comprehensively:

 This section discusses the national, local legal and institutional framework within
which the environmental assessment is carried out. It also identifies project-
relevant international environmental agreements to which the country is a party.

C. Description of the Project

This section is expected to cover the following aspects comprehensively:

This section is expected to cover the following aspects comprehensively:

 The background of the Project
 Review of Existing EIA report
 The rationale of the Project
  Project’s major components;
 Drawings and maps showing the Project’s layout and components, the project
site, and the project's area of influence.

D. Description of the Baseline Condition

This section is expected to cover the following aspects comprehensively:

 Relevant physical, biological, and socioeconomic conditions within the study area. It also
looks into the current and proposed development activities within the Project's area of
influence, including those not directly connected to the Project.
 Under Physical condition there should be detail description of local geology, topography
and soil condition.
 While describing the meteorological condition, minimum and maximum temperature of at
least last five years including mean temperature map of Bangladesh has to be provided.
 Similarly, monthly and yearly total rainfall of last five years including Bangladesh
average rainfall map and humidity data of last five years of the project specific area are
to be provided.
 In addition, wind speed and wind direction of last five years of the project specific area
would be added.
 Cyclones and alignment of cyclones are to be provided with maps, figures, data and
information.
 Similarly, seismicity risk and flood risk have to be described with relevant maps, figures,
data and information.
 Ambient noise level at 06 locations (day & night) of the project site is to be mentioned
and value Leq is to be determined.
 While describing the ambient air quality, the concentration of PM2.5, PM10, CO, SOx
and NOx are to be mentioned for 4 locations.
 In case of 1 surface and 1 ground water quality, the amount of Physical parameters: pH,
Temperature, Conductivity, Turbidity and Colour; Chemical Parameters: Alkalinity, TDS,
TSS, Salinity, Oil & Grease, DO, Chlorides, Total Hardness, Calcium, Magnesium,
Sulphate, Fluorides, Nitrate, Iron, COD, BOD, Phosphate will be analyzed
 Soil quality will be analyzed for 1 location of Physical Parameters: Particle Size
Distribution, Texture, pH, and Permeability, Porosity, Electrical Conductivity, etc. as well
as Chemical Parameters: Nitrites, Nitrates, Phosphates.
 Information will be collected on traffic volume for roads and river connecting the project
site by conducting traffic volume monitoring at two locations (1 road + 1 river). The traffic
volume counts will be recorded continuously for 24 hours at one time during the study
period to assess the existing total daily traffic, peak hour traffic and traffic composition.
 In describing ecology, aquatic flora, aquatic fauna, terrestrial flora, terrestrial fauna and
forest as are available in the site and site area (5 km radius from the project site) are to
be described with photographs.
 In addition, vulnerability of Project site with respect to Climate Change impacts is to be
described in detail.
 A realistic list of endangered species including flora, fauna, plants and animals as are
available in the project site, project area or even project region has to be mentioned with
proper facts.

E. Air Quality Description Modeling

This section is expected to cover the following aspects comprehensively:

 In Air Quality Dispersion Modeling (AQDM) the consultant has to explain about the
rationale of his selected model.
 The model has to be AERMOD or any other US EPA approved well practiced model.
The modeling methodology is to be properly described.
 Ambient air quality standards of Department of Environment (DOE) and World Bank are
to be mentioned.
 The radius of AQDM will be at least 10 km
 Background air quality data and measured background concentration are to be properly
mentioned.
 Emission estimates and stack parameters are to be mentioned.
 With modeling results, summary of maximum ground level concentration (GLC) of SO 2,
NOx, SPM are to be mentioned.
 Based on the modeling results, overall impacts assessment of the Project are to be
described comprehensively.
 While, conducting AQDM, the trend of industrialization in near future (at least next 5
years) of the project area is to be considered.
 In this chapter, there should be six wind-roses of SOx and NOx representing the six
seasons in the project area.
 There should be a list of affected infrastructure, physical cultural resources and
neighborhood within 5 km radius considering the middle position of the project site at
center of the radius.

F. Modeling of Noise Levels

CUSTIC 3.2 software for noise pollution modelling is used for the assessment of the
noise propagation of this project. The CUSTIC Software allows us to create robust and
useful numeric simulations that fully make use of the graphical user interface, with a
certain security that the software CUSTIC 3.2 is one of the best tool, to carry out numeric
simulations of noise pollution.
 The cumulative impact from the stationary noise sources at proposed project site has
been predicted using the above model. It was found that the ambient noise is higher
than predicted levels therefore, due to the masking effect, an increase is not expected.

G. Anticipated Environmental Impacts and Mitigation Measures

This section is expected to cover the following aspects:

 Identification of the existing social and physical conditions that may be affected by
the construction of the Facility;
 Identification of the existing land, air, water, and solid waste environmental
conditions and parameters;
 Definition of the permissible environmental conditions and parameters applicable to
the Project, including legislation and regulation;
 Identification of the areas (if any) where the initial proposed design for the Facility
would not meet the required criteria;
 Identification of the permits and licenses required to comply with the environmental
requirements prior to, during and after construction and commissioning of the
Facility;
 Specification and design of the monitoring programs that shall ensure that the
Facility shall comply with current and anticipated future environmental standards.

The EIA shall address, but not limited to the following key impacts:

 Air Quality Impacts

 Soil and Groundwater Contamination
 Noise and vibration Levels
 Other mandatory parameters
 The EIA will identify sensitive receptors within the nearby area and undertake an
assessment of the cumulative impact on background noise levels. Both construction
and operational impacts will be considered.

H. Analysis of Alternatives

This section is expected to cover the following aspects comprehensively:

 Examines alternatives to the proposed project site, technology, design, and operation
including the no project alternative-in terms of their potential environmental impacts;
 Feasibility of mitigating these impacts;
 Capital and recurrent costs;
 Suitability under local conditions; and
  Institutional, training, and monitoring requirements.
 It also states the basis for selecting the particular project design proposed and, justifies
recommended emission levels and approaches to pollution prevention and abatement.

I. Disaster Management Plan

This section is expected to cover the following aspects comprehensively:

 A detail disaster management plan is to be described with possible sources, types and
natures of disasters associated with the project.
 Possible realistic impacts of the disasters on the project are to be depicted with relevant
facts, figures, data and information.
 At last, the disaster management process is to be formulated with tentative cost,
technology and others as relevant.

J. Information Disclosure, Consultation, and Participation

This section is expected to cover the following aspects comprehensively:

 Describe the process undertaken during project design and preparation for engaging
stakeholders, including information disclosure and consultation with affected people and
other stakeholders;
 Summarize comments and concerns received from affected people and other
stakeholders and how these comments have been addressed in project design and
mitigation measures, with special attention paid to the needs and concerns of vulnerable
groups, including women, the poor, and Indigenous Peoples; and
 Describe the planned information disclosure measures (including the type of information
to be disseminated and the method of dissemination) and the process for carrying out
consultation with affected people and facilitating their participation during project
implementation.

K. Grievance Redress Mechanism

This section describes the grievance redress framework (both informal and formal
channels), setting out the time frame and mechanisms for resolving complaints about
environmental performance.

L. Environmental Management Plan

This section is expected to cover the following aspects comprehensively:

 This section deals with the set of mitigation and management measures to be taken
during project implementation to avoid, reduce, mitigate, or compensate for adverse
environmental impacts (in that order of priority). It may include multiple management
plans and actions.
 It includes the following key components (with the level of detail commensurate with the
project’s impacts and risks)

(i) Mitigation:

a. Identify and summarizes anticipated significant adverse environmental impacts and risks;
b. Describe each mitigation measure with technical details, including the type of impact to
which it relates and the conditions under which it is required (for instance, continuously or in
the event of contingencies), together with designs, equipment descriptions, and operating
procedures, as appropriate; and
c. Provide links to any other mitigation plans (for example, for involuntary resettlement,
Indigenous Peoples, or emergency response) required for the project.

(ii) Monitoring:

a. Describe monitoring measures with technical details, including parameters to be

measured, methods to be used, sampling locations, frequency of measurements, detection
limits and definition of thresholds that will signal the need for corrective actions; and
b. Describe monitoring and reporting procedures to ensure early detection of conditions that
necessitate particular mitigation measures and document the progress and results of
mitigation.

(iii) Implementation arrangements:

a. Specify the implementation schedule showing phasing and coordination with overall
project implementation;
b. Describe institutional or organizational arrangements, namely, who is responsible for
carrying out the mitigation and monitoring measures, which may include one or more of the
following additional topics to strengthen environmental management capability: technical
assistance programs, training programs, procurement of equipment and supplies related to
environmental management and monitoring, and organizational changes; and
c. Estimate capital and recurrent costs and describes sources of funds for implementing the
environmental management plan.
 (iv) Performance indicators:

Describe the desired outcomes as measurable events to the extent possible, such as
performance indicators, targets, or acceptance criteria that can be tracked over defined time
periods.

M. Social Impact Assessment:

Socio-economic survey will be carried out with special focus on survey to carry out the
Social Impact Assessment (SIA). The survey will cover the basic requirement of the DOE. A
census will be completed among the decided number of households. Socio economic data
will cover the following but not limited:

 Population and community characteristics ( male, female, religion, profession and age
group)
 Land acquisition, Compensation and Resettlement issues, if any
 Physical and cultural resources (school, college, madrasa, mosque, temple, church,
vocational institute) within 1km of the plant site Health and safety facility Income
structure
 Access to education (literacy rate etc. number of student)
 Access to energy (percentage of electricity facility)
 Communication and transportation facility
 Physical cultural resources

Methodology for baseline socio-economic survey: As discussed in the ESIA baseline study
section.

N. Conclusion and Recommendation

This section provides the conclusions drawn from the assessment and provides
Recommendations.

8. Completion of Works

Necessary revisions, augmentation, deletions, additions are need to be done in order to

conform the final report as per requirements of the DOE and other lenders. The report will have
to be presented to DOE for the finalization and approval.
9. Duration

The draft EIA report will have to be submitted for review within 60 days of starting the
assignment. The final report will have to be submitted within 15 days incorporating all the
comments and suggestions of the Project sponsor.