Key issues associated with this project include assessment of social, environmental, health and safety impacts including site selection process and cumulative impacts; management of these impacts during construction and operations; maintenance dredging and dredge spoil disposal during construction and operations; dust emissions control; storm-water management; liquid, solid and hazardous waste disposal; oil/hazardous materials storage and handling; employee health, safety and training programs; emergency response planning and preparedness; and impacts on biodiversity.
PS1: Social and Environmental Assessment and Management System
As noted above, PIBT commissioned an independent ESIA in 2010. The ESIA was carried out against the requirements of all relevant Government of Pakistan laws and regulations, as well as those of IFC’s Performance Standards, World Bank Group Environmental, Health and Safety (EHS) guidelines, and applicable international treaties and conventions (see Chapter 2 for a complete list of the reference standards/legislation). Consistent with good international impact assessment methods, the ESIA contains an alternatives analysis, a detailed baseline assessment based on both historical data as well as information obtained from recently conducted field work; as well as a robust stakeholder consultation program (see Chapter 6).
The analysis of E&S impacts covers all elements of both the construction and operational phases of the project. It includes a highly detailed Mitigation Matrix (see Table 8.1 in the ESIA) and Environmental Management Plan (EMP; see Table 8.4 in the ESIA). PIBT has agreed to carry out all of the activities presented in the Mitigation Matrix, and to implement the EMP in full. Comments at the public hearing for the project in October 2011 noted that the EMP was extremely detailed but that execution would require regular monitoring. PIBT is in the process of finalizing an EMP implementation plan for construction, which will assign responsibility for each task to particular members of the construction management team and will specify the frequency with which specific monitoring and reporting activities will be undertaken. For several items, such as the mangrove reforestation program and monitoring of impacts to the marine environment that might affect fish stocks, PIBT has agreed to establish joint monitoring committees, as described under the Biodiversity Conservation and Sustainable Natural Resource Management and Community Engagement sections below.
As noted, since 2003, PICT’s environmental and social performance has demonstrated that its activities comply with applicable Pakistan laws and regulations, and WBG requirements. PICT has adopted an Integrated Management System (IMS) to oversee quality, environmental and health and safety, for which it has obtained certification from Det Norske Veritas (DNV) against ISO 9001:2000, ISO 14001 and OHSAS 18001 respectively. The same system will be used by PIBT to manage the proposed bulk terminal at Port Qasim. HSE performance during construction will be managed jointly by PIBT, its EPC contractor and the local construction JV partner. Consistent with good industry practice on large construction sites, PIBT’s HSE team will hold weekly project progress meetings, including a thorough review of HSE performance at all job sites. PIBT has confirmed that it will engage a full-time safety officer and environmental coordinator with responsibility for all safety and environmental matters once the terminal commences operations. As is the case for its existing operations at Karachi Port, the role of the Safety and Environment Officers will be clearly defined within the PIBT organizational structure, including a detailed written job description and clear reporting lines to senior management. Consistent with its management system for the Karachi Port container terminal, all employees and contractors engaged in the operation of the bulk terminal will be trained on the key aspects of the IMS, which will be posted throughout the facilities and made available to staff and other stakeholders in both English and Urdu. PIBT will engage a third party to carry out regular environmental monitoring of key parameters, including potential impacts on sensitive receptors such as mangrove forests, as described below.
PS2: Labor and Working Conditions
Once operational, the bulk terminal will operate on a 24 hour basis, seven days a week, 365 days a year. The staff complement required to operate the terminal – including both direct employees and contractors – will number 250-300 over three shifts. PIBT will utilize the same Human (HR) policies and procedures as are employed at PICT. An HR department will be established to oversee all aspects of employee recruiting, hiring, training, evaluation, remuneration and promotion. The HR policies and procedures will be identical to those in place at PICT, which conform to all relevant requirements of IFC’s PS2, including establishing, maintaining and improving employee-management relations; allowing for the formation of worker’s organizations if these are desired by its employees; promoting fair treatment, non-discrimination and equal opportunity of workers; ensuring compliance with national labor and employment laws; promoting safe and healthy working conditions; protecting and promoting the health of workers; and establishing a mechanism that allows employee grievances to be articulated and addressed, as and when they may occur.
Given the nature of port and terminal operations, a key element of PIBT’s HR program will be management of health, safety and environment (HSE), during operations but especially during the construction period, which is expected to take at least 30 months with a peak labor force of 1,500 workers, including PIBT employees and the labor forces of the EPC contractor and subcontractors. PIBT has awarded the EPC contract, and the construction will be undertaken by a joint venture (JV) comprising of a foreign EPC firm and Pakistani construction contractor.
The EPC contractor will prepare and distribute an HSE Handbook in English, Urdu and other languages as needed depending on the nationalities of the on-site workforce. The EPC contractor, with oversight from PIBT’s HSE management team, will conduct weekly safety briefings for all construction supervisors, provide training for all on-site workers including vehicle drivers, and provide all requisite personal protective equipment (PPE) to contractor and subcontractor workers. With respect to HSE training and performance, no distinction will be made between PIBT employees, the EPC contractor workforce and sub-contractor labor. It is expected that the EPC will employ some foreign nationals, largely as skilled laborers and in supervisory positions, and the Pakistani JV partner will oversee the hiring of the local labor force. As it has at its Karachi Port operations, PIBT will give preference to local residents in hiring and training semi-skilled and unskilled labor. Expatriate workers will be accommodated in on-site housing equipped with adequate sanitation facilities and centralized cafeteria facilities. PIBT has confirmed that the practices set forth in IFC’s Good Practice Note (GPN) on Workers Accommodation will guide development of all on-site facilities for the resident work force during construction. In addition, PIBT has confirmed that all of the specific activities presented in the Mitigation Matrix and EMP related to establishment and maintenance of labor camps will be adhered to in full.
During operations PIBT will follow an HSE program for the bulk terminal that is identical to that in place at PICT. The HSE system has been developed to ensure the workplace safety of all employees and on-site contract workers and includes pre-employment and periodic medical evaluations, provision of PPE, and regular training in hazards, safe work procedures, and emergency response activities. As is the case at PICT, the Project Company’s HSE team will provide induction training to all staff working on the premises (both employees and contractor’s employees), hold daily safety briefings for all units, and require contractors to provide requisite PPE to their workers. An interdepartmental Safety Committee, including staff from the HSE, Administration, Security, and Engineering departments, will be set up to review practices and performance on a monthly basis. Policies and supporting documentation (i.e., a detailed health and safety manual) for PICT’s HSE program have been provided to IFC during previous site visits. As has been done for PICT’s Karachi Port container terminal, PIBT will implement systems for measuring, monitoring and reporting on lost time injuries (LTIs) on a monthly basis.
PIBT has confirmed that it will comply with all Pakistani labor regulations and standards during both construction and operations, including those relating to employment of minors. The minimum age of employees at all of its operations will be 18 years of age, a policy that will extend to all contractor employees and casual workers. Security staff are required to check the national identify cards of anyone entering the terminal premises to verify that they are 18 years of age or older.
PS3: Pollution Prevention and Abatement
The ESIA includes a very thorough analysis of potential pollution impacts to all media during construction and operation, as well as detailed measures required to mitigate, manage and monitor these impacts. Key aspects are described below.
Air emissions
The independent ESIA consultant commissioned a baseline air quality survey at the proposed project site and immediate vicinity. The results, which are presented in full in the ESIA, indicate that ambient levels for all primary pollutants are within the limits of both the Pakistan National Environmental Quality Standards (NEQS) as well as international ambient air quality standards. Air emissions during construction will occur primarily as a result of earth moving activities and vehicle traffic. The Mitigation Matrix/EMP includes extensive measures for controlling these emissions, including use of appropriate dust suppressions methods and use of generators that conform to host country and WBG EHS guideline limits.
During operations the terminal will obtain electricity from a captive 10MW heavy fuel oil fired substation, until such time as connection to the national grid is possible. PIBT is also considering use of natural gas as fuel for the substation, as and when supply is available. The power plant is being designed to meet all host country and WBG emissions guidelines. The other main source of emissions during operations will be from the bulk commodities (coal, clinker, cement) that the terminal will handle, including during transfer of coal by conveyor over the trestle to the coal yard; transfer of cement from silos to ships, and movement of clinker from vehicles to the clinker yard and from the clinker yard to ships. These operations will generate particulates as well as gaseous pollutants including aerosols, greenhouse gases (including CO2) and nitrogen oxides. The ESIA utilized air dispersion modeling to simulate the physical process of dispersion from these sources and identify potential high impact areas. The purpose of the dispersion modeling exercise was to estimate ambient ground level concentrations of particulates and other contaminants. The results identified mitigation measures needed to control emissions from coal, clinker and cement cargoes, especially during period of high wind. The most important of these will be dust suppression by water sprinkling via a mechanized stockpile water spray method designed to be effective in high wind conditions. PIBT has included this suppression equipment in the terminal design. Emissions of carbon monoxide (CO), nitrogen oxides (NOx), sulfur oxides (SOx), particulates (PM10 and PM2.5) and suspended particulate matter (SPM) will be monitored and reported monthly to SEPA and summarized in PIBT’s annual E&S monitoring report to IFC.
An additional consideration for bulk cargo terminals relates to the presence of coal dust in silos or storage yards. As noted in the ESIA, it is essential that large volumes of coal stored at the terminal site not be allowed to become dry, as such conditions can result in a spontaneous fire or explosion. The ESIA further notes that pollution control for coal stockpiling must be achieved by mechanized water sprinkling equipment. Given the importance of this system to minimize the likelihood of a major explosion or fire incident, PIBT has engage a specialized consultant to prepare a report on this component of the project design to ensure that it conforms to global best practice for the industry and takes account of the climatic conditions prevalent in the Port Qasim area. Submission of detailed design and management system for managing explosion and fire risks to IFC’s satisfaction will be a condition of disbursement of IFC funds.
Wastewater management and impacts on the marine environment
The ESIA concluded that potential impacts from waste water discharges on both the terrestrial and marine environments can be effectively addressed by implementing well established management practices during both construction and operation. These are enumerated in the Mitigation Matrix.EMP that PIBT has agreed to adopt. During construction the most significant potential impacts are release of soils to the marine environment from earth moving activities, spills or leaks of contaminants that migrate to the sea or leach to underground water sources, discharges of domestic waste sewage, and disposal of dredged material. To manage these impacts the EMP requires (1) daily oversight of heavy machinery and equipment at all construction areas to prevent erosion runoff, especially during the rainy season; (2) installation of septic tank/soak pit systems at all worker accommodation sites; (3) controlled storage and use of hazardous materials, appropriate disposal of wastes and a detailed spill prevention plan/training to prevent and respond to spillage of such material/wastes; and (4) daily monitoring of dredge material disposal at a designated site to ensure that dredged spoils do not spill back into the marine environment. PIBT will include clauses in the EPC contract and subcontracts requiring that all items in the Mitigation Matrix/EMP be included in the contractors’ standard operating procedures (SOPs). The contracts will also stipulate that contractors must prepare and implement an effective emergency response and clean-up plan throughout the construction period.
During operations, PIBT will rely on the provisions of its IMS for preventing pollutant discharges. As there is currently no municipal sewage treatment plant at Port Qasim. PIBT will install a waste water treatment facility to treat domestic waste water to levels that meet both Pakistani regulations and WBG EHS guidelines for effluent discharge. Sludge generated by this new facility will periodically be removed by a licensed waste removal contractor. As is done at PIBT’s Karachi Port facilities, oily wastewaters generated from the maintenance workshop and other areas will be discharged to a dedicated oil/water separator. Solid and hazardous wastes generated by the workshop along with any oils recovered during separation will be collected by a licensed contractor and properly disposed at approved government-operated landfills or by authorized recyclers. Relatively small amounts of hazardous materials – paints, solvents, and petroleum lubricants – will be stored and handled in the workshop areas. Fuel tanks for standby power generators will be equipped with appropriate containment features to prevent spills from being released to the environment. Storm water will collected separately from the various operating areas of the terminal and uncontaminated runoff will be directed to the harbor via outfalls.
Solid waste management and disposal of dredge spoils
Solid waste collection and disposal during construction and operations will be handled in accordance with the same procedures in place at PICT, which meet both host country and WBG EHS guidelines. The most significant solid waste management issue in the context of this project will be the effective management of dredge spoils from construction and maintenance dredging during operations. Under Pakistani regulations routine dredging, as well as disposal of all construction-related dredge spoils is the responsibility of the port authority (in this case, PQA) in accordance with a Master Plan developed to guide such activities. The ESIA notes that the long term disposal of dredging spoils at Port Qasim, which has been ongoing since the mid‑1970s, is being independently monitored by the Hydraulic Research Laboratory in the UK. To date no significant impacts from disposal have been reported. The ESIA notes that dredging associated with the berthing pocket required for the development of PIBT will be much less significant than the routine maintenance dredging of the navigation channel that is carried out regularly by PQA. It concludes that impacts of this dredging will be confined to the immediate site and can be managed by an effective management and monitoring program that meets good international industry practice.
The ESIA also notes that PIBT intends to use much of the soil obtained from dredging and excavation as fill for other construction activities, provided that soil testing confirms that the dredged/excavated material is suitable for such use. If testing indicates that the spoils are contaminated, they will be disposed at the site designated by PQA, located opposite the FOTCO Oil handling area (see the attached PQA Master Plan which indicates the designated PIBT disposal site in yellow). Where disposal is necessary, the Mitigation Matrix presents a number of measures PIBT will undertake to prevent migration of this material to the marine environment including (1) construction of protective bunds around disposed materials, (2) monitoring of haulage activities to prevent spillage, and (3) protection of fill slopes against erosion using sand bags as a temporary measure until permanent protection can be constructed.
Emergency Preparedness and Response
PQA provides port-wide fire-fighting and emergency response services consistent with international maritime conventions (MARPOL 73/78). Additional services provided by PQA include harbor oil spill response and clean-up, harbor water quality monitoring, and vessel surveillance and inspection. PIBT will coordinate with PQA in responding to incidents that occur on terminal property. As it has done at Karachi Port, PIBT will develop its own emergency plans and procedures and acquire the necessary equipment for preventing and combating any spills, fires and accidents that occur within the terminal in the course of normal operations. PICT has experienced only minor incidents – small equipment fires, oil and chemical spills – at its Karachi Port operations over the past several years, all of which were properly responded to, contained and investigated. PIBT will adopt similar emergency response procedures that include appropriate personnel training in emergency response for all employees, quarterly fire drills, and joint exercises with the local fire brigade.
All of PIBT’s operations will take place within the Port Qasim footprint, which is located in the industrial zone of Western Port Qasim. There are no residential areas within the immediate vicinity. PIBT’s security and emergency response efforts will be developed to take into account the proximity of other facilities and structured and implemented to ensure that its premises and normal activities do not pose a risk to any of its neighbors. PIBT will participate in a forum of private sector companies with terminal operations within Port Qasim, including the Essar Bulk Terminal Ltd. (EBTL), Fauji Akbar Portia (FAP) grain storage terminal, Liquefied Cargo Terminal, Sui Southern Gas Company (SSGC) Pakistan LPG terminal, Fauji Oil Terminal (FOTCO) oil handling facility, Qasim International Container Terminal (QICT) and Pakistan Steel. The forum shares information and resources on shared issues such as security and emergency response best practice, and is available to provide backup support to each other’s facilities and to PQA in the event of a large scale emergency or security incident.
PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources
Given the location of the terminal facilities in a marine/estuarial environment, potential impacts on the receiving environment was a key consideration in the ESIA. As part of the baseline studies EMC carried out a survey of the marine ecology in the area, aimed at characterizing the mangrove ecosystem, marine organisms and their habitats, bird fauna of the creek system and the ecosystems that they inhabit. The findings of these baseline surveys were considered against the potential risks and impacts that could result from the bulk terminal development, in particular impacts on the marine flora and fauna of the mudflats that would require special management during the development and operation phase of the Project.
Results of the baseline survey indicate that Avicenna marina is the dominant species of mangrove in the Indus Delta. In the microenvironment of the project area (i.e., the Kadiro Creek system) that was studied, there are significant mangrove forests on the northern and southern banks of the Phitti Creek with dense, mature populations (estimated at between 50‑60/100 m2) of Avicenna marina at the project site.
The ESIA estimated that construction of the 2.4km trestle bridge will require removal of approximately 450 mangrove trees. To address this impact, the EMP requires PIBT to reforest the area at a rate of four trees for every one removed. PIBT has already entered into an agreement to carry out the mangrove forest rehabilitation program in collaboration with the Karachi branch of the International Union for the Conservation of Nature (IUCN) and the Sindh Forest Department. Once the reforestation efforts are completed, PIBT, the IMC and IUCN will continue to undertake joint monitoring of the mangrove forests in the vicinity of the terminal, and specifically the reforested areas, during both the remainder of the construction phase and once the terminal is operational. The IUCN scientist designated to take part in the reforestation effort and post-reforestation monitoring attended the public hearing to describe these efforts in detail and confirm IUCN’s support for these efforts.
