PS 1 – Assessment and Management of Environmental and Social Risks and Impacts

MIP has an E&S policy in line with IFC Performance Standards (PS) and a certified Integrated Management System (IMS) based on ISO 9001:2015 (Quality), ISO14001:2015 (Environmental), OHSAS 45001:2018(OHS). Furthermore, the port meets the requirements of the International Ship and Port Facility Security Code. The IMS is comprehensive and include relevant operational procedures, covering equipment operation safety, emergency preparedness and response, ship unloading/loading, E&S requirements for contractors, hazardous material management, solid and hazardous waste management. MIP carries out annual audits to verify compliance with the IMS requirements. MIP will update the ESMS to include the new berth and a Change Management Procedure to capture any future project design changes (ESAP#1).

MIP has an in-house Environmental, Health and Safety (EHS) team who manages MIP’s port operations as well as oversight of the operations of other port tenants. For the expansion project, the company hired a project management team including a dedicated EHS specialist. During the construction phase, MIP’s team will supervise the contractor’s EHS activities and conduct periodic audits. Furthermore, MIP will commission a recognized construction supervision engineering firm to oversee all phases of the construction process including EHS aspects. The supervision engineering firm will also have a dedicated EHS team.

The local EIA for the expansion project was carried out in compliance with Turkish regulations and obtained approval in 2020. As part of this project, MIP has commissioned expert consultancy firms to undertake a set of supplementary studies aligned with IFC and EBRD E&S standards, including a SIA, a biodiversity habitat assessment and corresponding BMP,  CESMPs, a SEP and a LRP which altogether constitute as Supplementary E&S Studies (SEAS). The mitigation measures identified in the local EIA and SEAS will be implemented during the construction and operational phases of the project. The EPC contractor will develop and implement the project level construction E&S management plans (in line with the EIA and SEAS and MIP’s policies and procedures, and IFC PS and relevant WBG EHS Guidelines), as per the requirements included into the contract include i. Dredging Management and Monitoring Plan, ii. Traffic Management Plan, iii. Waste Management Plan, iv. OHS Management Plan, v. Emergency Preparedness and Response Plan, vi Biodiversity Management Plan, vii. Air and Noise Emissions Management Plan, and viii. Stakeholder Engagement Plan. The contractor will have a dedicated ESHS management team to manage the construction related EHS aspects. (ESAP#2).

E&S and other relevant permitting processes for various construction and operation phase activities are ongoing. As part of its ESMS, MIP will develop and maintain an E&S compliance register to document all applicable legal requirements, including that associated with relevant permits, licenses, registrations, and approvals. This register will also include requirements as defined by the EIA and SEAS and appropriate actions as described in ESAP#3.

The company has a documented operational emergency preparedness and response plan (EPRP), consistent with IFC’s PS. The contractor’s CESMP will include a construction phase EPRP in line with ESAP #2.

PS 2 – Labor and Working Conditions

MIP currently employs a total of 2112 direct workers and approximately 940 contracted workers. Women represent 5.45% of direct workers and 16.67% of management positions. Third party workers are employed in support tasks for main business operations and other service activities such as cleaning and security. The project will create an additional 500 permanent jobs for the operations phase and approximately 50 jobs for the construction phase.

MIP has HR policies, processes and practices that are in line with local labor laws and are largely consistent with provisions of IFC PS2, covering all aspects of employment including general principles related to freedom of association, training and development, equal opportunities, working hours, resignation, retrenchment, terminations, and prohibition of child and forced labor. The procedures also require non-discrimination and equal opportunity for its staff, contract staff, and contractor workers, as well as equal work opportunities for both women and men. All hiring and promotions are merit-based and no employment decisions are made on the basis of personal characteristics.

MIP respects freedom of association and workers have the right to form and join workers organizations and has a collective bargaining agreement with a union that is reviewed every three years (last one was signed on 1 January 2022). MIP has a formal worker’s grievance mechanism managed by HR department, however it requires an update to fully meet IFC requirements. Complaints can be raised by the workers through trade union representatives, on the intranet, in written and/or verbal communication to HR and via a dedicated phone line to the internal audit department. Contract workers in the port have access to the mechanism. All complaints are formally registered, and MIP is committed to handling every grievance on a fair and equitable basis. MIP does not employ anyone under the age of 18 years and employee’s age is verified and recorded during the recruitment process.

As per ESAP#4, MIP will update its HR policies and procedures in line with PS2 to i. provide information about trade unions and workers’ grievance mechanism to all new employees including contractors’ workforce, ii. revise employee and contractor contracts to include IFC PS2 requirements on labor, iii. enhance contractor monitoring and training on new management plans specific to the project, iv. update employee training documents to include PS2, gender-based violence and harassment (GBVH) and workers’ grievance mechanism, v. update workers’ grievance mechanism.

MIP maintains general OHS programs and its operations are managed generally in line with ISO 45001 standard and local regulations including identification of OHS risks, job hazard analysis, implementation of controls, and monitoring of working conditions and accident statistics. MIP undertakes task-specific risk assessments for all key jobs and tasks and identifies relevant risk mitigation measures. These are all documented in work instruction and standard operating procedures (SOPs) displayed throughout the facility. The training program including induction and annual refreshers are provided to all employees.

MIP is implementing a contractor management plan. Contractors working on site are required to have a permit to work system based on a risk assessment covering their tasks and work activities. Contractor and sub-contractor agreements include employment conditions and requirements to comply with MIP’s EHS requirements. For the construction phase of the project, in line with ESAP#2, EPC contractor will develop construction OHS management plan along with other construction management plans in accordance with the project’s E&S provisions and MIP’s policies and procedures. MIP will implement a monitoring program to ensure that contractor implements the respective management plans and follows IFC PS and relevant WBG EHS Guidelines as part of ESAP#5.

PS 3 – Resource Efficiency and Pollution Prevention

The operational phase of the project is not expected to generate significant amounts of direct emissions, waste or effluents, considering it mainly involves container off-loading, on-loading, handling, transport and storage within the port premises and managed consistently with the respective local regulations and IFC PSs and WBG general and sector-specific EHS Guidelines. Electricity and water are sourced from the grid, back-up diesel generators are available. MIP is undertaking efficiency measures to reduce resource consumption i.e., electric cranes, LED lightning.

Total GHG emissions (Scope 1 and Scope 2) associated with this project are estimated to be around 11,000 tons of CO2 eq. The key climate risks for the project are identified as sea level rise and extreme heat (under RCP4.5 and 8.5 climate change scenarios). Accordingly, the berth was designed with an allowance of 0.34 m for sea level rise considering the predicted increase in mean sea level between 0.43 m and 0.84 m by 2100 (which is considered a long-term impact). MIP has a stormwater collection and drainage system for the existing facilities. As part of the project, MIP will construct an effective drainage system for the new buildings and other facilities.  Going forward, as part of its ESMS, MIP will integrate climate risks to its risk screening & assessment procedure and management plans for identifying and addressing any climate-related risks for its operations including OHS related risks and flood risk management as per ESAP# 6.

The construction phase will generate short-term impacts related to the air quality, noise, seawater quality and sediment. In accordance with the local EIA, air and noise emissions, dredging and marine impact assessment, and the respective management plans. The EPC’s CESMP will include specific requirements to address those issues.

During the construction, the primary air emission sources (PM10, PM2.5) will be associated with dredging activities, vehicle movements (transport of materials and equipment) and earthworks, which will be controlled through implementation of the CESMP to be developed per ESAP#2. Air emissions modelling results showed no exceedance of WHO ambient air quality limit values. MIP will continue monitoring air emissions at its premises as per the existing ESMS, and, if exceedance occurs, MIP will take necessary mitigation measures i.e., use of shore power.

Container loading/unloading, vehicular traffic and cargo handling are the main sources of operational noise pollution. According to the baseline measurement program, noise levels are within the national limits and slightly exceed WBG EHS Guideline limit values for some receptors. Noise modelling studies indicate slight exceedance for one recreational receptor during both construction and operation and only at night. Based on the observations during the site visits and information provided by MIP, no significant adverse impact is expected as the recreational site is not actively used during the night. As per ESAP#7, MIP will undertake a study to identify and characterize the noise pollution within its premises based on which it will implement a Noise Management and Monitoring Plan in line with national regulations, GIIP and the WBG EHS Guidelines. The plan will include a noise monitoring program to periodically measure the noise levels in the sensitive receptors. MIP will provide trainings to lashers, crane operators and any other relevant staff to limit noise emissions while conducting their respective operations.

Within the scope of the project, around 3.3 million m3 capital dredging is expected to be extracted. All dredging works including removal, handling and disposal of the seabed material shall be conducted in compliance with the “Dredging of Marine and Inland Waters Regulation” issued by Turkish Ministry of Transport. MIP carried out a sediment measurement campaign for to be dredged area including inner basin adjoining to the berth, access channel and the disposal site and compared the sample test results carried out by an accredited laboratory with the international (i.e., Australian, Canadian and European countries) and Turkish guideline values. Test results confirm its formation and suitability for the dredging offshore.

The dredging will be performed in the same area that was dredged during the construction of the existing berth in 2013. The monitoring measurement results from the previous dredging activities showed no adverse impacts to the marine environment in the dredging, dumping site and surrounding. The baseline measurement results level for seawater quality at the port area and disposal area indicate no existing pollution. As part of this project, dredging of access channel up to 18.5 m, container berth docking area and turning basin up to 17.6 m and the west docking area up to 10 m will be required to allow for the safe entrance of larger vessels into the port. The container yard area will be reclaimed up to 3 m above sea level along the quay wall length of 880 m. The dredging works will generate about 3.3 million m3 of material and a total area of around 177,000 m2 will be reclaimed. While the option to reuse the dredged material for reclamation was evaluated, due to the poor engineering characteristics, it was found not suitable as filling material.  Analytical testing including heavy metals and polychlorinated biphenyls confirmed that the dredged material will not further contaminate the water column and disposal area sediment. Based on the results and multiple exchange with an independent expert, it was concluded that the dredged material is suitable for disposing off-site to Ministry of Environment and Urbanization designated offshore disposal area located around 5 km from the shore at a water depth of between 42-54 m. The disposal site has enough capacity and similar characteristics with to be dredged material.

As specified in ESAP#2, contractor will develop a dredging management and monitoring plan (DMMP) which will spell out the technical specifications considering the potential impacts identified especially with regard to protecting biodiversity with the guidance provided in the biodiversity risk assessment and management plan and other related management plans during the transport of the material in line with the permit conditions, IFC PSs and international good practices. The key mitigation actions while undertaking dredging activities will include but not limited to: a. combining trail suction  (TSH) barge and cutter suction dredger for to pre-cut soil that cannot be dredged by TSH; b. the dredged material will be hauled to the disposal area with a leakproof split hopper barge; c. the dredging activities in the approach channel and any area outside of breakwaters will not be undertaken between 1st of April and 30th of September during the breeding season of most fishes and migratory activities of marine turtles; d. the contractor will implement relevant controls to limit turbidity form the dredging activities; e. Turtle deflector (e.g. tickler chains) or similar devices will be used in case turtles are in the vicinity of dredger trailer and there will be a dedicated marine turtles observer staff onboard. Additionally, contractor’s DMMP will comprise of required monitoring and control measures including plume and water quality, biodiversity, navigational safety and specific targeted community engagement regarding dredgers.

The bulk of the wastes managed by MIP as port operator are those generated by ships and from its own operations. MIP has a license to store wastes on site on a temporary basis, after which the wastes are removed by licensed waste management contractors. Solid waste (e.g., plastics, scrap metals, wastepaper) and hazardous wastes (e.g., drums, batteries) are segregated effectively at the site and collected by licensed third-party contractors. Secondary containments were implemented to all waste oil or hazardous materials storage drums/containers.

Bilge water from the vessels is collected and treated on-site. The sludge is disposed by a licensed third-party contractor while the treated wastewater is discharged to the municipality sewage network for further treatment. Sanitary wastewater collected from the vessels by trucks and sanitary wastewater from the office buildings is discharged to the municipality sewage network. Wastewater sourced from canteen and wastewater generated in the workshops are pre-treated on-site (e.g., grease, oil, suspended solids) and discharged to the network for further treatment. Drainage systems are cleaned regularly. As part of the expansion project, the capacity of the waste treatment facility to collect wastewater from the vessels was increased by adding two new sludge tanks (35m3 each). Storm water drainage is collected in catch basins with oil-water separator. The water quality is monitored by yard inspectors and storm water runoff free of contamination is discharged to the sea.

Hazardous Materials Handling

Hazardous materials use during construction phase of the project will be limited. During operations, Hazardous materials are stored in the port’s maintenance yard and typically include oils, diesel fuel and degreasing agents used in maintenance activities, with secondary containment, and material safety data sheets (“MSDS”) posted nearby. Hazardous and flammable cargos, such as industrial chemicals, are stored in an open area within the port and handled in accordance with International Maritime Dangerous Goods Code (IMDG). Proper firefighting equipment is available. Refueling for the ships is provided by fuel companies under the supervision of Mersin Port Authority.

PS 4 – Community Health, Safety and Security

The EIA and SIA identified community health and safety related impacts during construction and operational phases (e.g., dust, noise, supply of drilling and dredging materials and truck movements), and potential impacts on recreational area use and possible community complaints particularly during the construction phase of the project.

MIP has a number of policies and procedures addressing various issues related to the management of community health and safety both on the premises of the port and in the nearby areas. These include traffic management, security services, emergency preparedness and response and hazardous materials management.

Traffic management

During the construction phase of the project, the main traffic impact will be associated with the transportation of materials from quarry for filling. The location of the existing quarry will be confirmed once the contractor for the project is selected and appointed. The impact assessment on community health and safety will be revisited once the quarry is selected and the required mitigation actions will be incorporated into the Traffic Management Plan which will be developed by the contractor in line with the EIA and SEAS (as part of ESAP #2).

For its operations, MIP established a scheduling system for pick-up and delivery of cargos to organize the traffic within MIP’s premises and minimize congestion and safety risks. Additionally, MIP developed a penalty system to encourage the implementation of road safety rules by truck drivers. Currently, there are four gates that are allowed for truck entrance. Based on the traffic impact assessment findings and MIP’s internal modelling assessments, the number of gates were found insufficient to accommodate the current and future truck traffic and the location of the gates needs to be changed to eliminate truck traffic on the highway. Hence, MIP decided to increase the number of gates for truck entrance and change the location of the some of the existing gates to shorten the waiting times and avoid entering to highway and directly entering to MIP premises. During the project construction, within the terminal, the internal truck traffic will be separated from the construction activities by using different gates and roads. The construction of the gates is expected to be completed by the end of 2023. Going forward, as part of its ESMS, MIP will continue monitoring the traffic related risks and effectiveness management activities within its premises and take necessary corrective actions to minimize any traffic related impacts and risks.

Construction nuisances for surrounding businesses

The non-residential public buildings at the first line behind the Ataturk Park are located in the east and around 400 m distance from MIP’s premises. Additionally, there are a few non-residential public buildings (i.e., port authority offices) located in the north and around 50 m away from the terminal. There are expected nuisances identified for park users and businesses due to noise, dust, increased construction traffic that will be managed through the CESMP that will be developed by the contractor as part of ESAP#2. Ataturk Park will not be used for construction or operations by the port.

Visual impacts

The perception of the local residents is that the Ataturk Park will be affected both during the construction and operation phases of the project. Based on the SIA findings, the main impact anticipated during the construction phase will be associated with the construction related nuisances which will be managed in line with the CESMP (as per ESAP#2). and the key operations phase impacts for the park users are expected to be   visual impacts. To understand the magnitude of the visual impact, MIP has provided photos, renderings, simulation of views from different parts of the park, and other visual information materials to showcase what the port will look like during operations. Based on the visual evidence provided by MIP, the landscape will not change significantly in nature as there will be expansion of an existing berth as part of this project. The eastern part of the Park will be more exposed to such visual impacts because it is located closer to the container storage area. MIP is committed to engage with local communities to provide further information and address any remaining concerns related to visual impacts as part of the communication plan set forth in the construction phase SEP.

Security

The private security company was contracted to undertake port security protection activities. The security company employs people with verified licenses to fulfil port security management in line with international security requirements for ports. HR policies and procedures are applicable to security personnel as per the contractor management procedure that cascades relevant E&S requirement to any contractor. The port underwent an international ship security audit in December 2022 and received a renewal of its ISPS certificate.

PS6 - Biodiversity Conservation and Sustainable Management of Living Natural Resources

The project is located on the Mediterranean coast of Turkey, where the terrestrial components fall within the Eastern Mediterranean conifer-sclerophyllous-broadleaf forests ecoregion of the Mediterranean Forests, woodlands and scrubs biome, and the marine section is part of the Mediterranean Sea bioregion (as designated by WWF).

Mersin Port has been in operation for some decades, and there is no terrestrial natural habitat that overlaps with the project. The marine components are in a mix of Natural Habitat composed of the Mediterranean infralittoral mud, and Modified Habitat, composed of the artificial breakwater rock and hard substratum, which have also been impacted by ongoing port operations. The project does not overlap with any Legally Protected or Internationally Recognized Areas either. However, some of the nearest protected areas include nesting beaches for two threatened sea turtle species whose migration routes in the Mediterranean basin pass through the project area.

Priority biodiversity values associated with the project include these two sea turtle species, Green Turtle (IUCN Red List – Endangered) and Loggerhead Turtle (IUCN Red List – VU), threatened fish and the Mediterranean infralittoral mud habitat. Threatened fish species were identified to occur in the area from previous records but not observed during project biodiversity surveys. IFC Natural Habitat No Net Loss (NNL) requirements will apply to these priority biodiversity values. The project has in place a Biodiversity Management Plan (BMP), which sets forth mitigation measures to avoid and minimize risks to priority biodiversity values and will be implemented under the supervision of the MIP’s appointed biodiversity specialists (ESAP#10).

The BMP includes measures to ensure impacts on priority biodiversity values are mitigated through avoiding dredging works during the migration seasons of the sea turtles in April and August-September, avoiding direct discharge into the marine habitat and turbidity from dredging activities, and monitoring sea water quality periodically. Along the access channel where construction works will be undertaken, PS6 requirements will be achieved through implementation of GIIP as also outlined in the project’s CESMP, DMMP and related procedures to be implemented as part of the dredging contractor’s management plan, i.e. if sea turtles approach the construction areas In addition to avoiding sea turtle migration periods, the dredging contractor will monitor the marine habitat for presence of individuals to avoid their interference with construction areas.

Underwater noise and vibration are expected to occur due to pile driving, filling, and dredging activities during construction phase, and vessel activities during operation phase. To minimize impacts related to underwater noise and vibration, pier piles will be selected in line with GIIP implementing low noise/low vibration methods, filling will be done by a ramp at water level and right after dredging to ensure no impact on sea turtles during their migration season. During the operations phase of the project, MIP will continue to monitor the port area for presence of sea turtles to avoid vessel strikes and have port users to take necessary measures to reduce collision risk through adjusting vessel speed especially during the migration seasons of the species.