The proposed brownfield expansion entails only purchase of equipment which will be within the premises of the existing container terminal with no land acquisition involved and no major construction activities envisaged. An existing empty yard of 51,600 sqm has been taken on lease from DPT, exclusively for stacking the empty units and minor construction activities will be involved for development of the yard (essentially including paving the surface, laying storm water drainage line, providing an access gate and installation of electrical poles and lighting). There is no capital dredging required on account of the project nor is any maintenance dredging undertaken/required within the scope of KICT. If any dredging occurs in future, it would continue to be responsibility of DPT to dispose of dredged materials at designated and approved offshore disposal site. Hence involuntary resettlement (PS5), biodiversity impacts (PS6), impacts on Indigenous Peoples (PS7) or cultural heritage (PS8) are not expected on account of the project and its operations.                                                   

The project primarily involves purchase of equipment to increase the capacity of the container terminal; key risks and impacts will therefore be limited within existing premises of KICT and the project is not expected to result in any new significant adverse E&S risks and/or impacts. Accordingly, this is a Category B project as per IFC’s Policy on Environmental and Social Sustainability and key risks and impacts are limited, largely reversible and can be avoided or mitigated by adhering to generally recognized performance standards, guidelines or design criteria. Further, it is possible to readily design and implement engineering and management measures to mitigate the limited risks and adverse impacts. 

Key E&S issues related to the project and reviewed at appraisal are: the company's management and monitoring systems to assess and manage E&S risks and impacts from its operations; assurance of fair, safe and healthy working conditions for employees and contracted workers in line with the legal and PSs requirements and consistent management of occupational health and safety (OHS) policies and practices; monitoring and management of air emissions, waste and wastewater and hazardous materials; emergency response preparedness and response including that for COVID-19 pandemic and community engagement activities related to E&S  commensurate to the risks and impacts associated with the company's operations.                                                     

KICT has developed and implemented an integrated management system (IMS) as per ISO 9001:2015, ISO 14001:2015, and ISO 45001:2018 (the new standard on Occupational Health and Safety Management Systems that has superseded the OHSAS 18001:2007). KICT has also implemented a security management system (SMS) certified to ISO 28000:2007 standards. KICT will extend its existing IMS and SMS requirements to the project.

KICT has adopted both the quality, environmental, occupational health and safety (QEHS) policy and the security management policy of the Group. A QEHS manual and occupational health and safety management system (OH&SMS) manuals have been developed which include detailed procedures for ensuring compliance with applicable legal, regulatory and other requirements; Hazard Identification and Assessment of Risk and Opportunity (HIARO); performance measurement and monitoring; communication (internal and external); incident investigation and root cause analysis; safety, including safety guidelines for contractors; emergency response procedures; internal audit mechanisms and management review. KICT has, as part of the process for development and implementation of the IMS, undertaken a comprehensive assessment of environmental, occupational health and safety risks and impacts from its operations, and has put in place operational control procedures to mitigate the identified risks and impacts. KICT has also developed a procedural manual encompassing procurement systems, operation systems such as vessel operations, yard operations, rail operations and bunkering operations.

As included in ESAP # 1, KICT will: (a) include the requirement of meeting IFC Performance Standards in KICT’s ISO 14001 and ISO 45001 certified EHS management system and upgrade and align its Standard Operating Procedures/work instructions to the GIIP of the relevant and applicable sections of the IFC EHS Guidelines; (b) implement a stakeholder engagement and grievance redress procedure in accordance with IFC Performance Standard provisions; (c ) update the legal register capturing all applicable EHS and labor requirements for the  operations along with a provision of setting a compliance register for  periodic monitoring of compliance status; and (d) develop contractor management plan with detailed procedures to monitor, audit and document contractor compliance with company’s requirements.

KICT has in place valid consent and authorization from Gujarat Pollution Control Board (GPCB) for its current operations and will obtain appropriate regulatory consent from GPCB for capacity expansion, prior to commencement of project. In accordance with the regulatory requirements, an environmental impact assessment (EIA) was carried out for berth 11 and 12 prior to start of the construction in the year 2002-2003 (much before KICT took over the operations). For the proposed expansion, there is no need to update the EIA.

For the proposed yard development entailing minor construction works such as paving, laying storm water drainage line, providing an access gate and installation of electrical poles and lighting, KICT will implement the mitigation measures detailed in the ESDD report. Further, KICT will, as mentioned in ESAP # 2, contractually require the EPC contractor to develop and implement a construction phase EHS management plan aligned with IFC Performance Standards and the IMS manual for the proposed yard development. 

KICT has a well-articulated and detailed organization chart with clearly defined roles and responsibilities and reporting lines for staff managing EHS issues. There is a designated deputy general manager QHSE, who reports to the terminal head and is supported by four safety officers, one trainee and one documentation officer. The company has a structured EHS training program covering aspects such as health and safety, first aid, fire safety and vehicle safety and training is provided to all staff including contractor workers.

Based on the identified hazards and risks, an on-site emergency preparedness and response plan has been developed which includes details of key personnel and their responsibilities; details of site plan indicating emergency control center, assembly points and emergency exits and emergencies and response procedure (for various scenarios including fire, flood, cyclone, earthquake, epidemic and terrorist attack). KICT has developed a COVID management plan and all employees and contracted workers are trained on COVID protection measures.

Environmental monitoring is governed largely by the permit requirements and is undertaken for ambient air quality, stack emissions, ambient noise and treated wastewater quality. In addition, water and energy consumption are regularly monitored for internal benchmarking and reporting to management on monthly basis. The monthly reporting to management also includes details of OHS indicators such as lost time incidents (LTI), first aid cases, near miss and HSE events and details of QHSE audits and emergency drills carried out.                                                     

KICT has a total workforce of 457 of which 187 (including 10 females) are direct employees and 269 are contracted workers provided through manpower agencies with whom KICT signs a contract. The contracted workers are engaged by KICT in terminal operation and maintenance, housekeeping and horticulture activities. The number of employees and contracted workers is expected to increase on account of the project to about 219 and 287 respectively.

The company has Human Resources (HR) policies and procedures that apply to the direct employees and includes information on: leave, attendance, code of conduct, working hours, holiday, maternity benefit, medical benefits, provident fund (PF) and other applicable allowances and gratuity. The company has various policies in place such as sexual harassment policy and prevention of child and forced labor policy. For ensuring a safe workplace for women, a sexual harassment committee has been formed at the corporate level with the company’s Vice Chairman being the head of the committee and including a female representative. 

KICT requires its contractors to adhere to all applicable labor laws including prevention of child labor and forced labor. Going forward as included in ESAP#3, the company will: (a) develop and implement an action plan with measures required to address the identified variances with respect to applicable labor law provisions for both employees and contracted workers and including those pertaining to: working hours, overtime, maintenance of records and display of provisions of applicable labor laws; and (b) implement appropriate  procedures to periodically review and audit compliance with applicable labor laws.

Terms of employment is also conveyed in the appointment letter which KICT provides to each employee. KICT as part of its HR policies and procedures adheres to non-discrimination and equal opportunity policy. the company has no plans for retrenchment: the project will result in expansion of KICT’s operations, which in turn will result in the employment of more workers.

There is no existing workers’ union although the company has neither formally nor informally restricted formation of labor unions. As included in ESAP item#4, the company will update its HR policy and include: (a) the provision for right of employees to form and join unions; (b) update the retrenchment plan; and (c) update the existing grievance redress policy, all meeting IFC PS 2 requirements.  In particular, the grievance mechanism will strengthen the process by detailing it and clarifying the various channels through which a complaint can be filed, laying down time bound steps for redress of the complaints and provisions for appeal to a higher authority in the event the complainant feels the concerns have not been resolved. The grievance mechanism will be accessible to all workers including contracted workers engaged in terminal operation and maintenance, will enable employees to raise anonymous complaints and will have provisions for protection of confidentiality and non-retribution. KICT will maintain grievance records and will monitor redress of grievances.

The company has, as part of the OHSMS, undertaken hazard and risk assessment for each key activity and, based on the outcomes of the assessment, developed safe operational procedures. The company has in place a safety committee comprised of both worker and management staff, which meets every month. Mock drills are conducted, opportunities for improvement identified and corrective measures implemented.

The facility has implemented a permit-to-work system for routine and non-routine operations and has organized regular training program, toolbox talk for both employees and contracted workers on H&S aspects. Usage of personal protective equipment (PPE), safety signage, vehicle speed and movement plan on the terminal were presented by the company and noted to be adequate during the review. Health check-up are conducted once a year for workers/employees above 40 years and once in two years for worker/employee below 40 years.

Within KICT premises, there is one first aid facility. The first aid center is equipped with three trained and certified paramedic staff. KICT has a safety training program to ensure that all employees and contracted workers are properly trained in the relevant hazards, fire and other safety procedures and emergency response. Training modules have been developed and cover 31 topics such as engineering safety, vessel safety, EHS policy, PPE, types of emergency, etc. Truck drivers entering the terminal are provided induction on safe procedures to be followed. Accident, incident and near misses, including those involving contracted workers, are recorded, investigated, and reported and corrective action implemented. There have been no lost time incidents at KICT terminal in the last three years. First aid cases and near misses are duly reported.

For ensuring compliance to safety requirement, KICT conducts regular monthly meetings and safety performance check for all contractors. A checklist for evaluation of contractor’s safety performance is in place and includes aspects such as provision of PPE, availability of supervisors, awareness of emergency response plan (ERP) and emergency exits/evacuation procedures and training undertaken on HSE aspects. As included in ESAP # 1, KICT will develop a contractor management plan with detailed procedures to monitor, audit and document contractor compliance with national requirements and IFC Performance Standards.                                                  

Pollution prevention and abatement aspects of relevance for KICT operations include: management of emissions to air from terminal equipment and transport vehicles; management of discharges on land or surface water including storm water, sewage, spills and other terminal waste; and emergency response planning and preparedness. There is no capital dredging required on account of the project nor is any maintenance dredging undertaken/required within the scope of KICT.

Primary source of electricity is the grid but two diesel generators (DG) are in place as backup power (625 KVA and 1250 KVA capacities respectively). As included in ESAP #5, KICT will ensure installation of stacks with proper height for DG Sets.

KICT is planning to install roof top solar power of 300kV in order to reduce their energy consumption from the grid. Two underground diesel storage tanks each with 20 kiloliter (KL) capacity and a fuel dispenser unit have been installed at the site by Indian Oil Corporation Limited (IOCL) at a dedicated fuel storage area and with valid license from Petroleum and Explosives Safety Organization. KICT requires vessels to ensure that all safety and spill prevention measures are in place during bunkering of the vessel.

The terminal handles on an average 30-40 vessels in a month. Daily movement of truck is in the range of 1000-1200 and 26 internal transport vehicles (ITVs) are operated and the terminal has parking space for 250 trucks/trailers. It is expected that seven more ITVs will be added to the fleet after expansion. .

The DG set emissions (particulate matter, sulfur dioxide, oxides of nitrogen) meet both national standards and IFC emission guideline values. Suspended Particulate Matter, Respirable Suspended Particulate Matter (PM10), SO2, NOx and ambient noise levels are within national standards. While significant impact on ambient conditions is not expected on account of the project, the company will continue to implement procedures to ensure that: (a) all equipment operated by the terminal are properly maintained and their emissions are within national standards and IFC guideline values; (b) trucks entering the terminal premises have appropriate pollution under control certificates; and (c) truck dwell time (particularly engine idling time) is minimized. The company will put in place procedures to ensure that refrigeration gases used in the reefers meet national ozone depleting substances rules requirements under the Montreal Protocol.

The total water requirement for the day-to-day operation of the terminal is estimated to be around 52 kilo liters which is sourced from private tankers and is mainly for domestic usage. The primary liquid effluent generated on the terminal is domestic wastewater/sewage, which is treated on site. Two Sewage Treatment Plants (STPs) with capacity of 5 KLD and 10 KLD have been provided and only the 5 KLD STP is currently operational while 10 KLD STP is kept as a standby for the new administrative building which is still under construction. Treated water from the STP and is utilized for gardening purposes and the sludge generated is kept in a designated open space and handed over to the municipal authority for disposal.

Domestic waste/garbage generated on the terminal is collected by authorized municipal contractors and disposed of at municipal bins or approved government-operated waste facilities. Stormwater from the berth area is collected in a chamber after passing it through oil & grease traps and then discharged through a 900 mm diameter pipe into the sea. The stormwater run-off from the scrap yard which has oil & grease and other hazardous waste is collected in an oil & grease separation pit associated with the stormwater network before the final release.

Ship/vessel generated waste, including bilge water, is collected by authorized entities from the vessels and removed to an offsite location for treatment and disposal. As included in ESAP#6, KICT will improve the hazardous waste management, storage and handling practices and provide for a contained storage on paved surface with provision for leachate collection drain and sump. KICT will ensure segregated storage for hazardous and non-hazardous waste and hazardous waste quantity to be recorded.

Greenhouse gas emissions for the year 2020 were 4670 tCO2e per annum and they are expected to increase to about 5400 tCO2e per annum after proposed expansion.                                                    

KICT is located within the DPT premises with restricted access and the nearest settlement is located beyond 10 km distance. Terminal operations of KICT has no interaction with the local communities. The terminal is located on a 4-lane road that connects to the national highway.

KICT has prepared an ERP and communicated and linked the ERP to the DPT and district/local emergency authorities; undertakes drills on emergency response; participates in drill conducted by DPT and/or district/local government emergency authorities; and continually improves the ERP based on outcome of the drills.

KICT terminal is equipped with fire extinguishers and fire hydrants at key locations such as fuel dispenser, container stackyard, dock area, and administrative building. Fire safety certificate has been obtained from the Inspectorate of Fire Service as per the regulatory requirements. Regular internal inspections for all fire equipment is conducted.

Through an outsourcing agency, KICT has deployed 57 (including one female guard) security personnel. KICT does not employ armed guards and has implemented a formal security management system certified to ISO 28000. Detailed standard operating procedures have been developed that security personnel are required to adhere to and security incidents are recorded, investigated and corrective action implemented. Security awareness training is provided to all employees and contracted workers. Past records of security personnel are screened and there is a process in place to take disciplinary action against security personnel who violate standard operating procedures.

KICT has developed a security management plan as per International Ship and Port Facility Security (ISPS) protocol including security management policy, access point security deployment, CCTV monitoring, parameter patrolling and cargo security. The security personnel are provided with regular training on ISPS and ERP.